Stampede Tx Energy, LLC F/K/A Stampede Energy, LLC and Ballengee Interest, LLC v. Bridgetex Pipeline Company, LLC ( 2018 )

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