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 4/28/2025 9:37 AM No. 15-25-00027-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS IN THE COURT OF APPEALS FOR AUSTIN, TEXAS THE FIFTEENTH JUDICIAL DISTRICT 4/28/2025 9:37:12 AM AT AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

NICHOLAS KREINES, DAVID P. RYAN, LIBERTY MINERAL PARTNERS LLC, NAK RESOURCES INC., AND CGR OIL AND GAS, LLC, Appellants, v. ES3 MINERALS, LLC, Appellee.

On Appeal from the 459th Judicial District Court of Travis County, Texas

UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLEE’S BRIEF

Appellee ES3 Minerals, LLC respectfully files this Unopposed First Motion for Extension of Time to File Appellee’s Brief. The current deadline to file Appellee’s Brief is May 7, 2025. A thirty-day extension of time would create a new deadline of June 6, 2025.

UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME PAGE 1 TO FILE APPELLEE’S BRIEF This motion is not filed for purposes of delay, but rather so that justice may be done and a thorough and helpful brief prepared for the Court. In addition, counsel for Appellee have conflicts that necessitate additional time to prepare the brief. For example, Mr. Clinton and Ms. Schmelzer are also working on matters including: • PBEX II, LLC v. Dorchester Minerals, L.P., No. 23-0423 in the Supreme Court of Texas (Mr. Clinton only) (reply in support of motion for rehearing due May 7, 2025); • Transitus Capital, LLC v. Aspen Strategic Holdings, LLC, No. 24-0849 in the Supreme Court of Texas (reply in support of petition for review due May 22, 2025); • Carla Lindley v. Concho Valley Electric Cooperative, Inc., No. 03-25-00009-CV in the Court of Appeals for the Third District of Texas at Austin (Appellant’s Brief due May 5, 2025); • Marsana de Monserat v. Winter Sun Management, Inc., 05-24-01506-CV in the Court of Appeals for the Fifth District of Texas at Dallas (Appellant’s Brief due May 5, 2025); • Evans Resources, L.P. v. Petroplex Energy, Inc., No. 1- 24-00192-CV in the Court of Appeals for the Eleventh District of Texas at Eastland (oral argument set April 2, 2025); • Obra J. Moore, III v. 1789 Minerals Fund I, LP, 06-24- 00080-CV in the Court of Appeals for the Sixth District of Texas at Texarkana (Appellant’s Reply Brief due May 12, 2025); and • Great Western Drilling Ltd. v. Pioneer Natural Resources USA, Inc., No. CV59670 in the 142nd Judicial

UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME PAGE 2 TO FILE APPELLEE’S BRIEF District of Midland County (two-week trial setting begins May 3, 2025).

For these reasons, Appellee respectfully requests that the Court grant this Unopposed First Motion for Extension of Time to File Appellee’s Brief, creating a new deadline of June 6, 2025.

Respectfully submitted, /s/ Ryan Clinton Ryan Clinton State Bar No. 24027934 [email protected] Laine Weatherford Schmelzer State Bar No. 24131649 [email protected] DAVIS, GERALD & CREMER PC Congress Ave., Suite 1510 Austin, Texas 78701 (512) 493-9603 COUNSEL FOR ES3 MINERALS, LLC

UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME PAGE 3 TO FILE APPELLEE’S BRIEF CERTIFICATE OF CONFERENCE I conferred with counsel for Appellants, who indicated that Appellants do not oppose this motion.

/s/ Ryan Clinton Ryan Clinton

CERTIFICATE OF SERVICE On April 28, 2025, this motion was served by e-filing.

/s/ Ryan Clinton Ryan Clinton

UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME PAGE 4 TO FILE APPELLEE’S BRIEF 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.

Kaycie Martinez on behalf of Ryan Clinton Bar No. 24027934 [email protected] Envelope ID: 100144588 Filing Code Description: Other Document Filing Description: Notice of Appearance Status as of 4/28/2025 9:50 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status James F.Parker [email protected] 4/28/2025 9:37:12 AM SENT Gabrielle C.Smith [email protected] 4/28/2025 9:37:12 AM SENT Sydney P.Sadler [email protected] 4/28/2025 9:37:12 AM SENT Michael D.Marin [email protected] 4/28/2025 9:37:12 AM SENT Tori B.Bell [email protected] 4/28/2025 9:37:12 AM SENT Steven Garrett [email protected] 4/28/2025 9:37:12 AM SENT Kaycie Martinez [email protected] 4/28/2025 9:37:12 AM SENT

Associated Case Party: ES3 Minerals, LLC Name BarNumber Email TimestampSubmitted Status Ryan Clinton [email protected] 4/28/2025 9:37:12 AM SENT Laine Weatherford Schmelzer [email protected] 4/28/2025 9:37:12 AM SENT