Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 8/11/2015 2:31:25 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00266-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 8/11/2015 2:31:25 PM CHRISTOPHER PRINE CLERK NO. 01-15-00266-CV In The First Court of Appeals
U NOCAL P IPELINE C OMPANY , Appellant, v.
BP P IPELINES (A LASKA ) I NC ., ET AL . Appellees. On Appeal from the 165th District Court of Harris County, Texas
Hon. Elizabeth Ray, Presiding U NOPPOSED M OTION FOR E XTENSION OF T IME TO F ILE B RIEF OF A PPELLEES TO THE HONORABLE FIRST COURT OF APPEALS:
Pursuant to T EX . R. A PP . P. 38.6(d), Appellees BP Pipelines (Alaska)
Inc.; ConocoPhillips Transportation Alaska, Inc.; and ExxonMobil Pipeline
Co. (“Appellees”) ask this Court to extend by 30 days the time for filing
their Response Brief. The new deadline would be September 18, 2015. This
motion is their first request and it is not opposed.
1. Background: The Appellant filed its initial brief on July 20,
2015, after one extension of time. Accordingly, Appellees’ response brief is
presently due on August 19, 2015.
2. Grounds for the extension:
Michael Powell has taken primary responsibility for drafting the
Appellees’ brief. Although Mr. Powell and his team have begun work on
the response brief, Mr. Powell had surgery on July 27 that required time
and additional care during the time allocated for the briefing in this case.
Other pending cases have also required his attention, including:
July 31 Commissioner of the General Land Office v. SandRidge Energy, Inc.,
et al. , No. 15-0246 in the Supreme Court of Texas— filed two
Responses to Petitions for Review
ongoing Texas Crude Energy, LLC v. Burlington Resources Oil & Gas Co.,
LP , No. L-13-0061-CV-B, in the 156th District Court— motions
for summary judgment, mediation, depositions, and jury
charge
ongoing Smith v. SEECO, et al. , No. 4:14-cv-435-BRW in the United States
District Court for the Eastern District of Arkansas—
depositions, hearings, and preparation for class certification
hearing
3. This motion is unopposed.
PRAYER Appellees pray that this Motion be granted and that the time for
filing their Response Brief be extended by 30 days to September 18, 2015.
Respectfully submitted, L OCKE L ORD LLP By: /s/ Michael Powell (by permission) Michael V. Powell State Bar No. 16204400 2200 Ross Ave., Suite 2200 Dallas, TX 75201 Telephone: (214) 740-8000 Facsimile: (214) 756-8520 Christopher Dove State Bar No. 24032138 L OCKE L ORD LLP 600 Travis Street, Suite 2800 Houston, Texas 77002 Telephone: (713) 226-1200 Facsimile: (713) 223-3717 A TTORNEYS FOR A PPELLEES *4 CERTIFICATE OF CONFERENCE I have conferred with opposing counsel, and opposing counsel is
unopposed to this motion.
/s/ Michael Powell (by permission) Michael Powell CERTIFICATE OF SERVICE I hereby certify that on August 11, 2015, a true and correct copy of the
foregoing was served on the following counsel of record via electronic
service through electronic filing:
Mark A. Giugliano
mgiugliano@gibbsbruns.com
Anthony N. Kaim
akaim@gibbsbruns.com
J. Benjamin Bireley
bbireley@gibbsbruns.com
G IBBS & B RUNS , LLP
1100 Louisiana, Suite 5300
Houston, TX 77002
Attorneys for Appellant Unocal Pipeline Company
/s/ Christopher Dove Christopher Dove