ACCEPTED
14-15-00704-cv
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
CASE NO. 14-15-00704-CV 11/18/2015 3:09:52 PM
CHRISTOPHER PRINE
CLERK
IN THE FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
AIMEE HARVEY INDIVIDUALLY AND AS NEXT FRIEND OF3:09:52
11/18/2015 TALISA PM
PHILLIPS, AMANDA HARVEY, HENRY WILSON, III, AS NEXT FRIEND
CHRISTOPHER A. PRINE
OF AALEISA PHILLIPS (A MINOR) AND GWENDOLYN WILSON Clerk
Appellants,
vs.
KINDRED HEALTHCARE OPERATING, INC., KINDRED HOSPITAL
HOUSTON MEDICAL CENTER, KINDRED HOSPITALS LIMITED
PARTNERSHIP
Appellees
On Appeal from the 190th District Court, Harris County, Texas
Trial Court Cause No. 2014-27575
APPELLANTS’ FIRST UNOPPOSED MOTION
FOR AN EXTENSION OF TIME TO FILE BRIEF
Respectfully submitted,
THE LAW OFFICE OF PERCY C. SINGLETON, JR.
By:_______________________
Percy C. Singleton, Jr.,
Texas Bar No. 24046854
2818 Cleburne St,
Houston, Texas 77004
Telephone 713.664.7678
Facsimile 713.436.8788
Email: psinglaw@gmail.com
ATTORNEY FOR APPELLANT
-1-
TO THE HONORABLE FOURTEENTH COURT OF APPEALS:
COMES NOW, APPELLANTS’ AIMEE HARVEY, ET. AL., respectfully
showing the Court as follows:
This is Appellants’ first unopposed motion for extension of time to file its
brief. The Appellants’ brief is due on November 23, 2015. Appellant moves
the Court for a 50-day extension. This extension is necessary is because
Appellants’ Counsel has had an extremely busy schedule the past forty-five (45)
days, in completing discovery and getting ready for trial in two cases, where trials
were set. The record in this matter was also delayed in some form. Appellants’
Counsel was also set for trial in criminal district court as well.
Appellants’ Counsel believes a 50-day extension would allow the response
brief for appellee to submitted after the holiday period and not cause an
inconvenience regarding preplanned travel arrangements for any involved parties.
PRAYER
Appellants’ move the Court for a 50-day extension to file their brief and for
all other relief to which he is entitled.
[signature page follows)
-2-
Respectfully submitted,
THE LAW OFFICE OF PERCY C. SINGLETON, JR.
By:_______________________
Percy C. Singleton, Jr.,
Texas Bar No. 24046854
2818 Cleburne St,
Houston, Texas 77004
Telephone 713.664.7678
Facsimile 713.436.8788
Email: psinglaw@gmail.com
ATTORNEY FOR APPELLANT
CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I
have conferred with opposing counsel, listed below, about the merits of this motion
with the following results:
Lori Proctor, with the Cooper and Scully Law Firm, attorney for
Appellee, Kindred Hospital Inc., does not oppose motion.
Jon Hlavinka, with the Cooper and Scully Law Firm, attorney for
Appellee, Kindred Hospital Inc., does not oppose motion.
Dated: Wednesday, November 18, 2015 _________________________
-3-
CERTIFICATE OF SERVICE
As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d), (e), I
certify that on Wednesday, November 18, 2015, I have served this document on all
other parties listed below:
Ms. Lori Proctor Via Electronic Filing
Cooper & Scully
700 Louisiana Street, Suite 3850
Houston, TX 77002
Telephone (713) 236-6800
Facsimile (713) 236-6880
Counsel for Appellee, Kindred Hospital Houston, Inc.
Mr. Jon Hlavinka Via Electronic Filing
Cooper & Scully
700 Louisiana Street, Suite 3850
Houston, TX 77002
Telephone (713) 236-6800
Facsimile (713) 236-6880
Counsel for Appellee, Kindred Hospital Houston, Inc.
By (check all that apply)
Electronic filing
Personal delivery
Mail
Commercial delivery service
Fax
___________________________
-4-
Aimee Harvey Individually and as Next Friend of Talisa Phillips, Amanda Harvey, Henry Wilson, III, as Next Friend of Aaleisa Phillips (A Minor) and Gwendolyn Wilson v. Kindred Healthcare Operating, Inc., Kindred Hospital Houston Medical Center, Kindred Hospitals Limited Partnership
Combined Opinion