BP Oil Pipeline Company v. Plains Pipeline, L.P.

Opinion

ACCEPTED

14-13-00352-CV

FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/15/2015 5:48:46 PM CHRISTOPHER PRINE

CLERK

NO. 14-13-00352-CV

FILED IN

14th COURT OF APPEALS

IN THE COURT OF APPEALS FOR THE HOUSTON, TEXAS FOURTEENTH DISTRICT OF TEXAS 7/15/2015 5:48:46 PM CHRISTOPHER A. PRINE

Clerk

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

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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 Certified Mail – RRR Elizabeth Fletcher Jane Robinson No.: Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing, P.C. Private Delivery 1221 McKinney St., Suite 3460 Houston, Texas 77010 E-Mail Telephone: (713) 655-1101 Facsimile: (713) 655-0062 Personal Delivery

Thomas C. Wright Certified Mail – RRR Natasha N. Taylor Wright & Close, LLP No.: One Riverway, Suite 200 Houston, Texas 77056 Private Delivery Telephone: (713) 572-4321 Facsimile: (713) 572-4320 E-Mail

Attorneys for Appellee, Plains Pipeline, L.P. 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