NO. 1 4-14- 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 PHYSICIAN S 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

S TRAWN 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

CLERK2 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”)

(“Ap pellees ”) respectfull y file this unopposed Second Motion seeking an

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

show the following:

1. Appellee s 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 , 2015.3 6. Appellees request an additional thirty (30) days to file their brief,

extending the time that the brief is due until April 21, 201 5

.

7. Appe llees 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:

**•** Pr eparation 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 ha d been assigned t o 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.4 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.5 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

13 th day of March 2015

.

Alexander B. Klein, II I

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@ba kerbotts.com

BAKER BOTTS, L.L.P.

One Shell Plaza

910 Louisiana Street

Houston, Texas 77002

/s/ John R. Strawn, Jr.

John R. Strawn, Jr.