NO. 01-09-00328-CV

In The 

FIRST COURT OF APPEALS

Houston, Texas

SAMSON LONE STAR, LIMITED PARTNERSHIP N/K/A SAMSON 

EXPLORATION, LLC

Appellant–Cross-Appellee, 

V. 

CHARLES G. HOOKS III, et al.

Appellees–Cross-Appellants.

Appeal from Cause B173008-B 

60th District Court

Jefferson County, Texas 

JOINT AGREED MOTION BY

APPELLEES/CROSS-APPELLANTS

AND APPELLANT/CROSS-APPELLEE

FOR EXTENSION OF TIME TO FILE RESPONSES

Appellees/Cross-Appellants (“the Hooks”) and Appellant/Cross-Appellee, 

Samson Lone Star L.L.C. n/k/a Samson Exploration, LLC (“Samson”) jointly 

move to request an extension of time in which to file their responses in the 

referenced appeal. Both Hooks and Samson request an extension of sixteen days 

to and including August 21, 2015 in which to file their responses to supplemental 

briefs. In support of this motion, the parties would show as follows:

1. Under the current briefing schedule, the parties’ responses to 

supplemental briefing requested by the Court are due August 5, 2015.

ACCEPTED

01-09-00328-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

7/21/2015 8:58:44 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/21/2015 8:58:44 AM CHRISTOPHER A. PRINE Clerk
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2. The primary attorneys responsible for preparing and filing the 

responses on behalf of each of the parties have commitments and conflicts in their 

schedules that necessitate this request for an extension of time. Those conflicts 

include:

a. Counsel for the Hooks has a long-scheduled vacation out of the 

country at the end of the July and has pre-trial deadlines and other 

work commitments that were already on the calendar before the 

supplemental briefing in this matter was scheduled.

b. Counsel for Samson is currently working on an Appellee’s brief in an 

antitrust and Lanham Act appeal involving significant damages and 

injunctive relief, which brief is currently due in the Fifth Circuit also 

in August. Moreover, different deadlines for Appellant and 

Cross-Appellants to file their response briefs would create 

complications and awkwardly mismatched corresponding deadlines 

between the parties. Having such mismatched deadlines would likely 

not expedite this appeal, so a matching extension for Appellant/CrossAppellee Samson should not cause delay.

3. This is the first extension of time for filing the response briefs that the 

parties have requested.
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4. The parties have conferred with one another regarding their mutual 

motions for extension of time and have both agreed to each other’s requested 

extension, as shown by their filing of this joint agreed motion.

WHEREFORE, PREMISES CONSIDERED, Appellees/Cross-Appellants, 

the Hooks, and Appellant/Cross-Appellee, Samson jointly request the Court for an 

extension of time to and including August 21, 2015 in which to file their 

respective responses in the referenced action.
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/s/ Marla Broaddus

Shannon H. Ratliff

State Bar No. 16573000

Marla Broaddus

State Bar No. 24001791

Ratliff Law Firm, PLLC

600 Congress Avenue, Suite 3100

Austin, Texas 78701

(512) 493-9600

(512) 493-9625 (Fax)

sratliff@ratlifflaw.com

mbroaddus@ratlifflaw.com

David M. Gunn

State Bar No. 08621600

Beck Redden, LLP

1221 McKinney, Suite 4500

Houston, Texas 77010-2010

(713) 951-3700

(713) 951-3720 (Fax)

dgunn@beckredden.com

Paul F. Simpson

State Bar No. 18403800

McGinnis Lochridge, LLP

711 Louisiana Street, Suite 1600

Houston, Texas 77002

(713) 615-8506

(713) 328-1806 (Fax)

psimpson@mcginnislaw.com

Patton G. Lochridge

State Bar No. 12458500

McGinnis Lochridge, LLP

600 Congress Avenue, Suite 2100

Austin, Texas 78701

(512) 495-6000

(512) 495-6093 (Fax)

plochridge@mcginnislaw.com

ATTORNEYS FOR APPELLEES/CROSSAPPELLANTS THE HOOKS PARTIES
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/s/ Cynthia K. Timms

Michael V. Powell

State Bar No. 16204400

Cynthia K. Timms

State Bar No. 11161450

LOCKE LORD, LLP

2200 Ross Avenue, Suite 2200

Dallas, Texas 75201

mpowell@lockelord.com

ctimms@lockelord.com

(214) 740-8000

(214) 740-8800 (Fax)

M.C. Carrington

State Bar No. 03880800

Mehaffy Weber

P.O. Box 16

Beaumont, Texas 77704

(409) 835-5011

(409) 835-5177 (Fax)

Dick Watt

State Bar No. 20977700

Watt Beckworth Thompson & Henneman, 

LLP

1800 Pennzoil Place, South Tower

711 Louisiana Street

Houston, Texas 77002

(713) 650-8100

(713) 650-8141 (Fax)

ATTORNEYS FOR APPELLANT/CROSSAPPELLEE SAMSON LONESTAR 

LIMITED PARTNERSHIP N/K/A/ 

SAMSON EXPLORATION, LLP
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CERTIFICATE OF SERVICE

I hereby certify that on July 21, 2015, a true and correct copy of the above 

and foregoing Motion for Extension of Time was forwarded to all counsel of 

record by ECF and email as follows:

Michael V. Powell

Cynthia K. Timms

LOCKE LORD, LLP

2200 Ross Avenue, Suite 2200

Dallas, Texas 75201

mpowell@lockelord.com

ctimms@lockelord.com

M.C. Carrington

Mehaffy Weber

P.O. Box 16

Beaumont, Texas 77704

mccarrington@mehaffyweber.com

Dick Watt

Watt Beckworth Thompson & 

Henneman, LLP

1800 Pennzoil Place, South Tower

711 Louisiana Street

Houston, Texas 77002

dwatt@wattbeckworth.com

Attorneys for Appellant/Cross-Appellee, Samson

/s/ Marla Broaddus

Marla Broaddus