NO. 01-12-01108-CV

IN THE COURT OF APPEALS

FOR THE FIRST DISTRICT OF TEXAS 

AT HOUSTON 

TELICIA OWENS, 

Appellant, 

V.

MEMORIAL HERMANN HOSPITAL SYSTEM D/B/A MEMORIAL HERMANN –

TEXAS MEDICAL CENTER, ET AL., 

Appellees.

On Appeal from the 152nd Judicial District Court of Harris County, Texas 

Trial Court Cause No. 2012-07534

MEMORIAL HERMANN HOSPITAL SYSTEM D/B/A MEMORIAL HERMANN –

TEXAS MEDICAL CENTER’S UNOPPOSED MOTION FOR

EXTENSION OF TIME TO FILE A MOTION FOR REHEARING AND/OR 

A MOTION FOR EN BANC RECONSIDERATION 

Richard M. Law

State Bar No. 12004500 

Angela M. Nolan 

State Bar No. 00798400 

Smith Adams Law Feehan LLP 

1415 Louisiana, Suite 3800 

Houston, Texas 77002 

(713) 652-3200 – Telephone 

(713) 652-6000 – Facsimile 

ATTORNEYS FOR APPELLEE, 

MEMORIAL HERMANN HOSPITAL SYSTEM D/B/A MEMORIAL HERMANN –

TEXAS MEDICAL CENTER 

ACCEPTED

01-12-01108-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

5/8/2015 9:25:08 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 5/8/2015 9:25:08 AM CHRISTOPHER A. PRINE Clerk
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MEMORIAL HERMANN HOSPITAL SYSTEM D/B/A MEMORIAL HERMANN –

TEXAS MEDICAL CENTER’S UNOPPOSED MOTION FOR

EXTENSION OF TIME TO FILE A MOTION FOR REHEARING AND/OR

A MOTION FOR EN BANC RECONSIDERATION

Appellee, MEMORIAL HERMANN HOSPITAL SYSTEM D/B/A 

MEMORIAL HERMANN – TEXAS MEDICAL CENTER (“Memorial Hermann”), 

files this Unopposed Motion respectfully requesting an extension of forty-five (45) 

days to file a Motion for Rehearing and/or a Motion for En Banc Reconsideration 

in this matter. In support of the same, Memorial Hermann shows the Court the 

following:

1. Appellees are Memorial Hermann Hospital System d/b/a Memorial Hermann 

– Texas Medical Center, Kenneth A. Totz, D.O., Krista G. Handyside, M.D., and 

Samuel J. Prater, M.D.; Appellant is Telicia Owens.

2. This Unopposed Motion is filed within any deadlines contemplated under 

Texas Rules of Appellate Procedure 10.1, 10.5, and 49.

3. This Motion for Extension is unopposed.

4. The Court may grant an extension of time under the authority of Texas Rule 

of Appellate Procedure 10.5(b).

5. This is an unopposed motion requesting an extension of time to file a Motion 

for Rehearing and/or a Motion for En Banc Reconsideration of the Judgment and 

Opinion entered by this Court on April 23, 2015. The current deadline to file 
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Memorial Hermann’s Motion for Rehearing and/or Motion for En Banc 

Reconsideration is May 8, 2015.

6. Memorial Hermann requests an additional forty-five (45) days to file its

Motion for Rehearing and/or Motion for En Banc Reconsideration, extending the 

time that the motions are due until June 22, 2015.

7. Memorial Hermann does not seek this extension for reasons of delay, but

so counsel may have more time for consideration of appellate issues and so that 

justice may be done.

8. Memorial Hermann has sought no prior extensions to file these motions.

9. For the above reasons, Memorial Hermann respectfully requests that the 

Court grant an extension of time to file its Motion for Rehearing and/or Motion for 

En Banc Reconsideration until June 22, 2015.

10. Memorial Hermann respectfully requests all other appropriate relief.
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Respectfully submitted,

SMITH ADAMS LAW FEEHAN LLP

/s/ Angela M. Nolan______________

Richard M. Law

Texas Bar No. 12004500

Richard@SmithAdamsLaw.com

Angela M. Nolan

Texas Bar No. 00798400

Angela@SmithAdamsLaw.com

1415 Louisiana, Suite 3800

Houston, Texas 77002

(713) 652-3200 Phone

(713) 652-6000 Fax

ATTORNEYS FOR APPELLEE,

MEMORIAL HERMANN HOSPITAL SYSTEM 

D/B/A MEMORIAL HERMANN – TEXAS 

MEDICAL CENTER
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CERTIFICATE OF CONFERENCE

Counsel for Memorial Hermann has conferred with Appellant’s counsel 

regarding this Motion for Extension of Time to File a Motion for Rehearing and/or 

a Motion for En Banc Reconsideration. Appellant’s counsel is unopposed.

/s/ Angela M. Nolan

Angela M. Nolan

CERTIFICATE OF SERVICE

I, Charles B. Holm, hereby certify that a true and correct copy of the foregoing 

instrument was provided to all counsel of record in accordance with the applicable 

Texas Rules of Appellate Procedure on this the 8

th day of May, 2015.

Reginald E. McKamie, Sr.

Law Offices of Reginald E. McKamie, Sr.

1210 Antoine Drive, Suite 100

Houston, Texas 77055

Via Facsimile: (713) 465-2894

Charles B. Holm

Holm Bambace LLP

1010 Lamar, Suite 100

Houston, Texas 77002

Via Facsimile: (713) 652-9702

Frank A. Doyle

Gabe A. Sassin

Myers Doyle

7676 Woodway, Suite 350

Houston, Texas 77063

Via Facsimile: (713) 278-9163

/s/ Angela M. Nolan

Angela M. Nolan