Lakeway Regional Medical Center, LLC and Surgical Development Partners, LLC// Lake Travis Transitional LTCH, LLC N/K/A Lake Travis Specialty Hospital, LLC v. Lake Travis Transitional LTCH, LLC N/K/A Lake Travis Specialty Hospital, LLC// Lakeway Regional Medical Center, LLC Surgical Development Partners, LLC Brennan, Manna, & Diamond, LLC And Frank T. Sossi

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ACCEPTED 03-15-00025-CV 8060668 THIRD COURT OF APPEALS AUSTIN, TEXAS 12/2/2015 4:36:49 PM JEFFREY D. KYLE CLERK No. 03-15-00025-CV _____________________________________________ FILED IN 3rd COURT OF APPEALS IN THE COURT OF APPEALS AUSTIN, TEXAS THIRD DISTRICT OF TEXAS 12/2/2015 4:36:49 PM AUSTIN, TEXAS JEFFREY D. KYLE ______________________________________________Clerk APPELLANTS, LAKEWAY REGIONAL MEDICAL CENTER, LLC AND SURGICAL DEVELOPMENT PARTNERS, LLC// CROSS-APPELLANT, LAKE TRAVIS TRANSITIONAL LTCH, LLC N/K/A LAKE TRAVIS SPECIALTY HOSPITAL, LLC v. APPELLEES, LAKE TRAVIS TRANSITIONAL LTCH, LLC N/K/A LAKE TRAVIS SPECIALTY HOSPITAL, LLC// CROSS-APPELLEES, LAKEWAY REGIONAL MEDICAL CENTER, LLC, SURGICAL DEVELOPMENT PARTNERS, LLC, BRENNAN, MANNA, & DIAMOND, LLC AND FRANK T. SOSSI ______________________________________________ LTT’S MOTION TO FILE A REPLY BRIEF OF 5000 WORDS AND RESPONSE TO THE HOSPITAL DEFENDANTS’ MOTION ______________________________________________ TO THE HONORABLE COURT OF APPEALS: Ordinarily a party may file a reply brief of up to 7,500 words. Tex. R. App. P. 9.4(i)(2)(C). Where there are cross-appeals and each party ends up filing multiple briefs, as in this case, there is a cumulative cap of 27,000 words for all briefs filed by a party. Tex. R. Civ. P. 9.4(i)(2)(B). Appellee Lake Travis Transitional LTCH, LLC n/k/a Lake Travis Specialty Hospital, LLC (“LTT”) has already filed a Brief of Appellant and Brief of Appellee in this case. Though each 1266956 stayed within the 15,000 word limit for briefs, LTT is now constrained by the 27,000 cumulative word limit in filing its reply brief. LTT therefore asks this Court to grant it relief from the cumulative word limit and allow it to file a reply brief of 5,000 words. Without this extension of the word limit, LTT cannot file a reply brief that would be meaningful in assisting this Court in deciding this appeal. By requesting 5,000 words rather than the full 7,500 ordinarily allowed for reply briefs, LTT seeks to minimize the burden on the Court. For that same reason, LTT opposes— in part—the request by SDP/LRMC for an extension of 7,500 words for their reply brief. LTT submits that 5,000 words are sufficient for reply briefs for all parties in this appeal. SDP/LRMC do not oppose this motion. The Lawyer Defendants have not responded to state whether they oppose or not. WHEREFORE, LTT respectfully requests that this Court grant this motion, allow all parties to file a reply brief of 5,000 words, and grant to it all other relief to which it may be entitled. 2 1266956 Respectfully submitted, SCOTT DOUGLASS & MCCONNICO LLP 303 Colorado Street, 24th Floor Austin, TX 78701 (512) 495-6300 (512) 495-6399 Fax By: /s/ Jane Webre_________ S. Abraham Kuczaj, III State Bar No. 24046249 akuczaj@scottdoug.com Paige Arnette Amstutz State Bar No. 00796136 pamstutz@scottdoug.com Steven J. Wingard State Bar No. 00788694 swingard@scottdoug.com Jane Webre State Bar No. 21050060 jwebre@scottdoug.com ATTORNEYS FOR CROSS- APPELLANT/APPELLEE LAKE TRAVIS TRANSITIONAL LTCH, LLC n/k/a LAKE TRAVIS SPECIALTY HOSPITAL, LLC CERTIFICATE OF CONFERENCE I certify that I contacted Joy Soloway, counsel for SDP/LRMC, and Ryan Fellman, counsel for the Lawyer Defendants, regarding this motion. Joy Soloway informed me that she does not oppose this motion. As of the time the motion was filed, Ryan Fellman had had responded whether he opposes the relief sought through this motion. /s/ Jane Webre Jane M.N. Webre 3 1266956 CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing pleading was served on the following counsel of record via the CM/ECF electronic noticing system and e-mail, on December 2, 2015 Jeff Cody Barton Wayne Cox NORTON ROSE FULBRIGHT 2200 Ross Avenue, Suite 2800 Dallas, TX 75201-2784 Joy Soloway NORTON ROSE FULBRIGHT 1301 McKinney, Suite 5100 Houston, TX 77010-3095 Robert A. Bragalone B. Ryan Fellman GORDON & REES, LLP 2100 Ross Avenue, Suite 2800 Dallas, TX 75201 Jessica Z. Barger Raffi Melkonian Wright & Close, LLP One Riverway, Suite 2200 Houston, TX 77056 /s/ Jane Webre Jane M.N. Webre 4 1266956