NO. 14

- 15

- 00348

- CV

__________________________________________________________________ IN THE COURT OF APPEALS FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS AT HOUSTON

__________________________________________________________________ WILLIAM B. HARRISON, INDIVIDUALLY, ET AL.,

Appellants,

v.
HARRISON INTERESTS, LTD. AND DANIEL J. HARRISON, III, INDIVIDUALLY, ET AL.,

Appellees.

__________________________________________________________________ On Appeal from 190th Judicial District Court, Harris County, Texas, Cause No. 2010-82117

__________________________________________________________________
APPELLEES’ UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF

__________________________________________________________________
Pu rsuant to Texas Rules of Appellate Procedure 10.5(b) and 38.6(d),

Appellees Harrison Interests, Ltd. (“HIL”) et al. 1 request an extension of thirty (30)

1 Appellees comprise HIL; Daniel J. Harrison III, individually, as Trustee of the Bruce F. Harrison Testamentary Trust held under the Last Will and Testament of Daniel J. Harrison, Jr., Deceased, as Trustee of the Daniel J. Ha rrison III Testamentary Trust held under the Last Will and Testament of Daniel J. Harrison, Jr., Deceased, as Trustee of the Daniel J. Harrison III GST Non

- Exempt Trust held under the Complete Amendment and Restatement of the Declaration of Mary Alice Smit h Revocable Management Trust Agreement, as General Partner and Managing Partner of HIL, and as Co

- Independent Executor of the Estate of Bruce F. Harrison, Deceased; Edwin H. Knight, Jr., individually, as General Manager of HIL, and as Co

- Independent Execut or of the Estate of Bruce F. Harrison, Deceased; Fulshear Oil & Gas Partners, LP; and Fulshear Oil & Gas LLC.

Active 21042776 ACCEPTED 14-15-00348-CV FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS 10/20/2015 3:09:40 PM CHRISTOPHER PRINE

CLERKdays to file their appellees’ brief, through and until December 7, 2015. In support

of an extension, A ppellees show as follows:

1. Appellants filed their brief on October 5, 2015. Accordingly,

under Texas Rule of Appellate Procedure 38.6(b), Appellees’ brief is due

November 4, 2015.

2. This is Appellees’ first request for an extension of time to file

thei r brief. Appellants do not oppose the requested extension.

3. Appellees request an extension not for purposes of delay, but so
that their counsel may have adequate time to prepare their brief. In addition to this

brief, Appellees’ counsel, Macey Reasoner Stokes and Amy Pharr Hefley, have :
(i) a response brief on the merits due November 24 in the Texas Supreme Court in

Cause No. 15

- 0005, Oncor Electric Delivery Co. LLC v. Public Utility Commission

of Texas ; (ii) an appellee’s brief due November 25 in the Fifth Circuit in Case No.

15

- 30592, Yolande Burst et al. v. Shell Oil Co. et al. ; and (iii) a response to petition

for review due November 25 in the Texas Supreme Court in Cause No. 15

- 0502,
Noble Energy, Inc. v. ConocoPhillips Co.

For these reasons, Appel lees respectfully request an extension of
thirty (30) days, through and until December 7, to file their brief.

Active 21042776 2Respectfully submitted,

BAKER BOTTS L

. L

. P

. By: /s/Macey Reasoner Stokes Macey Reasoner Stokes State Bar No. 00788253 macey.stokes@bakerbot ts.com Amy Pharr Hefley State Bar No. 24046046 amy.hefley@bakerbotts.com One Shell Plaza 910 Louisiana Houston, Texas 77002 713.229.1234 713.229.1522 (facsimile)

HOGAN LOVELLS US LLP Maria Wyckoff B oyce State Bar No. 22095050 maria.boyce@hoganlovells.com 700 Louisiana Street Suite 4300 Houston, Texas 77002 713.632.1410 713.632.1401 (facsimile)

A TTORNEYS FOR A PPELLEES

Active 21042776 3C ERTIFICATE OF C ONFERENCE I hereby certify that on October 20, 2015, I confe rred with David Berg, counsel for Appellants, regarding this motion. Mr. Berg stated that Appellants do not oppose the 30

- day extension of time requested in this motion.

/s/Macey Reasoner Stokes Macey Reasoner Stokes

C ERTIFICATE OF S ERVICE I certify t hat on this 20th day of October, 2015, a true and correct copy of this motion was served electronically on the following counsel of record:
Counsel for Appellants: David Berg Berg & Androphy 3704 Travis Street Houston, Texas 77002 dberg@bafirm.com

/s/Amy P harr Hefley Amy Pharr Hefley

Active 21042776 4