B.W.D. v. James W. Turnage, Forensic Dna & Drug Testing Services, Inc. ( 2015 )

FILED
15-0367
5/15/2015 12:14:38 PM
tex-5300580
SUPREME COURT OF TEXAS
BLAKE A. HAWTHORNE, CLERK
No. _____________________________
IN THE
SUPREME COURT OF TEXAS
___________________________________________________
B.W.D.,
Petitioner,
v.
JAMES W. TURNAGE, FORENSIC DNA
& DRUG TESTING SERVICES, INC.,
Respondents.
___________________________________________________
PETITIONER’S MOTION FOR EXTENSION
OF TIME TO FILE PETITION FOR REVIEW
TO THE HONORABLE SUPREME COURT OF TEXAS:
Petitioner files this First [Unopposed] Motion for Extension of Time to
File Petition for Review under Tex. R. App. P. 10.1, 10.5(b), and 53.7(f). In support
of this motion, Petitioner shows the following:
1. The Court of Appeals for the Fifth District of Texas at Dallas rendered its Order
Denying Appellant’s Motion for Rehearing B.W.D. v. James W. Turnage and
Forensic DNA Drug Testing Services, Inc., No. 05-13-01733-CV on March 31, 2015.
The Petition for Review is due no later than May 15, 2015.
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2. Petitioner requests an extension of time of 14 days, to May 29, 2015. This is
Petitioner's first request for an extension of time in this case.
3. Petitioner relies on the following facts as a reasonable explanation for the
requested extension of time. Petitioner's counsel, in addition to preparing a Petition
for Review in this case, has also devoted and must continue to devote time to the
following additional matters:
Cause No. DC-12-05346; Susan Ashton v. KoonsFuller, P.C.; In the
95th District Court of Dallas County, Texas: response to Motion for
Summary Judgment
Case No. 2:15-CV-00034-J; Lovell, Lovell, Newsom & Isern, LLP v.
Julian Bivins, II; United States District Court for the Northern District
of Texas, Amarillo Division: out of town depositions with necessary
travel, other discovery, and briefing and preparation required;
Cause No. 2012-DCV04088; Ashley Bowling v. Michael C. Graham and
The Graham Law Firm, PLLC; In the 384th Judicial District of El Paso
County, Texas: settlement details;
Cause No. DC-14-04075; Robertson et al v. Shariati et al; In the 14th
District of Dallas County, Texas: depositions, discovery
supplementation, and briefing with preparation required;
Cause No. 101782-E; Christina Lee Kite f/ka/ Christina Lee Barnhill v.
Charles Edward King and Sprouse Shrader Smith, P.C.; In the 108th
District Court of Potter County, Texas: depositions with travel
required, other discovery and legal briefing and preparation;
Cause No. D-506-CV-2014-00369; Purvis Operating Co. and Purvis Oil
Co. v. Sean Guerrero; In the Fifth Judicial District of Lea County, New
Mexico: legal briefing and out of town deposition; and
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Cause No. D-117-CV-2013-00306; Debbie Trujillo, Individually and as
Personal Representative of the Estate of Harry Thompson, Deceased;
Kelly Thompson; Michael Trujillo; and Bernadette Trujillo v.
Presbyterian Healthcare Services d/b/a Espanola Hospital and W.
Murray Ryan, M.D.; In the First Judicial District of Rio Arriba County,
New Mexico: hearing, preparation, and travel.
4. The undersigned has conferred with opposing counsel, who has opposition to
this requested extension.
THEREFORE, Petitioner prays that this Court grant this motion for extension
of time.
Respectfully submitted,
THE PERRIN LAW FIRM
1910 Pacific Avenue, Suite 6050
Dallas, Texas, 75201
Telephone: (214) 646-2004
Facsimile: (214) 646-6117
Email: dougperrin@perrinlaw.org
markperrin@perrinlaw.org
/s/Doug Perrin
Doug Perrin
State Bar No. 15796520
J. Mark Perrin
State Bar No. 24013313
ATTORNEYS FOR PETITIONER
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CERTIFICATE OF CONFERENCE
As required by Tex. R. App. P. 10.1(a)(5), I certify that I have conferred with
Jose Portela, attorney for Respondents, who indicated that this Motion is unopposed.
Certified this 15th day of May, 2015.
/s/Doug Perrin
Doug Perrin
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of the above and foregoing
document was forwarded to counsel for the Respondents in the above cause as stated
below, on this the 15th day of May, 2015.
Jose Portela VIA E-SERVICE
The Beckham Group
3400 Carlisle, Suite 550
Dallas, Texas 75204
/s/Doug Perrin
Doug Perrin
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