NO. 14-13-00352-CV 

 

IN THE COURT OF APPEALS FOR THE 

FOURTEENTH DISTRICT OF TEXAS 

 

BP OIL PIPELINE COMPANY, 

 Appellant, 

v. 

 

PLAINS PIPELINE, L.P., 

 Appellee. 

 

ON APPEAL FROM THE 80TH JUDICIAL DISTRICT COURT 

HARRIS COUNTY, TEXAS 

 

APPELLANT’S UNOPPOSED MOTION FOR EXTENSION 

OF TIME TO FILE MOTION FOR REHEARING 

 

To the Honorable Court of Appeals: 

Plaintiff and Appellant BP Oil Pipeline Company (“BP”) files this motion 

for extension of time to file its motion for rehearing, pursuant to Texas Rules of 

Appellate Procedure 49.8 and 10.5(b). 

 BP requests this extension of time because its appellate counsel needs 

additional time to prepare its motion for rehearing. Specifically, BP needs 

additional time to review the substantial majority and dissenting opinions issued by 

the Court on June 30, 2015 and the numerous authorities cited therein that have not 

ACCEPTED

14-13-00352-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

7/15/2015 5:48:46 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 7/15/2015 5:48:46 PM CHRISTOPHER A. PRINE Clerk
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previously been reviewed by the parties or briefed in the original appellate 

briefing. In addition, BP’s counsel are currently involved in other litigation 

matters that have required and will continue to require their attention over the next 

several weeks. 

 This is BP’s first request for an extension of time to file its motion for 

rehearing. Any motions for rehearing are currently due to be filed with this Court 

on July 15, 2015. BP timely requests a thirty-one (31) day extension of this 

deadline under Texas Rule of Appellate Procedure 49.8, making its motion for 

rehearing due on August 17, 2015. 

 WHEREFORE, Appellant BP Oil Pipeline Company requests a thirty-one 

(31) day 

 
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extension of time to file its motion for rehearing, making the motion for rehearing 

due August 17, 2015. 

Respectfully submitted,

LISKOW & LEWIS

By: /s/ Alma F. Gomez

 Jana L. Grauberger 

Texas State Bar No. 24047502 

Michael P. Cash 

Texas State Bar No. 03965500 

Alma F. Gomez 

Texas State Bar No. 24069800 

James T. Kittrell 

Texas State Bar No. 24078795 

1001 Fannin Street, Suite 1800 

Houston, Texas 77002 

Telephone: (713) 651-2900 

Facsimile: (713) 651-2908 

Email: jlgrauberger@liskow.com 

Email: mcash@liskow.com 

Email: afgomez@liskow.com 

Email: jkittrell@liskow.com 

Joe B. Norman 

Louisiana State Bar No. 8160 

One Shell Square 

701 Poydras Street, Suite 5000 

New Orleans, Louisiana 70139 

Telephone: (504) 556-4052 

Facsimile: (504) 556-4108 

Email: jbnorman@liskow.com 

ATTORNEYS FOR APPELLANT 

BP OIL PIPELINE COMPANY 
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CERTIFICATE OF CONFERENCE

 Under Texas Rules of Appellate Procedure 10.1(a)(5), I certify that on July 

15, 2015, I conferred with Jane Robinson, counsel for Appellee Plains Pipeline, 

L.P., and she does not oppose the extension of time requested. 

 /s/ Alma F. Gomez 

Alma F. Gomez 

CERTIFICATE OF SERVICE

 I hereby certify that a copy of Appellant’s Motion for Extension of Time to 

File Motion for Rehearing is being served on all attorneys of record for Appellee 

on this 15th day of July, 2015, by the method indicated below. 

 /s/ Alma F. Gomez 

Alma F. Gomez 

John Zavitsanos 

Elizabeth Fletcher 

Jane Robinson 

Ahmad, Zavitsanos, Anaipakos, Alavi & 

Mensing, P.C. 

1221 McKinney St., Suite 3460 

Houston, Texas 77010 

Telephone: (713) 655-1101 

Facsimile: (713) 655-0062 

Thomas C. Wright 

Natasha N. Taylor

Wright & Close, LLP 

One Riverway, Suite 200 

Houston, Texas 77056 

Telephone: (713) 572-4321 

Facsimile: (713) 572-4320 

Attorneys for Appellee, Plains Pipeline, L.P.

Certified Mail – RRR 

No.: 

Private Delivery 

E-Mail 

Personal Delivery 

Certified Mail – RRR 

No.: 

Private Delivery 

E-Mail 

Personal Delivery 
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CERTIFICATE OF COMPLIANCE

I hereby certify that Appellant’s Motion for Extension of Time to File 

Motion for Rehearing was produced on a computer using Microsoft Word and 

contains 216 words, as determined by the word-count feature of the word 

processing software, excluding the sections of the documented listed in Tex. R. 

App. 9.4(i)(1). 

 /s/ Alma F. Gomez 

Alma F. Gomez