Gemini Insurance Company and Berkley Oil & Gas Specialty Services, LLC v. Drilling Risk Management, Inc.

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ACCEPTED 04-15-00318-CV FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 8/21/2015 2:08:18 PM KEITH HOTTLE CLERK No. 04-15-00318-CV _________________________________________________________________ FILED IN 4th COURT OF APPEALS I C N THE OURT OF PPEALS A SAN ANTONIO, TEXAS FOR THE OURTH ISTRICT OF EXAS 8/21/2015 2:08:18 PM F D T KEITH E. HOTTLE _________________________________________________________________ Clerk GEMINI INSURANCE COMPANY AND BERKLEY OIL AND GAS SPECIALTY SERVICES, LLC, APPELLANTS V. DRILLING RISK MANAGEMENT, INC., APPELLEE ____________________________________________________________________ On Appeal from the 216th Judicial District Court Kendall County, Texas Trial Court Cause No. 12-066 Honorable Bill Palmer, Judge Presiding ____________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANTS’ BRIEF ____________________________________________________________________ TO THE HONORABLE FOURTH COURT OF APPEALS: Appellants, Gemini Insurance Company and Berkley Oil and Gas Specialty Services, LLC, respectfully requests a 30-day extension of the deadline to file their brief as appellants under Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), and would respectfully show this Court as follows: 1. The filing deadline for appellants’ brief is presently August 26, 2015. 2. Appellants request a 30-day extension of the deadline to file their opening brief, which would make the brief due Friday, September 25, 2015. 3. This is Appellants’ first request for an extension of time to file their opening brief. 4. Appellants’ counsel needs additional time to file their opening brief in this matter because they have been working to comply with concurrent deadlines and briefing requirements in other matters, including:  Richard Cuevas, et al. v. Critical Path Resources, Inc., et al.; Cause No. 2012-21574; in the 129th Judicial District Court, Harris County, Texas. Trial preparation and representation of sole defendant against wrongful death and severe burn injury claims arising from oil refinery explosion. Pretrial hearings began July 9, 2015 and a jury verdict was returned on August 6, 2015.  Robert W. Pate, et al. v. The Bishop’s Lodge, et al.; Cause No. 1:13- cv-00618-TH; in the United States District Court for the Eastern District of Texas, Beaumont Division. Preparation and filing of briefing and exhibits in support of motion to dismiss defendant for lack of personal jurisdiction, filed August 11, 2015.  Noble Energy, Inc. v. ConocoPhillips Co., Cause No. 15-0502; in the Supreme Court of Texas. Preparation of Petition for Review, filed August 19, 2015. 5. As indicated in the attached certificate of conference, counsel for Appellee, Drilling Risk Management, Inc., does not oppose the relief sought in this motion. WHEREFORE, Appellants Gemini Insurance Company and Berkley Oil and Gas Specialty Services, LLC respectfully request that the Court grant this motion and extend the deadline for their opening brief to Friday, September 25, 2015. 2 CONCLUSION Appellants Gemini Insurance Company and Berkley Oil and Gas Specialty Services, LLC respectfully request that the Court grant this motion and extend the deadline for them to file their opening brief to September 25, 2015. Respectfully submitted, /s/ R. Russell Hollenbeck R. Russell Hollenbeck State Bar No. 00790901 Thomas C. Wright State Bar No. 22059400 Natasha N. Taylor State Bar No. 24071117 Andrea G. Tindall State Bar No. 24079467 WRIGHT & CLOSE, LLP One Riverway, Suite 2200 Houston, Texas 77056 (713) 572-4321 (713) 572-4320 (fax) hollenbeck@wrightclose.com wright@wrightclose.com taylor@wrightclose.com tindall@wrightclose.com George H. Lugrin, IV State Bar No. 00787930 Reece Rondon State Bar No. 00794559 Amanda J. Kujda State Bar No. 24053565 HALL MAINES LUGRIN, PC. Williams Tower, 64th Floor 2800 Post Oak Blvd. Houston, Texas 77056 3 (713) 871-9000 (713) 871-8962 (fax) glugrin@hallmaineslugrin.com rrondon@hallmaineslugrin.com akujda@hallmaineslugrin.com Attorneys for Appellants, Gemini Insurance Co. and Berkley Oil & Gas Specialty Services, LLC CERTIFICATE OF CONFERENCE As required by Texas Rule of Appellate Procedure 10.1(a)(5), I personally conferred via email with Catherine M. Stone, counsel for Appellee, Drilling Risk Management, Inc., and she indicated her client is not opposed to this motion. /s/ R. Russell Hollenbeck R. Russell Hollenbeck 4 CERTIFICATE OF SERVICE I certify that a true and correct copy of this motion was served on all counsel of record electronically on August 21, 2015. Catherine M. Stone LANGLEY & BANACK, INC. 745 E. Mulberry Avenue, Suite 900 San Antonio, Texas 78212 cstone@langleybanack.com Steve Skarnulis Charles J. Cain CAIN & SKARNULIS, LLP 400 W. 15th Street, Suite 900 Austin, Texas 78701 skarnulis@cstrial.com ccain@cstrial.com /s/ R. Russell Hollenbeck R. Russell Hollenbeck 5