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.
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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
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(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
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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
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