HOULITIGATION:1438938.1 1

NO. 06-15-00091-CV 

IN THE SIXTH COURT OF APPEALS 

TEXARKANA, TEXAS 

ON APPEAL FROM THE COUNTY COURT AT LAW 

PANOLA COUNTY, TEXAS 

TRIAL COURT NUMBER 2013-457 

BRAMMER PETROLEUM, INC., 

 APPELLANT 

v. 

BAGLEY MINERALS, L.P., BILLY MCFADDEN AND ARTHUR 

MCFADDEN, 

APPELLEES 

JOINT MOTION TO EXTEND TIME TO FILE BRIEFS 

In accordance with Texas Rules of Appellate Procedure 10.5 and 38.6(d), 

Appellant Brammer Petroleum, Inc. and Appellees Bagley Minerals, L.P., Billy 

McFadden and Arthur McFadden (collectively referred to herein as “the Parties”) 

file this Joint Motion for Extension of Time to File Briefs as follows: 

ACCEPTED

06-15-00091-CV

SIXTH COURT OF APPEALS

TEXARKANA, TEXAS

11/24/2015 9:43:46 AM

DEBBIE AUTREY

CLERK

 FILED IN 6th COURT OF APPEALS TEXARKANA, TEXAS 11/24/2015 9:43:46 AM DEBBIE AUTREY Clerk
HOULITIGATION:1438938.1 2

I. 

Appellant’s Brief is currently due on or before December 23, 2015. 

Appellant request an extension of the deadline to file its brief. If granted, 

that would make Appellant’s Brief due on or before Friday, January 22, 2016. 

This is Appellant’s first requested extension of its briefing deadline. 

Following the Rules thereafter, Appellee’s Brief would then be due on 

February 22, 2016 and any Reply Brief by Appellant would be due on March 14, 

2016. 

II.

Appellant Brammer Petroleum, Inc. requests this extension because its 

appellate counsel is preparing for 3-4 day jury trial in Cause No. 2013-36621A 

styled Lawsky v. SureTec Insurance Co., in the 61st District Court of Harris 

County set for trial on December 7, 2015. Further, a significant portion of 

Appellee’s response time would fall during the holidays. All counsel for the 

Parties need this extension due to the press of numerous other business and 

litigation matters. Allowing Appellees an extension on its brief would provide for 

a single briefing schedule. 

III. 

The parties have conferred, and Appellees do not oppose and join in the 

requested extension.
HOULITIGATION:1438938.1 3

IV. 

The Court may grant an extension of time to file a brief under the authority 

of Texas Rule of Appellate Procedure 10.5(b). Because this is an unopposed joint 

motion to extend time to file a brief, it may be determined by the Court without 

waiting the 10-day submission delay. See Tex. R. App. P. 10.3(a)(1)-(2). 

WHEREFORE, Appellees request an extension for filing their briefs, 

making the Appellees’ Briefs due on or before January 22, 2016.

Respectfully submitted, 

/s/ Konor Cormier 

Konor A. Cormier 

 State Bar No. 24040731 

 MehaffyWeber, P.C. 

 One Allen Center 

 500 Dallas, Suite 1200 

 Houston, Texas 77002 

 Phone: (713) 655-1200 

 Facsimile: (713) 655-0222 

Counsel for Appellant Brammer Petroleum, 

Inc.  
HOULITIGATION:1438938.1 4

/s/ J. Don Westbrook 

J. Don Westbrook 

State Bar No. 24040731 

 Coghlan Crowson 

 1127 Judson Road 

Suite 211 

Longview, TX 75601 

 Phone: (903) 758-5543 

 Facsimile: (903) 753-6989 

Counsel for Appellees  

CERTIFICATE OF SERVICE

I hereby certify that on November 24th, 2015, a true and correct copy of 

this Motion was served in accordance with the Texas Rules of Appellate 

Procedure by electronic filing and/or first-class U.S. mail to all known counsel of 

record.

/s/ Konor Cormier