Appellee’s Unopposed Motion for 

Extension of Time To File Appellee Brief Page 1

NO. 03-15-00596-CV

IN THE COURT OF APPEALS 

THIRD DISTRICT OF TEXAS, AUSTIN 

GRACY WOODS I NURSING HOME 

Appellant, 

v.

MARTHA MAHAN, AS REPRESENTATIVE 

OF THE ESTATE OF MARY RIVERA 

Appellee. 

ON INTERLOCUTORY APPEAL FROM 

THE 250TH JUDICIAL DISTRICT, TRAVIS COUNTY, TEXAS 

APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

APPELLEE BRIEF 

JACK MODESETT 

STATE BAR NO. 14244337 

WALTER V. WILLIAMS 

STATE BAR NO. 21584800 

MODESETT WILLIAMS, PLLC

515 CONGRESS AVENUE, SUITE 1650 

AUSTIN, TEXAS 78701 

(512) 472-6097 TELEPHONE 

(512) 481-0130 FACSIMILE 

ATTORNEYS FOR APPELLEE 

ACCEPTED

03-15-00596-CV

7879540

THIRD COURT OF APPEALS

AUSTIN, TEXAS

11/18/2015 10:08:28 AM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 11/18/2015 10:08:28 AM JEFFREY D. KYLE Clerk
Appellee’s Unopposed Motion for 

Extension of Time To File Appellee Brief Page 2

TO THE HONORABLE COURT OF APPEALS:

1. In accordance with TEX. R. APP. P. 10.5(b)(1) Appellee Martha Mahan, as 

Representative of the Estate of Mary Rivera brings this unopposed request for an extension of time 

to file Appellee’s Brief.

2. This motion is Appellee’s first request for extension of time to file its Brief.

3. Appellee’s deadline to file its brief is currently November 30, 2015. 

4. Appellee seeks a 14 day extension. If granted, Appellee’s deadline to file its Brief 

would be December 14, 2015.

5. Appellee requests the extension due to appellee counsel’s commitments in other 

matters, which will affect counsel’s ability to devote a sufficient amount of time to file Appellee’s 

Brief.

6. Counsel for Appellant does not object to Appellee’s request for a 14 day extension 

of time to file Appellee’s Brief.

7. Appellee does not seek this extension of time for the sole purpose of delay but so 

that justice may be done.
Appellee’s Unopposed Motion for 

Extension of Time To File Appellee Brief Page 3

PRAYER

WHEREFORE, PREMISES CONSIDERED, Appellee Martha Mahan, as Representative 

of the Estate of Mary Rivera, respectfully requests that this Court grant an additional fourteen days 

from November 30, 2015 to December 14, 2015 for Appellee to file its Brief.

Respectfully Submitted,

MODESETT WILLIAMS, PLLC

2202 Lake Austin Boulevard

Austin, Texas 78703

512.472.6097 Telephone

512.481.0130 – Telecopier

By: 

 Walter V. Williams

 Texas Bar No. 21584800

 Jack H. Modesett, III

 Texas Bar No. 14244337

 Attorneys for Plaintiffs 

CERTIFICATE OF CONFERENCE

Counsel for Appellee conference with counsel for Appellee concerning this request for a 

14 day extension via email on November 12, 2015. Counsel for Appellee does not oppose the 

request.

Walter V. Williams
Appellee’s Unopposed Motion for 

Extension of Time To File Appellee Brief Page 4

CERTIFICATE OF SERVICE

Pursuant to rule 9.5 of the Texas Rules of Appellate Procedure, I hereby certify that a true 

and correct copy of the foregoing instrument has been filed electronically and delivered 

electronically and via facsimile to the following counsel of record on this 18th day of November, 

2015: 

Emily Davenport (612) 660-5979

Reed, Claymon, Meeker & Hargett, PLLC

5608 Parkcrest Drive, Suite 200

Austin, Texas 78731

edavenport@rcmhlaw.com

Walter V. Williams