Nicholas Kreines, David P. Ryan, Liberty Mineral Partners LLC, Nak Resources INC., and CGR Oil and Gas, LLC v. ES3 Minerals, LLC

ACCEPTED 15-25-00027-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 4/7/2025 10:15 AM NO. 15-25-00027-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH JUDICIAL DISTRICT 15th COURT OF APPEALS AUSTIN, TEXAS AT AUSTIN, TEXAS 4/7/2025 10:15:28 AM CHRISTOPHER A. PRINE NICHOLAS KREINES, DAVID P. RYAN, LIBERTY MINERAL Clerk PARTNERS LLC, NAK RESOURCES INC, AND CGR OIL AND GAS, LLC, Appellants, v. ES3 MINERALS, LLC, Appellee.

APPELLANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF Appellants Nicholas Kreines (“Kreines”), David P. Ryan (“Ryan”), Liberty Mineral Partners LLC (“LMP”), NAK Resources Inc. (“NAK”), and CGR Oil and Gas, LLC (“CGR,” and all together, the “Appellants”) file this Motion for Extension of Time to File Appellant’s Brief.

1. Appellants’ Brief is currently due on or before April 8, 2025.

2. Appellants seek a 13-day extension of time to file the Appellants’ Brief, which would make the Brief due on or before April 21, 2025.

3. This extension of time is necessary because of recent developments in proceedings in the Business Court that may change the scope of the appeal or moot the appeal altogether. On February 27, 2025, the Business Court conducted a hearing on Appellants’ Motion to Dissolve the Temporary Injunction that is the subject of this appeal. At the same time, the Business Court heard Appellee’s alternative Motion to Modify the Temporary Injunction.

4. At the end of the day on Friday, April 4, the parties received an email from the Business Court’s staff stating that the court would rule on the motions concerning the Temporary Injunction by the end of the day on Monday, April 7. If the Business Court were to dissolve the Temporary Injunction, this appeal would be rendered moot.

5. To allow Appellants time to analyze the Business Court’s anticipated order and provide the Court with a brief that is not immediately superseded by events, Appellants respectfully ask the Court to extend the deadline to file its Brief to April 21, 2025.

6. This is the first extension of time Appellants have requested from this Court since the case was transferred from the Eighth Court of Appeals. This Motion is not filed for the purpose of delay, but to allow counsel adequate time to prepare a Brief that will protect the interests of Appellants and be helpful to the Court. Counsel anticipates that this will be the last extension sought to file Appellants’ Brief.

7. Counsel for Appellants have conferred with counsel for Appellee and Appellee does not oppose this motion to extend time.

For these reasons, Appellants request that this Court grant Appellants’ Motion for Extension of Time to File Appellants’ Brief, so that the Brief will be due on or before April 21, 2025. Appellants also request any other relief to which they may be entitled.

Respectfully submitted, LLOYD GOSSELINK ROCHELLE & TOWNSEND, P.C.

816 Congress Avenue, Suite 1900 Austin, Texas 78701 (512) 322-5800 Phone (512) 472-0532 Facsimile By: /s/ James F. Parker JAMES F. PARKER State Bar No. 24027591 [email protected] GABRIELLE C. SMITH State Bar No. 24093172 [email protected] SYDNEY P. SADLER State Bar No. 24117905 [email protected] ATTORNEYS FOR APPELLANTS

CERTIFICATE OF CONFERENCE I hereby certify that I spoke with counsel for Appellee, Michael Marin, on April 7, 2025. Mr. Marin informed me that Appellee does not oppose an extension of time for Appellants to file their Brief.

/s/ James F. Parker JAMES F. PARKER

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been forwarded to the following attorneys of record via the Court’s electronic filing case management system and electronic mail on this 7th day of April, 2025.

Michael D. Marin [email protected] Tori B. Bell [email protected] BOULETTE GOLDEN & MARIN L.L.P. 2700 Via Fortuna, Suite 250 Austin, TX 78746 ATTORNEYS FOR APPELLEE /s/ James F. Parker JAMES F. PARKER

Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Cathy Daniels on behalf of James Parker Bar No. 24027591 [email protected] Envelope ID: 99341729 Filing Code Description: Motion Filing Description: Appellants' Unopposed Motion for Extension of Time to File Brief Status as of 4/7/2025 10:19 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status James F.Parker [email protected] 4/7/2025 10:15:28 AM SENT Gabrielle C.Smith [email protected] 4/7/2025 10:15:28 AM SENT Sydney P.Sadler [email protected] 4/7/2025 10:15:28 AM SENT Michael D.Marin [email protected] 4/7/2025 10:15:28 AM SENT Tori B.Bell [email protected] 4/7/2025 10:15:28 AM SENT Steven Garrett [email protected] 4/7/2025 10:15:28 AM SENT