ACCEPTED
01-12-00578-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/5/2015 12:19:59 PM
CHRISTOPHER PRINE
CLERK
No. 01-12-00578-CV
In the First Court of Appeals FILED IN
1st COURT OF APPEALS
Houston, Texas HOUSTON, TEXAS
3/5/2015 12:19:59 PM
CHRISTOPHER A. PRINE
Clerk
JIM P. BENGE, MD AND
KELSEY-SEYBOLD MEDICAL GROUP PLLC
DEFENDANTS/APPELLANTS
V.
LAUREN WILLIAMS
PLAINTIFF/APPELLEE
On Appeal from the 164th District Court
Harris County, Texas
No. 2010-52657
APPELLANTS’ UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE RESPONSES TO MOTIONS
FOR REHEARING AND EN BANC RECONSIDERATION
David George
Texas Bar No. 00793212
Earnest W. Wotring
Texas Bar No. 22012400
Amy Nilsen
Texas Bar No. 24027574
CONNELLY•BAKER•WOTRING LLP
700 JPMorgan Chase Tower
600 Travis Street
Houston, Texas 77002
Telephone: (713) 980-6513
Fax: (713) 980-1701
dgeorge@connellybaker.com
Counsel for Appellants
Pursuant to Texas Rules of Appellate Procedure 10.5(b),
Appellants Jim Benge, MD and Kelsey-Seybold Medical Group, PLLC
(collectively, “Kelsey”) request a two-week extension of the due date on
their responses to Appellee Lauren Williams’ motions for rehearing and
en banc reconsideration, which are currently due on March 18, 2015.
Williams does not oppose this request.
David George is Kelsey’s attorney who is drafting the response to
the motions. His work in other cases makes it difficult for him to
complete the responses by March 18, 2015. George has a brief that is
due in the Fifth Circuit on March 23, 2015, and that due date cannot be
extended.1 Another attorney in George’s firm was handling that case,
but she recently left the firm. George, therefore, is having to review the
entire case to be in a position to properly draft the brief. That, of
course, is taking additional time and interferes with his ability to draft
the responses to Williams’ motions by March 18.
Kelsey, therefore, requests that this Court extend the due date for
its responses to Williams’ motions for rehearing and en banc
reconsideration by two weeks, which is until Wednesday, April 1, 2015.
1Kelsey-Seybold Medical Group PA v. Great-West Healthcare of Tex., Inc., No. 14-
20506 (5th Cir.).
2
Respectfully submitted,
/s/ David George
David George
Texas Bar No. 00793212
Earnest W. Wotring
Texas Bar No. 22012400
Amy Nilsen
Texas Bar No. 24027574
CONNELLY•BAKER•WOTRING LLP
700 JPMorgan Chase Tower
600 Travis Street
Houston, Texas 77002
Telephone: (713) 980-6513
Fax: (713) 980-1701
dgeorge@connellybaker.com
Counsel for Appellants
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CERTIFICATE OF CONFERENCE
I certify that on March 4, 2015, I conferred via e-mail with
Appellee’s counsel Lucy Forbes. She informed me that she does not
oppose the Court granting the relief requested in this motion.
/s/ David George
David George
CERTIFICATE OF SERVICE
I certify that on March 5, 2015, I served a copy of the foregoing
document upon the following counsel of record by e-mail and certified
mail/return receipt requested:
Lucy H. Forbes
THE FORBES FIRM, PLLC
2114 Woodcrest Drive
Houston, Texas 77018
lucy@forbesfirm.com
Randall O. Sorrels
ABRAHAM, WATKINS, NICHOLS,
SORRELS, AGOSTO & FRIEND
800 Commerce Street
Houston, Texas 77002
rsorrels@abrahamwatkins.com
/S/ David George
David George
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