NO. 14-14-00754-CV

IN THE COURT OF APPEALS

FOR THE FOURTEENTH JUDICIAL DISTRICT

OF TEXAS AT HOUSTON

 

ANDRE MCCOY, AS PERMANENT GUARDIAN OF 

SHANNON MILES MCCOY, AN INCAPACITATED PERSON, 

Appellants, 

V. 

FEMPARTNERS, INC., FEMPARTNERS OF CENTRAL

HOUSTON, L.P. f/k/a OGA MANAGEMENT PARTNERSHIP, L.P.

NEW OGA, INC., PROASSURANCE CORPORATION; AMERICAN

PHYSICIANS SERVICES GROUP, INC. AND AMERICAN PHYSICIANS 

SERVICES GROUP, INC. F/K/A AMERICAN PHYSICIANS INSURANCE 

COMPANY F/K/A AMERICAN PHYSICIANS INSURANCE EXCHANGE, 

Appellees. 

 

On Appeal from Probate Court Number Two 

Of Harris County, Texas

Trial Court Cause No. 352,923-404

 

UNOPPOSED SECOND MOTION FOR 

EXTENSION OF TIME TO FILE APPELLEES’ BRIEF

 

 

 STRAWN PICKENS, LLP 

 John R. Strawn, Jr. #19374100

 Victoria Skinner #24005579

 Pennzoil Place, South Tower

711 Louisiana, Suite 1850

 Houston, Texas 77002

jstrawn@strawnpickens.com

vskinner@strawnpickens.com

 ATTORNEYS FOR APPELLEE

FemPartners, Inc., FemPartners of 

Central Houston, L.P., and New 

OGA, Inc

ACCEPTED

14-14-00754-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

3/13/2015 1:10:59 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 3/13/2015 1:10:59 PM CHRISTOPHER A. PRINE Clerk
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UNOPPOSED SECOND MOTION FOR 

EXTENSION OF TIME TO FILE BRIEF

Appellees FemPartners, Inc., FemPartners of Central Houston, L.P. 

(“Central Houston”), and New OGA, Inc. (collectively “FemPartners”)

(“Appellees”) respectfully file this unopposed Second Motion seeking an 

extension of thirty (30) days to file Appellees’ brief in this matter. Appellees 

show the following:

1. Appellees are FemPartners, Inc., FemPartners of Central 

Houston, L.P. (“Central Houston”), and New OGA, Inc. (collectively 

“FemPartners”); Appellant is Andre McCoy, as permanent guardian of 

Shannon Miles McCoy, an Incapacitated Person. 

2. This motion is filed within any deadline contemplated under 

Tex. R. App. P. 10.1, 10.5.

3. This Motion for Extension is unopposed.

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

Tex. R. App. P. 10.5(b).

5. This is an appeal of a summary judgment entered in Probate 

Court Number Two, Harris County, Texas. The deadline to file Appellees’

brief is March 23, 2015. 
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6. Appellees request an additional thirty (30) days to file their brief, 

extending the time that the brief is due until April 21, 2015.

7. Appellees do not seek this extension for reasons of delay. 

Rather, counsel for Appellees have been exceptionally busy with other 

projects which occupy the time that counsel would ordinarily use to prepare 

the Appellees’ brief, including but not limited to:

• Preparation for and participation in a multi-million dollar 

complex international arbitrating hearing, Friede & Goldman 

L.L.C. v HICO America Sales & Technology, Inc. (American 

Arbitration Association ICDR Case 50 20 1200 0918 2 GM) that 

ended March 9, 2015;

• Preparation for trial in Cause No. 2013-76981; Adam Lefton vs. 

Northstar Healthcare Acquisitions, L.L.C. and Northstar 

Healthcare, Inc., in the 11th Judicial District of Harris County, 

Texas, which had been assigned to trial starting March 30, 

2015; and

• Counsel has a longstanding family trip scheduled for March 13, 

2015 through March 23, 2015.

8. Appellees have sought one prior extension to file their brief in 

this matter.

9. For the above reasons, Appellees respectfully request the 

Court grant an extension of time to file Appellees’ brief in this appeal until 

April 21, 2015. Appellees respectfully request all other appropriate relief.
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Respectfully submitted,

STRAWN PICKENS LLP

By: /s/ John R. Strawn Jr. 

John R. Strawn, Jr., #19374100

Victoria Skinner #24005579

Pennzoil Place, South Tower

711 Louisiana, Suite 1850

Houston, Texas 77002

(713) 659-9600

(713) 659-9601 Facsimile

jstrawn@strawnpickens.com

vskinner@strawnpickens.com

ATTORNEYS FOR APPELLEE 

FemPartners, Inc., FemPartners of 

Central Houston, L.P., and New 

OGA, Inc.

CERTIFICATE OF CONFERENCE

In accordance with TEX. R. APP. P. 10.1(a)(5), the undersigned 

counsel has contacted counsel for Appellant and Appellant is unopposed to 

the Motion For Extension of Time To File Appeelles’ Brief. 

/s/ John R. Strawn, Jr. 

John R. Strawn, Jr. 
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CERTIFICATE OF SERVICE

I, John R. Strawn, Jr., hereby certify that a true and correct copy of the 

foregoing instrument has been provided to all counsel of record in 

accordance with the applicable Texas Rules of Appellate Procedure on this 

13th day of March 2015.

Alexander B. Klein, III

Email: alex@thekleinlawfirm.com

THE KLEIN LAW FIRM

2000 The Lyric Centre

440 Louisiana Street

Houston, Texas 77002

J. Todd Trombley

Email: todd@trombleylaw.com

THE TROMBLEY LAW FIRM, 

P.L.L.C.

442 Heights Boulevard

Houston, Texas 77007

Tynan Buthod

Email: ty.buthod@bakerbotts.com

Brandon Goodwin

Email:Brandon.goodwin@bakerbotts.com

BAKER BOTTS, L.L.P.

One Shell Plaza

910 Louisiana Street

Houston, Texas 77002

/s/ John R. Strawn, Jr. 

John R. Strawn, Jr.