BP Oil Pipeline Company v. Plains Pipeline, L.P. ( 2015 )

ACCEPTED
14-13-00352-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/15/2015 5:48:46 PM
CHRISTOPHER PRINE
CLERK
NO. 14-13-00352-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS
FOURTEENTH DISTRICT OF TEXAS 7/15/2015 5:48:46 PM
CHRISTOPHER A. PRINE
Clerk
BP OIL PIPELINE COMPANY,
Appellant,
v.
PLAINS PIPELINE, L.P.,
Appellee.
ON APPEAL FROM THE 80TH JUDICIAL DISTRICT COURT
HARRIS COUNTY, TEXAS
APPELLANT’S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE MOTION FOR REHEARING
To the Honorable Court of Appeals:
Plaintiff and Appellant BP Oil Pipeline Company (“BP”) files this motion
for extension of time to file its motion for rehearing, pursuant to Texas Rules of
Appellate Procedure 49.8 and 10.5(b).
BP requests this extension of time because its appellate counsel needs
additional time to prepare its motion for rehearing. Specifically, BP needs
additional time to review the substantial majority and dissenting opinions issued by
the Court on June 30, 2015 and the numerous authorities cited therein that have not
previously been reviewed by the parties or briefed in the original appellate
briefing. In addition, BP’s counsel are currently involved in other litigation
matters that have required and will continue to require their attention over the next
several weeks.
This is BP’s first request for an extension of time to file its motion for
rehearing. Any motions for rehearing are currently due to be filed with this Court
on July 15, 2015. BP timely requests a thirty-one (31) day extension of this
deadline under Texas Rule of Appellate Procedure 49.8, making its motion for
rehearing due on August 17, 2015.
WHEREFORE, Appellant BP Oil Pipeline Company requests a thirty-one
(31) day
-2-
extension of time to file its motion for rehearing, making the motion for rehearing
due August 17, 2015.
Respectfully submitted,
LISKOW & LEWIS
By: /s/ Alma F. Gomez
Jana L. Grauberger
Texas State Bar No. 24047502
Michael P. Cash
Texas State Bar No. 03965500
Alma F. Gomez
Texas State Bar No. 24069800
James T. Kittrell
Texas State Bar No. 24078795
1001 Fannin Street, Suite 1800
Houston, Texas 77002
Telephone: (713) 651-2900
Facsimile: (713) 651-2908
Email: jlgrauberger@liskow.com
Email: mcash@liskow.com
Email: afgomez@liskow.com
Email: jkittrell@liskow.com
Joe B. Norman
Louisiana State Bar No. 8160
One Shell Square
701 Poydras Street, Suite 5000
New Orleans, Louisiana 70139
Telephone: (504) 556-4052
Facsimile: (504) 556-4108
Email: jbnorman@liskow.com
ATTORNEYS FOR APPELLANT
BP OIL PIPELINE COMPANY
-3-
CERTIFICATE OF CONFERENCE
Under Texas Rules of Appellate Procedure 10.1(a)(5), I certify that on July
15, 2015, I conferred with Jane Robinson, counsel for Appellee Plains Pipeline,
L.P., and she does not oppose the extension of time requested.
/s/ Alma F. Gomez
Alma F. Gomez
CERTIFICATE OF SERVICE
I hereby certify that a copy of Appellant’s Motion for Extension of Time to
File Motion for Rehearing is being served on all attorneys of record for Appellee
on this 15th day of July, 2015, by the method indicated below.
/s/ Alma F. Gomez
Alma F. Gomez
John Zavitsanos Certified Mail – RRR
Elizabeth Fletcher
Jane Robinson No.:
Ahmad, Zavitsanos, Anaipakos, Alavi &
Mensing, P.C. Private Delivery
1221 McKinney St., Suite 3460
Houston, Texas 77010 E-Mail
Telephone: (713) 655-1101
Facsimile: (713) 655-0062 Personal Delivery
Thomas C. Wright Certified Mail – RRR
Natasha N. Taylor
Wright & Close, LLP No.:
One Riverway, Suite 200
Houston, Texas 77056 Private Delivery
Telephone: (713) 572-4321
Facsimile: (713) 572-4320 E-Mail
Attorneys for Appellee, Plains Pipeline, L.P. Personal Delivery
-4-
CERTIFICATE OF COMPLIANCE
I hereby certify that Appellant’s Motion for Extension of Time to File
Motion for Rehearing was produced on a computer using Microsoft Word and
contains 216 words, as determined by the word-count feature of the word
processing software, excluding the sections of the documented listed in Tex. R.
App. 9.4(i)(1).
/s/ Alma F. Gomez
Alma F. Gomez
-5-