Gemini Insurance Company and Berkley Oil & Gas Specialty Services, LLC v. Drilling Risk Management, Inc.

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ACCEPTED 04-15-00318-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 7/18/2016 2:46:37 PM KEITH HOTTLE CLERK NO. 04-15-00318-CV IN THE COURT OF APPEALS FILED IN 4th COURT OF APPEALS FOR THE FOURTH JUDICIAL DISTRICT OF TEXAS SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS 07/18/2016 2:46:37 PM KEITH E. HOTTLE Clerk GEMINI INSURANCE COMPANY AND BERKLEY OIL AND GAS SPECIALTY SERVICES, LLC, Appellants vs. DRILLING RISK MANAGEMENT, INC., Appellee APPELLEE’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING OR MOTION FOR EN BANC RECONSIDERATION TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: Appellee Drilling Risk Management, Inc. files this Unopposed Motion to Extend Time to File Motion for Rehearing or Motion for En Banc Reconsideration and would show the Court the following: 1. This case is on appeal from Cause Number 12-066 in the 216th Judicial District Court of Kendall County, Texas, the Honorable William Palmer, Judge Presiding. 2. This Court issued its Opinion and Judgment on July 6, 2016. 1 3. The original deadline for filing a motion for rehearing or motion for en banc reconsideration is July 21, 2016. The Court has the authority under Rule 49.8 of the Texas Rules of Appellate Procedure to extend the time for a party to file a motion for rehearing or motion for en banc reconsideration. Appellee requests an additional fifteen (15) days from the date of the initial deadline to file a motion for rehearing or motion for en banc reconsideration until August 5, 2016. 4. The extension is necessary so that Appellee may fully evaluate the Court’s opinion and prepare its motion for rehearing or motion for en banc reconsideration. In addition, this extension is necessary because Appellee’s counsel Steve Skarnulis had to prepare for and attend a mediation hosted by the Fifth Circuit in New Orleans on July 12, 2016, in Cause No. 16-50373, Julie Garza, et al. v. Rebecca Bolin, et al. Mr. Skarnulis will also be on vacation from July 26-29, 2016. 5. This is the first extension sought by Appellee to file a motion for rehearing or motion for en banc reconsideration, and it is not sought for the purposes of delay but so that justice may be done. For these reasons, Appellee Drilling Risk Management, Inc. asks the Court to grant an extension of time to file a Motion for Rehearing or Motion for En Banc Reconsideration until August 5, 2016. 2 Signed July 18, 2016. Respectfully submitted: /s/ Steve Skarnulis Charles J. Cain State Bar No. 00796292 ccain@cstrial.com Steve Skarnulis State Bar No. 24041924 skarnulis@cstrial.com Ryan E. Chapple State Bar No. 24036354 rchapple@cstrial.com CAIN & SKARNULIS PLLC 400 W. 15th Street, Suite 900 Austin, Texas 78701 512-477-5000 512-477-5011—Facsimile Catherine M. Stone State Bar No. 1928600 cstone@langleybanack.com LANGLEY & BANACK INCORPORATED Trinity Plaza II 745 Mulberry, Suite 900 San Antonio, Texas 78212-3166 210-736-6600 210-735-6889—Facsimile ATTORNEYS FOR APPELLEE DRILLING RISK MANAGEMENT, INC. 3 CERTIFICATE OF CONFERENCE Counsel for Appellee hereby certifies that his office has conferred with counsel for Appellants and represents that Appellants are not opposed to the relief requested in this motion. /s/ Steve Skarnulis Steve Skarnulis CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing Motion has been forwarded to all counsel of record in accordance with the Texas Rules of Appellate Procedure on this 18th day of July 2016, as follows: Thomas C. Wright George H. Lugrin, IV wright@wrightclose.com glugrin@hallmaineslugrin.com R. Russell Hollenbeck Reece Rondon hollenbeck@wrightclose.com rrondon@hallmaineslugrin.com Andrea G. Tindall Amanda J. Kujda tindall@wrightclose.com akujda@hallmaineslugrin.com WRIGHT & CLOSE, LLP HALL MAINES LUGRIN, P.C. One Riverway, Suite 2200 Williams Tower, 64th Floor Houston, Texas 77056 2800 Post Oak Boulevard 713-572-4320—Facsimile Houston, Texas 77056 713-871-8962—Facsimile /s/ Steve Skarnulis Steve Skarnulis 4