Curadev Pharma PVT. LTD. and Curadev Pharma Limited v. the University of Texas Southwestern Medical Center, Dr. Xiaochen Bai, and Dr. Xuewu Zhang

Opinion

ACCEPTED 15-25-00004-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/4/2025 3:21 PM No. 15-25-00004-CV CHRISTOPHER A. PRINE CLERK FILED IN In the Court of Appeals 15th COURT OF APPEALS AUSTIN, TEXAS For the Fifteenth District of Texas 3/4/2025 3:21:21 PM CHRISTOPHER A. PRINE Clerk Curadev Pharma Pvt. Ltd. and Curadev Pharma Limited,

Plaintiffs-Appellants,

v.

The University of Texas Southwestern Medical Center, Dr. Xiaochen Bai, and Dr. Xuewu Zhang,

Defendants-Appellees.

Interlocutory Appeal from the 101st District Court of Dallas County Trial Court No. DC-24-03875

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF OF APPELLANTS

ALLEN OVERY SHEARMAN STERLING US LLP David P. Whittlesey Trey Hebert 300 W. 6th Street, Suite 2250 Austin, Texas 78701 (512) 647-1900 (phone)

Jacob Fields 2601 Olive Street, 17th Floor Dallas, Texas 75201 (214) 271-5777 (phone)

Attorneys for Curadev Pharma Pvt. Ltd. and Curadev Pharma Limited To the Honorable Court of Appeals:

Pursuant to Tex. R. App. P. 10.5(b) and 38.6(d), Appellants Curadev Pharma

Pvt. Ltd. and Curadev Pharma Limited (“Appellants”) file this Unopposed Motion

for Extension of Time to File Reply Brief of Appellants and would respectfully show

the Court as follows:

1. The Brief of Appellants was filed on January 21, 2025. The Brief of

Appellees was filed on February 24, 2025. Appellants Reply Brief is currently due

on March 17, 2025, pursuant to Tex. R. App. P. 38.6(c).

2. A reasoned justification for an extension of time exists. The

undersigned counsel for Appellants has had and will have other commitments

necessitating this extension, including the following conflicts that impact the time

period counsel needs to prepare Appellees’ reply brief:

a. preparing and submitting pre-trial filings by March 7, 2025, in

Driftwood Energy Operating, LLC v. KLX Energy Services LLC, et

al, Case No. 22-06-U4942-ANC, In the 112th Judicial District

Court, Upton County, Texas;

b. preparing and submitting a dispositive motion due March 14, 2025,

in Abrams v. Trive Capital Mgmt., LLC et al., No. 24-AP-50130 in

the United States Bankruptcy Court for the District of Delaware; and

1 c. preparing and conducting multiple depositions in PURIS LLC v.

Mayer, No. 25-cv-00157 in the United States District Court for the

Middle District of Florida.

These and other scheduling conflicts necessitate this request for an extension.

3. Appellants therefore request that the deadline for filing its Reply Brief

of Appellants be extended 14 days to March 31, 2025. This is Appellants’ first

request for an extension of time for its Reply Brief of Appellants and is not sought

for the purpose of delay.

4. Counsel for Appellees has advised that they do not oppose this

requested extension.

For these reasons, Appellants Curadev Pharma Pvt. Ltd. and Curadev Pharma

Limited respectfully pray that the Court extend the time to file its Reply Brief of

Appellants to March 31, 2025.

2 Dated: March 4, 2025 Respectfully Submitted,

Allen Overy Shearman Sterling US LLP

/s/ David P. Whittlesey David P. Whittlesey Texas Bar No. 00791920 david.whittlesey@aoshearman.com Trey Hebert Texas Bar No. 24067819 trey.hebert@aoshearman.com 300 West 6th Street, Suite 2250 Austin, TX 78701 (512) 647-1900 (tel)

Jacob Fields Texas Bar No. 24115134 jacob.fields@aoshearman.com The Link at Uptown 2601 Olive St., 17th Floor Dallas, TX 75201 (214) 271-5777 (tel)

Attorneys for Appellants

3 CERTIFICATE OF CONFERENCE

I hereby certify that on March 3, 2025, the undersigned conferred with counsel

for Appellees about the relief requested in this motion. Counsel does not oppose the

requested relief and extension requested in this motion.

/s/ David P. Whittlesey David P. Whittlesey

CERTIFICATE OF SERVICE

I hereby certify that on March 4, 2025, a true and correct copy of this

document was served on the following counsel via email and/or electronic filing:

/s/ David P. Whittlesey David P. Whittlesey Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Ashley Duncum on behalf of David Whittlesey Bar No. 791920 ashley.duncum@aoshearman.com Envelope ID: 98054752 Filing Code Description: Motion Filing Description: 20250304 Appellants Motion for Extension Reply Status as of 3/4/2025 3:55 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Nathaniel St Clair nstclair@jw.com 3/4/2025 3:21:21 PM SENT

David Schlottman dschlottman@jw.com 3/4/2025 3:21:21 PM SENT

Olin Hebert 24097819 trey.hebert@aoshearman.com 3/4/2025 3:21:21 PM SENT

David Whittlesey 791920 david.whittlesey@aoshearman.com 3/4/2025 3:21:21 PM SENT

Jacob Fields 24115134 jacob.fields@shearman.com 3/4/2025 3:21:21 PM SENT

Hailey Oestreich hoestreich@jw.com 3/4/2025 3:21:21 PM SENT

Demi Williams dswilliams@jw.com 3/4/2025 3:21:21 PM SENT

Associated Case Party: Curadev Pharma PVT. LTD

Name BarNumber Email TimestampSubmitted Status

Amanda Adame amanda.adame@aoshearman.com 3/4/2025 3:21:21 PM SENT

David P.Whittlesey david.whittlesey@aoshearman.com 3/4/2025 3:21:21 PM SENT

Jacob Fields jacob.fields@aoshearman.com 3/4/2025 3:21:21 PM SENT

Ashley CegielskiDuncum ashley.duncum@aoshearman.com 3/4/2025 3:21:21 PM SENT