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 

__________________________________________________________________ 

Pursuant 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. Harrison 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 Smith 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 Executor 

of the Estate of Bruce F. Harrison, Deceased; Fulshear Oil & Gas Partners, LP; and Fulshear Oil 

& Gas LLC.

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ACCEPTED

14-15-00348-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

10/20/2015 3:09:40 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 10/20/2015 3:09:40 PM CHRISTOPHER A. PRINE Clerk
days to file their appellees’ brief, through and until December 7, 2015. In support 

of an extension, Appellees 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 

their 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, Appellees respectfully request an extension of 

thirty (30) days, through and until December 7, to file their brief.

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Respectfully submitted,

BAKER BOTTS L.L.P.

By: /s/Macey Reasoner Stokes

Macey Reasoner Stokes

State Bar No. 00788253

macey.stokes@bakerbotts.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 Boyce

State Bar No. 22095050

maria.boyce@hoganlovells.com

700 Louisiana Street

Suite 4300

Houston, Texas 77002 

713.632.1410

713.632.1401 (facsimile)

ATTORNEYS FOR APPELLEES 

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CERTIFICATE OF CONFERENCE

I hereby certify that on October 20, 2015, I conferred 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

CERTIFICATE OF SERVICE

I certify that 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 Pharr Hefley

Amy Pharr Hefley

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