BP Oil Pipeline Company v. Plains Pipeline, L.P.

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ACCEPTED 14-13-00352-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/15/2015 5:48:46 PM CHRISTOPHER PRINE CLERK NO. 14-13-00352-CV FILED IN 14th COURT OF APPEALS IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS FOURTEENTH DISTRICT OF TEXAS 7/15/2015 5:48:46 PM CHRISTOPHER A. PRINE Clerk BP OIL PIPELINE COMPANY, Appellant, v. PLAINS PIPELINE, L.P., Appellee. ON APPEAL FROM THE 80TH JUDICIAL DISTRICT COURT HARRIS COUNTY, TEXAS APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR REHEARING To the Honorable Court of Appeals: Plaintiff and Appellant BP Oil Pipeline Company (“BP”) files this motion for extension of time to file its motion for rehearing, pursuant to Texas Rules of Appellate Procedure 49.8 and 10.5(b). BP requests this extension of time because its appellate counsel needs additional time to prepare its motion for rehearing. Specifically, BP needs additional time to review the substantial majority and dissenting opinions issued by the Court on June 30, 2015 and the numerous authorities cited therein that have not previously been reviewed by the parties or briefed in the original appellate briefing. In addition, BP’s counsel are currently involved in other litigation matters that have required and will continue to require their attention over the next several weeks. This is BP’s first request for an extension of time to file its motion for rehearing. Any motions for rehearing are currently due to be filed with this Court on July 15, 2015. BP timely requests a thirty-one (31) day extension of this deadline under Texas Rule of Appellate Procedure 49.8, making its motion for rehearing due on August 17, 2015. WHEREFORE, Appellant BP Oil Pipeline Company requests a thirty-one (31) day -2- extension of time to file its motion for rehearing, making the motion for rehearing due August 17, 2015. Respectfully submitted, LISKOW & LEWIS By: /s/ Alma F. Gomez Jana L. Grauberger Texas State Bar No. 24047502 Michael P. Cash Texas State Bar No. 03965500 Alma F. Gomez Texas State Bar No. 24069800 James T. Kittrell Texas State Bar No. 24078795 1001 Fannin Street, Suite 1800 Houston, Texas 77002 Telephone: (713) 651-2900 Facsimile: (713) 651-2908 Email: jlgrauberger@liskow.com Email: mcash@liskow.com Email: afgomez@liskow.com Email: jkittrell@liskow.com Joe B. Norman Louisiana State Bar No. 8160 One Shell Square 701 Poydras Street, Suite 5000 New Orleans, Louisiana 70139 Telephone: (504) 556-4052 Facsimile: (504) 556-4108 Email: jbnorman@liskow.com ATTORNEYS FOR APPELLANT BP OIL PIPELINE COMPANY -3- CERTIFICATE OF CONFERENCE Under Texas Rules of Appellate Procedure 10.1(a)(5), I certify that on July 15, 2015, I conferred with Jane Robinson, counsel for Appellee Plains Pipeline, L.P., and she does not oppose the extension of time requested. /s/ Alma F. Gomez Alma F. Gomez CERTIFICATE OF SERVICE I hereby certify that a copy of Appellant’s Motion for Extension of Time to File Motion for Rehearing is being served on all attorneys of record for Appellee on this 15th day of July, 2015, by the method indicated below. /s/ Alma F. Gomez Alma F. Gomez John Zavitsanos Certified Mail – RRR Elizabeth Fletcher Jane Robinson No.: Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing, P.C. Private Delivery 1221 McKinney St., Suite 3460 Houston, Texas 77010 E-Mail Telephone: (713) 655-1101 Facsimile: (713) 655-0062 Personal Delivery Thomas C. Wright Certified Mail – RRR Natasha N. Taylor Wright & Close, LLP No.: One Riverway, Suite 200 Houston, Texas 77056 Private Delivery Telephone: (713) 572-4321 Facsimile: (713) 572-4320 E-Mail Attorneys for Appellee, Plains Pipeline, L.P. Personal Delivery -4- CERTIFICATE OF COMPLIANCE I hereby certify that Appellant’s Motion for Extension of Time to File Motion for Rehearing was produced on a computer using Microsoft Word and contains 216 words, as determined by the word-count feature of the word processing software, excluding the sections of the documented listed in Tex. R. App. 9.4(i)(1). /s/ Alma F. Gomez Alma F. Gomez -5-