ACCEPTED
03-13-00817-CV
5268395
THIRD COURT OF APPEALS
AUSTIN, TEXAS
5/13/2015 2:01:18 PM
JEFFREY D. KYLE
CLERK
No. 03-13-00817-CV
________________________________________________________________
FILED IN
3rd COURT OF APPEALS
IN THE COURT OF APPEALS AUSTIN, TEXAS
THIRD DISTRICT OF TEXAS, AUSTIN 5/13/2015 2:01:18 PM
________________________________________________________________
JEFFREY D. KYLE
Clerk
SETON FAMILY OF HOSPITALS D/B/A SETON MEDICAL CENTER,
Appellant,
v.
BEVERLY J. HAYWOOD,
Appellee.
________________________________________________________________
ON INTERLOCUTORY APPEAL FROM
THE 345TH JUDICIAL DISTRICT, TRAVIS COUNTY, TEXAS
________________________________________________________________
APPELLANT’S MOTION FOR LEAVE TO FILE SUPPLEMENTAL
LETTER BRIEF
________________________________________________________________
EMILY J. DAVENPORT
State Bar No. 24012501
REED, CLAYMON, MEEKER &
HARGETT, PLLC
5608 Parkcrest Drive, Suite 200
Austin, Texas 78731
(512) 660-5960
(512) 660-5979 (Facsimile)
Attorneys for Appellant
1
TO THE HONORABLE COURT OF APPEALS:
Pursuant to Texas Rule of Appellate Procedure 38.7, Appellant
respectfully requests that the Court grant it leave to file a supplemental
letter brief in response to Appellee’s letter brief concerning Ross v. St.
Luke’s Hosp., No. 13-0439 (Tex. May 1, 2015).
Appellee was granted leave to file her letter brief concerning Ross
on May 8, 2015. Her letter brief was accepted as filed on May 11, 2015. If
leave is granted, Appellant will file its reply brief on or before May 23,
2015.
PRAYER
Seton prays that the Court grant this Motion and allow it to file a
supplemental letter brief.
Respectfully submitted,
By: s/ Emily J. Davenport
EMILY J. DAVENPORT
State Bar No. 24012501
ROBERT L. HARGETT
State Bar No. 08996550
JANICE M. BYINGTON
State Bar No. 24006938
REED, CLAYMON, MEEKER & HARGETT,
PLLC
5608 Parkcrest Drive, Suite 200
2
Austin, Texas 78731
(512) 660-5960 – telephone
(512) 660-5979 – facsimile
edavenport@rcmhlaw.com
rhargett@rcmhlaw.com
jbyington@rcmhlaw.com
Attorneys for Appellant
3
CERTIFICATE OF CONFERENCE
Pursuant to Tex. R. App. P 10.1(a)(5), Appellant has conferred with
counsel for Appellee, Robert C. Alden, and he has expressed no objection
to Appellant seeking leave to file its letter brief.
/s/ Emily J. Davenport
Emily J. Davenport
CERTIFICATE OF COMPLIANCE
I hereby certify that the foregoing motion has been compiled using
a computer program in Word with 14-point font conventional typeface for
the body of the motion. Excluding the portions exempted pursuant to Tex.
R. App. P. 9.4, this motion contains 107 words.
/s/ Emily J. Davenport
Emily J. Davenport
4
CERTIFICATE OF SERVICE
Pursuant to rule 9.5 of the Texas Rules of Appellate Procedure, I
hereby certify that a true and correct copy of the foregoing instrument
has been sent by e-mail and certified mail, return receipt requested to
the following counsel of record on this 13th day of May, 2015:
Robert C. Alden
Byrd, Davis Furman & Alden, LLP
707 West 34th St.
Austin, TX 78705
(512) 454-3751
ralden@byrddavis.com
/s/ Emily J. Davenport
Emily J. Davenport
5
Seton Family of Hospitals, D/B/A Seton Medical Center v. Beverly J. Haywood
Combined Opinion