ACCEPTED 01-17-00881-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 3/23/2018 12:21 PM CHRISTOPHER PRINE CLERK No. 01-17-00881-CV FILED IN 1st COURT OF APPEALS In the First District Court of Appeals HOUSTON, TEXAS Houston, Texas 3/23/2018 12:21:50 PM CHRISTOPHER A. PRINE Clerk CERTAIN UNDERWRITERS AT LLOYD’S, LONDON SYNDICATE NUMBER 2020, 1084, 2001, 457, 510, 2791, 2987, 3000, 1221, 5000 AND NAVIGATORS INSURANCE COMPANY UK, Appellants, v. PRIME NATURAL RESOURCES, INC., Appellee.

On Appeal from the 129th Judicial District Court, Harris County, Texas Cause No. 2015-51137

UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF OF APPELLANTS

Appellants, Certain Underwriters at Lloyd’s, London Syndicate Number 2020, 1084, 2001, 457, 510, 2791, 2987, 3000, 1221, 5000 and Navigators Insurance Company UK, respectfully file this unopposed motion for extension of time to file their brief.

1. The present deadline for filing the brief is April 18, 2018.

2. Appellants seek an extension of 30 days, until May 18, 2018 in which to file their brief.

3. This is Appellants’ second request for an extension of time to file their brief.

4. This motion is unopposed.

5. Appellants request an extension because the Brief of Appellants will require additional time to prepare for a number of reasons: • This is a complex insurance coverage appeal for a judgment for more than $19 million.

• A review of the record is important for the issues in this case. and the record is far more voluminous than in most appeals. The clerk’s record is 14 volumes.

The reporter’s record is 33 volumes, and includes the transcript of a 5-week trial and more than 15,000 pages of exhibits.

• The number of counsel in this case requires extensive coordination.

• Counsel with primary responsibility for preparing the brief for Appellants, Robert Dubose, has had the following schedule conflicts that require extra time to prepare this brief: o Participation in a three-week trial that began March 20, 2018 in Routon v. EOG Resources, Inc., No. 2015-34043; In the 295th Judicial District Court, Harris County, Texas.

o An Appellant’s Reply Brief and Cross-Appellee’s Brief filed March 22, 2018 in Ex Parte City of El Paso; No. 03-17-00566-CV; In the Third Court of Appeals, Austin, Texas.

o A hearing on April 5 and 6 on entry of judgment regarding a $6 billion verdict in Hopper v. JPMorgan Chase Bank, N.A.; No. PR-11-3238-1; In the Probate Court No. 1, Dallas County, Texas.

o Oral argument on April 10, 2018 in TRO-X, L.P. v. Eagle Oil & Gas Co., No. 05-17-00062-CV; In the Fifth Court of Appeals, Dallas, Texas.

o Preparation for two continuing legal education speeches on March 27 and April 26, 2018.

6. This motion is not filed for the purpose of delay, but to allow counsel adequate time to prepare Appellants’ Brief in a way that will assist the Court in reaching a decision.

For these reasons, Appellants respectfully request that the deadline for filing their brief be extended until May 18, 2018.

Respectfully submitted, Robert B. Dubose J. Clifton Hall, III State Bar No. 00787396 State Bar No. 00793204 [email protected] [email protected] Roger D. Townsend William P. Maines State Bar No. 20167600 State Bar No. 12849700 [email protected] [email protected] ALEXANDER DUBOSE Reece Rondon JEFFERSON & TOWNSEND LLP State Bar No. 00794559 1844 Harvard Street [email protected] Houston, Texas 77008 Allyson L. Wilkinson Telephone: (713) 523-2358 State Bar No. 24010481 Facsimile: (713) 522-4553 [email protected] HALL MAINES LUGRIN, P.C. Charles T. Frazier, Jr. Williams Tower, Suite 6400 ALEXANDER DUBOSE 2800 Post Oak Boulevard JEFFERSON & TOWNSEND LLP Houston, Texas 77056-6125 State Bar No. 07403100 Telephone: (713) 871-9000 [email protected] Facsimile: (713) 871-8962 4925 Greenville Avenue, Suite 510 Dallas, Texas 75206 Telephone: (214) 369-2358 Facsimile: (214) 369-2359 ATTORNEYS FOR APPELLANTS CERTIFICATE OF CONFERENCE I have conferred with Robert M. Roach, Jr., one of the attorneys for Appellee, and he is unopposed to this motion for extension of time.

/s/Robert B. Dubose Robert B. Dubose

CERTIFICATE OF SERVICE On March 23, 2018, I electronically filed this Unopposed Second Motion for Extension of Time to File Brief of Appellants with the Clerk of Court using the eFile.TX.gov electronic filing system which will send notification of such filing to the following: Robert M. (Randy) Roach, Jr. John Zavitsanos [email protected] [email protected] Daniel W. Davis Foster C. Johnson [email protected] [email protected] Robert J. Cunningham AHMAD ZAVITSANOS ANAIPAKOS [email protected] ALAVI & MENSING, P.C ROACH & NEWTON LLP 1221 McKinney Street, Suite 3460 One Westchase Center Houston, Texas 77010 10777 Westheimer, Suite 212 Houston, Texas 77042 /s/Robert B. Dubose Robert B. Dubose