Donal Turner v. Christus St. Michael Health System ( 2015 )

ACCEPTED 06-15-00068-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 12/16/2015 4:55:21 PM DEBBIE AUTREY CLERK Docket Number: 06-1 5-00068-CV DONAL TURNER IN THE OMCOURT OF APPEAL FILED IN Appellant 6th COURT OF APPEALS TEXARKANA, TEXAS YERSUS or' 12/16/2015 4:55:21 PM DEBBIE AUTREY CHRISTUS ST. MICIM,AL Clerk HEALTH CENTER TEXARKANA, TEXAS MOTION TOR EXTENSION OF TIME TO THE TIONORABLE JUSTICES OF SAID COURT NOW COMES Appellant, Donal Tumer, who ask the Court to extend the time to file their brief. A. Introduction 1. Appellant is Donal Turner; Appellee is Christus St. Michael Health Center. B. Argument & Authorities 2. The Court has the authority under Texas Rule of Appellate Procedure 38.6(d) to extend the time to file the brief. 3. Appellant brief is due on December 21,2015. 4. Appellant requests an additional 30 days to file their brief, extending the time until January 19,2016. 5. No previous extension has been granted to extend the time to file Appellants' brief. Appellant needs additional time to file their brief in this matter because Counsel's recent schedule has included several hearings, mediations, and other matter which hasn't given counsel time to prepare a brief in this matter. C. Prayer 7. For these reason, Appellant ask the Court to grant an extension of time to file their brief until January 19,2016. THE BERNOUDY LAW FIRM Respectfully Submitted by: THE BERNOUDY LA Michael L. Bemoudy, Jr. Texas Bar No. 24051882 2400 W. Grand Ave Marshall, TX75670 Telephone: (903) 935 -4223 MLBj r@bernoudyl awfirrn. com www.bernoudylawfi rm. com CERTIFICATE OF SERVIQE I HEREBY CERTIFY that a copy of the foregoing pleading was served via fax n to Michelle E. Robbers on at (214) 712-9540this it' day of December, 2015. SIGNED this