RSM Production Corp. and Jack Grynberg v. Global Petroleum Group, Ltd., Tricon Geophysics, Inc., Seabird Exlporation, America, Inc., and Blackwater Subsea, LLC ( 2015 )

ACCEPTED
01-15-00866-cv
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/25/2015 12:15:53 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00866-CV
_________________________________________________________________
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
I C
N THE OURT OF PPEALS A 11/25/2015 12:15:53 PM
FOR THE IRST ISTRICT OF EXAS CHRISTOPHER
F D T Clerk
A. PRINE
_________________________________________________________________
RSM PRODUCTION CORP. AND JACK GRYNBERG,
Appellants
v.
GLOBAL PETROLEUM GROUP, LTD.
Appellee
____________________________________________________________________
On Appeal from the 189th Judicial District Court
Harris County, Texas
Trial Court Cause No. 2013-74337
Honorable Bill Burke, Judge Presiding
____________________________________________________________________
MOTION FOR 30-DAY EXTENSION OF TIME TO FILE
BRIEF AS APPELLANTS
____________________________________________________________________
TO THE HONORABLE FIRST COURT OF APPEALS:
Appellants, RSM Production and Jack Grynberg, respectfully request 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. This is Appellants’ first motion for extension of time to file their brief.
2. The filing deadline for Appellants’ brief is presently December 10, 2015.
3. Appellants request a 30-day extension of the deadline to file their opening
brief, which would make the brief due January 11, 2016.
4. Appellants’ counsel needs additional time to file the brief because of the
intervening Thanksgiving holiday, as well as pending deadlines in other
litigation.
WHEREFORE, Appellants RSM Production and Jack Grynberg respectfully
request that the Court grant this motion and extend the deadline for their opening
brief to Monday, January 11, 2016.
Respectfully submitted,
/s/ Andrew C. Nelson
Howard L. Close
State Bar No. 04406500
Randall C. Owens
State Bar No. 15380700
Bradley W. Snead
State Bar No. 24049835
Andrew C. Nelson
State Bar No. 24074801
WRIGHT & CLOSE, LLP
One Riverway, Suite 2200
Houston, Texas 77056
Telephone: (713) 572-4321
Facsimile: (713) 572-4320
close@wrightclose.com
owens@wrightclose.com
snead@wrightclose.com
nelson@wrightclose.com
Attorneys for Appellants,
RSM Production Corp. and Jack Grynberg
2
CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I conferred
with counsel for Appellee via email on Monday, November 23rd at 5:14 pm,
asking whether counsel opposed this motion. I received an email response on
Tuesday morning, stating: “We are consulting with our client and will get back to
you once we hear from him.” As of the time of this filing, Wednesday, November
25th, I have not received any further response.
/s/ Bradley W. Snead
Bradley W. Snead
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of this document was served on
the following attorneys by electronic service on this 25th day of November 2015:
Brian F. Antweil
Emily L. Rochy
KATTEN MUCHIN ROSENMAN UK, LLP
1301 McKinney Street, Suite 3000
Houston, TX 77010-3033
brian.antweil@kattenlaw.com
emily.rochy@kattenlaw.com
Attorneys for Appellee,
Global Petroleum Group, Ltd.
/s/ Andrew C. Nelson
Andrew C. Nelson
3