ACCEPTED
12-15-00083-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
4/21/2015 4:21:23 PM
CATHY LUSK
CLERK
No. 12-15-00083-CV
FILED IN
12th COURT OF APPEALS
In the Twelfth District Court of Appeals TYLER, TEXAS
Tyler, Texas 4/21/2015 4:21:23 PM
CATHY S. LUSK
Clerk
Carrizo Oil & Gas, Inc.,
Appellant,
v.
Barrow-Shaver Resources Company,
Appellee.
On Appeal from the 7th Judicial District Court
Smith County, Texas
Cause No. 12-2565-A
AGREED MOTION TO EXTEND DEADLINE FOR SELECTING MEDIATOR
TO THE HONORABLE COURT OF APPEALS:
On April 14, 2015, the Court issued an Order Referring Case to Mediation
that required the parties, among other things, to notify the Court in writing of any
agreed mediator within seven days of the Order.
Counsel for both parties have been researching and discussing possible
mediators and logistical issues relating to mediation since that time and believe they
can reach an agreement as to a mediator and place for mediation for this matter, but
need more time to do so. The parties anticipate that they will be able to inform the
Court of an agreement by the end of the week, but want to insure sufficient time to
work out the details. The parties therefore jointly and respectfully request that the
Court grant them an extension of time of seven days to comply with the Court’s
Order as to the written notification of an agreed mediator.
CONCLUSION AND PRAYER
For these reasons, Appellant Carrizo Oil & Gas, Inc. and Appellee Barrow-
Shaver Resources Company request that the Court: (i) grant this Agreed Motion to
Extend Deadline for Selecting Mediator; (ii) order that the deadline for complying
with the Court’s April 14, 2015, Order requiring the parties to notify it in writing as
to an agreed mediator is extended to April 28, 2015; and (iii) grant such other and
further relief to which the parties are entitled.
Respectfully submitted,
/s/ Marcy Hogan Greer
Marcy Hogan Greer
State Bar No. 08417650
mgreer@adjtlaw.com
ALEXANDER DUBOSE JEFFERSON &
TOWNSEND LLP
515 Congress Avenue, Suite 2350
Austin, Texas 78701
Telephone: (512) 482-9300
Facsimile: (512) 482-9303
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John M. Zukowski
State Bar No. 22293400
jmz@zbsplaw.com
Pascal Paul Piazza
State Bar No. 15966850
ppp@zbsplaw.com
ZUKOWSKI, BRESENHAN, SINEX &
PETRY, L.L.P.
1177 West Loop South, Suite 1100
Houston, Texas 77027
Telephone: (713) 965-7597
Facsimile: (713) 963-9169
Charles H. Clark
State Bar No. 04274000
chc@charlesclarklaw.com
THE LAW OFFICES OF CHARLES H. CLARK
604 West Woldert Street
Tyler, Texas 75702
Telephone: (903) 593-2514
Facsimile: (903) 595-1294
ATTORNEYS FOR CARRIZO OIL &
GAS, INC.
CERTIFICATE OF CONFERENCE
I hereby certify that on April 21, 2015, I conferred with Deborah Race,
counsel for Appellee, Barrow-Shaver Resources Company, and she stated that her
client joins in requesting the relief sought by this motion.
/s/ Marcy Hogan Greer
Marcy Hogan Greer
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CERTIFICATE OF SERVICE
The undersigned certifies that, on April 21, 2015, this Agreed Motion to
Extend Deadline for Selecting Mediator was electronically filed with the Clerk of
Court using the eFile.TXCourts.gov electronic filing system which will send
notification to the following:
Otis Carroll
ocarrroll@icklaw.com
Collin M. Maloney
cmaloney@icklaw.com
Deborah Race
drace@icklaw.com
IRELAND, CARROLL & KELLEY, P.C.
6101 S. Broadway, Ste. 500
Tyler, Texas 75703
R. Clay Hoblit
choblit@hfdlaw.com
HOBLIT FERGUSON DARLING L.L.P.
2000 Frost Bank Plaza
802 North Carancahua
Corpus Christi, Texas 78401
Counsel for Plaintiff Barrow-Shaver
Resources Company
/s/ Marcy Hogan Greer
Marcy Hogan Greer
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