ACCEPTED
14-15-00348-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
10/20/2015 3:09:40 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00348-CV
__________________________________________________________________
FILED IN
IN THE COURT OF APPEALS 14th COURT OF APPEALS
FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS HOUSTON, TEXAS
AT HOUSTON 10/20/2015 3:09:40 PM
__________________________________________________________________
CHRISTOPHER A. PRINE
Clerk
WILLIAM B. HARRISON, INDIVIDUALLY, ET AL.,
Appellants,
v.
HARRISON INTERESTS, LTD. AND
DANIEL J. HARRISON, III, INDIVIDUALLY, ET AL.,
Appellees.
__________________________________________________________________
On Appeal from 190th Judicial District Court,
Harris County, Texas, Cause No. 2010-82117
__________________________________________________________________
APPELLEES’ UNOPPOSED FIRST MOTION
FOR EXTENSION OF TIME TO FILE BRIEF
__________________________________________________________________
Pursuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d),
Appellees Harrison Interests, Ltd. (“HIL”) et al. 1 request an extension of thirty (30)
1
Appellees comprise HIL; Daniel J. Harrison III, individually, as Trustee of the Bruce F.
Harrison Testamentary Trust held under the Last Will and Testament of Daniel J. Harrison, Jr.,
Deceased, as Trustee of the Daniel J. Harrison III Testamentary Trust held under the Last Will
and Testament of Daniel J. Harrison, Jr., Deceased, as Trustee of the Daniel J. Harrison III GST
Non-Exempt Trust held under the Complete Amendment and Restatement of the Declaration of
Mary Alice Smith Revocable Management Trust Agreement, as General Partner and Managing
Partner of HIL, and as Co-Independent Executor of the Estate of Bruce F. Harrison, Deceased;
Edwin H. Knight, Jr., individually, as General Manager of HIL, and as Co-Independent Executor
of the Estate of Bruce F. Harrison, Deceased; Fulshear Oil & Gas Partners, LP; and Fulshear Oil
& Gas LLC.
Active 21042776
days to file their appellees’ brief, through and until December 7, 2015. In support
of an extension, Appellees show as follows:
1. Appellants filed their brief on October 5, 2015. Accordingly,
under Texas Rule of Appellate Procedure 38.6(b), Appellees’ brief is due
November 4, 2015.
2. This is Appellees’ first request for an extension of time to file
their brief. Appellants do not oppose the requested extension.
3. Appellees request an extension not for purposes of delay, but so
that their counsel may have adequate time to prepare their brief. In addition to this
brief, Appellees’ counsel, Macey Reasoner Stokes and Amy Pharr Hefley, have:
(i) a response brief on the merits due November 24 in the Texas Supreme Court in
Cause No. 15-0005, Oncor Electric Delivery Co. LLC v. Public Utility Commission
of Texas; (ii) an appellee’s brief due November 25 in the Fifth Circuit in Case No.
15-30592, Yolande Burst et al. v. Shell Oil Co. et al.; and (iii) a response to petition
for review due November 25 in the Texas Supreme Court in Cause No. 15-0502,
Noble Energy, Inc. v. ConocoPhillips Co.
For these reasons, Appellees respectfully request an extension of
thirty (30) days, through and until December 7, to file their brief.
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Respectfully submitted,
BAKER BOTTS L.L.P.
By: /s/Macey Reasoner Stokes
Macey Reasoner Stokes
State Bar No. 00788253
macey.stokes@bakerbotts.com
Amy Pharr Hefley
State Bar No. 24046046
amy.hefley@bakerbotts.com
One Shell Plaza
910 Louisiana
Houston, Texas 77002
713.229.1234
713.229.1522 (facsimile)
HOGAN LOVELLS US LLP
Maria Wyckoff Boyce
State Bar No. 22095050
maria.boyce@hoganlovells.com
700 Louisiana Street
Suite 4300
Houston, Texas 77002
713.632.1410
713.632.1401 (facsimile)
ATTORNEYS FOR APPELLEES
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CERTIFICATE OF CONFERENCE
I hereby certify that on October 20, 2015, I conferred with David
Berg, counsel for Appellants, regarding this motion. Mr. Berg stated that
Appellants do not oppose the 30-day extension of time requested in this motion.
/s/Macey Reasoner Stokes
Macey Reasoner Stokes
CERTIFICATE OF SERVICE
I certify that on this 20th day of October, 2015, a true and correct
copy of this motion was served electronically on the following counsel of record:
Counsel for Appellants:
David Berg
Berg & Androphy
3704 Travis Street
Houston, Texas 77002
dberg@bafirm.com
/s/Amy Pharr Hefley
Amy Pharr Hefley
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