Case Information
*0 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 6/9/2015 9:13:52 PM CATHY S. LUSK Clerk *1 ACCEPTED 12-14-00262-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 6/9/2015 9:13:52 PM CATHY LUSK CLERK No. 12 - 14 - 00262 -CV in the Twelfth Court of Appeals Tyler, Texas Charles and Mary Lou Alford, Appellants , v.
Robert Thomas McKeithen; EOG Resources, Inc.; and Central Texas Land Services, Appellees.
EOG’s Second Motion for Extension
Appellee EOG Resources, Inc. respectfully asks the Court to extend the
due date of its appellee’s brief by 15 days, to July 10, 2015. [1]
I. RULE 10.5 INFORMATION 1. Deadline for filing appellee’s brief:
June 25, 2015.
2. Length of extension sought:
Fifteen days, so that the new deadline would be July 10, 2015. *2 3. Facts relied on to reasonably explain the need for extension:
Five considerations warrant an extension.
First, EOG’s counsel has a trial scheduled for the week of June 9 in York
v. Oleum Operating Co. , No. 2011-1933-CCL2 in the County Court at Law No.
2 of Gregg County, Texas.
Second, EOG’s counsel has a motion to compel hearing and a summary-
judgment hearing on June 12 in Goodwin v. XTO Energy Inc. , No. CV-13-9496
in the District Court of San Augustine County, Texas.
Third, EOG’s counsel has a designation of experts deadline on June 15 in
CEC Operations of Texas, LLC v. United Petroleum & Gas, Inc. , No. 10-C-007
in the District Court of Cass County, Texas. EOG’s counsel has a deposition
in that case on June 17.
Fourth, EOG’s counsel has a hearing on a motion for reconsideration on
June 17 in Lorance v. Red Water Resources, Inc. , No. 5:14-cv-00053-RWS-CMC
in the United States District Court for the Eastern District of Texas Texar-
kana Division.
Fifth, EOG’s counsel has a pretrial order due June 15 in Freeman v. Har-
leton Oil & Gas, Inc. , No. 2013-1411-CCL2 in the County Court at Law No. 2
of Gregg County, Texas. EOG’s counsel has a pretrial conference in that case
on June 18, and trial starts on June 22.
4. Number of previous extensions:
One. *3 II. CERTIFICATE OF CONFERENCE EOG has conferred with the Alfords’ counsel and with McKeithen’s
counsel, and neither opposes this motion.
III. CONCLUSION This is EOG’s second request for an extension. The extension is not
sought merely for delay. The five above considerations warrant the extension.
Accordingly, EOG respectfully asks the Court to grant the 15-day extension,
so that EOG’s brief will be due on July 10, 2015, in accordance with Tex. R.
App. P. 10.5(b)(1) & 38.6(d).
Respectfully submitted, Freeman Mills PC 110 N. College, Ste. 1400 Tyler, Texas 75702 903.592.7755 phone 903.592.7787 fax www.freemanmillspc.com By: Jason R. Mills Bar No. 24041494 eservicejrm@freemanmillspc.com Graham K. Simms Bar No. 24060610 gimms@freemanmillspc.com Joshua C. Ashley Bar No. 24078161 jashley@freemanmillspc.com *4 CERTIFICATE OF SERVICE I certify that a true and correct copy of this document was served on all
counsel of record on June 9, 2015 in accordance with the Texas Rules of Ap-
pellate Procedure.
Jason R. Mills
[1] References to EOG include Central Texas Land Services, which is also an appellee.