PGAL, Inc. v. Ian Miramon and Caroline Miramon

Opinion

ACCEPTED 15-25-00178-cv FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/2/2025 4:28 PM NO. 15-25-00178-CV CHRISTOPHER A. PRINE ____________________________________________________________ CLERK FILED IN IN THE FIFTEENTH DISTRICT COURT OF APPEALS15th OFCOURT TEXAS OF APPEALS AUSTIN, TEXAS AT AUSTIN, TEXAS 12/2/2025 4:28:23 PM ______________________________________________________________ CHRISTOPHER A. PRINE Clerk PGAL, INC., Appellant, v.

IAN MIRAMON AND CAROLINE MIRAMON, Appellees. ____________________________________________________________

On Interlocutory Appeal From the District Court of Travis County, Texas, Cause No. D-1-GN-001130; The Honorable Laurie Eiserloh, Presiding Judge ____________________________________________________________

APPELLEES IAN MIRAMON AND CAROLINE MIRAMON’S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLEES

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellees Ian Miramon and Caroline Miramon file this First Unopposed

Moton for Extension of Time to File Brief of Appelles as follows:

1. Appellant PGAL, Inc. (“PGAL”) filed its Brief of Appellant on

November 19, 2025, after extension of time. The Brief of Appellees is due to

be filed on or before Tuesday, December 9, 2025. 2. Appellees seek a first extension of time of 30 days to Thursday,

January 8, 2026, to file the Brief of Appellees. This 30 day extension of time

to file the Brief of Appellees is unopposed.

3. Appellate counsel for Appellees responsible for preparing and

filing the Brief of Appellees is Vincent L. Marable III. Mr. Marable was out of

his office from Tuesday, November 25, 2025, to Sunday, November 30,

2025, for the Thanksgiving Holiday.

4. Mr. Marable prepared and filed a reply in support of petition for

writ of mandamus on Monday, December 1, 2025, in No. 25-0811; In re

Thomas Petroleum Holdings, LLC, C.L. Thomas, Inc., C.L. Thomas Holdings

Investments, LLC and Clifton L. Thomas, Jr.; in the Supreme Court of Texas.

5. Mr. Marable has been assisting in preparing the motion for

rehearing in No. 14-23-00923-CV; San Jacinto River Authority v. Thomas E.

and Beth F. Ross, et al., in the Fourteenth Court of Appeals of Houston,

Texas, which motion for rehearing was due to be filed on Monday, December

1, 2025, and for which a second motion for extension of time to file motion

for rehearing has been filed.

6. Mr. Marable is responsible for filing the Brief of Appellees in No.

15-25-00173-CV; Encotech Consulting Engineers, Inc. v. Ian Miramon and

Caroline Miramon; in the Fifteenth Court of Appeals of Texas at Austin,

2 Texas, due to be filed on Tuesday, December 9, 2025, and as to which

Appellees will be seeking a 30 day extension of time.

7. Mr. Marable will be preparing two replies to responses to petition

for review in No. 25-0444; Anna Dorsey, et al. v. Environmental Resources

Management Southwest, Inc. and Pastor, Behling & Wheeler, LLC; In the

Supreme Court of Texas, due to be filed on Wednesday, December 10,

2025.

8. Mr. Marable is required to prepare responses to multiple pre-trial

motions to exclude in Cause No. 2023-77730; Yumila Reyes Acosta and

Olga Palencia v. ExxonMobil Pipeline Company LLC and Armando

Gonzalez; In the 164th District Court of Harris County, Texas set for

submission on Monday, December 16, 2025.

9. Mr. Marable is required to file a response to motion for new trial

in Cause No. 23DCCV0902; Walter Harris v. Ellen May and Allstate Fire and

Casualty Insurance Company; in the 136th District Court of Jefferson County,

Texas., which is scheduled for hearing on Wednesday, December 17, 2025.

10. Mr. Marable has a previously planned vacation with his family

from Wednesday, December 24, 2025, to Sunday, December 28, 2025.

11. For these reasons, Appellees Ian Miramon and Caroline

Miramon request that this Court grant the unopposed first motion for

3 extension of time to file Brief of Appellees to and including Thursday, January

8, 2026.

Respectfully submitted,

RAMSEY LAW GROUP John C. Ramsey State Bar No. 24027762 K. Grace Hooten State Bar No. 24092980 Woodway Tower 6363 Woodway Drive, Suite 500 Houston, Texas 77057 Telephone: (713) 489-7577 Facsimile: (888) 858-1452 john@ramseylawpc.com grace@ramseylawpc.com eservice@ramseylawpc.com

RICK FREEMAN, P.C. Rick Freeman State Bar No. 07428800 3660 Stoneridge Road, B-102 Austin, Texas 78746 Telephone: (512) 477-6111 Facsimile: (512) 473-2131 rick@freemanlaw.com

PAUL WEBB, P.C. /s/ Vincent L. Marable III Vincent L. Marable III State Bar No. 12961600 221 N. Houston Street Wharton, Texas 77488 Telephone: (979) 532-5331 Facsimile: (979) 532-2902 tripp@paulwebbpc.com

4 ATTORNEYS FOR APPELLEES IAN MIRAMON AND CAROLINE MIRAMON

5 CERTIFICATE OF CONFERENCE

Counsel for Appellees (Vincent L. Marable III) conferred with counsel for Appellant on December 2, 2025, concerning this requested extension of time. Appellant is unopposed to the requested extension of time.

/s/ Vincent L. Marable III VINCENT L. MARABLE III

6 CERTIFICATE OF SERVICE

I hereby certify that on the 2nd day of December, 2025, a true and correct copy of the above and foregoing was sent to all the attorneys of record, in accordance with the Texas Rules of Appellate Procedure.

/s/ Vincent L. Marable III VINCENT L. MARABLE III

7 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.

Vincent Marable III on behalf of Vincent Marable III Bar No. 12961600 tripp@paulwebbpc.com Envelope ID: 108632820 Filing Code Description: Motion Filing Description: Appellees Ian and Caroline Miramon's First Unopposed Motion for Extension of Time to File Brief of Appellees Status as of 12/2/2025 4:37 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michelle Koledi 24072189 mconner@wslawpc.com 12/2/2025 4:28:23 PM SENT

Vincent Marable 12961600 tripp@paulwebbpc.com 12/2/2025 4:28:23 PM SENT

Nicholas Scott 24093965 nscott@wslawpc.com 12/2/2025 4:28:23 PM SENT

Rick Freeman 7428800 rick@rickfreemanlaw.com 12/2/2025 4:28:23 PM SENT

John Ramsey 24027762 john@ramseylawpc.com 12/2/2025 4:28:23 PM SENT

Michael Waddell 24042106 bwaddell@wslawpc.com 12/2/2025 4:28:23 PM SENT

John Nugent 24116840 eservice@ramseylawpc.com 12/2/2025 4:28:23 PM SENT

Jeniffer Mendez jmendez@thompsoncoe.com 12/2/2025 4:28:23 PM SENT

Judith Ramsey Jramsey@thompsoncoe.com 12/2/2025 4:28:23 PM SENT

Derek Bauman Dbauman@thompsoncoe.com 12/2/2025 4:28:23 PM SENT

Grace Hooten grace@ramseylawpc.com 12/2/2025 4:28:23 PM SENT