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CAUSE NO. 2016-45652
PEREGRINE OIL & GAS, LP § IN THE DISTRICT COURT OF
Plaintiff,
§ HARRIS COUNTY, TEXAS
HRB OIL & GAS, Ltd. and
VHPM, LLC
Defendants. § 190 JUDICIAL DISTRICT
AGREEDJOINT MOTION FOR NEW TRIAL DATE
To the Honorable Judge of the Court:
COMES NOW, Plaintiff PEREGRINE OIL & GAS, LP Plaintiff , and Defendants
HRB OIL & GAS, Ltd. and VHPM, LLC Defendants”) and file this Agreed Joint Motion for
New Trial Date and, in support thereof, would respectfully show the Court as follows:
On July 1, 2020, Defendants filed their Second Motion for Continuance. The Court
reset the trial of this matter on the next day to November 16, 2020 and then on December 10, 2020
this honorable Court set this case for trial for the two week period beginning on May 17, 2021.
copy of the July 2, 2020 Order and the December 10, 2020 Order are attached as Exhibits 1 and 2.
Lead counsel for Plaintiff, Michael D. Jones, is one of three arbitrators in an arbitration
styled as:
In Arbitration:Cause No. 2389 James K. Norwood, Maurice Meyer, III and John
R. Norris, III, Co Trustees of Texas Pacific Land Trust, Plaintiffs, Chevron U.S.A., Inc.,
Defendant In the 51 District Court, Sterling County, Texas (the Sterling County
Case”) And Cause No. P 10959 James K. Norwood, Maurice Meyer, III and John
R. Norris, III, Co Trustees of Texas Pacific Land Trust, Plaintiffs, Chevron U.S.A., Inc.,
Defendant In the 112th Judicial District Court, Pecos County, Texas (the Pecos
County Case”)
and scheduled for final hearing on the liability issues commencing on May 17, 2021 in Dallas,
Texas. The parties to the arbitration proposed May 17, 2021 date as a continuance of the original
hearing date of April 5, 2021 n December 2, 2020, the panel agreed to the May 17, 2021 date.
See December 2, 2020 email attached as Exhibit 3. The formal Order in Arbitration dated
December 9, 2020 is attached as Exhibit 4.
The undersigned had no conflicts regarding the May 17, 2021 hearing date in the
referenced arbitration on either December 2, 2020 or on December 9, 2020. The undersigned
learned of this Court’s scheduling Order on December 10, 2020.
The parties to the arbitration have estimated one week for the “in person” hearing
on the liability phase of the arbitration.
Movants respectfully ask that the Court reset Movants’ trial setting for this case for
the two week docket commencing on April 19
This Motion is filed not for purposes of delay but so that justice may be done.
WHEREFORE, PREMISES CONSIDERED, PEREGRINE OIL & GAS, LPand HRB
OIL & GAS, Ltd. and VHPM, LLC respectfully request that the Court grant a new trial setting in
this matter.
Respectfully submitted,
ONES ILL ORTER RAWFORD RAWFORD LLP
By s/s Michael D. Jones
Michael D. Jones
State Bar No. 10929350
Joseph D. Porter
State Bar No.
6363 Woodway, Suite 1100
Houston, Texas 77057
Telephone: (713)652 4068
Facsimile: (713)651 0716
Email: mjones@jonesgill.com
Emailjporter@jonesgill.com
ATTORNEYS FOR PLAINTIFF.
PEREGRINE OIL & GAS,
Dentons US LLP
By: s/s Barry F. Cannaday
Barry F. Cannaday
Email: barry.cannaday@dentons.com
State Bar No. 03743500
2000 McKinney Ave. Suite 1900
Dallas, Texas 75201
0900(telephone)
0910 (facsimile)
ATTORNEYS FOR DEFENDANTS
HRB OIL & GAS, LTD. and VHPM, LLC
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the foregoing Peregrine Oil & Gas, LP
and HRB Oil & Gas, Ltd., and VHPM, LLC Agreed Joint Motion for Continuance was, on
this day of January 202, served on all parties of record in accordance with the Texas Rules of
Civil Procedure.
s/s Michael D. Jones
Michael Jones
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CAUSE NO. 2016-45652 PEREGRINE OIL & GAS, LP § IN THE DISTRICT COURT OF Plaintiff, § HARRIS COUNTY, TEXAS HRB OIL & GAS, Ltd. and VHPM, LLC Defendants. § 190 JUDICIAL DISTRICT AGREEDJOINT MOTION FOR NEW TRIAL DATE To the Honorable Judge of the Court: COMES NOW, Plaintiff PEREGRINE OIL & GAS, LP Plaintiff , and Defendants HRB OIL & GAS, Ltd. and VHPM, LLC Defendants”) and file this Agreed Joint Motion for New Trial Date and, in support thereof, would respectfully show the Court as follows: On July 1, 2020, Defendants filed their Second Motion for Continuance. The Court reset the trial of this matter on the next day to November 16, 2020 and then on December 10, 2020 this honorable Court set this case for trial for the two week period beginning on May 17, 2021. copy of the July 2, 2020 Order and the December 10, 2020 Order are attached as Exhibits 1 and 2. Lead counsel for Plaintiff, Michael D. Jones, is one of three arbitrators in an arbitration styled as: In Arbitration:Cause No. 2389 James K. Norwood, Maurice Meyer, III and John R. Norris, III, Co Trustees of Texas Pacific Land Trust, Plaintiffs, Chevron U.S.A., Inc., Defendant In the 51 District Court, Sterling County, Texas (the Sterling County Case”) And Cause No. P 10959 James K. Norwood, Maurice Meyer, III and John R. Norris, III, Co Trustees of Texas Pacific Land Trust, Plaintiffs, Chevron U.S.A., Inc., Defendant In the 112th Judicial District Court, Pecos County, Texas (the Pecos County Case”) and scheduled for final hearing on the liability issues commencing on May 17, 2021 in Dallas, Texas. The parties to the arbitration proposed May 17, 2021 date as a continuance of the original hearing date of April 5, 2021 n December 2, 2020, the panel agreed to the May 17, 2021 date. See December 2, 2020 email attached as Exhibit 3. The formal Order in Arbitration dated December 9, 2020 is attached as Exhibit 4. The undersigned had no conflicts regarding the May 17, 2021 hearing date in the referenced arbitration on either December 2, 2020 or on December 9, 2020. The undersigned learned of this Court’s scheduling Order on December 10, 2020. The parties to the arbitration have estimated one week for the “in person” hearing on the liability phase of the arbitration. Movants respectfully ask that the Court reset Movants’ trial setting for this case for the two week docket commencing on April 19 This Motion is filed not for purposes of delay but so that justice may be done. WHEREFORE, PREMISES CONSIDERED, PEREGRINE OIL & GAS, LPand HRB OIL & GAS, Ltd. and VHPM, LLC respectfully request that the Court grant a new trial setting in this matter. Respectfully submitted, ONES ILL ORTER RAWFORD RAWFORD LLP By s/s Michael D. Jones Michael D. Jones State Bar No. 10929350 Joseph D. Porter State Bar No. 6363 Woodway, Suite 1100 Houston, Texas 77057 Telephone: (713)652 4068 Facsimile: (713)651 0716 Email: mjones@jonesgill.com Emailjporter@jonesgill.com ATTORNEYS FOR PLAINTIFF. PEREGRINE OIL & GAS, Dentons US LLP By: s/s Barry F. Cannaday Barry F. Cannaday Email: barry.cannaday@dentons.com State Bar No. 03743500 2000 McKinney Ave. Suite 1900 Dallas, Texas 75201 0900(telephone) 0910 (facsimile) ATTORNEYS FOR DEFENDANTS HRB OIL & GAS, LTD. and VHPM, LLC CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing Peregrine Oil & Gas, LP and HRB Oil & Gas, Ltd., and VHPM, LLC Agreed Joint Motion for Continuance was, on this day of January 202, served on all parties of record in accordance with the Texas Rules of Civil Procedure. s/s Michael D. Jones Michael Jones