Donna Pulkrabek v. the University of Texas Southwestern Medical Center

• Court: Court of Appeals of Texas
• Decided: January 9, 2015
• Docket: 05-14-01341-CV
• Status: Published

Opinion

ACCEPTED 05-14-01341-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 1/9/2015 3:24:56 PM LISA MATZ CLERK

CAUSE NO. 05-14-01341-CV

FILED IN DONNA PULKRABEK, § IN THE COURT OF APPEALS 5th COURT OF APPEALS Appellant § DALLAS, TEXAS § 1/9/2015 3:24:56 PM vs. § FIFTH DISTRICT OF LISATEXAS MATZ § Clerk THE UNIVERSITY OF TEXAS § SOUTHWESTERN MEDICAL § DALLAS, TEXAS CENTER § Appellees §

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APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF ______________________________________________________________________

Appellant, pursuant to Tex.R.App.P. 10 and 10.5(b), files this Motion to Extend

Time to File Appellant’s Brief and, in support thereof, would show as follows:

I. ARGUMENT

Appellant currently has a deadline of January 17, 2015, with which to file this

brief. Appellant seeks to extend this deadline sixty days to March 18, 2015. No

previous extensions have been requested as January 17, 2015, is the first briefing

deadline given to the Appellant.

The office of Wes Dauphinot, had a jury trial in the 116th District Court, Dallas

County, Texas, from December 1-11, 2014. Additionally, Wes Dauphinot was set on a

four week docket in the United States District Court, Northern District, Dallas, Texas

beginning January 12, 2015. Finally, Plaintiff’s counsel has had to engage in extensive

pretrial preparations for a case set in the 48th District Court, Tarrant County, Texas,

Appellant Donna Pulkrabek’s Motion for Extension of Time to File Brief Page 1 styled Cora Hunter vs. McDonald Transit, Inc. on January 26, 2015. This case should

last two weeks.

Based on all of the above, Plaintiff’s counsel will have an extremely challenging

time to prepare the appellate brief that the Appellant deserves to have filed on her

behalf. Accordingly, Plaintiff’s counsel is asking for the aforementioned extension of

time.

WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant

this Motion.

Respectfully submitted,

__/s/ Wes Dauphinot____ Wes Dauphinot Texas Bar No. 00793584 wes@dauphinotlawfirm.com

Dauphinot Law Firm 900 W. Abram Arlington, Texas 76013 (817) 462-0676 (817) 704-4788 facsmile

ATTORNEYS FOR PLAINTIFF

Appellant Donna Pulkrabek’s Motion for Extension of Time to File Brief Page 2 CERTIFICATE OF SERVICE

The undersigned certifies that the following counsel of record were furnished a copy of this Motion for Extension of Time via facsimile and electronic filing on January 9, 2015:

Yvonne D. Bennett Assistant Attorney General PO Box 12548 Austin, Texas 78711-2548 Fax. (512) 320-0667 Attorney for Appellees

/s/ Wes Dauphinot WES DAUPHINOT

CERTIFICATE OF CONFERENCE

The undersigned certifies that he conferenced the following counsel of record regarding the foregoing Motion for Extension of Time on January 9, 2015, Appellee’s Counsel, Yvonne Bennett, below stated that she was not opposed to a 60 day extension of the briefing deadline:

Yvonne D. Bennett Assistant Attorney General PO Box 12548 Austin, Texas 78711-2548 Fax. (512) 320-0667 Attorney for Appellees

______/s/ Wes Dauphinot________ WES DAUPHINOT

Appellant Donna Pulkrabek’s Motion for Extension of Time to File Brief Page 3