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 7364377 THIRD COURT OF APPEALS AUSTIN, TEXAS 10/14/2015 9:36:45 AM 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 10/14/2015 9:36:45 AM 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 ______________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLEE ______________________________________________ TO THE HONORABLE COURT OF APPEALS: Appellee Lake Travis Transitional LTCH, LLC n/k/a Lake Travis Specialty Hospital, LLC (“LTT”) files this unopposed motion for an extension of time to file its Brief of Appellee in this appeal. Currently the brief is due on October 21, 2015. LTT respectfully requests that this Court extend the time for filing its brief by thirty days to Nov. 20, 2015. This is the first request for an extension of time for this filing. 1253892 There is good cause to grant this extension. LTT seeks this extension in order to have adequate time to analyze and brief this issues in this case. The record in this appeal is sizeable, including a 20-volume Reporter’s Record from a jury trial. Moreover, Cross-Appellees have moved for a thirty day extension of time to file their brief; it makes sense to keep all parties on a parallel briefing schedule. In addition, on Oct. 2, 2015, the Fifth Circuit accepted an interlocutory appeal in which LTT’s appellate counsel, Jane Webre, is lead appellate counsel. That order triggered an accelerated briefing schedule under which Ms. Webre had to prepare and file her client’s opening brief by Oct. 13, 2015. This motion is unopposed. WHEREFORE, LTT respectfully requests that this Court grant this motion, extend the deadline to file its brief of Appellee to Nov. 20, 2015, and grant to it all other relief to which it may be entitled. 2 1253892 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 Joy Soloway and Steven Lawson, counsel for Appellants and Cross-Appellees in this appeal, stated that they do not oppose the relief sought through this motion. /s/ Jane Webre Jane M.N. Webre 3 1253892 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 October 13, 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 1253892