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

A GREED M OTION TO E XTEND D EADLINE FOR S ELECTING M EDIATOR

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 CLERK2

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 compl y with the Court’s

Order as to the written notif ication of an agreed mediator.

C ONCLUSION AND P RAYER
For these reasons, Appellant Carrizo Oil & Gas, Inc. and Appellee Barrow

Shaver 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 A LEXANDER D UBOSE J EFFERSON & T OWNSEND L LP 515 Congress Avenue, Suite 2350 Austin, Texas 78701 Telephone: (512) 482

- 9300 Facsimile: (512) 482

- 93033 John M. Zukowski State Bar No. 22293400 jmz@zbsplaw.com Pascal Paul Piazza State Bar No. 15966850 ppp@zbsplaw.com Z UKOWSKI , B RESENHAN , S INEX & P ETRY , L.L.P. 1177 West Loop South, Suite 1100 Houston, Te xas 77027 Telephone: (713) 965

- 7597 Facsimile: (713) 963

- 9169

Charles H. Clark State Bar No. 04274000 chc@charlesclarklaw.com T HE L AW O FFICES O F C HARLES H. C LARK 604 West Woldert Street Tyler, Texas 75702 Telephone: (903) 593

- 2514 Facsimile: (903) 595

- 1294

ATTORNEYS FOR CARRIZO OIL & GAS, INC

.

C ERTIFICATE OF C ONFERENCE
I hereby certify that on April 21, 20 15 , I conferred with Deborah Race,

counsel for Appellee, Barrow

- Shaver Resources Company , and she stated that her

client joins in requesting the relief sough t by this motion.

/s/ Marcy Hogan Greer Marcy Hogan Greer4 C ERTIFICATE OF S ERVICE
The undersigned certifies that, on April 2 1

, 2015, this Agreed Motion to

Extend Deadline f

or Selecting Mediator was electronically filed with the Clerk of

C ourt 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 I RELAND , C ARROLL & K ELLEY , P.C. 6101 S. Broadway, Ste. 500 Tyler, Texas 75703

R. Clay Hoblit choblit@hfdlaw.com H OBLIT F ERGUSON D ARLING 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