ACCEPTED
01-15-00266-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/11/2015 2:31:25 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00266-CV
FILED IN
1st COURT OF APPEALS
In The First Court of Appeals HOUSTON, TEXAS
8/11/2015 2:31:25 PM
CHRISTOPHER A. PRINE
Clerk
UNOCAL PIPELINE COMPANY,
Appellant,
v.
BP PIPELINES (ALASKA) INC., ET AL.
Appellees.
On Appeal from the 165th District Court of Harris County, Texas
Hon. Elizabeth Ray, Presiding
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE BRIEF OF APPELLEES
TO THE HONORABLE FIRST COURT OF APPEALS:
Pursuant to TEX. R. APP. P. 38.6(d), Appellees BP Pipelines (Alaska)
Inc.; ConocoPhillips Transportation Alaska, Inc.; and ExxonMobil Pipeline
Co. (“Appellees”) ask this Court to extend by 30 days the time for filing
their Response Brief. The new deadline would be September 18, 2015. This
motion is their first request and it is not opposed.
HOU 1803831
1. Background: The Appellant filed its initial brief on July 20,
2015, after one extension of time. Accordingly, Appellees’ response brief is
presently due on August 19, 2015.
2. Grounds for the extension:
Michael Powell has taken primary responsibility for drafting the
Appellees’ brief. Although Mr. Powell and his team have begun work on
the response brief, Mr. Powell had surgery on July 27 that required time
and additional care during the time allocated for the briefing in this case.
Other pending cases have also required his attention, including:
July 31 Commissioner of the General Land Office v. SandRidge Energy, Inc.,
et al., No. 15-0246 in the Supreme Court of Texas—filed two
Responses to Petitions for Review
ongoing Texas Crude Energy, LLC v. Burlington Resources Oil & Gas Co.,
LP, No. L-13-0061-CV-B, in the 156th District Court—motions
for summary judgment, mediation, depositions, and jury
charge
ongoing Smith v. SEECO, et al., No. 4:14-cv-435-BRW in the United States
District Court for the Eastern District of Arkansas—
depositions, hearings, and preparation for class certification
hearing
3. This motion is unopposed.
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PRAYER
Appellees pray that this Motion be granted and that the time for
filing their Response Brief be extended by 30 days to September 18, 2015.
Respectfully submitted,
LOCKE LORD LLP
By: /s/ Michael Powell (by permission)
Michael V. Powell
State Bar No. 16204400
2200 Ross Ave., Suite 2200
Dallas, TX 75201
Telephone: (214) 740-8000
Facsimile: (214) 756-8520
Christopher Dove
State Bar No. 24032138
LOCKE LORD LLP
600 Travis Street, Suite 2800
Houston, Texas 77002
Telephone: (713) 226-1200
Facsimile: (713) 223-3717
ATTORNEYS FOR APPELLEES
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CERTIFICATE OF CONFERENCE
I have conferred with opposing counsel, and opposing counsel is
unopposed to this motion.
/s/ Michael Powell (by permission)
Michael Powell
CERTIFICATE OF SERVICE
I hereby certify that on August 11, 2015, a true and correct copy of the
foregoing was served on the following counsel of record via electronic
service through electronic filing:
Mark A. Giugliano
mgiugliano@gibbsbruns.com
Anthony N. Kaim
akaim@gibbsbruns.com
J. Benjamin Bireley
bbireley@gibbsbruns.com
GIBBS & BRUNS, LLP
1100 Louisiana, Suite 5300
Houston, TX 77002
Attorneys for Appellant Unocal Pipeline Company
/s/ Christopher Dove
Christopher Dove
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