Shannon Medical Center v. Michael Sickels and James Christopher Cole

ACCEPTED
15-25-00167-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/5/2025 10:59 AM
Case No. 15-25-00167-CV CHRISTOPHER A. PRINE
CLERK
Shannon Medical Center § FILED IN
15th COURT OF APPEALS
§ AUSTIN, TEXAS
Court of Appeals of Texas
v. § 12/5/2025 10:59:01 AM
§ CHRISTOPHER A. PRINE
Fifteenth DistrictClerk
Michael Sickels, et al. §

Appellees’ Unopposed Motion to Extend Time
to File Appellees’ Brief

Appellees Michael Sickels and James Christopher Cole respectfully

request this Court to grant this unopposed motion and to extend their

deadline to file their brief to January 12, 2026 for the following reasons:

1. Appellant filed its brief in this accelerated appeal on November

24, 2025.

2. Under the rules, Appellees’ brief is currently due December 16,

2025.

3. Appellees respectfully request a 44-day extension of their

deadline because, in the days and weeks after Appellant filed its brief, their

undersigned appellate counsel has been responsible for the following

additional obligations:

¾ November 27–30, 2025: Thanksgiving holiday with family and
preparation for ten-day jury trial, which began on December 1,

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2025 in Forrest v. Lucas Construction Co., and is pending in the
122nd District Court of Galveston County, Texas as Cause No.
23-CV-1475;

¾ December 11, 2025: Reply brief due in Bencomo v. Embrey
Management Services, which is pending in Texas’s Eleventh
Court of Appeals as Case No. 11-25-00152-CV;

¾ December 18, 2025: Motion for rehearing due in Elite Protective
Services LLC v. Black, which is pending in Texas’s Fourteenth
Court of Appeals as Case No. 14-24-00423-CV;

¾ December 26–30, 2025: Pre-planned and pre-paid out-of-state
trip with family;

¾ December 29, 2025: Reply brief due in Debord v. Levya, which is
pending in Texas’s Fifth Court of Appeals as Case No. 05-25-
00646-CV; and

¾ January 6, 2025: Reply brief due in Salazar v. First Alarm
Security & Patrol Inc., which is pending in California’s Sixth
District Court of Appeal as Case No. H052632.

4. This is Appellees’ first request for an extension of any deadline

in this appeal; this Court granted Appellant two extensions totaling 44 days.

5. Because Appellant’s counsel does not oppose this extension,

Appellant will not suffer any prejudice if this motion is granted.

6. This motion is not made for purposes of delay.

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Respectfully submitted,

/s/ Matthew J. Kita
Matthew J. Kita
Texas Bar No. 24050883
3110 Webb Avenue, Suite 150
Dallas, Texas 75205
(214) 699-1863
matt@mattkita.com

Counsel for Appellees

Certificate of Conference

On November 27, 2025, I conferenced with counsel for Appellant,
David Walsh, via e-mail regarding the merits of this motion and he
represented that he does not oppose the relief requested.

/s/ Matthew J. Kita
Matthew J. Kita

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Certificate of Service

I certify that on December 5, 2025, I served a copy of this motion on
the following counsel of record in accordance with Texas Rule of Appellate
Procedure 9.5 and this Court’s local rules:

Counsel for Appellant:

David Walsh
dwalsh@kaktxlaw.com

/s/ Matthew J. Kita
Matthew J. Kita

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Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Matthew Kita on behalf of Matthew Kita
Bar No. 24050883
matt@mattkita.com
Envelope ID: 108764803
Filing Code Description: Motion
Filing Description: Appellees??? Unopposed Motion to Extend Time to
File Appellees??? Brief
Status as of 12/5/2025 11:20 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Kyle Dreyer 6119500 kdreyer@mytexasfirm.com 12/5/2025 10:59:01 AM SENT

David Walsh dwalsh@katxlaw.com 12/5/2025 10:59:01 AM SENT

Jeffery M.Kershaw kalawefiling@katxlaw.com 12/5/2025 10:59:01 AM SENT

E-Service KAK e-service@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Laurie Stroh lstroh@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Jacqueline Cochrane jcochrane@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Ana Romano aromano@kaktxlaw.com 12/5/2025 10:59:01 AM SENT

Josh Flippin legal@mytexasfirm.com 12/5/2025 10:59:01 AM SENT