## No. 01

- 12

- 00578

- CV

In the First Court of Appeals Houston, Texas J IM 

## P. B ENGE 

## , MD AND 

## K ELSEY 

## -S EYBOLD 

## M EDICAL 

## GROUP PLLC D EFENDANT S/A

PPELLANT S V . 

## LAUREN 

## WILLIAMS PLAINTIFF /A PPELLEE On Appeal from the 164 th District Court

Harris County, Texas No. 201 0- 52657 

## APPELLANTS 

## í U NOPPOSED 

## M OTION FOR 

## E XTENSION OF 

## T IME TO 

## F ILE 

## R ESPONSES TO 

## M OTIONS FOR 

## R EHEARING AND 

## E N 

## BANC 

## R ECONSIDERATION David George Texas Bar No. 00793212 Earnest W. Wotring Texas Bar No. 22012400 Amy Nilsen Texas Bar No. 24027574 C ONNELLY ïBAKER ïW OTRING LLP 700 JPMorgan Chase Tower 600 Travis Street Houston, Texas 77002 Telephone: (713) 980

- 6513 Fax: (713) 980

- 1701 dgeorge@connellybaker.com Counsel for Appellant s ACCEPTED 01-12-00578-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 3/5/2015 12:19:59 PM CHRISTOPHER PRINE

CLERK2

Pursuant to Texas Rule s of Appellate Procedure 10.5(b), Appellant s Jim Benge, MD and Kelsey

- Seybold Medical Group, PLLC (collectively, ì Kelseyî) 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, 2 015
. Williams does not oppose this request. David George is Kelsey ís 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 i n 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 K elsey

- 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 C ONNE LLY ïBAKER ïW OTRING LLP 700 JPMorgan Chase Tower 600 Travis Street Houston, Texas 77002 Telephone: (713) 980

- 6513 Fax: (713) 980

- 1701 dgeorge@connellybaker.com Counsel for Appellant s4 

### C **ERTIFICATE OF** 

### C **ONFERENCE** 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 D avid George



### C **ERTIFICATE OF** 

### S **ERVICE** 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 T HE F ORBES F IRM , PLLC 2114 W oodcrest Drive Houston, Texas 770 18 lucy@forbesfirm.com Randall O. Sorrels A BRAHAM , WATKINS , N ICHOLS , S ORRELS , A GOSTO & F RIEND 800 Commerce Street Houston, Texas 77002 rsorrels@abrahamwatkins.com

/ S/ D avid George D avid George