Old Republic Insurance Co. v. Wuensche
This worker's compensation case examines whether Texas Rule of Civil Procedure 93's requirement for verified denials to be filed "not less than seven days before... trial" is absolute or can be modified by Rule 4's provisions for extending deadlines that fall on weekends or holidays. Jo Ann Wuensche, injured at Piccadilly Cafeteria, appealed an IAB award, seeking total disability benefits and asserting a specific daily wage rate. Old Republic, the opposing party, attempted to deny her wage rate claim six days before trial. The trial court disallowed the amendment, citing Rule 93. Old Republic argued for Rule 4's application due to intervening holidays. The appellate court affirmed the trial court, ruling that Rule 93's backward-calculated seven-day period is absolute and not subject to Rule 4's forward-calculated extensions, as applying Rule 4 would shorten, not lengthen, the required notice period.