Maria De Los Angeles Rodriguez, Individually and as the Administrator of the Estate of Gabriel Vela, Amanda Lopez Vela and and Jose G. Vela v. OGT, LLC, Delaware G&P, LLC, and Enlink Midstream Operating, LP

ACCEPTED
05-23-00874-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
3/4/2024 1:54 PM
RUBEN MORIN
CLERK

No. 05-23-00874-CV

FILED IN
5th COURT OF APPEALS
IN THE COURT OF APPEALS DALLAS, TEXAS
FOR THE FIFTH JUDICIAL DISTRICT 3/4/2024 1:54:19 PM
DALLAS, TEXAS Ruben Morin
Clerk

MARIA DE LOS ANGELES RODRIGUEZ, INDIVIDUALLY AND AS THE
ADMINISTRATOR OF THE ESTATE OF GABRIEL VELA, DECEASED,
AMANDA LOPEZ VELA AND JOSE G. VELA,
Appellants,

v.

OGT, LLC, DELAWARE G&P, LLC, AND ENLINK MIDSTREAM
OPERATING, LP,
Appellees.

APPELLEES’ SECOND UNOPPOSED
MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE COURT OF APPEALS:

Appellees Delaware G&P, LLC and Enlink Midstream Operating, LP

respectfully request a 30-day extension of time to file their Brief under Texas Rules

of Appellate Procedure 10.5(b) and 38.6(d). Appellees’ Brief is currently due March

8, 2024. Appellees request an extension of 30 days from the current deadline,

making the Brief due April 8, 2024.

This is Appellees’ second request for an extension to file their Brief.

Appellees’ counsel needs additional time to prepare and file the Brief because
counsel has been diligently working to comply with multiple concurrent deadlines

and briefing requirements, including (but not limited to) the following:

 Cause No. 04-24-00121-CV; In re Key Energy Services and Abel Guerrero;
in the Fourth Court of Appeals of San Antonio, Texas (Petition for Writ of
Mandamus filed February 20, 2024);

 Cause No. 202158169; Jennifer Locklear v. Juan Gomez and ABC
Professional Tree Services, Inc.; in the 55th District of Harris County, Texas
(Pretrial pleadings filed on February 26, 2024);

 Cause No. C-0340-23-D; Rene Guadalupe Lara, Jr. v. Gerardo Bocanegra,
et al.; in the 206th District of Hidalgo County, Texas (Mediation on February
26, 2024);

 Cause No. 2023-12676; Hannah Rogers, et al. v. Henry Lopez, et al.; in the
164th District of Harris County, Texas (Deposition on February 28, 2024);

 Cause No. DC-19-18649; Li Huang et al. v. NorthPark Partners, L.P., et al.;
in the 134th District of Dallas County, Texas (Response to Motion for
Spoliation filed on February 29, 2024);

 Cause No. CV59238; Mark Ciarkowski v. J&W Services and Equipment
Company, et al.; in the 238th Judicial District of Midland County, Texas
(Deposition on February 29, 2024);

 Cause No. 2021-38749; Alicia Lozano a/n/f of M.A.P., a Minor v. Ches-Lee
Enterprises d/b/a American Fireworks, et al.; in the 295th Judicial District of
Harris County, Texas (Hearing on Defendant’s No-Evidence Motion for
Summary Judgment on March 4, 2024);

 Cause No. 2022CCV-61553-2; Shawn Brown v. H&S Constructors, Inc.; in
the County Court at Law No. 2 of Nueces County, Texas (Deposition on
March 6, 2024);

 Cause No. DC-19-18649; Li Huang et al. v. NorthPark Partners, L.P., et al.;
in the 134th District of Dallas County, Texas (Hearing on Motion for
Spoliation on March 7, 2024);

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  Cause No. 2023-000976-2; Nastasi Bizimana v. Mitchell Alvarez Rivera, et
al.; in the County Court at Law No. 2 of Tarrant County, Texas (Mediation
on March 7, 2024);

 Cause No. 22-DCV-295852; Danielle Cantu et al. v. Miguel Espinosa, et al.;
in the 268th District of Fort Bend County, Texas (Hearing on Motion for
Summary Judgment on March 11, 2024); and

 Cause No. 23-0801; In re Tri-National, Inc.; in the Supreme Court of Texas
(Reply in Support of Petition for Writ of Mandamus due on March 14, 2024).

All other counsel in the case have indicated they are unopposed to this

Motion.

For these reasons, Appellees request that this Court grant an extension of time

to file the Brief, making it due on or before April 8, 2024.

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Respectfully submitted,

/s/ Andrew C. Nelson
Andrew C. Nelson
State Bar No. 24074801
Brittany R. Greger
State Bar No. 24097766
WRIGHT CLOSE & BARGER, LLP
One Riverway, Suite 2200
Houston, Texas 77056
(713) 572-4321 Telephone
(713) 572-4320 Facsimile
nelson@wrightclosebarger.com
greger@wrightclosebarger.com

J.J. Knauff
State Bar No. 24032517
MILLER KNAUFF LAW FIRM
Three Forest Plaza
12221 Merit Drive, Suite 1210
Dallas, Texas 75251
(469) 916-2552 Telephone
(469) 916-2555 Facsimile
jknauff@mklawpc.com

COUNSEL FOR APPELLEES
DELAWARE G&P, LLC AND
ENLINK MIDSTREAM OPERATING,
LP

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 CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), Appellees’

counsel conferred with counsel for Appellants, who indicated that they are not

opposed to the relief sought in this motion.

/s/ Andrew C. Nelson
Andrew C. Nelson

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing was served on the

following counsel of record by e-service on March 4, 2024, in accordance with the

Texas Rules of Appellate Procedure.

/s/ Andrew C. Nelson
Andrew C. Nelson

5
 Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Annie Martin on behalf of Andrew Nelson
Bar No. 24074801
martin@wrightclosebarger.com
Envelope ID: 85162326
Filing Code Description: Motion
Filing Description: Appellees' Second Unopposed Motion for Extension of
Time to File Brief
Status as of 3/4/2024 1:57 PM CST

Associated Case Party: Maria de los Angeles Rodriguez

Name BarNumber Email TimestampSubmitted Status

David S.Coale dcoale@lynnllp.com 3/4/2024 1:54:19 PM SENT

Kay Ridenour kridenour@lynnllp.com 3/4/2024 1:54:19 PM SENT

Beverly Congdon bcongdon@lynnllp.com 3/4/2024 1:54:19 PM SENT

Michael K. Hurst 10316310 mhurst@lynnllp.com 3/4/2024 1:54:19 PM SENT

Aizar J. Karam 796860 akaram@karamlawfirm.com 3/4/2024 1:54:19 PM SENT

Raymond L. Thomas 19865350 rthomas@raythomaspc.com 3/4/2024 1:54:19 PM SENT

Ricardo Pumarejo 24056168 ricardo@pumarejolaw.com 3/4/2024 1:54:19 PM SENT

Gina Flores gflores@lynnllp.com 3/4/2024 1:54:19 PM SENT

Associated Case Party: Amanda Lopez Vela

Name BarNumber Email TimestampSubmitted Status

Alyssa Romero 24084725 alr@gflawoffices.com 3/4/2024 1:54:19 PM SENT

George Farah 24040882 gkf@gflawoffices.com 3/4/2024 1:54:19 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Nancy Karnes nkarnes@gdhm.com 3/4/2024 1:54:19 PM SENT

Jim Hemphill jhemphill@gdhm.com 3/4/2024 1:54:19 PM SENT

Associated Case Party: JoseG.Vela
 Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Annie Martin on behalf of Andrew Nelson
Bar No. 24074801
martin@wrightclosebarger.com
Envelope ID: 85162326
Filing Code Description: Motion
Filing Description: Appellees' Second Unopposed Motion for Extension of
Time to File Brief
Status as of 3/4/2024 1:57 PM CST

Associated Case Party: JoseG.Vela

Name BarNumber Email TimestampSubmitted Status

Oscar Alvarez 24036133 oscar@alvarezatty.com 3/4/2024 1:54:19 PM SENT

Associated Case Party: OGT, LLC

Name BarNumber Email TimestampSubmitted Status

Todd Wright 24010493 twright@graulawgroup.com 3/4/2024 1:54:19 PM SENT

James Grau 8306350 jgrau@graulawgroup.com 3/4/2024 1:54:19 PM SENT

Associated Case Party: Delaware G&P, LLC

Name BarNumber Email TimestampSubmitted Status

Jerry Joe Knauff 24032517 jknauff@mklawpc.com 3/4/2024 1:54:19 PM SENT

Associated Case Party: EnLink Midstream Operating, LP

Name BarNumber Email TimestampSubmitted Status

Andrew C.Nelson nelson@wrightclosebarger.com 3/4/2024 1:54:19 PM SENT

Brittany R.Greger greger@wrightclosebarger.com 3/4/2024 1:54:19 PM SENT