ACCEPTED 06-16-00029-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 6/30/2016 9:26:17 AM DEBBIE AUTREY CLERK No. 06-16-00029-CV IN THE FILED IN COURT OF APPEALS FOR THE 6th COURT OF APPEALS SIXTH SUPREME JUDICIAL DISTRICT OF TEXASTEXARKANA, TEXAS AT TEXARKANA, TEXAS 6/30/2016 9:26:17 AM DEBBIE AUTREY Clerk GREAT NORTHERN ENERGY, INC. Appellant, vs. CIRCLE RIDGE PRODUCTION, INC. Appellee.

Appeal from the 71st District Court of Harrison County, Texas Honorable Brad Morin

AGREED SECOND MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

TO THE HONORABLE COURT OF APPEALS: COMES NOW, Circle Ridge Production, Inc., Appellee in the above-captioned proceeding (the “Appellee”), and respectfully asks the Court to extend the time to file its Appellee’s Brief.

A. INTRODUCTION 1. Appellant is Great Northern Energy, Inc.; Appellee is Circle Ridge Production, Inc. 2. Great Northern Energy, Inc., the Appellant, consents and agrees to the requested extension.

B. ARGUMENT & AUTHORITIES 3. Appellee’s Brief is due on July 1, 2016.

4. Appellee respectfully requests an additional Twenty (20) days to file Appellee’s Brief, extending the time until July 21, 2016.

5. This is Appellee’s second request for an extension of briefing deadline in this case.

6. Appellee respectfully presents the following facts to the Court as a reasonable explanation for the additional requested extension of time: Due to the complex nature of settlement negotiations in this matter, the parties to this interlocutory appeal have agreed that another twenty (20) day extension of time would be in the interest of the parties. The settlement requires the participation of parties not before the court, as well as complex title issues associated with the property. These issues necessitate additional time to conclude a settlement.

7. The requested enlargement of time, which is unopposed, is not sought for the sake of delay, but rather so that settlement resolutions may be further explored.

Therefore, Appellee prays that this Court grant this Motion for extension of time to extend the due date for appellee’s brief for twenty (20) days until July 21, 2016.

Respectfully submitted,

Michael T. Runyan State Bar No. 24033143 RUNYAN LAW FIRM, P.C.

305 West Rusk St. Marshall, TX 75670 Office: (903) 935-7700 Fax: (903) 935-7702 [email protected] RONAN S. SEARLE Texas Bar No. 24079292 SEARLE & SEARLE, PC P.O. Box 910 West Rusk Street Marshall, Texas 75671 Phone (903) 935-9772 Fax (903) 935-9790 [email protected]

ATTORNEYS FOR THE APPELLEE CIRCLE RIDGE PRODUCTION, INC.

By: /s/ Michael T. Runyan (w/p Ronan S. Searle) Michael T. Runyan Texas Bar No. 24033143

CERTIFICATE OF CONFERENCE I hereby certify that, on June 30, 2016, Michael T. Runyan conferred with William J.

Gardner, counsel for Appellant, who indicated that Appellant is unopposed and agrees to the extension requested herein.

/s/ Michael T. Runyan (w/p Ronan S. Searle) Michael T. Runyan

CERTIFICATE OF SERVICE I, the undersigned, hereby certify that, on June 30, 2016, I caused to be served the foregoing pleading upon the counsel listed below via email and also via the Court’s electronic transmission facilities.

William J. Gardner Attorney at Law B N. Green Street P.O. Box 1746 Longview, TX 75606-1746 Tel. No. 903-236-7900 Fax No. 903-236-3367 Email: [email protected]

/s/ Ronan S. Searle Ronan S. Searle