Regina Carson v. Blue Cross Blue Shield of Texas, Inc., a Division of Health Care Service Corporation, Anita C. Johnson, Yvonne Sternadel A/K/A Vonnie S., Lauren Collins Reeser OR, Laura M. McClelland
This text of Regina Carson v. Blue Cross Blue Shield of Texas, Inc., a Division of Health Care Service Corporation, Anita C. Johnson, Yvonne Sternadel A/K/A Vonnie S., Lauren Collins Reeser OR, Laura M. McClelland (Regina Carson v. Blue Cross Blue Shield of Texas, Inc., a Division of Health Care Service Corporation, Anita C. Johnson, Yvonne Sternadel A/K/A Vonnie S., Lauren Collins Reeser OR, Laura M. McClelland) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
ACCEPTED 15-24-00108-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 1/15/2025 12:07 PM No. 15-24-00108-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE COURT OF APPEALS FOR THE FIFTEENTH DISTRICT 15th COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 1/15/2025 12:07:26 PM CHRISTOPHER A. PRINE Clerk REGINA CARSON, Appellant
v.
BLUE CROSS BLUE SHIELD OF TEXAS, INC., a division of HEALTH CARE SERVICE CORPORATION, ANITA C. JOHNSON, YVONNE STERNADEL a/k/a VONNIE S., LAUREN COLLINS REESER OR LAURA M. MCCLELLAND a/k/a LORI, JANE CORDRAY a/k/a JANE, JASON RAMIREZ a/k/a JASON R., JENNIFER TRACEY a/k/a JENNIFER T., CHRISTOPHER FLINN a/k/a CHRIS, and TEACHERS RETIREMENT SYSTEM OF TEXAS d/b/a TEACHERS RETIREMENT SYSTEM OF TEXAS ACTIVECARE PLAN, Appellees
From Cause No. CC-23-02212-E in the County Court at Law No. 5, Dallas County, Texas, Honorable Nicole Taylor, Presiding
APPELLANT’S SECOND UNOPPOSED MOTION TO EXTEND TIME TO FILE APPELLANT’S REPLY BRIEF
TO THE HONORABLE JUSTICES OF THE FIFTH COURT OF APPEALS:
COMES NOW, Regina Carson (“Appellant” or “Carson”), and files
Appellant’s Second Unopposed Motion to Extend Time to File Appellant’s Reply
Brief, and would show this Honorable Court as follows:
Page 1 of 5 I. BACKGROUND
Appellant’s Reply Brief is due on January 16, 2025 based on this Court’s letter
of December 20, 2024. Appellant requests a second thirty (30) day extension until
February 17, 2025.
No party opposes this extension.
II. RELIEF REQUESTED
Appellant respectfully requests the Court grant her an extension until
February 17, 2025 to file Appellant’s Reply Brief. This is the second extension
request sought for Appellant’s Reply Brief.
III. ARGUMENT AND AUTHORITIES
A. The Law
Rule 10.5(b) of the Texas Rules of Appellate Procedure provides that a party
may seek an extension of time to file its brief by complying with Rule 10.5(b)(1).
See Tex. R. App. P. 38.6(d). A motion to extend time must include: (1) the deadline
for filing the item at issue; (2) the length of the extension sought; (3) the facts relied
on to support the request for an extension; and (4) the number of previous extensions
granted. See Tex. R. App. P. 10.5(b)(1).
Page 2 of 5 B. Application of the Law to the Facts
Appellant has complied with Rule 10.5(b)(1) and demonstrated good cause
for an extension. Appellant’s Reply Brief is currently due on January 16, 2025. Good
cause exists for granting Appellant a thirty (30) day extension to February 17, 2025.
Among other considerations, Plaintiff’s counsel has been involved in the following
matters:
1. Response to Motions for Summary Judgment, Motion for Continuance,
and related matters in Holbert v. Charles Noteboom, Brian Butcher, and
Charles M. Noteboom, P.C. d/b/a Noteboom – the Law Firm, Cause No.
CC-24-01570-B, in the County Court at Law No. 2;
2. Significant motion practice including hearings in Angela Vasquez,
Individually and a/n/f to A.V., A.V., and D.V., Minors, v. Auto Club County
Mutual Insurance Company d/b/a AAA Texas, Brittany Burks, and
Alejandro Padilla-Villavicencio, Cause No. CC-18-05739-C, in the
County Court at Law No. 3;
3. Preparation of motion for writ of mandamus and request for stay in Melissa
Hollmann and Scot Hollmann v. Van Shaw v. Paul Kramer, Cause No.
236-267402-13, in the 236th Judicial District of Tarrant County, Texas;
4. Preparation for trial including significant pretrial matters in Stacey Jean
Relton v. Lynn Pinker Hurst & Schwegmann, LLP & Michael K. Hurst,
Page 3 of 5 Cause No. DF-22-18203, in the 301st Judicial District of Dallas County,
Texas; and
5. Preparation of motion to reconsider and mediation in Dristi Shrestha v.
Enya Hernandez Gonzalez, cause No. CC-19-02805-E, in the County
Court at Law No. 5 of Dallas County, Texas.
In addition to the foregoing, Carson’s counsel spent time with out of town
family including two of his daughters during the Christmas holidays.
The extension is not sought for delay, will not prejudice any party, and is made
so that justice will be done. Appellees are unopposed to Appellant’s extension
request.
Appellant requests the Court grant her an extension until February 17, 2025
to file Appellant’s Reply Brief.
IV. CONCLUSION
Appellant has demonstrated good cause for the extension sought. Appellant’s
request should be granted.
WHEREFORE, PREMISES CONSIDERED, Appellant prays this Honorable
Court grant her motion as requested herein and grant Appellant such other and
further relief to which she is entitled.
Page 4 of 5 Respectfully submitted,
By: /s/ Mark A. Ticer Mark A. Ticer State Bar #20018900 mticer@ticerlaw.com Jennifer W. Johnson State Bar #24060029 jjohnson@ticerlaw.com
LAW OFFICE OF MARK A. TICER 10440 N. Central Expressway, Suite 600 Dallas, Texas 75231 (214) 219-4220 (214) 219-4218 (FAX)
ATTORNEYS FOR APPELLANT REGINA CARSON
CERTIFICATE OF CONFERENCE
I hereby certify that I had a conference on January 14, 2025 with Appellees’ counsel who graciously advised that they do not oppose an extension for filing Appellants’ Reply Brief.
/s/ Mark A. Ticer Mark A. Ticer
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was served on all counsel of record, via e-file, on this the 15th day of January 2025.
Page 5 of 5 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.
Lisa Amerson on behalf of Mark Ticer Bar No. 20018900 lamerson@ticerlaw.com Envelope ID: 96249487 Filing Code Description: Motion Filing Description: Appellant's Second Unopposed Motion to Extend Time to File Appellant's Reply Brief Status as of 1/15/2025 12:40 PM CST
Associated Case Party: Blue Cross Blue Shield of Texas, Inc., an unincorporated division of Health Care Service Corporation, a Mutual Legal Reserve Company
Name BarNumber Email TimestampSubmitted Status
Alan York ayork@reedsmith.com 1/15/2025 12:07:26 PM SENT
Scott Williams scott.williams@reedsmith.com 1/15/2025 12:07:26 PM SENT
Martin Bishop mbishop@reedsmith.com 1/15/2025 12:07:26 PM SENT
Cheryl Blount cblount@reedsmith.com 1/15/2025 12:07:26 PM SENT
Associated Case Party: ReginaCarson
Brooke Bailey bbailey@ticerlaw.com 1/15/2025 12:07:26 PM SENT
Michelle Smith msmith@ticerlaw.com 1/15/2025 12:07:26 PM SENT
Mark Ticer mticer@ticerlaw.com 1/15/2025 12:07:26 PM SENT
Jennifer Johnson jjohnson@ticerlaw.com 1/15/2025 12:07:26 PM SENT
Associated Case Party: Teachers Retirement System of Texas
Thomas Bevilacqua thomas.bevilacqua@oag.texas.gov 1/15/2025 12:07:26 PM SENT
Troy Sager troy.sager@oag.texas.gov 1/15/2025 12:07:26 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status 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.
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Regina Carson v. Blue Cross Blue Shield of Texas, Inc., a Division of Health Care Service Corporation, Anita C. Johnson, Yvonne Sternadel A/K/A Vonnie S., Lauren Collins Reeser OR, Laura M. McClelland, Counsel Stack Legal Research, https://law.counselstack.com/opinion/regina-carson-v-blue-cross-blue-shield-of-texas-inc-a-division-of-texapp-2025.