NO. 03-12-00247-CV 

ROLAND OIL COMPANY § IN THE THIRD 

Appellant, § 

§ 

VS. § COURT OF APPEALS 

§ 

RAILROAD COMMISSION OF § 

TEXAS § SAN ANTONIO, TEXAS 

Appellee. 

APPELLANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE 

MOTION FOR REHEARING 

TO THE HONORABLE COURT OF APPEALS: 

COMES NOW Appellant, Roland Oil Company, and moves 

the Court to Extend the Time to File a Motion for 

Rehearing. 

A. Introduction 

1. Appellant is Roland Oil Company; appellee is 

Railroad Commission of Texas. 

2. This motion is filed within the 15-day period to 

file a motion to extend the time to file a motion for 

rehearing, as required by Texas Rule of Appellate 

Procedure 49.8. 

3. An inquiry was made to the attorney for Appellee, 

Railroad Commission of Texas, about this motion who 

indicated that he was unopposed. 

B. Argument and Authorities 

4. The Court has the authority under Rule 49.8 to 

extend the time for a party to file a motion for 

rehearing. 

ACCEPTED

03-12-00247-CV

4919051

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/16/2015 3:57:48 PM

JEFFREY D. KYLE

CLERK

 FILED IN 3rd COURT OF APPEALS AUSTIN, TEXAS 4/16/2015 3:57:48 PM JEFFREY D. KYLE Clerk
5. Appellant's motion for rehearing is due on April 

15, 2015, per the Court's Order dated March 25, 2015. 

6. Appellant requests an additional forty-one (41) 

days to file a motion for rehearing, extending the time 

until May 26, 2015. 

7. A previous extension was granted to extend the 

time to file the motion for rehearing, pursuant to a 

Motion filed by Appellant, acting pro se. 

8. Appellant needs additional time to file the 

motion for rehearing because: (1) appellant has 

diligently looked for a replacement attorney, and has 

engaged Jeffrey R. Akins, Attorney at Law, (2) being just 

now engaged, Mr. Akins has not had adequate time to 

prepare a motion for rehearing, 3) Mr. Akins has been ill 

during the last three weeks with a respiratory illness 

and then a stomach illness and has only now recovered to 

about 80%; therefore he has missed so much work that he 

has several deadlines coming up in other client matters, 

(4) Mr. Akins is a scheduled speaker at the Texas Bar CLE 

Oil, Gas and Mineral Title Examination Course to be held 

in Houston on June 25-26, and is required to have his 

seminar paper submitted by May 11, 2015; and due to his 

illness Mr. Akins has not been able to work on completing 

this paper, which is estimated will take sixty (60) 

additional hours to complete, (5) between his ongoing 

work deadlines and the work required for the paper, Mr. 

Akins will not reasonably have time available to prepare 

an adequate motion for rehearing, (6) being realistic, 

Mr. Akins will not reasonably be able to do substantial 

work on this motion until after May 11, barring a 

physically and mentally exhausting work schedule, and (7) 

insofar as the status quo in the field (involving the 

wells) this extension does not cause any harm and no 

exigent circumstances exist. 

9. This extension is not sought solely for delay, 

but that justice may be done. 

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PRAYER 

For these reasons, Appellant asks the Court to grant 

an extension of time to file a Motion for Rehearing until 

May 26, 2015. 

Respectfully submitted, 

/s/ Jeffrey R. Akins 

JEFFREY R. AKINS 

State Bar No. 00962425 

14350 Northbrook Drive 

Suite 150 

San Antonio, Texas 78232 

Telephone: (210) 599-4905 

Facsimile: (210) 490-2776 

jrakins@sbcglobal.net 

ATTORNEY FOR APPELLANT 

CERTIFICATE OF CONFERENCE 

I certify that I have conferred with Anthony Benedict 

by telephone and he is unopposed to this motion. 

/s/ Jeffrey R. Akins 

Jeffrey R. Akins 

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CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the 

above and foregoing document has been served upon the 

following counsel of record, pursuant to the Texas Rules 

of Appellate Procedure on the 15thday of April, 2015, 

after 5:00 p.m. 

Anthony W. Benedict VIA FACSIMILE - (512) 320-0911 

/s/ Jeffrey R. Akins 

Jeffrey R. Akins 

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