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- CASE NO. 14-15-00704-CV

IN THE FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

AIMEE HARVEY INDIVIDUALLY AND AS NEXT FRIEND OF TALISA

PHILLIPS, AMANDA HARVEY, HENRY WILSON, III, AS NEXT FRIEND

OF AALEISA PHILLIPS (A MINOR) AND GWENDOLYN WILSON

Appellants,

vs.

KINDRED HEALTHCARE OPERATING, INC., KINDRED HOSPITAL

HOUSTON MEDICAL CENTER, KINDRED HOSPITALS LIMITED

PARTNERSHIP

Appellees

On Appeal from the 190 th District Court, Harris County, Texas

Trial Court Cause No. 2014-27575

APPELLANTS’ FIRST UNOPPOSED MOTION

FOR AN EXTENSION OF TIME TO FILE BRIEF

Respectfully submitted,

T HE L AW O FFICE OF P ERCY C. S INGLETON

, J R

.

By:_______________________

Percy C. Singleton, Jr.,

Texas Bar No. 24046854

2818 Cleburne St,

Houston, Texas 77004

Telephone 713.664.7678

Facsimile 713.436.8788

Email: psinglaw@gmail.com

ATTORNEY FOR APPELLANT ACCEPTED

14-15-00704-cv

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

11/18/2015 3:09:52 PM

CHRISTOPHER PRINE

CLERK- 2

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TO THE HONORABLE FOURTEENTH COURT OF APPEALS:

COMES NOW, APPELLANTS’ AIMEE HARVEY, ET. AL., respectfully

showing the Court as follows:

This is Appellants’ first unopposed motion for extension of time to file its

brief. The Appellants’ brief is due on November 23, 2015. Appellant moves

the Court for a 50-day extension. This extension is necessary is because

Appellants’ Counsel has had an extremely busy schedule the past forty-five (45)

days, in completing discovery and getting ready for trial in two cases, where trials

were set. The record in this matter was also delayed in some form. Appellants’

Counsel was also set for trial in criminal district court as well.

Appellants’ Counsel believes a 50-day extension would allow the response

brief for appellee to submitted after the holiday period and not cause an

inconvenience regarding preplanned travel arrangements for any involved parties.

PRAYER

Appellants’ move the Court for a 50-day extension to file their brief and for

all other relief to which he is entitled.

[signature page follows)- 3

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Respectfully submitted,

T HE L AW O FFICE OF P ERCY C. S INGLETON

, J R

.

By:

_______________________ Percy C. Singleton, Jr.,

Texas Bar No. 24046854

2818 Cleburne St,

Houston, Texas 77004

Telephone 713.664.7678

Facsimile 713.436.8788

Email: psinglaw@gmail.com

ATTORNEY FOR APPELLANT

CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I

have conferred with opposing counsel, listed below, about the merits of this motion

with the following results:

Lori Proctor, with the Cooper and Scully Law Firm, attorney for

Appellee, Kindred Hospital Inc., does not oppose motion.

Jon Hlavinka, with the Cooper and Scully Law Firm, attorney for

Appellee, Kindred Hospital Inc., does not oppose motion.

Dated: Wednesday, November 18, 2015

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- CERTIFICATE OF SERVICE

As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d), (e), I

certify that on Wednesday, November 18, 2015, I have served this document on all

other parties listed below:

Ms. Lori Proctor Via Electronic Filing

Cooper & Scully

700 Louisiana Street, Suite 3850

Houston, TX 77002

Telephone (713) 236-6800

Facsimile (713) 236-6880

Counsel for Appellee, Kindred Hospital Houston, Inc.

Mr. Jon Hlavinka Via Electronic Filing

Cooper & Scully

700 Louisiana Street, Suite 3850

Houston, TX 77002

Telephone (713) 236-6800

Facsimile (713) 236-6880

Counsel for Appellee, Kindred Hospital Houston, Inc.

By (check all that apply)

 Electronic filing

 Personal delivery

 Mail

 Commercial delivery service

 Fax

___________________________