IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI

VICKSBURG HEALTHCARE, LLC D/B/A

RIVER REGION HEALTH SYSTEM APPELLANT
VS. NO. 2013-IA-00181-SCT
CLARA DEES APPELLEE
RESPONSE TO REQUEST TO SHOW CAUSE
COMES NOW, Michael E. Winfield, counsel for Appellee, and answers this Courts
request to show cause as follows:
That I sincerely apologize for my tardiness in filing responsive pleadings herein. I have
endured one of the more stressful periods of my life. About a year ago my oldest child was
diagnosed with cancer. Adding insult to injury I my only means of access to my child or her
condition was through the court system. Thankfully, she is now cancer free. After winning that
battle my brother was prosecuted by the federal government for bribery charges to which he is
now serving a two year sentence. In addition to the aforementioned, I was just divorced of my
wife of ten years about a month ago. Furthermore, due to financial hardship, I have been
operating without the benefit of a secretary for the past six or so months. I do not share my
experience as excuses but merely as explanations of my failure to comply with this Courts
scheduling order. In light of the foregoing, I humbly request the mercy, leniency and
understanding of this Court and pray that my clients brief be accepted and considered and that
this Honorable Court not sanction myself.
Thanks in advance for your consideration of my plea.
E-Filed Document Mar 6 2014 16:17:55 2013-IA-00181-SCT Pages: 2
WHEREFORE, PREMISES CONSIDERED I respectfully request that this Court not
enter sanctions but instead accept the untimely brief of Appellant, plus any further relief this
Court deems appropriate.
Respectfully submitted,
_________________________
/S MICHAEL E. WINFIELD
MICHAEL E. WINFIELD, ESQ. MSB 99979
WINFIELD & MORAN, PLLC
Vicksburg, Mississippi 39183
Tel.: 601-638-3911
Attorney for Appellee