ACCEPTED
03-15-00596-CV
8218229
THIRD COURT OF APPEALS
AUSTIN, TEXAS
12/14/2015 11:10:10 AM
JEFFREY D. KYLE
CLERK
NO. 03-15-00596-CV
FILED IN
IN THE COURT OF APPEALS 3rd COURT OF APPEALS
THIRD DISTRICT OF TEXAS, AUSTIN AUSTIN, TEXAS
12/14/2015 11:10:10 AM
JEFFREY D. KYLE
Clerk
GRACY WOODS I NURSING HOME
Appellant,
v.
MARTHA MAHAN, AS REPRESENTATIVE
OF THE ESTATE OF MARY RIVERA
Appellee.
ON INTERLOCUTORY APPEAL FROM
THE 250™ JUDICIAL DISTRICT, TRAVIS COUNTY, TEXAS
APPELLEE'S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE
APPELLEE BRIEF
JACI( MODESETT
STATE BARN0.14244337
WALTER V. WILLIAMS
STATE BAR NO. 21584800
MODESETT WILLIAMS, PLLC
515 CONGRESS AVENUE, SUITE 1650
AUSTIN, TEXAS 78701
(512) 472-6097 TELEPHONE
(512) 481-0130 FACSIMILE
ATTORNEYS FOR APPELLEE
Appellee's Unopposed Motion for
Extension of Time To File Appellee Brief Page 1
TO THE HONORABLE COURT OF APPEALS:
1. In accordance with TEX. R. APP. P. 10.5(b)(l) Appellee Martha Mahan, as
Representative of the Estate of Mary Rivera brings this unopposed request for an extension of time
to file Appellee's Brief.
2. This motion is Appellee's second request for extension of time to file its Brief.
3. Appellee's deadline to file its brief is cunently December 14,2015.
4. Appellee seeks a 7 day extension. If granted, Appellee's deadline to file its Brief
would be December 21, 2015.
5. Appellee requests the extension due to appellee counsel's commitments in other
matters, which will affect counsel's ability to devote a sufficient amount of time to file Appellee's
Brief.
6. Counsel for Appellant does not object to Appellee's request for a 7 day extension
of time to file Appellee's Brief.
7. Appellee does not seek this extension of time for the sole purpose of delay but so
that justice may be done.
Appellee's Unopposed Motion for
Extension of Time To File Appellee Brief Page2
PRAYER
WHEREFORE, PREMISES CONSIDERED, Appellee Matiha Mahan, as Representative
of the Estate of Mary Rivera, respectfully requests that this Court grant an additional fourteen days
from December 14, 2015 to December 21, 2015 for Appellee to file its Brief.
Respectfully submitted,
MODESETTWILLIAMS, PLLC
515 Congress Avenue, Suite 1650
Austin, Texas 78701
512.472.6097- Telephone
512.481.0130- Telecopier
i ack@jmodesettlaw.com
_walter@1nodwill.com
By:
alter V. Williams
exas Bar No. 21584800
Appellee's Unopposed Motion for
Extension of Time To File Appellee Brief Page3
CERTIFICATE OF CONFERENCE
Counsel for Appellee conference with counsel for Appellee concetning this request for a 7
day extension via email on December 14, 201 nsel for Appellee does not op request.
CERTIFICATE OF SERVICE
Pursuant to rule 9.5 of the Texas Rules of Appellate Procedure, I hereby certify that a true
and conect copy of the foregoing instrument has been filed electronically and delivered
electronically and via facsimile to the following counsel of record on this 14th day of December,
2015:
Emily Davenport (612) 660-5979
Reed, Clayman, Meeker & Hargett, PLLC
5608 Parkcrest Drive, Suite 200
Austin, Texas 78731
edavenport@rcmhlaw.com
Appellee's Unopposed Motion for
Extension of Time To File Appellee Brief Page 4