ACCEPTED
06-16-00029-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
6/30/2016 9:26:17 AM
DEBBIE AUTREY
CLERK
No. 06-16-00029-CV
IN THE
FILED IN
COURT OF APPEALS FOR THE 6th COURT OF APPEALS
SIXTH SUPREME JUDICIAL DISTRICT OF TEXASTEXARKANA, TEXAS
AT TEXARKANA, TEXAS 6/30/2016 9:26:17 AM
DEBBIE AUTREY
Clerk
GREAT NORTHERN ENERGY, INC.
Appellant,
vs.
CIRCLE RIDGE PRODUCTION, INC.
Appellee.
Appeal from the 71st District Court
of Harrison County, Texas
Honorable Brad Morin
AGREED SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLEE’S BRIEF
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TO THE HONORABLE COURT OF APPEALS:
COMES NOW, Circle Ridge Production, Inc., Appellee in the above-captioned
proceeding (the “Appellee”), and respectfully asks the Court to extend the time to file its
Appellee’s Brief.
A. INTRODUCTION
1. Appellant is Great Northern Energy, Inc.; Appellee is Circle Ridge Production,
Inc.
2. Great Northern Energy, Inc., the Appellant, consents and agrees to the requested
extension.
B. ARGUMENT & AUTHORITIES
3. Appellee’s Brief is due on July 1, 2016.
4. Appellee respectfully requests an additional Twenty (20) days to file Appellee’s
Brief, extending the time until July 21, 2016.
5. This is Appellee’s second request for an extension of briefing deadline in this
case.
6. Appellee respectfully presents the following facts to the Court as a reasonable
explanation for the additional requested extension of time: Due to the complex nature of
settlement negotiations in this matter, the parties to this interlocutory appeal have agreed that
another twenty (20) day extension of time would be in the interest of the parties. The settlement
requires the participation of parties not before the court, as well as complex title issues associated
with the property. These issues necessitate additional time to conclude a settlement.
7. The requested enlargement of time, which is unopposed, is not sought for the sake
of delay, but rather so that settlement resolutions may be further explored.
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Therefore, Appellee prays that this Court grant this Motion for extension of time to
extend the due date for appellee’s brief for twenty (20) days until July 21, 2016.
Respectfully submitted,
Michael T. Runyan
State Bar No. 24033143
RUNYAN LAW FIRM, P.C.
305 West Rusk St.
Marshall, TX 75670
Office: (903) 935-7700
Fax: (903) 935-7702
michael@runyanlaw.com
RONAN S. SEARLE
Texas Bar No. 24079292
SEARLE & SEARLE, PC
P.O. Box 910
305 West Rusk Street
Marshall, Texas 75671
Phone (903) 935-9772
Fax (903) 935-9790
Ronan.searle@gmail.com
ATTORNEYS FOR THE APPELLEE
CIRCLE RIDGE PRODUCTION, INC.
By: /s/ Michael T. Runyan (w/p Ronan S. Searle)
Michael T. Runyan
Texas Bar No. 24033143
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CERTIFICATE OF CONFERENCE
I hereby certify that, on June 30, 2016, Michael T. Runyan conferred with William J.
Gardner, counsel for Appellant, who indicated that Appellant is unopposed and agrees to the
extension requested herein.
/s/ Michael T. Runyan (w/p Ronan S. Searle)
Michael T. Runyan
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that, on June 30, 2016, I caused to be served the
foregoing pleading upon the counsel listed below via email and also via the Court’s electronic
transmission facilities.
William J. Gardner
Attorney at Law
422 B N. Green Street
P.O. Box 1746
Longview, TX 75606-1746
Tel. No. 903-236-7900
Fax No. 903-236-3367
Email: wjg@wjg-law.com
/s/ Ronan S. Searle
Ronan S. Searle
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