Stampede Tx Energy, LLC F/K/A Stampede Energy, LLC and Ballengee Interest, LLC v. Bridgetex Pipeline Company, LLC

Opinion

ACCEPTED

01-18-00113-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS 3/22/2018 5:45 PM

CHRISTOPHER PRINE

CLERK

NO. 01-18-00113-CV

FILED IN

IN THE COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS

FOR THE FIRST JUDICIAL DISTRICT OF TEXAS3/22/2018 5:45:48 PM AT HOUSTON, TEXAS CHRISTOPHER A. PRINE Clerk

STAMPEDE TX ENERGY, LLC, F/K/A STAMPEDE ENERGY, LLC, AND BALLENGEE INTERESTS, LLC Appellant,

V.

BRIDGETEX PIPELINE COMPANY, LLC,

Appellee,

ON APPEAL FROM THE 157TH DISTRICT COURT, HARRIS COUNTY, TEXAS Trial Court No. 2016-57036

AGREED MOTION TO

EXTEND TIME TO SELECT MEDIATOR

Bridgetex Pipeline Company, LLC, Stampede Tx Energy, LLC, and Ballengee Interests,

LLC (collectively, the “Parties”) file this Agreed Motion to Extend Time to Select Mediator.

The original deadline to select a mediator is March 22, 2018. The Parties ask for a one-week

extension, to March 29, 2018, to select a mediator for this matter.

The underlying Judgment in the case is almost $300 million dollars and great care has

been taken to select a qualified mediator that is acceptable to all parties. However, with multiple

parties and multiple representatives needed for each party, the logistics have been tougher than

originally expected. The Parties have agreed on using one of two mediators and working to AGREED MOTION TO EXTEND TIME TO SELECT MEDIATOR PAGE 1 ensure the schedules of everyone involved will allow it.

Therefore, the Parties respectfully request that their Agreed Motion to Extend Time to

Select Mediator is granted, and that the deadline be moved from March 22, 2018 to March 29,

2018.

Respectfully submitted,

Calhoun, Bhella & Sechrest, LLP

By: /s/ Robert McNiel Robert McNiel State Bar No. 24043814 rmcniel@cbsattorneys.com Paul Green State Bar No. 24081405 pgreen@cbsattorneys.com 325 N. Saint Paul Street, Suite 2300 Dallas, Texas 75201 Telephone: 214.981.9200 Facsimile: 214.981.9203 ATTORNEYS FOR DEFENDANTS

AGREED MOTION TO EXTEND TIME TO SELECT MEDIATOR PAGE 2

CERTIFICATE OF CONFERENCE

The undersigned counsel for Defendants hereby certifies that he and counsel for Plaintiffs have

personally conferred to discuss the items presented to the Court in this motion. Counsel for Plaintiffs is

AGREED to the Motion.

/s/ Paul Green Paul Green

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing instrument has been served

on all counsel of record via the electronic service manager and/or by email on this 22nd day of

March, 2018.

/s/ Robert A. McNiel Robert A. McNiel

AGREED:

/s/ Robert A. McNiel Robert A. McNiel Attorney for Appellant

/s/ David Bryant David Bryant Attorney for Appellee

AGREED MOTION TO EXTEND TIME TO SELECT MEDIATOR PAGE 3