Denbury Resources, Inc. and Denbury Onshore, LLC v. Gemini Insurance Company

Court of Appeals of Texas

Denbury Resources, Inc. and Denbury Onshore, LLC v. Gemini Insurance Company

Court of Appeals of Texas·Decided July 6, 2015·No. 14-15-00041-CV·Published

Opinion

ACCEPTED 14-15-00041-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/6/2015 9:56:49 AM CHRISTOPHER PRINE CARVER, DARDEN, CLERK KORETZKY, TESSIER, FINN, BLOSSMAN & AREAUX LLC SARAH E. STOGNER FILED IN ASSOCIATE 14th COURT OF APPEALS A HOUSTON, TEXAS (504) 585.3845 stogner@carverdarden.com 7/6/2015 9:56:49 AM CHRISTOPHER A. PRINE Clerk

July 6, 2015

Civil-Post Trial Division Harris County District Clerk Attn: Ms. Phyllis Washington, Post-Trial 201 Caroline Street, Suite 250 Houston, Texas 77002

Re: Gemini Insurance Company vs. Denbury Resources, Inc. Case No. 2012-10397, 270th Judicial District Appeal No. 14-15-00041-CV, 14th Circuit Court of Appeals Our File: 1782.18331

Dear Ms. Washington:

On April 23, 2015 we requested the Court supplement the record to include motions for summary judgment inadvertently omitted from the Clerk’s record to the 14th Circuit Court of Appeals in the above-captioned litigation. However, the exhibits attached to those motions are still missing from the record:

1. Exhibit “A” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463542); 2. Exhibit “B” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463543); 3. Exhibit “C” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463544); 4. Exhibit “D” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463545); and 5. This correspondence.

ENERGY CENTRE $ 1100 POYDRAS ST.$ SUITE 3100 $ NEW ORLEANS, LA 7016 3 TELEPHONE (504) 585-3800 $ FACSIMILE (504) 585-3801 Ms. Phyllis Washington July 6, 2015 CARVER, DARDEN, Page 2 KORETZKY, TESSIER, FINN, BLOSSMAN & AREAUX LLC

Please prepare, certify, and file in the appellate court a supplement containing these omitted items. The parties have completed their briefing, with Denbury’s Reply Brief being filed today. Please expedite this request to ensure the Appellate Court has a full and complete record for its determination. Should you have any questions or concerns, please do not hesitate to contact me directly. Thank you for your assistance in this matter.

Sincerely,

Sarah E. Stogner SES/daj

cc: 14th Circuit Court of Appeals

4845-0013-4437, v. 1

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ACCEPTED 14-15-00041-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/6/2015 9:56:49 AM CHRISTOPHER PRINE CARVER, DARDEN, CLERK KORETZKY, TESSIER, FINN, BLOSSMAN & AREAUX LLC SARAH E. STOGNER FILED IN ASSOCIATE 14th COURT OF APPEALS A HOUSTON, TEXAS (504) 585.3845 stogner@carverdarden.com 7/6/2015 9:56:49 AM CHRISTOPHER A. PRINE Clerk

July 6, 2015

Civil-Post Trial Division Harris County District Clerk Attn: Ms. Phyllis Washington, Post-Trial 201 Caroline Street, Suite 250 Houston, Texas 77002

Re: Gemini Insurance Company vs. Denbury Resources, Inc. Case No. 2012-10397, 270th Judicial District Appeal No. 14-15-00041-CV, 14th Circuit Court of Appeals Our File: 1782.18331

Dear Ms. Washington:

On April 23, 2015 we requested the Court supplement the record to include motions for summary judgment inadvertently omitted from the Clerk’s record to the 14th Circuit Court of Appeals in the above-captioned litigation. However, the exhibits attached to those motions are still missing from the record:

1. Exhibit “A” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463542); 2. Exhibit “B” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463543); 3. Exhibit “C” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463544); 4. Exhibit “D” to Denbury’s Consolidated Reply Memorandum in Support of Its “Plugged and Abandoned” and “Due Diligence” No Evidence Motions for Summary Judgment (image number 62463545); and 5. This correspondence.

ENERGY CENTRE $ 1100 POYDRAS ST.$ SUITE 3100 $ NEW ORLEANS, LA 7016 3 TELEPHONE (504) 585-3800 $ FACSIMILE (504) 585-3801 Ms. Phyllis Washington July 6, 2015 CARVER, DARDEN, Page 2 KORETZKY, TESSIER, FINN, BLOSSMAN & AREAUX LLC

Please prepare, certify, and file in the appellate court a supplement containing these omitted items. The parties have completed their briefing, with Denbury’s Reply Brief being filed today. Please expedite this request to ensure the Appellate Court has a full and complete record for its determination. Should you have any questions or concerns, please do not hesitate to contact me directly. Thank you for your assistance in this matter.

Sincerely,

Sarah E. Stogner SES/daj

cc: 14th Circuit Court of Appeals

4845-0013-4437, v. 1

Denbury Resources, Inc. and Denbury Onshore, LLC v. Gemini Insurance Company, (Tex. Ct. App. 2015).

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