ACCEPTED
01-18-00113-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
3/22/2018 5:45 PM
CHRISTOPHER PRINE
CLERK
NO. 01-18-00113-CV
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
FOR THE FIRST JUDICIAL DISTRICT OF TEXAS3/22/2018 5:45:48 PM
AT HOUSTON, TEXAS CHRISTOPHER A. PRINE
Clerk
STAMPEDE TX ENERGY, LLC, F/K/A STAMPEDE ENERGY, LLC,
AND BALLENGEE INTERESTS, LLC
Appellant,
V.
BRIDGETEX PIPELINE COMPANY, LLC,
Appellee,
ON APPEAL FROM THE 157TH DISTRICT COURT,
HARRIS COUNTY, TEXAS
Trial Court No. 2016-57036
AGREED MOTION TO
EXTEND TIME TO SELECT MEDIATOR
Bridgetex Pipeline Company, LLC, Stampede Tx Energy, LLC, and Ballengee Interests,
LLC (collectively, the “Parties”) file this Agreed Motion to Extend Time to Select Mediator.
The original deadline to select a mediator is March 22, 2018. The Parties ask for a one-week
extension, to March 29, 2018, to select a mediator for this matter.
The underlying Judgment in the case is almost $300 million dollars and great care has
been taken to select a qualified mediator that is acceptable to all parties. However, with multiple
parties and multiple representatives needed for each party, the logistics have been tougher than
originally expected. The Parties have agreed on using one of two mediators and working to
AGREED MOTION TO EXTEND TIME TO SELECT MEDIATOR PAGE 1
ensure the schedules of everyone involved will allow it.
Therefore, the Parties respectfully request that their Agreed Motion to Extend Time to
Select Mediator is granted, and that the deadline be moved from March 22, 2018 to March 29,
2018.
Respectfully submitted,
Calhoun, Bhella & Sechrest, LLP
By: /s/ Robert McNiel
Robert McNiel
State Bar No. 24043814
rmcniel@cbsattorneys.com
Paul Green
State Bar No. 24081405
pgreen@cbsattorneys.com
325 N. Saint Paul Street, Suite 2300
Dallas, Texas 75201
Telephone: 214.981.9200
Facsimile: 214.981.9203
ATTORNEYS FOR DEFENDANTS
AGREED MOTION TO EXTEND TIME TO SELECT MEDIATOR PAGE 2
CERTIFICATE OF CONFERENCE
The undersigned counsel for Defendants hereby certifies that he and counsel for Plaintiffs have
personally conferred to discuss the items presented to the Court in this motion. Counsel for Plaintiffs is
AGREED to the Motion.
/s/ Paul Green
Paul Green
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument has been served
on all counsel of record via the electronic service manager and/or by email on this 22nd day of
March, 2018.
/s/ Robert A. McNiel
Robert A. McNiel
AGREED:
/s/ Robert A. McNiel
Robert A. McNiel
Attorney for Appellant
/s/ David Bryant
David Bryant
Attorney for Appellee
AGREED MOTION TO EXTEND TIME TO SELECT MEDIATOR PAGE 3