Case Information
*0 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 6/18/2015 1:24:14 PM DEBBIE AUTREY Clerk *1 ACCEPTED 06-15-00007-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/18/2015 1:24:14 PM DEBBIE AUTREY CLERK
No. 06-15-00007-CV
In the Sixth Court of Appeals
Texarkana, Texas
______________________________________
H YDROGEO , LLC AND F IRST B ANK & T RUST E AST T EXAS
Appellants
AND
D E B ERRY 3 O PERATING C OMPANY , LLC,
Appellant
v.
Q UITMAN I NDEPENDENT S CHOOL D ISTRICT , W OOD C OUNTY , U PPER S ABINE W ASTE
D ISPOSAL D ISTRICT , AND W OOD C OUNTY C ENTRAL H OSPITAL D ISTRICT ,
Appellees
_______________________________________
On Appeal from the 402 nd Judicial District Court
Wood County, Texas MOTION TO EXTEND TIME FOR FILING BRIEF OF APPELLANT
TO THE HONORABLE COURT OF APPEALS:
Hydrogeo, LLC and First Bank & Trust East Texas, Appellants in the above styled and
numbered cause, hereby move the Court pursuant to Rule 38.6(d), Texas Rules of Appellate
Procedure, for an extension of time to file their brief. As grounds for such extension, the
Appellants would show the Court the following:
I.
This is Appellants’ first request for an extension of time in which to file their brief.
Appellees’ brief is due to be filed on June 18, 2015.
II.
Due to other previously scheduled matters, the undersigned counsel for Appellants, despite
best efforts to do so, has been unable to complete research and briefing necessary to finalize the
brief in this case by the due date. Those matters have included:
1. Being out of town the entire week between June 8 th and June 14 th .
2. Reviewing voluminous title documents regarding a complex oil and gas matter for a
client in Rusk County, Texas.
3. Extensive Motion practice, including drafting Motion for Entry of Judgment in Cause
No. 2013-457; Bagley Minerals, L.P. v. Brammer Petroleum, Inc. ; In the 123 rd District
Court of Panola County, Texas.
III.
Therefore, Appellants request a fourteen day extension until Thursday, July 2, 2015 in
which to file their brief. The requested extension should not in the ordinary course of procedure
in this Court delay oral argument and submission and is not requested for delay but that justice be
served.
WHEREFORE, PREMISES CONSIDERED, Appellants Hydrogeo, LLC and First Bank
& Trust East Texas, pray that the time for filing their appellate brief be extended to Thursday, July
2, 2015.
Respectfully Submitted, J. DON WESTBROOK
Texas Bar No. 21215500
C OGHLAN C ROWSON , LLP
1127 Judson Road, Suite 211
Longview, Texas 75601
(903) 758-5543
(903) 753-6989 (fax)
dwestbrook@ccfww.com
Attorneys for Hydrogeo, LLC and
First Bank & Trust East Texas
Certificate of Conference
I have contacted Edward J. (Nick) Nicholas and Jim Lambeth, Attorneys for Appellees,
Wood County, Upper Sabine Waste Disposal District and Wood County Central Hospital District,
David Hudson, Attorney for Appellee Quitman ISD, and Michael Dunn, Attorney for Appellant,
DeBerry 3 Operating Company, LLC regarding the relief sought by this motion and they have no
objection to the motion. J. Don Westbrook
Certificate of Service
I hereby certify that a true and correct copy of the foregoing Motion to Extend Time for
Filing Brief of Appellants has been forwarded to:
Appellant Counsel for DeBerry 3 Operating
DeBerry 3 Operating Company, LLC Company, LLC:
Michael L. Dunn
Smead, Anderson & Dunn
2110 Horseshoe Lane
Longview, Texas 75606
Appellee Counsel for Wood County, Upper
Wood County, Upper Sabine Sabine Waste Disposal District and
Waste Disposal District and Wood Wood County Central Hospital
County Central Hospital District District
Edward J. (Nick) Nicholas
Linebarger Goggan Blair &
Sampson, LLP
4828 Loop Central Drive, Suite 600
Houston, Texas 77081
Jim L. Lambeth
Alison Wylie
Linebarger Goggan Blair & Sampson, LLP
1517 W. Front St. Suite 202
Tyler, Texas 75702
Appellee Counsel for Quitman Independent
Quitman Independent School District School District
David Hudson
Perdue, Brandon, Fielder, Collins & Mott,
LLP
PO Box 2007
Tyler, Texas 75710 J. Don Westbrook