No. 01-12-00578-CV

In the First Court of Appeals

Houston, Texas

JIM P. BENGE, MD AND 

KELSEY-SEYBOLD MEDICAL GROUP PLLC

DEFENDANTS/APPELLANTS

V.

LAUREN WILLIAMS

PLAINTIFF/APPELLEE

On Appeal from the 164th District Court

Harris County, Texas

No. 2010-52657

APPELLANTSí UNOPPOSED MOTION FOR

EXTENSION OF TIME TO FILE RESPONSES TO MOTIONS 

FOR REHEARING AND EN BANC RECONSIDERATION

David George

Texas Bar No. 00793212

Earnest W. Wotring

Texas Bar No. 22012400

Amy Nilsen

Texas Bar No. 24027574

CONNELLYïBAKERïWOTRING LLP

700 JPMorgan Chase Tower

600 Travis Street

Houston, Texas 77002

Telephone: (713) 980-6513

Fax: (713) 980-1701

dgeorge@connellybaker.com

Counsel for Appellants

ACCEPTED

01-12-00578-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

3/5/2015 12:19:59 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 3/5/2015 12:19:59 PM CHRISTOPHER A. PRINE Clerk
2

Pursuant to Texas Rules of Appellate Procedure 10.5(b), 

Appellants Jim Benge, MD and Kelsey-Seybold Medical Group, PLLC 

(collectively, ìKelseyî) request a two-week extension of the due date on 

their responses to Appellee Lauren Williamsí motions for rehearing and 

en banc reconsideration, which are currently due on March 18, 2015.

Williams does not oppose this request.

David George is Kelseyís attorney who is drafting the response to 

the motions. His work in other cases makes it difficult for him to 

complete the responses by March 18, 2015. George has a brief that is 

due in the Fifth Circuit on March 23, 2015, and that due date cannot be 

extended.1 Another attorney in Georgeís firm was handling that case, 

but she recently left the firm. George, therefore, is having to review the 

entire case to be in a position to properly draft the brief. That, of 

course, is taking additional time and interferes with his ability to draft 

the responses to Williamsí motions by March 18.

Kelsey, therefore, requests that this Court extend the due date for 

its responses to Williamsí motions for rehearing and en banc 

reconsideration by two weeks, which is until Wednesday, April 1, 2015.

1 Kelsey-Seybold Medical Group PA v. Great-West Healthcare of Tex., Inc., No. 14-

20506 (5th Cir.).
3

Respectfully submitted,

/s/ David George

David George

Texas Bar No. 00793212

Earnest W. Wotring

Texas Bar No. 22012400

Amy Nilsen

Texas Bar No. 24027574

CONNELLYïBAKERïWOTRING LLP

700 JPMorgan Chase Tower

600 Travis Street

Houston, Texas 77002

Telephone: (713) 980-6513

Fax: (713) 980-1701

dgeorge@connellybaker.com

Counsel for Appellants
4

CERTIFICATE OF CONFERENCE

I certify that on March 4, 2015, I conferred via e-mail with 

Appelleeís counsel Lucy Forbes. She informed me that she does not 

oppose the Court granting the relief requested in this motion.

/s/ David George

David George

CERTIFICATE OF SERVICE

I certify that on March 5, 2015, I served a copy of the foregoing 

document upon the following counsel of record by e-mail and certified 

mail/return receipt requested:

Lucy H. Forbes

THE FORBES FIRM, PLLC

2114 Woodcrest Drive

Houston, Texas 77018

lucy@forbesfirm.com

Randall O. Sorrels

ABRAHAM, WATKINS, NICHOLS,

SORRELS, AGOSTO & FRIEND

800 Commerce Street

Houston, Texas 77002

rsorrels@abrahamwatkins.com

/S/ David George

David George