On July 20, 2017 a
Letter,Correspondence
was filed
involving a dispute between
Ace Property & Casualty Insurance Company,
Total Petrochemicals & Refining Usa Inc,
and
Kinder Morgan Petcoke Gp Llc,
Kinder Morgan Petcoke Lp,
for Insurance
in the District Court of Harris County.
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CARNEGIE
ack.carnegie@clarkhillstrasburger.com
The Honorable Michael Gomez
Re: Cause No. 2017-48075;
Petcoke GP, LLC
Dear Judge Gomez,
I write because this case is set for trial in the 164
of November 4, 2019, a date that is rapidly approaching. At the same time, the parties have
motions for summary judgment pending that could eliminate the need for trial and the substantial
costs associated with preparing for trial.
On August 17, Your Honor granted summary judgment on liability for breach of contract
(Chubb), leaving only the issue of damages.
TOTAL and Chubb have filed a Motion for Final Summary Judgment addressing damages,
which was set for submission on September 2. Kinder Morgan also has pending a motion for
summary judgment on damages that was set for submission on September 16.
We know the Court is extremely busy, particular
handling not only its own docket but
possible for the Court to rule on the pending motions before the parties have to go into full trial
appreciated. If it would assist the Court in making a ruling,
onference in person or by
4055.1/A7284/A26161/100219
Jack Carnegie
Counsel for TOTAL Petrochemi
cc: Jim Bettis
Sarah Smith
sualty Insurance Company
4055.1/A7284/A26161/100219
Document Filed Date
October 02, 2019
Case Filing Date
July 20, 2017
Status
Case On Appeal - Civil
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CARNEGIE ack.carnegie@clarkhillstrasburger.com The Honorable Michael Gomez Re: Cause No. 2017-48075; Petcoke GP, LLC Dear Judge Gomez, I write because this case is set for trial in the 164 of November 4, 2019, a date that is rapidly approaching. At the same time, the parties have motions for summary judgment pending that could eliminate the need for trial and the substantial costs associated with preparing for trial. On August 17, Your Honor granted summary judgment on liability for breach of contract (Chubb), leaving only the issue of damages. TOTAL and Chubb have filed a Motion for Final Summary Judgment addressing damages, which was set for submission on September 2. Kinder Morgan also has pending a motion for summary judgment on damages that was set for submission on September 16. We know the Court is extremely busy, particular handling not only its own docket but possible for the Court to rule on the pending motions before the parties have to go into full trial appreciated. If it would assist the Court in making a ruling, onference in person or by 4055.1/A7284/A26161/100219 Jack Carnegie Counsel for TOTAL Petrochemi cc: Jim Bettis Sarah Smith sualty Insurance Company 4055.1/A7284/A26161/100219