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.

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 Texarkana Division.

   Fifth, EOG‘s counsel has a pretrial order due June 15 in Freeman v. Harleton 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.

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

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 Appellate Procedure.