Enbridge G & P (East Texas) L.P. v. Ben Samford and Wife Bette Ann Samford, Cecil Jackson and Wife Michelle Jackson and Sammy Monk

CourtCourt of Appeals of Texas
DecidedApril 7, 2015
Docket12-13-00307-CV
StatusPublished

This text of Enbridge G & P (East Texas) L.P. v. Ben Samford and Wife Bette Ann Samford, Cecil Jackson and Wife Michelle Jackson and Sammy Monk (Enbridge G & P (East Texas) L.P. v. Ben Samford and Wife Bette Ann Samford, Cecil Jackson and Wife Michelle Jackson and Sammy Monk) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Enbridge G & P (East Texas) L.P. v. Ben Samford and Wife Bette Ann Samford, Cecil Jackson and Wife Michelle Jackson and Sammy Monk, (Tex. Ct. App. 2015).

Opinion

ACCEPTED 12-13-00307-CV TWELFTH COURT OF APPEALS TYLER, TEXAS 4/7/2015 3:46:46 PM CATHY LUSK CLERK

No. 12-13-00307-CV

FILED IN 12th COURT OF APPEALS IN THE TWELFTH COURT OF APPEALS TYLER, TEXAS AT TYLER 4/7/2015 3:46:46 PM ________________________________________________________________________ CATHY S. LUSK Clerk

ENBRIDGE G & P (EAST TEXAS) L.P.

Appellant

v.

BEN SAMFORD AND WIFE, BETTE ANN SAMFORD, CECIL JACKSON AND WIFE, MICHELLE JACKSON, AND SAMMY JOE MONK

Appellees ________________________________________________________________________

Appeal from the 273rd Judicial District Court of Shelby County, Texas

APPELLANT’S UNOPPOSED MOTION TO RESCHEDULE ORAL ARGUMENT

Comes now Enbridge G & P (East Texas) L.P., (“Enbridge”), Appellant, herein

(“Appellant”), and respectfully asks the Court to reschedule the oral argument in this case

because Appellant’s counsel, Julie P. Wright, has become very ill today with a virus. This

virus has affected several members of the Flowers Davis team over the past week and a half

and takes several days to recover from.

Appellant’s Motion to Reschedule Oral Argument Page 1 1. Oral Argument in this case is currently scheduled for 8:30 a.m. on April 9,

2015.

2. Appellees do not oppose this request for extension.

3. This is the first request for postponement made by Appellant.

4. This request for rescheduling is sought not for purposes of delay, but to allow

Appellant’s counsel time to recover from her current illness.

Prayer

Therefore, Appellant respectfully requests that the Court issue an order rescheduling

the oral argument in the above case.

Respectfully submitted,

FLOWERS DAVIS, P.L.L.C.

1021 ESE South Loop 323 Suite 200 Tyler, Texas 75701 (903) 534-8063 (903) 534-1650 Facsimile

/s/ Morgan M. Elliott

JULIE P. WRIGHT State Bar No. 00794883 jpw@flowersdavis.com MORGAN M. ELLIOTT State Bar No. 24065196 mme@flowersdavis.com ATTORNEYS FOR APPELLANT

Appellant’s Motion to Reschedule Oral Argument Page 2 CERTIFICATE OF CONFERENCE

On April 7, 2015, the office for counsel for Appellant spoke with counsel for Appellees via telephone conference and counsel for Appellees agreed not to oppose Appellant’s Motion to Reschedule Oral Argument.

/s/ Morgan M. Elliott Morgan M. Elliott

CERTIFICATE OF SERVICE

I hereby certify that the below-listed counsel of record was served with the foregoing document via certified mail, return-receipt requested, on April 7, 2015.

Mr. Don Wheeler Law Office of Don Wheeler 101 Tenaha Street Center, Texas 75935 Counsel for Appellees

Mr. George H. Pigg Mettauer Shires & Adams, L.L.P. 403 Nacogdoches St., Suite 1 Center, Texas 75935 Counsel for Appellees

Mr. Darrin Walker Law Office of Darrin Walker 6134 Riverchase Glen Dr. Kingwood, Texas 77345 Counsel for Appellees

Appellant’s Motion to Reschedule Oral Argument Page 3

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Bluebook (online)
Enbridge G & P (East Texas) L.P. v. Ben Samford and Wife Bette Ann Samford, Cecil Jackson and Wife Michelle Jackson and Sammy Monk, Counsel Stack Legal Research, https://law.counselstack.com/opinion/enbridge-g-p-east-texas-lp-v-ben-samford-and-wife-bette-ann-samford-texapp-2015.