RSM Production Corp. and Jack Grynberg v. Global Petroleum Group, Ltd., Tricon Geophysics, Inc., Seabird Exlporation, America, Inc., and Blackwater Subsea, LLC

Opinion

ACCEPTED 01-15-00866-cv FIRST COURT OF APPEALS HOUSTON, TEXAS 11/25/2015 12:15:53 PM CHRISTOPHER PRINE CLERK

No. 01-15-00866-CV _________________________________________________________________ FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS I C N THE OURT OF PPEALS A 11/25/2015 12:15:53 PM FOR THE IRST ISTRICT OF EXAS CHRISTOPHER F D T Clerk A. PRINE

_________________________________________________________________

RSM PRODUCTION CORP. AND JACK GRYNBERG, Appellants

v.

GLOBAL PETROLEUM GROUP, LTD. Appellee ____________________________________________________________________

On Appeal from the 189th Judicial District Court Harris County, Texas Trial Court Cause No. 2013-74337 Honorable Bill Burke, Judge Presiding ____________________________________________________________________

MOTION FOR 30-DAY EXTENSION OF TIME TO FILE BRIEF AS APPELLANTS ____________________________________________________________________

TO THE HONORABLE FIRST COURT OF APPEALS:

Appellants, RSM Production and Jack Grynberg, respectfully request a 30-

day extension of the deadline to file their brief as appellants under Texas Rules of

Appellate Procedure 10.5(b) and 38.6(d), and would respectfully show this Court

as follows: 1. This is Appellants’ first motion for extension of time to file their brief.

2. The filing deadline for Appellants’ brief is presently December 10, 2015.

3. Appellants request a 30-day extension of the deadline to file their opening brief, which would make the brief due January 11, 2016.

4. Appellants’ counsel needs additional time to file the brief because of the intervening Thanksgiving holiday, as well as pending deadlines in other litigation.

WHEREFORE, Appellants RSM Production and Jack Grynberg respectfully

request that the Court grant this motion and extend the deadline for their opening

brief to Monday, January 11, 2016.

Respectfully submitted,

/s/ Andrew C. Nelson Howard L. Close State Bar No. 04406500 Randall C. Owens State Bar No. 15380700 Bradley W. Snead State Bar No. 24049835 Andrew C. Nelson State Bar No. 24074801 WRIGHT & CLOSE, LLP One Riverway, Suite 2200 Houston, Texas 77056 Telephone: (713) 572-4321 Facsimile: (713) 572-4320 close@wrightclose.com owens@wrightclose.com snead@wrightclose.com nelson@wrightclose.com

Attorneys for Appellants, RSM Production Corp. and Jack Grynberg

2 CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I conferred with counsel for Appellee via email on Monday, November 23rd at 5:14 pm, asking whether counsel opposed this motion. I received an email response on Tuesday morning, stating: “We are consulting with our client and will get back to you once we hear from him.” As of the time of this filing, Wednesday, November 25th, I have not received any further response.

/s/ Bradley W. Snead Bradley W. Snead

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of this document was served on the following attorneys by electronic service on this 25th day of November 2015:

Brian F. Antweil Emily L. Rochy KATTEN MUCHIN ROSENMAN UK, LLP 1301 McKinney Street, Suite 3000 Houston, TX 77010-3033 brian.antweil@kattenlaw.com emily.rochy@kattenlaw.com

Attorneys for Appellee, Global Petroleum Group, Ltd.

/s/ Andrew C. Nelson Andrew C. Nelson