ACCEPTED
12-15-00083-CV
TWELFTH COURT OF APPEALS
TYLER, TEXAS
10/13/2015 1:06:12 PM
Pam Estes
CLERK
No. 12-15-00083
FILED IN
12th COURT OF APPEALS
In the Twelfth District Court of Appeals TYLER, TEXAS
Tyler, Texas 10/13/2015 1:06:12 PM
PAM ESTES
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
APPELLANT’S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
Appellant Carrizo Oil & Gas, Inc. (“Carrizo”) respectfully files this
Unopposed Second Motion for Extension of Time to File Appellant’s Brief. The
current deadline for filing Appellant’s Brief is October 23, 2015. Appellant requests
a 30-day extension of time for a new deadline of November 23, 2015.
The reasons for this request are as follows:
The reporter’s record in this case was filed on August 24, 2015, and it contains
36 volumes of transcripts and exhibits from a two-week jury trial. In reviewing the
Reporter’s Record, the undersigned noted that the questions and answers contained
in the videotaped depositions that were played to the jury at trial were not included
in the Reporter’s Record, although the parties agree that the portions of those
depositions designated by Plaintiff were in fact presented to the jury by video.
In addition, the Clerk’s Record contains 15 volumes of papers, and there are
several items that need to be corrected and supplemented in the Clerk’s Record.
Carrizo is working with opposing counsel to prepare a stipulation to complete
the Reporter’s Record. Carrizo will also be filing a Request to Supplement the
Clerk’s Record. Carrizo respectfully submits that it would be beneficial to the Court
and counsel to have a complete and accurate appellate record to cite in Carrizo’s
opening brief before that brief is filed.
This extension is not sought for the purposes of delay. One prior extension
has been granted for this deadline.
As set forth in the Certificate of Conference below, this motion for extension
of time is Unopposed.
For these reasons, Appellant requests that the Unopposed Second Motion for
Extension of Time be extended 30 days to November 23, 2015.
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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 78701-3562
Telephone: (512) 482-9300
Facsimile: (512) 482-9303
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) 9639169
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 APPELLANT
CARRIZO OIL & GAS, INC.
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CERTIFICATE OF CONFERENCE
I certify that on October 8, 2015, I conferred with Deborah Race, counsel for
Plaintiff-Appellee Barrow-Shaver Oil & Gas Resources Company, and she stated
that her client does not oppose the relief sought in this motion for extension of time.
/s/ Marcy Hogan Greer
Marcy Hogan Greer
CERTIFICATE OF SERVICE
On October 13, 2015, I electronically filed this motion with the Clerk of the
Court using the eFile.TXCourts.gov electronic filing system, which will send
notification of such filing to the following (unless otherwise noted below).
Otis Carroll R. Clay Hoblit
ocarroll@icklaw.com choblit@hfdlaw.com
Deborah Race HOBLIT FERGUSON DARLING L.L.P.
drace@icklaw.com 2000 Frost Bank Plaza
Collin M. Maloney 802 Carancahua
emaloney@icklaw.com Corpus Christi, Texas 78401
IRELAND, CARROLL & KELLEY, P.C. Telephone: (361) 888-9392
6101 S. Broadway, Suite 500 Facsimile: (361) 888-9187
Tyler, Texas 75703
Telephone: (903) 561-1600
Facsimile: (903) 561-1071
Counsel for Appellee
Barrow-Shaver Resources Company
/s/ Marcy Hogan Greer
Marcy Hogan Greer
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