Samson Lone Star Limited Partnership, N/K/A Samson Lone Star, L.L.C. v. Charles G. Hooks, III, Individually and as Independent of the Estate of Charles G. Hooks, Jr., as Trustee of the Scott Ira McKeever Trust and the David Wayne McKeever Trust, and on Behalf of Chas. G. Hooks & Son, a General Partnership ( 2015 )

ACCEPTED
01-09-00328-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/21/2015 8:58:44 AM
CHRISTOPHER PRINE
CLERK
NO. 01-09-00328-CV
In The FILED IN
1st COURT OF APPEALS
FIRST COURT OF APPEALS HOUSTON, TEXAS
Houston, Texas 7/21/2015 8:58:44 AM
CHRISTOPHER A. PRINE
Clerk
SAMSON LONE STAR, LIMITED PARTNERSHIP N/K/A SAMSON
EXPLORATION, LLC
Appellant–Cross-Appellee,
V.
CHARLES G. HOOKS III, et al.
Appellees–Cross-Appellants.
Appeal from Cause B173008-B
60th District Court
Jefferson County, Texas
JOINT AGREED MOTION BY
APPELLEES/CROSS-APPELLANTS
AND APPELLANT/CROSS-APPELLEE
FOR EXTENSION OF TIME TO FILE RESPONSES
Appellees/Cross-Appellants (“the Hooks”) and Appellant/Cross-Appellee,
Samson Lone Star L.L.C. n/k/a Samson Exploration, LLC (“Samson”) jointly
move to request an extension of time in which to file their responses in the
referenced appeal. Both Hooks and Samson request an extension of sixteen days
to and including August 21, 2015 in which to file their responses to supplemental
briefs. In support of this motion, the parties would show as follows:
1. Under the current briefing schedule, the parties’ responses to
supplemental briefing requested by the Court are due August 5, 2015.
2. The primary attorneys responsible for preparing and filing the
responses on behalf of each of the parties have commitments and conflicts in their
schedules that necessitate this request for an extension of time. Those conflicts
include:
a. Counsel for the Hooks has a long-scheduled vacation out of the
country at the end of the July and has pre-trial deadlines and other
work commitments that were already on the calendar before the
supplemental briefing in this matter was scheduled.
b. Counsel for Samson is currently working on an Appellee’s brief in an
antitrust and Lanham Act appeal involving significant damages and
injunctive relief, which brief is currently due in the Fifth Circuit also
in August. Moreover, different deadlines for Appellant and
Cross-Appellants to file their response briefs would create
complications and awkwardly mismatched corresponding deadlines
between the parties. Having such mismatched deadlines would likely
not expedite this appeal, so a matching extension for Appellant/Cross-
Appellee Samson should not cause delay.
3. This is the first extension of time for filing the response briefs that the
parties have requested.
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4. The parties have conferred with one another regarding their mutual
motions for extension of time and have both agreed to each other’s requested
extension, as shown by their filing of this joint agreed motion.
WHEREFORE, PREMISES CONSIDERED, Appellees/Cross-Appellants,
the Hooks, and Appellant/Cross-Appellee, Samson jointly request the Court for an
extension of time to and including August 21, 2015 in which to file their
respective responses in the referenced action.
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/s/ Marla Broaddus
Shannon H. Ratliff
State Bar No. 16573000
Marla Broaddus
State Bar No. 24001791
Ratliff Law Firm, PLLC
600 Congress Avenue, Suite 3100
Austin, Texas 78701
(512) 493-9600
(512) 493-9625 (Fax)
sratliff@ratlifflaw.com
mbroaddus@ratlifflaw.com
David M. Gunn
State Bar No. 08621600
Beck Redden, LLP
1221 McKinney, Suite 4500
Houston, Texas 77010-2010
(713) 951-3700
(713) 951-3720 (Fax)
dgunn@beckredden.com
Paul F. Simpson
State Bar No. 18403800
McGinnis Lochridge, LLP
711 Louisiana Street, Suite 1600
Houston, Texas 77002
(713) 615-8506
(713) 328-1806 (Fax)
psimpson@mcginnislaw.com
Patton G. Lochridge
State Bar No. 12458500
McGinnis Lochridge, LLP
600 Congress Avenue, Suite 2100
Austin, Texas 78701
(512) 495-6000
(512) 495-6093 (Fax)
plochridge@mcginnislaw.com
ATTORNEYS FOR APPELLEES/CROSS-
APPELLANTS THE HOOKS PARTIES
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/s/ Cynthia K. Timms
Michael V. Powell
State Bar No. 16204400
Cynthia K. Timms
State Bar No. 11161450
LOCKE LORD, LLP
2200 Ross Avenue, Suite 2200
Dallas, Texas 75201
mpowell@lockelord.com
ctimms@lockelord.com
(214) 740-8000
(214) 740-8800 (Fax)
M.C. Carrington
State Bar No. 03880800
Mehaffy Weber
P.O. Box 16
Beaumont, Texas 77704
(409) 835-5011
(409) 835-5177 (Fax)
Dick Watt
State Bar No. 20977700
Watt Beckworth Thompson & Henneman,
LLP
1800 Pennzoil Place, South Tower
711 Louisiana Street
Houston, Texas 77002
(713) 650-8100
(713) 650-8141 (Fax)
ATTORNEYS FOR APPELLANT/CROSS-
APPELLEE SAMSON LONESTAR
LIMITED PARTNERSHIP N/K/A/
SAMSON EXPLORATION, LLP
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CERTIFICATE OF SERVICE
I hereby certify that on July 21, 2015, a true and correct copy of the above
and foregoing Motion for Extension of Time was forwarded to all counsel of
record by ECF and email as follows:
Michael V. Powell M.C. Carrington
Cynthia K. Timms Mehaffy Weber
LOCKE LORD, LLP P.O. Box 16
2200 Ross Avenue, Suite 2200 Beaumont, Texas 77704
Dallas, Texas 75201 mccarrington@mehaffyweber.com
mpowell@lockelord.com
ctimms@lockelord.com
Dick Watt
Watt Beckworth Thompson &
Henneman, LLP
1800 Pennzoil Place, South Tower
711 Louisiana Street
Houston, Texas 77002
dwatt@wattbeckworth.com
Attorneys for Appellant/Cross-Appellee, Samson
/s/ Marla Broaddus
Marla Broaddus
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