Filed: Apr. 15, 2015
Latest Update: Apr. 15, 2015
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE REPLIES MIRANDA M. DU , District Judge . Third-Party Defendants JONATHAN FELDMAN ("Feldman"), CARTER HENSON, JR. ("Henson"), and PATRIOT EXPLORATION COMPANY, LLC ("Patriot") (collectively, the "Patriot Defendants"), Plaintiff MILLENNIUM DRILLING CO., Inc. ("Millennium") and Third-Party Plaintiffs/Defendants MOLLY HAMRICK, BEVERLY HOUSE-MYERS, BEVERLY HOUSE-MYERS REVOCABLE TRUST, GRACE MAE PROPERTIES, LLC, HAMRICK TRUST, ROBERT H. H
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE REPLIES MIRANDA M. DU , District Judge . Third-Party Defendants JONATHAN FELDMAN ("Feldman"), CARTER HENSON, JR. ("Henson"), and PATRIOT EXPLORATION COMPANY, LLC ("Patriot") (collectively, the "Patriot Defendants"), Plaintiff MILLENNIUM DRILLING CO., Inc. ("Millennium") and Third-Party Plaintiffs/Defendants MOLLY HAMRICK, BEVERLY HOUSE-MYERS, BEVERLY HOUSE-MYERS REVOCABLE TRUST, GRACE MAE PROPERTIES, LLC, HAMRICK TRUST, ROBERT H. HA..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE REPLIES
MIRANDA M. DU, District Judge.
Third-Party Defendants JONATHAN FELDMAN ("Feldman"), CARTER HENSON, JR. ("Henson"), and PATRIOT EXPLORATION COMPANY, LLC ("Patriot") (collectively, the "Patriot Defendants"), Plaintiff MILLENNIUM DRILLING CO., Inc. ("Millennium") and Third-Party Plaintiffs/Defendants MOLLY HAMRICK, BEVERLY HOUSE-MYERS, BEVERLY HOUSE-MYERS REVOCABLE TRUST, GRACE MAE PROPERTIES, LLC, HAMRICK TRUST, ROBERT H. HAMRICK and R&M HAMRICK FAMILY TRUST (collectively, the "Third-Party Plaintiffs"), by and through their respective undersigned counsel, stipulate on the following and request an Order from this Court granting such stipulation:
1. On March 30, 2015, the Third-Party Plaintiffs filed their Points and Authorities in Response to Third-Party Defendants Jonathan Feldman and Patriot Exploration Company's Omnibus Motion Re: (1) Partial Summary Judgment — Statute of Limitations; (2) Summary Judgment for Res Judicata or Collateral Estoppel; and (3) Summary Judgment on Third-Party Plaintiffs' Claims for (1) Breach of Fiduciary Duty; (2) Breach of Contract; (3) Imposition of Constructive Trust; (4) Unjust Enrichment; and (5) Money Had and Received. (Dkt. No. 214).
2. Additionally, on March 30, 2015, the Third-Party Plaintiffs filed their Points and Authorities in Response to Third-Party Defendant Carter Henson's Motion to Dismiss for Lack of Personal Jurisdiction (Dkt. No. 215).
3. The Patriot Defendants' Replies for the above-referenced Motions are due on April 16, 2015.
4. This is the Patriot Defendants' first request for entry of an agreed stipulation extending the Reply deadlines for the above-referenced Motions.
5. Having discussed between counsel for the Third-Party Plaintiffs and the Patriot Defendants, all parties are in agreement to extend the Patriot Defendants' deadline to file their Replies to the above-referenced Motions to April 28, 2015.
6. IT IS HEREBY STIPULATED AND AGREED that the deadlines for the Patriot Defendants' Replies to the above-referenced Motions are extended from April 16, 2015 to April 28, 2015.
ORDER
IT IS SO ORDERED.
