PHCC - La Hacienda Rehabilitation and Health Care Center LLC v. Keith Crume

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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