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 9/24/2015 2:51:48 PM KEITH HOTTLE CLERK No. 04-15-00318-CV _________________________________________________________________ FILED IN 4th COURT OF APPEALS I C N THE OURT OF PPEALS A SAN ANTONIO, TEXAS FOR THE OURTH ISTRICT OF EXAS 09/24/2015 2:51:48 PM F D T KEITH E. HOTTLE _________________________________________________________________ Clerk GEMINI INSURANCE COMPANY AND BERKLEY OIL AND GAS SPECIALTY SERVICES, LLC, APPELLANTS V. DRILLING RISK MANAGEMENT, INC., APPELLEE ____________________________________________________________________ On Appeal from the 216th Judicial District Court Kendall County, Texas Trial Court Cause No. 12-066 Honorable Bill Palmer, Judge Presiding ____________________________________________________________________ UNOPPOSED MOTION FOR SECOND EXTENSION OF TIME TO FILE APPELLANTS’ BRIEF ____________________________________________________________________ TO THE HONORABLE FOURTH COURT OF APPEALS: Appellants, Gemini Insurance Company and Berkley Oil and Gas Specialty Services, LLC, respectfully requests an extension of the deadline to file their brief as appellants under Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), and would respectfully show this Court as follows: 1. This is Appellants’ second motion for extension of time to file their brief. 2. The filing deadline for Appellants’ brief is presently September 25, 2015. 3. Appellants request a 30-day extension of the deadline to file their opening brief, which would make the brief due Monday, October 26, 2015 (because the 30th day falls on a Sunday). 4. Appellants’ counsel needs additional time to file the opening brief in this matter because they have been working to comply with concurrent deadlines and briefing requirements in other matters, including the following:  Cause No. 15-10655; White v. Regional Adjustment Bureau; in the Fifth Circuit Court of Appeals (Brief filed August 25, 2015).  Cause No. 14-14-00892-CV; The Branch Law Firm L.L.P., et al. v. W. Shane Osborn; in the Fourteenth Court of Appeals (Preparation and presentation of oral argument on September 1, 2015).  Cause No. 14-14-00470-CV; Robert S. Bennett v. Commission for Lawyer Discipline; in the Fourteenth Court of Appeals (Preparation and presentation of oral argument on September 16, 2015).  Cause No. CV-02121-13-02; Ochoa v. LSDI, LP, d/b/a Lonestar Distribution, Inc.; in the 159th District Court of Angelina County, Texas. (Preparation, attendance, and participation at extensive all-day pretrial hearings on September 22, 2015).  Cause No. 09-14-00325-CV; Fort Apache Energy, Inc. v. Resaca, et al., in the Ninth Court of Appeals (Preparation and presentation of oral argument on September 24, 2015).  Cause No. 15-20184; Wellogix, Inc. v. SAP America, Inc., et al., (consolidated with 15-20187); in the Fifth Circuit Court of Appeals (Reply Brief due October 5, 2015). 5. As indicated in the attached certificate of conference, counsel for Appellee, Drilling Risk Management, Inc., does not oppose the relief sought in this motion. 2 WHEREFORE, Appellants Gemini Insurance Company and Berkley Oil and Gas Specialty Services, LLC respectfully request that the Court grant this motion and extend the deadline for their opening brief to Monday, October 26, 2015. CONCLUSION Appellants Gemini Insurance Company and Berkley Oil and Gas Specialty Services, LLC respectfully request that the Court grant this motion and extend the deadline for them to file their opening brief to Monday, October 26, 2015. Respectfully submitted, /s/ R. Russell Hollenbeck R. Russell Hollenbeck State Bar No. 00790901 Thomas C. Wright State Bar No. 22059400 WRIGHT & CLOSE, LLP One Riverway, Suite 2200 Houston, Texas 77056 (713) 572-4321 (713) 572-4320 (fax) hollenbeck@wrightclose.com wright@wrightclose.com George H. Lugrin, IV State Bar No. 00787930 Reece Rondon State Bar No. 00794559 Amanda J. Kujda State Bar No. 24053565 HALL MAINES LUGRIN, PC. Williams Tower, 64th Floor 2800 Post Oak Blvd. Houston, Texas 77056 3 (713) 871-9000 (713) 871-8962 (fax) glugrin@hallmaineslugrin.com rrondon@hallmaineslugrin.com akujda@hallmaineslugrin.com Attorneys for Appellants, Gemini Insurance Co. and Berkley Oil & Gas Specialty Services, LLC CERTIFICATE OF CONFERENCE As required by Texas Rule of Appellate Procedure 10.1(a)(5), I personally conferred via email with Catherine M. Stone, counsel for Appellee, Drilling Risk Management, Inc., and she indicated her client is not opposed to this motion. /s/ R. Russell Hollenbeck R. Russell Hollenbeck 4 CERTIFICATE OF SERVICE I certify that a true and correct copy of this motion was served on all counsel of record electronically on September 24, 2015. Catherine M. Stone LANGLEY & BANACK, INC. 745 E. Mulberry Avenue, Suite 900 San Antonio, Texas 78212 cstone@langleybanack.com Steve Skarnulis Charles J. Cain CAIN & SKARNULIS, LLP 400 W. 15th Street, Suite 900 Austin, Texas 78701 skarnulis@cstrial.com ccain@cstrial.com /s/ R. Russell Hollenbeck R. Russell Hollenbeck 5