PGAL, Inc. v. Ian Miramon and Caroline Miramon

ACCEPTED
15-25-00178-cv
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/2/2025 4:28 PM
NO. 15-25-00178-CV CHRISTOPHER A. PRINE
____________________________________________________________ CLERK
FILED IN
IN THE FIFTEENTH DISTRICT COURT OF APPEALS15th
OFCOURT
TEXAS OF APPEALS
AUSTIN, TEXAS
AT AUSTIN, TEXAS
12/2/2025 4:28:23 PM
______________________________________________________________
CHRISTOPHER A. PRINE
Clerk
PGAL, INC.,
Appellant,
v.

IAN MIRAMON AND CAROLINE MIRAMON,
Appellees.
____________________________________________________________

On Interlocutory Appeal From the District Court of
Travis County, Texas, Cause No. D-1-GN-001130;
The Honorable Laurie Eiserloh, Presiding Judge
____________________________________________________________

APPELLEES IAN MIRAMON AND CAROLINE MIRAMON’S
FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
BRIEF OF APPELLEES

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellees Ian Miramon and Caroline Miramon file this First Unopposed

Moton for Extension of Time to File Brief of Appelles as follows:

1. Appellant PGAL, Inc. (“PGAL”) filed its Brief of Appellant on

November 19, 2025, after extension of time. The Brief of Appellees is due to

be filed on or before Tuesday, December 9, 2025.
2. Appellees seek a first extension of time of 30 days to Thursday,

January 8, 2026, to file the Brief of Appellees. This 30 day extension of time

to file the Brief of Appellees is unopposed.

3. Appellate counsel for Appellees responsible for preparing and

filing the Brief of Appellees is Vincent L. Marable III. Mr. Marable was out of

his office from Tuesday, November 25, 2025, to Sunday, November 30,

2025, for the Thanksgiving Holiday.

4. Mr. Marable prepared and filed a reply in support of petition for

writ of mandamus on Monday, December 1, 2025, in No. 25-0811; In re

Thomas Petroleum Holdings, LLC, C.L. Thomas, Inc., C.L. Thomas Holdings

Investments, LLC and Clifton L. Thomas, Jr.; in the Supreme Court of Texas.

5. Mr. Marable has been assisting in preparing the motion for

rehearing in No. 14-23-00923-CV; San Jacinto River Authority v. Thomas E.

and Beth F. Ross, et al., in the Fourteenth Court of Appeals of Houston,

Texas, which motion for rehearing was due to be filed on Monday, December

1, 2025, and for which a second motion for extension of time to file motion

for rehearing has been filed.

6. Mr. Marable is responsible for filing the Brief of Appellees in No.

15-25-00173-CV; Encotech Consulting Engineers, Inc. v. Ian Miramon and

Caroline Miramon; in the Fifteenth Court of Appeals of Texas at Austin,

2
Texas, due to be filed on Tuesday, December 9, 2025, and as to which

Appellees will be seeking a 30 day extension of time.

7. Mr. Marable will be preparing two replies to responses to petition

for review in No. 25-0444; Anna Dorsey, et al. v. Environmental Resources

Management Southwest, Inc. and Pastor, Behling & Wheeler, LLC; In the

Supreme Court of Texas, due to be filed on Wednesday, December 10,

2025.

8. Mr. Marable is required to prepare responses to multiple pre-trial

motions to exclude in Cause No. 2023-77730; Yumila Reyes Acosta and

Olga Palencia v. ExxonMobil Pipeline Company LLC and Armando

Gonzalez; In the 164th District Court of Harris County, Texas set for

submission on Monday, December 16, 2025.

9. Mr. Marable is required to file a response to motion for new trial

in Cause No. 23DCCV0902; Walter Harris v. Ellen May and Allstate Fire and

Casualty Insurance Company; in the 136th District Court of Jefferson County,

Texas., which is scheduled for hearing on Wednesday, December 17, 2025.

10. Mr. Marable has a previously planned vacation with his family

from Wednesday, December 24, 2025, to Sunday, December 28, 2025.

11. For these reasons, Appellees Ian Miramon and Caroline

Miramon request that this Court grant the unopposed first motion for

3
extension of time to file Brief of Appellees to and including Thursday, January

8, 2026.

Respectfully submitted,

RAMSEY LAW GROUP
John C. Ramsey
State Bar No. 24027762
K. Grace Hooten
State Bar No. 24092980
Woodway Tower
6363 Woodway Drive, Suite 500
Houston, Texas 77057
Telephone: (713) 489-7577
Facsimile: (888) 858-1452
john@ramseylawpc.com
grace@ramseylawpc.com
eservice@ramseylawpc.com

RICK FREEMAN, P.C.
Rick Freeman
State Bar No. 07428800
3660 Stoneridge Road, B-102
Austin, Texas 78746
Telephone: (512) 477-6111
Facsimile: (512) 473-2131
rick@freemanlaw.com

PAUL WEBB, P.C.
/s/ Vincent L. Marable III
Vincent L. Marable III
State Bar No. 12961600
221 N. Houston Street
Wharton, Texas 77488
Telephone: (979) 532-5331
Facsimile: (979) 532-2902
tripp@paulwebbpc.com

4
ATTORNEYS FOR APPELLEES IAN
MIRAMON AND CAROLINE MIRAMON

5
CERTIFICATE OF CONFERENCE

Counsel for Appellees (Vincent L. Marable III) conferred with counsel
for Appellant on December 2, 2025, concerning this requested extension of
time. Appellant is unopposed to the requested extension of time.

/s/ Vincent L. Marable III
VINCENT L. MARABLE III

6
CERTIFICATE OF SERVICE

I hereby certify that on the 2nd day of December, 2025, a true and
correct copy of the above and foregoing was sent to all the attorneys of
record, in accordance with the Texas Rules of Appellate Procedure.

/s/ Vincent L. Marable III
VINCENT L. MARABLE III

7
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.

Vincent Marable III on behalf of Vincent Marable III
Bar No. 12961600
tripp@paulwebbpc.com
Envelope ID: 108632820
Filing Code Description: Motion
Filing Description: Appellees Ian and Caroline Miramon's First Unopposed
Motion for Extension of Time to File Brief of Appellees
Status as of 12/2/2025 4:37 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michelle Koledi 24072189 mconner@wslawpc.com 12/2/2025 4:28:23 PM SENT

Vincent Marable 12961600 tripp@paulwebbpc.com 12/2/2025 4:28:23 PM SENT

Nicholas Scott 24093965 nscott@wslawpc.com 12/2/2025 4:28:23 PM SENT

Rick Freeman 7428800 rick@rickfreemanlaw.com 12/2/2025 4:28:23 PM SENT

John Ramsey 24027762 john@ramseylawpc.com 12/2/2025 4:28:23 PM SENT

Michael Waddell 24042106 bwaddell@wslawpc.com 12/2/2025 4:28:23 PM SENT

John Nugent 24116840 eservice@ramseylawpc.com 12/2/2025 4:28:23 PM SENT

Jeniffer Mendez jmendez@thompsoncoe.com 12/2/2025 4:28:23 PM SENT

Judith Ramsey Jramsey@thompsoncoe.com 12/2/2025 4:28:23 PM SENT

Derek Bauman Dbauman@thompsoncoe.com 12/2/2025 4:28:23 PM SENT

Grace Hooten grace@ramseylawpc.com 12/2/2025 4:28:23 PM SENT