Shannon Medical Center v. Michael Sickels and James Christopher Cole

ACCEPTED
15-25-00167-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
1/5/2026 6:46 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. § 1/5/2026 6:46:43 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 19, 2026 for the following reasons:

1. Appellees’ brief is currently due January 12, 2026.

2. Appellees respectfully request a 7-day extension of their

deadline because, after this Court granted their previous extension request,

the Fourteenth Court of Appeals ordered their undersigned counsel to

appear for oral argument on January 8, 2026 in In re Quintero, which is

pending in that Court as Case No. 14-25-00757-CV.

3. In re Quintero is an original mandamus proceeding involving an

important issue of first impression and preparation for this oral argument

will prevent Appellees’ counsel from timely finalizing their brief in this case.

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4. If Appellees’ counsel was aware that the Fourteenth Court

would set In re Quintero for oral argument on January 8, 2026, he would have

requested an extension of the briefing deadline to January 19, 2026 in his

previous motion.

5. This is Appellees’ second request for an extension of this

deadline; this Court previously granted Appellant a 44-day extension from

the original deadline.

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

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

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

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

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Certificate of Conference

On January 3, 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

Certificate of Service

I certify that on Jan 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: 109631889
Filing Code Description: Motion
Filing Description: Appellees??? Unopposed Motion to Extend Time to
File Appellees??? Brief
Status as of 1/5/2026 7:07 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Kyle Dreyer 6119500 kdreyer@mytexasfirm.com 1/5/2026 6:46:43 AM SENT

David Walsh dwalsh@katxlaw.com 1/5/2026 6:46:43 AM SENT

Jeffery M.Kershaw kalawefiling@katxlaw.com 1/5/2026 6:46:43 AM SENT

E-Service KAK e-service@kaktxlaw.com 1/5/2026 6:46:43 AM SENT

Laurie Stroh lstroh@kaktxlaw.com 1/5/2026 6:46:43 AM SENT

Jacqueline Cochrane jcochrane@kaktxlaw.com 1/5/2026 6:46:43 AM SENT

Ana Romano aromano@kaktxlaw.com 1/5/2026 6:46:43 AM SENT

Josh Flippin legal@mytexasfirm.com 1/5/2026 6:46:43 AM SENT