ACCEPTED
01-15-00854-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/21/2015 12:52:12 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00854
FILED IN
1st COURT OF APPEALS
IN THE FIRST DISTRICT COURT OF APPEALS HOUSTON, TEXAS
HOUSTON, TEXAS 12/21/2015 12:52:12 PM
CHRISTOPHER A. PRINE
Clerk
PHCC-LA HACIENDA REHABILITATION
AND HEALTH CARE CENTER, LLC,
Appellant
v.
KEITH CRUME,
Appellee
On appeal from the 189th Judicial District Court, Harris County
The Honorable Bill Burke Presiding Judge
APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF
TIME TO FILE RESPONSE TO APPELLANT’S BRIEF
TO THE HONORABLE FIRST COURT OF APPEALS:
Appelleee, Keith Crume, files this Unopposed Motion to Extend Time to File
Response to Appellant’s Brief an in support would respectfully show as follows:
1. Appellee’s response is currently due on January 4, 2016.
2. Appellee requests an additional fourteen (14) days to file his response to
Appellant’s Brief, extending the time to January 18, 2016.
3. This extension is needed because both John J. Kahn, Jr. and Jennifer H. Kahn,
counsel for Appellee, will be out of the state on a family vacation beginning
on December 26, 2015 and will not return until January 3, 2016. The family
vacation has been planned for several months, prior to the filing on the
Appellant’s Brief. Counsel will have spotty internet service, if any, as the
vacation will be in a mountainous region of New Mexico.
4. This request is not for purpose of delay, but so that justice may be done and
this Court may be fully informed of Appellee’s position including all factual
and legal information relevant to the proper disposition of this appeal.
WHEREFORE, PREMISES CONSIDERED, Appellee requests that this
Court grant his Motion to Extend Time to File a Response to Appellant’s Brief
on or before January 18, 2016.
Respectfully submitted,
THE KAHN LAW FIRM, PC
/s/ John J. Kahn, Jr.
JOHN J. KAHN JR.
Texas Bar No. 24034515
JENNIFER H. KAHN
Texas Bar No. 24032304
9330 Broadway, Suite A-224
Pearland, TX 77584
Tel. (713)226-9900
Fax. (713)226-9901
john@kahnlawyers.com
jennifer@kahnlawyers.com
ATTORNEYS FOR PLAINTIFF
KEITH CRUME
CERTIFICATE OF CONFERENCE
The undersigned certifies that counsel Jennifer Kahn has consulted with Afton
Sands, counsel for Appellant, via telephone and she is unopposed to the relief
requested herein.
/s/ John J. Kahn, Jr______________
JOHN J. KAHN, JR.
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing document was served to
all parties by and through their counsel of record at the following address via US
Postal Service, Certified Mail Return Receipt, eService and/or Facsimile on
December 21, 2015.
/s/ John J. Kahn, Jr______________
JOHN J. KAHN, JR.
Lorinda Holloway
Afton Sands
HUSCH BLACKWELL, LLP
111 Congress Ave, Suite 1400
Austin, TX 78701