Lakeway Regional Medical Center, LLC and Surgical Development Partners, LLC// Lake Travis Transitional LTCH, LLC N/K/A Lake Travis Specialty Hospital, LLC v. Lake Travis Transitional LTCH, LLC N/K/A Lake Travis Specialty Hospital, LLC// Lakeway Regional Medical Center, LLC Surgical Development Partners, LLC Brennan, Manna, & Diamond, LLC And Frank T. Sossi ( 2015 )

r/RECEIVED^
JUH 3 0 2015
THIRD COURT OfAPPEALS^,
\ JEFFREY D. KYLE /
CAUSE NO. D-l-GN-12-000983
LAKE TRAVIS TRANSITIONAL LTCH, IN THE DISTRICT COURT OF
LLC n/k/a LAKE TRAVIS SPECIALTY
HOSPITAL, L.L.C.,
Plaintiff,
TRAVIS COUNTY, TEXAS
LAKEWAY REGIONAL MEDICAL
CENTER, LLC, SURGICAL
DEVELOPMENT PARTNERS, LLC,
BRENNAN, MANNA & DIAMOND, LLC,
BRENNAN, MANNA & DIAMOND, P.L.,
AND FRANK T. SOSSI,
Defendants. 345TH JUDICIAL DISTRICT
DEFENDANTS' REQUEST FOR PREPARATION OF SUPPLEMENTAL CLERK'S
RECORD
TO: Hon. Velva L. Price, District Clerk, Civil Division, 1000 Guadalupe Street, Room 301,
Austin, TX 78701
Defendants Lakeway Regional Medical Center, LLC and Surgical Development Partners,
LLC ("Defendants") are appealing the final judgment signed in this case on October 16, 2014, to
the Third Court of Appeals, Austin, Texas, Case No. 03-15-00025-CV.
On January 12, 2015, Defendants filed their Request for Preparation of Clerk's Record.
The following items were requested but were not included in the Clerk's Record filed on June
16, 2015. Nor were they included in the Clerk's Record filed on May 21 and June \8.
Defendants respectfully request that you prepare, for inclusion in a Supplemental Clerk's
Record, the following designated items and any accompanying exhibits:
Original
Date Document Description
Request No.
10 12/9/13 Plaintiffs Motion to Compel Production of Documents Based on
Crime-Fraud Exception
(Only the first page of the motion was included in the June 16, 2015
Clerk's Record.)
540513171
Original
Date Document Description
Request No.
5/21/14 Affidavit in Support of Plaintiffs Responses to Defendants'
Motions for Summary Judgment
81 8/11/14 Defendants' Objections to Plaintiffs Deposition Designations
104 10/10/14 Defendants' Opposition to Plaintiffs Motion for Entry of Judgment j
105 10/10/14 Plaintiffs Response in Opposition to Defendants' Motion to j
Disregard Certain Jury Findings and for Rendition of a Take !
Nothing Judgment Against Plaintiff
106 10/17/14 Cover letter from Judge Livingston enclosing Orders
107 signed Order - denying Defendants' Motion to Disregard Certain Jury j
10/16/14; Findings and for Renditions of a Take Nothing Judgment Against i
filed Plaintiff
10/17/14
Defendants also respectfully request that the following item be included in the
Supplemental Clerk's Record:
signed 7/16/14; Order on Defendants Brennan, Manna & Diamond, LLC and Frank T.
filed 7/17/14 Sossi's Amended Traditional and No-Evidence Motion for Summary
Judgment
6/25/15 This Request for Preparation of Supplemental Clerk's Record
Please let me know when the record is complete so that I may arrange for prompt
payment. Because the Court of Appeals has set a due date for the Appellants' Brief, we ask that
you prepare and file the supplemental record as soon as you can do so.
54061317 i
Respectfully submitted,
NORTON ROSE FULBRIGHT US LLP
By: /s/JeffCody
Jeff Cody
State Bar No. 04468960
jeff.cody@nortonrosefulbright.com
Barton W. Cox
State Bar No. 24065087
beau. cox@nortonrosefulbright.com
James V. Leito IV
State Bar No. 24054950
james.leito@nortonrosefulbright.com
2200 Ross Avenue, Suite 3600
Dallas, TX 75201-2784
Telephone: (214)855-8000
Telecopier: (214)855-8200
Joy Solo way
State Bar No. 18838700
joy.soloway@nortonrosefulbright.com
1301 McKinney, Suite 5100
Houston, TX 77010-3095-
Telephone: (713)651-5151
Telecopier: (713)651-5246
Attorneysfor Defendants Lakeway Regional
Medical Center, LLCand Surgical Development
Partners, LLC
54061317.1
CERTIFICATE OF FILING AND SERVICE
On the 25th day of June 2015, this Request for Preparation of Supplemental Clerk's
Record was served on the following and filed in compliance with the Texas Rules of Civil
Procedure and Texas Rules of Appellate Procedure by FileTime.com upon:
Hon. Velva L. Price
Travis County District Clerk
Civil Division
1000 Guadalupe Street, Room 301
Austin, TX 78701
S. Abraham Kuczaj III
akuczaj@scottdoug. com
Paige A. Amstutz
pamstutz@scottdoug. com
Steven J. Wingard
swingard@scottdoug.com
Jane Webre
jwebre@scottdoug.com
Scott Douglass & McConnico LLP
303 Colorado Street, Suite 2400
Austin, TX 78701-3234
Via Email
Robert A. Bragalone
bbragalone@gordonrees.com
B. Ryan Fellman
rfellman@gordonrees. com
Gordon & Rees LLP
2100 Ross Avenue, Suite 2800
Dallas, TX 75201
Via Email
Jeffrey D. Kyle, Clerk
Third Court of Appeals District
Price Daniel, Sr. Building
209 West 14th Street, Room 101
Austin, TX 78701
Via U.S. Mail
/s/JeffCody
JEFF CODY
540613171
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25 3Lm '15
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Joy M. Soloway Ei!£ 0001395635 JUN 25 2015
Norton Rose Fulbright US LLP
FulbrigW Tower
1301 McKmney. Suite 5100
Houston. Texas 77010-3095
MR JEFFREY D KYLE
CLERK THIRD COURT OF APPEALS
PRICE DANIEL SR BUILDING
209 WEST 14 111 STREET ROOM 101
AUSTIN, TX 78701
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