Shannon Medical Center v. Michael Sickels and James Christopher Cole

Opinion

ACCEPTED 15-25-00167-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/5/2025 10:59 AM Case No. 15-25-00167-CV CHRISTOPHER A. PRINE CLERK Shannon Medical Center § FILED IN 15th COURT OF APPEALS § AUSTIN, TEXAS Court of Appeals of Texas v. § 12/5/2025 10:59:01 AM § CHRISTOPHER A. PRINE Fifteenth DistrictClerk Michael Sickels, et al. §

Appellees’ Unopposed Motion to Extend Time to File Appellees’ Brief

Appellees Michael Sickels and James Christopher Cole respectfully

request this Court to grant this unopposed motion and to extend their

deadline to file their brief to January 12, 2026 for the following reasons:

1. Appellant filed its brief in this accelerated appeal on November

24, 2025.

2. Under the rules, Appellees’ brief is currently due December 16,

2025.

3. Appellees respectfully request a 44-day extension of their

deadline because, in the days and weeks after Appellant filed its brief, their

undersigned appellate counsel has been responsible for the following

additional obligations:

¾ November 27–30, 2025: Thanksgiving holiday with family and preparation for ten-day jury trial, which began on December 1,

-1- 2025 in Forrest v. Lucas Construction Co., and is pending in the 122nd District Court of Galveston County, Texas as Cause No. 23-CV-1475;

¾ December 11, 2025: Reply brief due in Bencomo v. Embrey Management Services, which is pending in Texas’s Eleventh Court of Appeals as Case No. 11-25-00152-CV;

¾ December 18, 2025: Motion for rehearing due in Elite Protective Services LLC v. Black, which is pending in Texas’s Fourteenth Court of Appeals as Case No. 14-24-00423-CV;

¾ December 26–30, 2025: Pre-planned and pre-paid out-of-state trip with family;

¾ December 29, 2025: Reply brief due in Debord v. Levya, which is pending in Texas’s Fifth Court of Appeals as Case No. 05-25- 00646-CV; and

¾ January 6, 2025: Reply brief due in Salazar v. First Alarm Security & Patrol Inc., which is pending in California’s Sixth District Court of Appeal as Case No. H052632.

4. This is Appellees’ first request for an extension of any deadline

in this appeal; this Court granted Appellant two extensions totaling 44 days.

5. Because Appellant’s counsel does not oppose this extension,

Appellant will not suffer any prejudice if this motion is granted.

6. This motion is not made for purposes of delay.

-2- Respectfully submitted,

/s/ Matthew J. Kita Matthew J. Kita Texas Bar No. 24050883 3110 Webb Avenue, Suite 150 Dallas, Texas 75205 (214) 699-1863 matt@mattkita.com

Counsel for Appellees

Certificate of Conference

On November 27, 2025, I conferenced with counsel for Appellant, David Walsh, via e-mail regarding the merits of this motion and he represented that he does not oppose the relief requested.

/s/ Matthew J. Kita Matthew J. Kita

-3- Certificate of Service

I certify that on December 5, 2025, I served a copy of this motion on the following counsel of record in accordance with Texas Rule of Appellate Procedure 9.5 and this Court’s local rules:

Counsel for Appellant:

David Walsh dwalsh@kaktxlaw.com

-4- 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.

Matthew Kita on behalf of Matthew Kita Bar No. 24050883 matt@mattkita.com Envelope ID: 108764803 Filing Code Description: Motion Filing Description: Appellees??? Unopposed Motion to Extend Time to File Appellees??? Brief Status as of 12/5/2025 11:20 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Kyle Dreyer 6119500 kdreyer@mytexasfirm.com 12/5/2025 10:59:01 AM SENT

David Walsh dwalsh@katxlaw.com 12/5/2025 10:59:01 AM SENT

Jeffery M.Kershaw kalawefiling@katxlaw.com 12/5/2025 10:59:01 AM SENT

E-Service KAK e-service@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Laurie Stroh lstroh@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Jacqueline Cochrane jcochrane@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Ana Romano aromano@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Josh Flippin legal@mytexasfirm.com 12/5/2025 10:59:01 AM SENT