ACCEPTED
01-15-00680-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/8/2015 12:09:29 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00680-CV
________________________________________________________________________
FILED IN
IN THE FIRST COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
HOUSTON, TEXAS 10/8/2015 12:09:29 PM
CHRISTOPHER A. PRINE
Clerk
ESP RESOURCES, INC. F/K/A
PANTERA PETROLEUM, INC.,
Appellant
vs.
BWC MANAGEMENT, INC.,
Appellee
________________________________________________________________________
From the 113th District Court
Harris County, Texas
Cause No. 2013-25068
Hon. Michael Landrum presiding
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES Appellant, ESP Resources, Inc. f/k/a Panter Petroleum, Inc.
(hereinafter “Appellant”), and brings this, Appellant’s Motion for Extension of Time to File
Brief, and in support thereof, shows the Court the following:
1. Appellant’s current deadline for filing its brief is October 12, 2015. Appellant
requests a thirty (30) day extension of time to file its brief.
2. Appellant has not previously asked this Court to grant an extension of time with
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 1 OF 3
regard to this issue.
3. This extension of time is not sought for delay but in the interest of fairness and
justice.
4. Accordingly, Appellant respectfully requests this Court to extend the deadline for the
filing of its, Appellant’s Brief, until November 11, 2015.
WHEREFORE, PREMISES CONSIDERED, Appellant prays that this Court grant
its request for a thirty (30) day extension of time to file its, Appellant’s Brief, and for such
other and further relief to which Appellant may be entitled.
Respectfully Submitted,
FETTNER THOMPSON
By: /s/ David A. Fettner
Texas Bar No.: 00784048
6700 Sands Point Drive
Houston, Texas 77074
Tel. (713) 626-7277
Fax. (888) 876-2292
Email: daf@fettnerthomspon.com
Service Email: services@fettnerthompson.com
Attorney for Appellant
APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 2 OF 3
CERTIFICATE OF CONFERENCE
On October 7, 2015, Appellee’s counsel was contacted via email about the merits of
Appellant’s Motion for Extension of Time to File Brief and Appellee’s counsel responded that
Appellee is opposed to this request.
/s/ David A. Fettner
David A. Fettner
CERTIFICATE OF SERVICE
I hereby certify that on October 8, 2015, a true and correct copy of the above and
foregoing has been forwarded to all pro se parties and/or attorneys of record in accordance
with the Texas Rules of Appellate Procedure:
Timothy L. Henderson Via E-Service
State Bar No. 09432500 and/or Via Facsimile: (713) 668-5697
timjhenderson@msn.com and/or Via First Class Mail
6300 West Loop South, Suite 280
Bellaire, Texas 77401
713.667.7878 (Tel.)
713.668.5697 (Fax)
Attorney for Appellee
/s/ David A. Fettner
David A. Fettner
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APPELLANT’S MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 3 OF 3