ACCEPTED
06-15-00059-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
11/9/2015 11:00:56 AM
DEBBIE AUTREY
CLERK
NO. 06-15-00059-CV
______________________________________________________
FILED IN
6th COURT OF APPEALS
TEXARKANA, TEXAS
IN THE SIXTH DISTRICT COURT OF APPEALS
11/9/2015 11:00:56 AM
TEXARKANA, TEXAS DEBBIE AUTREY
Clerk
______________________________________________________
Frankie Marie Miller, Individually and as Representative
of the Estate of T.J. Miller,
Appellant,
v.
John D. Mullen, M.D. and Titus Regional Medical Center,
Appellees.
______________________________________________________
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
______________________________________________________
TO THE HONORABLE COURT OF APPEALS:
1. Appellant’s Brief is due on November 12, 2015. Appellant seeks a 21-
day extension to make the brief due on December 3, 2015.
2. This is the first request for an extension.
3. The record was filed in this case on October 12, 2015. Between
October 12 and November 12, the undersigned has had or will have two oral
arguments in the Supreme Court of Texas and another in the Texas Court of
MOTION FOR EXTENSION
PAGE 1
Criminal Appeals, and two petitions for review due in the Texas Supreme Court.
This is in addition to the ordinary workload of counsel (which includes a reply brief
in the El Paso Court of Appeals, appellees’ brief in the Dallas Court of Appeals,
appellee’s brief in the Fort Worth Court of Appeals, and appellant’s brief in the
Fort Worth Court of Appeals).
4. Appellee does not oppose this motion.
Based on the foregoing, Appellant asks that the deadline to file her brief be
extended to December 3, 2015.
Respectfully submitted,
/s/Charles “Chad” Baruch
The Law Office of Chad Baruch
Texas Bar Number 01864300
3201 Main Street
Rowlett, Texas 75088
Telephone: (972) 412-7192
Facsimile: (972) 412-4028
E-Mail: baruchEsq@aol.com
Attorney for Appellant
MOTION FOR EXTENSION
PAGE 2
CERTIFICATE OF CONFERENCE
The undersigned certifies that he conferred with Russell Schell, counsel for
appellee, who stated that he does not oppose the relief sought by this motion.
/s/Charles “Chad” Baruch
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of this notice of appeal was
served this 9th day of November, 2015, upon the following counsel of record by
efiling and email:
Russell W. Schell
Schell Cooley LLP
15455 Dallas Parkway, Suite 550
Addison, Texas 75001
Trial Counsel for Appellees
rschell@schellcooley.com
vbrumley@schellcooley.com
shaley@schellcooley.com
/s/Charles “Chad” Baruch
MOTION FOR EXTENSION
PAGE 3