Hydrogeo, LLC, First Bank & Trust East Texas v. Quitman Independent School District

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ACCEPTED 06-15-00007-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/18/2015 1:24:14 PM DEBBIE AUTREY CLERK No. 06-15-00007-CV FILED IN In the Sixth Court of Appeals 6th COURT OF APPEALS Texarkana, Texas TEXARKANA, TEXAS ______________________________________ 6/18/2015 1:24:14 PM DEBBIE AUTREY HYDROGEO, LLC AND FIRST BANK & TRUST EAST TEXAS Appellants Clerk AND DEBERRY 3 OPERATING COMPANY, LLC, Appellant v. QUITMAN INDEPENDENT SCHOOL DISTRICT, WOOD COUNTY, UPPER SABINE WASTE DISPOSAL DISTRICT, AND WOOD COUNTY CENTRAL HOSPITAL DISTRICT, Appellees _______________________________________ On Appeal from the 402nd Judicial District Court Wood County, Texas MOTION TO EXTEND TIME FOR FILING BRIEF OF APPELLANT TO THE HONORABLE COURT OF APPEALS: Hydrogeo, LLC and First Bank & Trust East Texas, Appellants in the above styled and numbered cause, hereby move the Court pursuant to Rule 38.6(d), Texas Rules of Appellate Procedure, for an extension of time to file their brief. As grounds for such extension, the Appellants would show the Court the following: I. This is Appellants’ first request for an extension of time in which to file their brief. Appellees’ brief is due to be filed on June 18, 2015. II. Due to other previously scheduled matters, the undersigned counsel for Appellants, despite best efforts to do so, has been unable to complete research and briefing necessary to finalize the brief in this case by the due date. Those matters have included: 1. Being out of town the entire week between June 8th and June 14th. 2. Reviewing voluminous title documents regarding a complex oil and gas matter for a client in Rusk County, Texas. 3. Extensive Motion practice, including drafting Motion for Entry of Judgment in Cause No. 2013-457; Bagley Minerals, L.P. v. Brammer Petroleum, Inc.; In the 123rd District Court of Panola County, Texas. III. Therefore, Appellants request a fourteen day extension until Thursday, July 2, 2015 in which to file their brief. The requested extension should not in the ordinary course of procedure in this Court delay oral argument and submission and is not requested for delay but that justice be served. WHEREFORE, PREMISES CONSIDERED, Appellants Hydrogeo, LLC and First Bank & Trust East Texas, pray that the time for filing their appellate brief be extended to Thursday, July 2, 2015. Respectfully Submitted, /s/ J. Don Westbrook J. DON WESTBROOK Texas Bar No. 21215500 COGHLAN CROWSON, LLP 1127 Judson Road, Suite 211 Longview, Texas 75601 (903) 758-5543 (903) 753-6989 (fax) dwestbrook@ccfww.com Attorneys for Hydrogeo, LLC and First Bank & Trust East Texas Certificate of Conference I have contacted Edward J. (Nick) Nicholas and Jim Lambeth, Attorneys for Appellees, Wood County, Upper Sabine Waste Disposal District and Wood County Central Hospital District, David Hudson, Attorney for Appellee Quitman ISD, and Michael Dunn, Attorney for Appellant, DeBerry 3 Operating Company, LLC regarding the relief sought by this motion and they have no objection to the motion. /s/ J. Don Westbrook J. Don Westbrook Certificate of Service I hereby certify that a true and correct copy of the foregoing Motion to Extend Time for Filing Brief of Appellants has been forwarded to: Appellant Counsel for DeBerry 3 Operating DeBerry 3 Operating Company, LLC Company, LLC: Michael L. Dunn Smead, Anderson & Dunn 2110 Horseshoe Lane Longview, Texas 75606 Appellee Counsel for Wood County, Upper Wood County, Upper Sabine Sabine Waste Disposal District and Waste Disposal District and Wood Wood County Central Hospital County Central Hospital District District Edward J. (Nick) Nicholas Linebarger Goggan Blair & Sampson, LLP 4828 Loop Central Drive, Suite 600 Houston, Texas 77081 Jim L. Lambeth Alison Wylie Linebarger Goggan Blair & Sampson, LLP 1517 W. Front St. Suite 202 Tyler, Texas 75702 Appellee Counsel for Quitman Independent Quitman Independent School District School District David Hudson Perdue, Brandon, Fielder, Collins & Mott, LLP PO Box 2007 Tyler, Texas 75710 /s/ J. Don Westbrook J. Don Westbrook