Page 1 

No. 15-0248 

In the Supreme Court of Texas 

BP AMERICA PRODUCTION COMPANY, 

 Petitioner/Cross-Respondent,

v. 

LADDEX, LTD., 

 Respondent/Cross-Petitioner. 

From the Seventh Court of Appeals, Amarillo 

Court of Appeals No. 07-13-00392-CV 

On Appeal from the 31st District Court, Roberts County, Texas 

Trial Court No. 1944 

FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME

TO FILE RESPONSE TO PETITION FOR REVIEW 

To The Honorable Supreme Court of Texas: 

Respondent/Cross-Petitioner Laddex, Ltd. files this First Unopposed Motion 

for Extension of Time to File Response to Petition for Review under Tex. R. App. 

P. 10.1, 10.5(b)(1) and 53.7(f). In support of this motion, Respondent/CrossPetitioner shows the following: 

FILED

15-0248

7/28/2015 5:44:14 PM

tex-6263293

SUPREME COURT OF TEXAS

BLAKE A. HAWTHORNE, CLERK
 Page 2 

1. BP America Production Company (“BP”) filed a Motion for 

Extension of Time to File Petition for Review on March 30, 2015. The Motion 

was granted. BP filed its Petition for Review on May 4, 2015. 

2. On May 4, 2015 Laddex, Ltd. filed its Cross-Petition for Review. 

3. One June 3, 2015 BP filed its Response to Cross-Petition for Review. 

On June 4, 2015, Laddex, Ltd. filed its Notice of Waiver of Response. On June 18, 

2015 Laddex, Ltd. filed a Reply to Response to Cross-Petition for Review. 

4. On July 10, 2015 this honorable court requested Laddex, Ltd. file a 

response to the petition for review on August 10, 2015. 

5. Laddex, Ltd. requests an extension of time of thirty (30) days, to 

September 9, 2015 to file its response to the petition for review. This is 

Respondent’s first request for an extension of time to file its response to BP’s 

Petition for Review. 

6. Respondent relies on the following facts as a reasonable explanation 

for the requested extension of time. Respondent’s counsel, in addition to preparing 

a response to the petition for review in this case has been required to prepare for 

and/or participate in the following additional matters prior to August 10, 2015: 

 July 15, 2015; Estate of Darwyn B. Metcalf, Deceased, in the 

County Court at Law No. 1, in and for Potter County, Texas 

(Deposition). 

 
 Page 3 

 July 15, 2015; Robert Howell, Plaintiff v. EOG Resources, Inc. and 

My Petro American Oilfield Services, LLC d/b/a Petro American, 

LLC, Defendants and My Petro American Oilfield Services, LLC 

d/b/a Petro American, LLC, Third-Party Plaintiff v. David Creacy, 

Robert Hallows, Gabriel Martinez, John Odom, Energy First 

Engineering & Consulting, LLC and DMIC, Inc., Third-Party 

Defendants, Cause No. 12-09-00199-CVK; in the 81st District 

Court, Karnes County, Texas (reply to Motion for Summary 

Judgment). 

 July 16, 2015; Robert Howell, Plaintiff v. EOG Resources, Inc. and 

My Petro American Oilfield Services, LLC d/b/a Petro American, 

LLC, Defendants and My Petro American Oilfield Services, LLC 

d/b/a Petro American, LLC, Third-Party Plaintiff v. David Creacy, 

Robert Hallows, Gabriel Martinez, John Odom, Energy First 

Engineering & Consulting, LLC and DMIC, Inc., Third-Party 

Defendants, Cause No. 12-09-00199-CVK; in the 81st District 

Court, Karnes County, Texas (Motion for Summary Judgment 

hearing). 

 July 20, 2015; Direct Petroleum Exploration, LLC, v. 

TransAtlantic Worldwide Ltd., and TransAtlantic Petroleum Ltd., 

Cause No. DC-14-11752-E; in the 101st District Court in and for 

Dallas County, Texas (respond to Motion for Summary Judgment). 

 July 21, 2015; Mayo Foundation for Medical Education and 

Research v. Latigo Petroleum, Inc. and Plains Exploration and 

Production Company, Cause No. 2060; 31st District Court for 

Roberts County, Texas (prepare and file expert report). 

 July 22, 2015; Estate of Darwyn B. Metcalf, Deceased, in the 

County Court at Law No. 1, in and for Potter County, Texas 

(Deposition). 

 July 23, 2015; Estate of Darwyn B. Metcalf, Deceased, in the 

County Court at Law No. 1, in and for Potter County, Texas 

(Mediation). 
 Page 4 

 July 27, 2015; Direct Petroleum Exploration, LLC, v. 

TransAtlantic Worldwide Ltd., and TransAtlantic Petroleum Ltd., 

Cause No. DC-14-11752-E; In the 101st District Court in and for 

Dallas County, Texas (Motion for Summary Judgment Hearing). 

 July 29, 2015; McMordie, et al v. Valence Operating Company, et 

al., Cause No. 2,040, in the 31st District Court in and for Roberts 

County, Texas (Pre-Trial hearing). 

 August 3, 2015; Direct Petroleum Exploration, LLC, v. 

TransAtlantic Worldwide Ltd., and TransAtlantic Petroleum Ltd., 

Cause No. DC-14-11752-E; in the 101st District Court in and for 

Dallas County, Texas (post-hearing briefing). 

 August 7, 2010; Walter O’Cheskey, as Chapter 11 Trustee, v. 

Robert L. Templeton, Adversary No. 10-02016-rlj; in the United 

States Bankruptcy Court for the Northern District of Texas, 

Amarillo Division (deadline for post-remand brief). 

 August 7, 2010; Richard D. Crawford v. XTO Energy Inc., Case 

No. 15-0142 in the Supreme Court of Texas (deadline to file reply 

to response to petition for review). 

 August 10, 2015; McMordie, et al v. Valence Operating Company, 

et al., Cause No. 2,040, in the 31st District Court in and for Roberts 

County, Texas (3 day Trial). 

7. In addition, Respondent’s counsel is facing the following pre-existing 

deadlines: 

 August 13, 2015; Walter O’Cheskey, as Chapter 11 Trustee, v. 

Robert L. Templeton, Adversary No. 10-02016-rlj; in the United 

States Bankruptcy Court for the Northern District of Texas, 

Amarillo Division (oral argument on remanded issues). 

 
 Page 5 

 August 14, 2015; Sutherland Energy Com, LLC v. Dimock 

Operating Company and Joe W. Dimock d/b/a Dimock Petroleum, 

Cause No. 11098, in the 46th District Court in and for Hardeman 

County, Texas (temporary injunction hearing).

 August 20, 2015; Michael Quinn Sullivan v. Salem Abraham, Case 

No. 14-0987, in the Supreme Court of Texas (Respondent’s brief). 

 August 20, 2015; Daniel Greer and Fix the Facts Foundation 

d/b/a Agendawise v. Salem Abraham, Case No. 14-0669, in the 

Supreme Court of Texas (Respondent’s brief). 

 August 21, 2015; Estate of Darwyn B. Metcalf, Deceased, in the 

County Court at Law No. 1, in and for Potter County, Texas 

(Deposition). 

 September 3, 2015; Estate of Darwyn B. Metcalf, Deceased, in the 

County Court at Law No. 1, in and for Potter County, Texas 

(Deposition). 

8. The undersigned has conferred with opposing counsel, who stated 

there was no opposition to this request. 

 Therefore, Respondent prays that this Court grant this unopposed motion for 

a thirty (30) day extension of time. 

 
 Page 6 

 Respectfully submitted, 

LOVELL, LOVELL, NEWSOM & ISERN, L.L.P. 

Joe L. Lovell, SBN 12609100 

joe@lovell-law.net 

Brian W. Farabough, SBN 24072989 

brian@lovell-law.net 

112 West 8th Avenue, Suite 1000 

Eagle Centre Building 

Amarillo, Texas 79101-2314 

Telephone: (806) 373-1515 

Facsimile: (806) 379-7176 

By: /s/ Brian W. Farabough 

 Brian W. Farabough 

CERTIFICATE OF CONFERENCE 

 As required by Tex. R. App. P. 10.1(a)(5), I certify that I have conferred 

with Charles “Skip” Watson, counsel for BP America Production Company, who 

indicated that he had no opposition to this motion. 

 /s/ Brian W. Farabough 

 Brian W. Farabough 

 
 Page 7 

CERTIFICATE OF SERVICE 

 I certify that, on July 28, 2015, I served a copy of this motion by e-mail on 

the following: 

Mr. Charles R. “Skip” Watson, Jr. Via email to: cwatson@lockelord.com 

Mr. Mike A. Hatchell and mahatchell@lockelord.com

Ms. Susan A. Kidwell and skidwell@lockelord.com

LOCKE LORD LLP 

600 Congress Avenue, Suite 2200 

Austin, Texas 78701 

 

 /s/ Brian W. Farabough 

 Brian W. Farabough