No. 04-15-00318-CV _________________________________________________________________ 

IN THE COURT OF APPEALS

FOR THE FOURTH DISTRICT OF TEXAS

_________________________________________________________________

GEMINI INSURANCE COMPANY AND BERKLEY OIL AND 

GAS SPECIALTY SERVICES, LLC, 

 APPELLANTS

V. 

DRILLING RISK MANAGEMENT, INC., 

 APPELLEE

____________________________________________________________________ 

On Appeal from the 216th Judicial District Court 

Kendall County, Texas 

Trial Court Cause No. 12-066 

Honorable Bill Palmer, Judge Presiding 

____________________________________________________________________

UNOPPOSED MOTION FOR SECOND EXTENSION OF TIME 

TO FILE APPELLANTS’ BRIEF 

____________________________________________________________________

TO THE HONORABLE FOURTH COURT OF APPEALS: 

 

Appellants, Gemini Insurance Company and Berkley Oil and Gas Specialty 

Services, LLC, respectfully requests an extension of the deadline to file their brief 

as appellants under Texas Rules of Appellate Procedure 10.5(b) and 38.6(d), and 

would respectfully show this Court as follows: 

ACCEPTED

04-15-00318-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

9/24/2015 2:51:48 PM

KEITH HOTTLE

CLERK

 FILED IN 4th COURT OF APPEALS SAN ANTONIO, TEXAS 09/24/2015 2:51:48 PM KEITH E. HOTTLE Clerk
2 

1. This is Appellants’ second motion for extension of time to file their brief. 

2. The filing deadline for Appellants’ brief is presently September 25, 2015. 

3. Appellants request a 30-day extension of the deadline to file their opening 

brief, which would make the brief due Monday, October 26, 2015 (because 

the 30th day falls on a Sunday). 

4. Appellants’ counsel needs additional time to file the opening brief in this 

matter because they have been working to comply with concurrent deadlines 

and briefing requirements in other matters, including the following: 

 Cause No. 15-10655; White v. Regional Adjustment Bureau; in the 

Fifth Circuit Court of Appeals (Brief filed August 25, 2015). 

 Cause No. 14-14-00892-CV; The Branch Law Firm L.L.P., et al. v. W. 

Shane Osborn; in the Fourteenth Court of Appeals (Preparation and 

presentation of oral argument on September 1, 2015). 

 Cause No. 14-14-00470-CV; Robert S. Bennett v. Commission for 

Lawyer Discipline; in the Fourteenth Court of Appeals (Preparation 

and presentation of oral argument on September 16, 2015). 

 Cause No. CV-02121-13-02; Ochoa v. LSDI, LP, d/b/a Lonestar 

Distribution, Inc.; in the 159th District Court of Angelina County, 

Texas. (Preparation, attendance, and participation at extensive all-day 

pretrial hearings on September 22, 2015). 

 Cause No. 09-14-00325-CV; Fort Apache Energy, Inc. v. Resaca, et 

al., in the Ninth Court of Appeals (Preparation and presentation of 

oral argument on September 24, 2015). 

 Cause No. 15-20184; Wellogix, Inc. v. SAP America, Inc., et al., 

(consolidated with 15-20187); in the Fifth Circuit Court of Appeals 

(Reply Brief due October 5, 2015). 

5. As indicated in the attached certificate of conference, counsel for Appellee, 

Drilling Risk Management, Inc., does not oppose the relief sought in this 

motion. 
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WHEREFORE, Appellants Gemini Insurance Company and Berkley Oil and 

Gas Specialty Services, LLC respectfully request that the Court grant this motion 

and extend the deadline for their opening brief to Monday, October 26, 2015. 

CONCLUSION 

 Appellants Gemini Insurance Company and Berkley Oil and Gas Specialty 

Services, LLC respectfully request that the Court grant this motion and extend the 

deadline for them to file their opening brief to Monday, October 26, 2015. 

Respectfully submitted, 

/s/ R. Russell Hollenbeck 

R. Russell Hollenbeck 

State Bar No. 00790901 

Thomas C. Wright 

State Bar No. 22059400 

WRIGHT & CLOSE, LLP 

One Riverway, Suite 2200 

Houston, Texas 77056 

(713) 572-4321 

(713) 572-4320 (fax) 

hollenbeck@wrightclose.com 

wright@wrightclose.com 

George H. Lugrin, IV 

State Bar No. 00787930 

Reece Rondon 

State Bar No. 00794559 

Amanda J. Kujda 

State Bar No. 24053565 

HALL MAINES LUGRIN, PC. 

Williams Tower, 64th Floor 

2800 Post Oak Blvd. 

Houston, Texas 77056 
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(713) 871-9000 

(713) 871-8962 (fax) 

glugrin@hallmaineslugrin.com 

rrondon@hallmaineslugrin.com 

akujda@hallmaineslugrin.com 

Attorneys for Appellants, 

Gemini Insurance Co. and 

Berkley Oil & Gas Specialty 

Services, LLC

CERTIFICATE OF CONFERENCE 

 As required by Texas Rule of Appellate Procedure 10.1(a)(5), I personally 

conferred via email with Catherine M. Stone, counsel for Appellee, Drilling Risk 

Management, Inc., and she indicated her client is not opposed to this motion. 

/s/ R. Russell Hollenbeck

 R. Russell Hollenbeck
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CERTIFICATE OF SERVICE 

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

of record electronically on September 24, 2015. 

Catherine M. Stone 

LANGLEY & BANACK, INC.

745 E. Mulberry Avenue, Suite 900 

San Antonio, Texas 78212 

cstone@langleybanack.com 

Steve Skarnulis 

Charles J. Cain 

CAIN & SKARNULIS, LLP 

400 W. 15th Street, Suite 900 

Austin, Texas 78701 

skarnulis@cstrial.com 

ccain@cstrial.com 

 

/s/ R. Russell Hollenbeck 

R. Russell Hollenbeck