Vicky McKenna v. Baylor College of Medicine

Court of Appeals of Texas·Decided October 12, 2015·No. 01-15-00090-CV·Published

Opinion

ACCEPTED 01-15-00090-cv

FIRST COURT OF APPEALS

HOUSTON, TEXAS 10/12/2015 9:30:31 AM CHRISTOPHER PRINE

CLERK

IN THE FIRST COURT OF APPEALS

VICKY McKENNA § FILED IN

§ 1st COURT OF APPEALS VS. § HOUSTON, TEXAS § CASE NO. 10/12/2015 9:30:31 AM 01-15-00090-CV

BAYLOR COLLEGE OF MEDICINE § CHRISTOPHER A. PRINE Clerk

APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE APPELLANT’S REPLY BRIEF

Appellant, Vicky McKenna, files this Motion under Rule 10.5(b), TEX. R. APP. P., and

asks this Court for an extension of time in which to file Appellant’s Reply Brief. In support of

this motion, Appellant would show the Court as follows.

1. This is Appellant’s first request for an extension to file her Reply Brief.

2. This motion is unopposed by Baylor College of Medicine.

3. Appellant requests until October 29, 2015 an extension of fourteen (14) days in

which to file her Reply Brief. The present deadline for filing is October 14, 2015.

4. Appellant’s counsel, a solo practitioner, has insufficient time to prepare and file

the Reply Brief due to a number of depositions and hearings and an arbitration.

5. Appellant submits that Appellee is not prejudiced by this delay.

6. This request is not made for delay only, but in order that justice may be done.

WHEREFORE, Appellant, Vicky McKenna, requests the Court extend the time for

Appellant to file until October 29, 2015.

Respectfully submitted,

By: /s/ Glenn W. Patterson, Jr. Glenn W. Patterson, Jr. State Bar No. 15612500 11 Greenway Plaza, Suite 2820 Houston, Texas 77046 (713) 961-1200 (713) 961-0941 (Fax) glenn@patterson-adr.com

ATTORNEY FOR APPELLANT VICKY MCKENNA

CERTIFICATE OF CONFERENCE

I spoke with counsel for Appellee, who advised that Appellee does not oppose the motion.

/s/ Glenn W. Patterson, Jr.

Glenn W. Patterson, Jr.

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing instrument was served on all counsel of record via electronic transmission.

Shauna Clark Heather Sherrod Fulbright & Jaworski, L.L.P. 1301 McKinney, Suite 5100 Houston, Texas 77010

/s/ Glenn W. Patterson, Jr.

Glenn W. Patterson, Jr.

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ACCEPTED 01-15-00090-cv

FIRST COURT OF APPEALS

HOUSTON, TEXAS 10/12/2015 9:30:31 AM CHRISTOPHER PRINE

CLERK

IN THE FIRST COURT OF APPEALS

VICKY McKENNA § FILED IN

§ 1st COURT OF APPEALS VS. § HOUSTON, TEXAS § CASE NO. 10/12/2015 9:30:31 AM 01-15-00090-CV

BAYLOR COLLEGE OF MEDICINE § CHRISTOPHER A. PRINE Clerk

APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE APPELLANT’S REPLY BRIEF

Appellant, Vicky McKenna, files this Motion under Rule 10.5(b), TEX. R. APP. P., and

asks this Court for an extension of time in which to file Appellant’s Reply Brief. In support of

this motion, Appellant would show the Court as follows.

1. This is Appellant’s first request for an extension to file her Reply Brief.

2. This motion is unopposed by Baylor College of Medicine.

3. Appellant requests until October 29, 2015 an extension of fourteen (14) days in

which to file her Reply Brief. The present deadline for filing is October 14, 2015.

4. Appellant’s counsel, a solo practitioner, has insufficient time to prepare and file

the Reply Brief due to a number of depositions and hearings and an arbitration.

5. Appellant submits that Appellee is not prejudiced by this delay.

6. This request is not made for delay only, but in order that justice may be done.

WHEREFORE, Appellant, Vicky McKenna, requests the Court extend the time for

Appellant to file until October 29, 2015.

Respectfully submitted,

By: /s/ Glenn W. Patterson, Jr. Glenn W. Patterson, Jr. State Bar No. 15612500 11 Greenway Plaza, Suite 2820 Houston, Texas 77046 (713) 961-1200 (713) 961-0941 (Fax) glenn@patterson-adr.com

ATTORNEY FOR APPELLANT VICKY MCKENNA

CERTIFICATE OF CONFERENCE

I spoke with counsel for Appellee, who advised that Appellee does not oppose the motion.

/s/ Glenn W. Patterson, Jr.

Glenn W. Patterson, Jr.

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the above and foregoing instrument was served on all counsel of record via electronic transmission.

Shauna Clark Heather Sherrod Fulbright & Jaworski, L.L.P. 1301 McKinney, Suite 5100 Houston, Texas 77010

/s/ Glenn W. Patterson, Jr.

Glenn W. Patterson, Jr.

Vicky McKenna v. Baylor College of Medicine, (Tex. Ct. App. 2015).

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