No. 12-15-00083-CV

In the Twelfth District Court of Appeals

Tyler, Texas

Carrizo Oil & Gas, Inc.,

Appellant,

v.

Barrow-Shaver Resources Company,

Appellee.

On Appeal from the 7th Judicial District Court

Smith County, Texas

Cause No. 12-2565-A

AGREED MOTION TO EXTEND DEADLINE FOR SELECTING MEDIATOR

TO THE HONORABLE COURT OF APPEALS: 

On April 14, 2015, the Court issued an Order Referring Case to Mediation 

that required the parties, among other things, to notify the Court in writing of any 

agreed mediator within seven days of the Order. 

Counsel for both parties have been researching and discussing possible 

mediators and logistical issues relating to mediation since that time and believe they 

can reach an agreement as to a mediator and place for mediation for this matter, but 

need more time to do so. The parties anticipate that they will be able to inform the 

ACCEPTED

12-15-00083-CV

TWELFTH COURT OF APPEALS

TYLER, TEXAS

4/21/2015 4:21:23 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 4/21/2015 4:21:23 PM CATHY S. LUSK Clerk
2

Court of an agreement by the end of the week, but want to insure sufficient time to 

work out the details. The parties therefore jointly and respectfully request that the 

Court grant them an extension of time of seven days to comply with the Court’s 

Order as to the written notification of an agreed mediator. 

CONCLUSION AND PRAYER

For these reasons, Appellant Carrizo Oil & Gas, Inc. and Appellee BarrowShaver Resources Company request that the Court: (i) grant this Agreed Motion to

Extend Deadline for Selecting Mediator; (ii) order that the deadline for complying 

with the Court’s April 14, 2015, Order requiring the parties to notify it in writing as 

to an agreed mediator is extended to April 28, 2015; and (iii) grant such other and 

further relief to which the parties are entitled.

Respectfully submitted,

/s/ Marcy Hogan Greer

Marcy Hogan Greer

State Bar No. 08417650

mgreer@adjtlaw.com

ALEXANDER DUBOSE JEFFERSON &

TOWNSEND LLP

515 Congress Avenue, Suite 2350

Austin, Texas 78701

Telephone: (512) 482-9300

Facsimile: (512) 482-9303
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John M. Zukowski

State Bar No. 22293400

jmz@zbsplaw.com

Pascal Paul Piazza

State Bar No. 15966850

ppp@zbsplaw.com

ZUKOWSKI, BRESENHAN, SINEX &

PETRY, L.L.P.

1177 West Loop South, Suite 1100

Houston, Texas 77027

Telephone: (713) 965-7597

Facsimile: (713) 963-9169

Charles H. Clark

State Bar No. 04274000

chc@charlesclarklaw.com

THE LAW OFFICES OF CHARLES H. CLARK

604 West Woldert Street

Tyler, Texas 75702

Telephone: (903) 593-2514

Facsimile: (903) 595-1294

ATTORNEYS FOR CARRIZO OIL & 

GAS, INC.

CERTIFICATE OF CONFERENCE

I hereby certify that on April 21, 2015, I conferred with Deborah Race, 

counsel for Appellee, Barrow-Shaver Resources Company, and she stated that her 

client joins in requesting the relief sought by this motion.

/s/ Marcy Hogan Greer

Marcy Hogan Greer
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CERTIFICATE OF SERVICE

The undersigned certifies that, on April 21, 2015, this Agreed Motion to 

Extend Deadline for Selecting Mediator was electronically filed with the Clerk of 

Court using the eFile.TXCourts.gov electronic filing system which will send 

notification to the following: 

Otis Carroll

ocarrroll@icklaw.com

Collin M. Maloney

cmaloney@icklaw.com

Deborah Race

drace@icklaw.com

IRELAND, CARROLL & KELLEY, P.C.

6101 S. Broadway, Ste. 500

Tyler, Texas 75703

R. Clay Hoblit

choblit@hfdlaw.com

HOBLIT FERGUSON DARLING L.L.P.

2000 Frost Bank Plaza

802 North Carancahua 

Corpus Christi, Texas 78401

Counsel for Plaintiff Barrow-Shaver 

Resources Company

/s/ Marcy Hogan Greer

Marcy Hogan Greer