Nicholas Kreines, David P. Ryan, Liberty Mineral Partners LLC, Nak Resources INC., and CGR Oil and Gas, LLC v. ES3 Minerals, LLC

Opinion

ACCEPTED 15-25-00027-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/18/2025 3:43 PM NO. 15-25-00027-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN 15th COURT OF APPEALS FOR THE FIFTEENTH JUDICIAL DISTRICTAUSTIN, TEXAS AT AUSTIN, TEXAS 7/18/2025 3:43:08 PM CHRISTOPHER A. PRINE Clerk NICHOLAS KREINES, DAVID P. RYAN, LIBERTY MINERAL PARTNERS LLC, NAK RESOURCES INC, AND CGR OIL AND GAS, LLC, Appellants,

v.

ES3 MINERALS, LLC, Appellee.

APPELLANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF

Appellants Nicholas Kreines (“Kreines”), David P. Ryan (“Ryan”),

Liberty Mineral Partners LLC (“LMP”), NAK Resources Inc. (“NAK”), and

CGR Oil and Gas, LLC (“CGR,” and all together, the “Appellants”) file this

Motion for Extension of Time to File Appellant’s Reply Brief.

1. Appellants’ Reply Brief is currently due on or before July 28,

2025.

2. Appellants seek a 15-day extension of time to file their reply

brief, which would make the brief due on or before August 12, 2025.

3. This extension of time is necessary due to other conflicting

deadlines and scheduling challenges. Specifically, counsel for Appellants have a number of upcoming appellate deadlines and scheduled vacation

that impact the current briefing deadline for their reply brief.

4. Counsel for Appellants has another appellate brief also due

on July 28, 2025, to the Thirteenth Court of Appeals in Aransas County

v. NorthStar Recovery Services, Inc., No. 13-25-00159-CV.

5. The following week, counsel for Appellants have four

appellate briefs currently due on Monday, August 4, 2025. Counsel for

Appellants have two reply briefs due to the Thirteenth Court of Appeals

in Aranas County v. Western Steel Company and T2J Partners LLC, No.

13-25-00148-CV. The same day, counsel for Appellants have an initial

brief due in the appeal styled Aransas County, Texas v. T2J Partners,

LLC, No. 13-25-00323-CV in the Thirteenth Court of Appeals. Finally,

counsel for Appellants has a response brief due in Public Utility

Commission v. Denton, No. 15-25-00018-CV in the Fifteenth Court of

Appeals.

6. Lead counsel for Appellants is currently out of the country until

July 28, 2025, pursuant to his vacation letter filed on April 1, 2025.

Additionally, the undersigned counsel will be out of the office July 23–25

for a State Bar of Texas Conference.

2 7. This Motion is not filed for the purpose of delay, but to allow

counsel adequate time to prepare a reply brief that will protect the interests

of Appellants and be helpful to the Court.

8. Counsel for Appellants has conferred with counsel for Appellee

and Appellee does not oppose this motion to extend time.

For these reasons, Appellants request that this Court grant

Appellants’ Motion for Extension of Time to File Appellants’ Reply Brief,

so that the reply brief will be due on or before August 12, 2025.

Appellants also request any other relief to which they may be entitled.

3 Respectfully submitted,

LLOYD GOSSELINK ROCHELLE & TOWNSEND, P.C. 816 Congress Avenue, Suite 1900 Austin, Texas 78701 (512) 322-5800 Phone (512) 472-0532 Facsimile

By: /s/ Gabrielle C. Smith JAMES F. PARKER State Bar No. 24027591 jparker@lglawfirm.com GABRIELLE C. SMITH State Bar No. 24093172 gsmith@lglawfirm.com SYDNEY P. SADLER State Bar No. 24117905 ssadler@lglawfirm.com

ATTORNEYS FOR APPELLANTS

4 CERTIFICATE OF CONFERENCE

I hereby certify that I conferred with counsel for Appellee, Ryan Clinton, on July 18, 2025. Mr. Clinton informed me that Appellee does not oppose an extension of time for Appellants to file their reply brief.

/s/ Gabrielle C. Smith GABRIELLE C. SMITH

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document has been forwarded to the following attorneys of record via the Court’s electronic filing case management system and electronic mail on this 18th day of July, 2025.

Ryan Clinton rdclinton@dgclaw.com Laine Weatherford Schmelzer lwschmelzer@dgclaw.com DAVIS GERALD & CREMER, PC 515 Congress Ave, Suite 1510 Austin, Texas 78701

Michael D. Marin mmarin@boulettegolden.com Steven Garrett steven@boulettegolden.com Tori B. Bell tori@boulettegolden.com BOULETTE GOLDEN & MARIN L.L.P. 2700 Via Fortuna, Suite 250 Austin, TX 78746

ATTORNEYS FOR APPELLEE

/s/ Gabrielle C. Smith GABRIELLE C. SMITH

5 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Cathy Daniels on behalf of Gabrielle Smith Bar No. 24093172 cdaniels@lglawfirm.com Envelope ID: 103331091 Filing Code Description: Motion Filing Description: Appellants' Unopposed Motion for Extension of Time to File Reply Brief Status as of 7/18/2025 4:22 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Ryan Clinton rdclinton@dgclaw.com 7/18/2025 3:43:08 PM SENT

Laine Weatherford Schmelzer lwschmelzer@dgclaw.com 7/18/2025 3:43:08 PM SENT

Kaycie Martinez kcmartinez@dgclaw.com 7/18/2025 3:43:08 PM SENT

James F.Parker jparker@lglawfirm.com 7/18/2025 3:43:08 PM SENT

Gabrielle C.Smith gsmith@lglawfirm.com 7/18/2025 3:43:08 PM SENT

Sydney P.Sadler ssadler@lglawfirm.com 7/18/2025 3:43:08 PM SENT

Michael D.Marin mmarin@boulettegolden.com 7/18/2025 3:43:08 PM SENT

Tori B.Bell tori@boulettegolden.com 7/18/2025 3:43:08 PM SENT

Steven Garrett steven@boulettegolden.com 7/18/2025 3:43:08 PM SENT