Eog Resources’ Mtn. for Extension 1 / 4

No. 12-14-00262-CV

in the

Twelfth Court of Appeals 

Tyler, Texas

Charles and Mary Lou Alford,

Appellants,

v.

Robert Thomas McKeithen; EOG Resources, Inc.; 

and Central Texas Land Services,

Appellees.

EOG’s Motion for Extension

Appellee EOG Resources, Inc. respectfully asks the Court to extend the 

due date of its appellee’s brief by 30 days, to June 25, 2015.

1

I. RULE 10.5 INFORMATION

1. Deadline for filing appellee’s brief:

May 26, 2015 (Appellant’s brief was filed on April 24, 2015). 

2. Length of extension sought:

Thirty days, so that the new deadline would be June 25, 2015.

 

1 References to EOG include Central Texas Land Services, which is also an appellee.

ACCEPTED

12-14-00262-CV

TWELFTH COURT OF APPEALS

TYLER, TEXAS

5/6/2015 2:06:21 PM

CATHY LUSK

CLERK

 FILED IN 12th COURT OF APPEALS TYLER, TEXAS 5/6/2015 2:06:21 PM CATHY S. LUSK Clerk
Eog Resources’ Mtn. for Extension 2 / 4

3. Facts relied on to reasonably explain the need for extension:

Four considerations warrant an extension. 

First, EOG’s counsel has a special-exceptions hearing on May 15 in B.D. 

Resources, Inc. v. Ellora Energy, Inc., No. 14CV32892 in the 123rd/273rd District Court of Shelby County, Texas. 

Second, EOG’s counsel has multiple discovery responses due on May 11

in Goodwin v. XTO Energy Inc., No. CV-13-9496 in the District Court of San 

Augustine County, Texas. 

Third, EOG’s counsel has a joint pretrial order due May 18 in White Rock 

Expl., Inc. v. Palestine Water Well Service, Inc., No. 14-0596-B in the 114th District Court of Smith County, Texas. EOG’s counsel has a pretrial conference 

in that case on May 29, and trial starts on June 8. 

Fourth, EOG’s counsel has a summary-judgment hearing on May 26 in 

Circulation Solutions v. R.A.M.P. Chemicals, No. 2015CVF000571 D3 in the 

341st District Court of Webb County, Texas. 

EOG wants to submit a brief worthy of this Court’s time and its own 

cause. These four issues endanger that desire. 

4. Number of previous extensions: 

None. 

II. CERTIFICATE OF CONFERENCE

EOG has conferred with the Alfords’ counsel and with McKeithen’s

counsel, and neither opposes this motion. 
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III. CONCLUSION

This is EOG’s first request for an extension. The extension is not sought 

merely for delay. The four above considerations warrant the extension. Accordingly, EOG respectfully asks the Court to grant the 30-day extension, so 

that EOG’s brief will be due on June 25, 2015, in accordance with Tex. R. 

App. P.10.5(b)(1) & 38.6(d). 

Respectfully submitted,

Freeman Mills PC

110 N. College, Ste. 1400

Tyler, Texas 75702

903.592.7755 phone

903.592.7787 fax

www.freemanmillspc.com

By: 

Jason R. Mills

Bar No. 24041494

eservicejrm@freemanmillspc.com

Graham K. Simms

Bar No. 24060610

gimms@freemanmillspc.com

Joshua C. Ashley

Bar No. 24078161

jashley@freemanmillspc.com
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CERTIFICATE OF SERVICE

I certify that a true and correct copy of this document was served on all 

counsel of record on May 6, 2015 in accordance with the Texas Rules of Appellate Procedure. 

Jason R. Mills