No. 08-21-00044-CV 

In The 

COURT OF APPEALS 

EIGHTH DISTRICT OF TEXAS 

EL PASO, TEXAS 

EVELYN GARZA, INDIVIDUALLY, AND ON BEHALF OF RUBEN 

ROBERTO GARZA, DECEASED, MALORIE ELISSA GARZA, VALERIE 

MARIE GARZA, AND ALICE HERNANDEZ GARZA, 

Appellants, 

v. 

RDL ENERGY SERVICES, LLC AND JPH HOLDINGS, LLC, 

Appellees. 

On Appeal from 112th District Court 

Crockett County, Texas 

Trial Court Cause No. 19-02-07955-CV 

APPELLEE JPH HOLDINGS, LLC’S 

UNOPPOSED MOTION FOR SECOND 

EXTENSION OF TIME TO FILE MOTION FOR REHEARING 

TO THE HONORABLE EIGHTH COURT OF APPEALS: 

 Pursuant to Tex. R. App. P. 10 and 49.9, Appellee JPH Holdings, LLC files 

this Unopposed Motion for Second Extension of Time to File Motion for Rehearing. 

In light of the Court’s ruling on the RDL Appellees’ Second Motion for Extension, 

ACCEPTED

08-21-00044-CV

EIGHTH COURT OF APPEALS

EL PASO, TEXAS

1/25/2023 10:19 AM

ELIZABETH G. FLORES

CLERK

08-21-00044-CV

 FILED IN 8th COURT OF APPEALS EL PASO, TEXAS 1/25/2023 10:19:11 AM ELIZABETH G. FLORES Clerk
2 

JPH requests the same extension until February 17, 2023, to file a motion for 

rehearing. JPH respectfully shows as follows: 

1. On December 20, 2022, this Court issued its judgment and opinion in 

this appeal. 

2. JPH now requests an extension until February 17, 2023, to file a motion 

for rehearing because of its appellate counsel’s following recent and upcoming 

responsibilities, in addition to counsel’s traveling to San Antonio on January 19-20, 

2023 for an officers and council meeting of the State Bar of Texas Appellate Section: 

 Preparing appellee brief in Cause 14-22-00544-CV, Roe v. 

Ferrer Poirot Wansbrough Feller Daniel & Abney, in the Fourteenth Court 

of Appeals, Texas, presently due February 1, 2023. 

 Preparing motion for summary judgment in Cause No. DC-19-04611, 

Wells v. Bosson, LLC, in the 44th District Court, Dallas County, Texas, 

presently due January 31, 2023. 

 Attending hearing regarding objections to proposed order on settlement 

apportionment in Cause No. 19-DCV-259569, Olson v. Liberty Mutual 

Insurance Company, in the 458th District Court, Fort Bend County, Texas, 

on February 1, 2023. 
3 

 Traveling to and attending status conference in Cause No. S-19-5852-CVC, Taft ISD v. Liberty Surplus Insurance Corp., in the 343rd District Court, 

San Patricio County, Texas, on February 7, 2023. 

3. This request is not made only for purposes of delay but so that justice 

may be served. Appellants’ counsel has generously indicated he is unopposed to 

this request. 

PRAYER 

For the foregoing reasons, Appellee JPH Holdings, LLC respectfully requests 

that the time for filing its motion for rehearing be extended until February 17, 2023, 

and for any other relief in law or equity to which it is entitled. 

Respectfully submitted, 

THOMPSON, COE, COUSINS & IRONS, L.L.P. 

By: /s/ Andrew L. Johnson 

Andrew L. Johnson 

Texas State Bar No. 24060025 

William R. Moye 

State Bar No. 24027553 

Molly L. Pela 

State Bar No. 24046606 

One Riverway, Suite 1400 

Houston, TX 77056 

Telephone: (713) 403-8205 

Telecopy: (713) 403-8299 

ajohnson@thompsoncoe.com

wmoye@thompsoncoe.com 

mpela@thompsoncoe.com

COUNSEL FOR APPELLEE, JPH 

HOLDINGS, LLC 
4 

CERTIFICATE OF CONFERENCE

I conferred with counsel for appellants, and they are unopposed to this 

requested extension. 

 /s/ Andrew L. Johnson 

ANDREW L.JOHNSON

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was 

sent pursuant to the Rules on January 25, 2023 to all counsel of record. 

 /s/ Andrew L. Johnson 

ANDREW L.JOHNSON
Automated Certificate of eService

This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system

on the date and to the persons listed below. The rules governing

certificates of service have not changed. Filers must still provide a

certificate of service that complies with all applicable rules.

Crystal Carrier on behalf of Andrew Johnson

Bar No. 24060025

ccarrier@thompsoncoe.com

Envelope ID: 72125350

Status as of 1/25/2023 1:53 PM MST

Case Contacts

Name

William R.Moye

Andrew Johnson

Molly L.Pela

Stephen Ballantyne

Desi Martinez

Andrew Petersen

Ronald E. Mendoza

William Moye

BarNumber

24053759

24053342

24059226

13937700

Email

WMoye@thompsoncoe.com

ajohnson@thompsoncoe.com

MPela@thompsoncoe.com

patrick@lahoodnorton.com

desi.martinez@martinez-law.com

apetersen@zgblaw.com

rmendoza@lawdcm.com

wmoye.service@thompsoncoe.com

TimestampSubmitted

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

Status

SENT

SENT

SENT

SENT

SENT

SENT

SENT

SENT

Associated Case Party: RDL Energy Services, LLC

Name

Jessica Z.Barger

Lisa Wright

Eric Boettcher

BarNumber Email

barger@wrightclosebarger.com

lwright@wrightclosebarger.com

boettcher@wrightclosebarger.com

TimestampSubmitted

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

1/25/2023 10:19:11 AM

Status

SENT

SENT

SENT