Unocal Pipeline Company v. BP Pipelines (Alaska) Inc., Conoco Phillips Transportation Alaska, Inc., and ExxonMobil Pipeline Co.

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.

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 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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