Alta Mesa Holdings, L.P., Alta Mesa Acquisition Sub, LLC, the Meridian Resource & Exploration LLC Change in Control Severance Plan, and the Meridian Resource & Exploration, LLC v. Steven Ives and Lloyd Delano
ACCEPTED
14-14-00739-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
8/17/2015 2:56:00 PM
CHRISTOPHER PRINE
CLERK
NO. 14-14-00739-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
8/17/2015 2:56:00 PM
FOR THE FOURTEENTH DISTRICT OF TEXAS
CHRISTOPHER A. PRINE
Clerk
AT HOUSTON
ALTA MESA HOLDINGS, L.P., ALTA MESA ACQUISITION SUB, LLC,
THE MERIDIAN RESOURCE & EXPLORATION LLC
CHANGE IN CONTROL SEVERANCE PLAN,
AND THE MERIDIAN RESOURCE & EXPLORATION, LLC,
Appellants,
v.
STEVEN IVES AND LLOYD DELANO,
Appellees.
UNOPPOSED MOTION TO RESCHEDULE ORAL ARGUMENT
TO THE HONORABLE COURT OF APPEALS:
Appellants, Alta Mesa Holdings, L.P., Alta Mesa Acquisition Sub, LLC,
The Meridian Resource & Exploration LLC Change In Control Severance Plan,
and The Meridian Resource & Exploration, LLC, (collectively, “Alta Mesa”) file
this Unopposed Motion to Reschedule Oral Argument currently set for Thursday,
September 24, 2015 at 2:00 p.m.
I.
On Monday, August 3, counsel for Alta Mesa received notice that this case
was set for oral argument on September 24, 2015 at 2:00 p.m. Counsel respectfully
requests that oral argument be rescheduled. Counsel does not make this request
lightly and understands the hardship it causes the Court to change its docket.
However, lead appellate counsel Polly Fohn, who will be presenting oral argument,
just gave birth to her first son on Sunday, July 26, and is expected to be on
maternity leave through November 16, 2015.
PRAYER
For these reasons, Appellants, Alta Mesa Holdings, L.P., Alta Mesa
Acquisition Sub, LLC, The Meridian Resource & Exploration LLC Change In
Control Severance Plan, and The Meridian Resource & Exploration, LLC,
respectfully urge the Court to reset oral argument for a date after November 16,
2015.
-2-
Respectfully submitted,
/s/ Matthew T. Deffebach
Matthew T. Deffebach
State Bar No. 24012516
Benjamin L. Mesches
State Bar No. 24032737
Liz E. Klingensmith
State Bar No. 24046496
Polly Fohn
State Bar No. 24065318
HAYNES AND BOONE, LLP
1221 McKinney, Suite 2100
Houston, Texas 77010
Telephone: (713) 547-2000
Telecopier: (713) 547-2600
Matthew.Deffebach@haynesboone.com
Ben.Mesches@haynesboone.com
Liz.Klingensmith@haynesboone.com
Polly.Fohn@haynesboone.com
ATTORNEYS FOR APPELLANTS,
ALTA MESA HOLDINGS, L.P., ET
AL.
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CERTIFICATE OF CONFERENCE
In accordance with Rule 10.1(a)(5) of the Texas Rules of Appellate
Procedure, I certify that I conferred with Mr. Mark J. Levine, counsel for
Appellees, concerning this request to reschedule oral argument. Mr. Levine does
not oppose the relief requested.
/s/ Matthew Deffebach
Matthew Deffebach
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CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the Unopposed Motion to
Reschedule Oral Argument has been served on the following counsel in accordance
with the Texas Rules of Appellate Procedure via e-service on this 17th day of
August, 2015:
Counsel for Appellees,
Steven Ives and Lloyd Delano:
Mark J. Levine
WEYCER, KAPLAN, PULASKI
& ZUBER, PC
11 Greenway Plaza, Suite 1400
Houston, Texas 77046
/s/ Matthew Deffebach
Matthew Deffebach
15277482.2 -5-