Preview
CAUSE NO. 2015-47031
QRE OPERATING, LLC § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
vs. § HARRIS COUNTY, TEXAS
§
ROGER D. PARSONS, IN HIS §
CAPACITY AS TRUSTEE OF THE §
LL&E ROYALTY TRUST §
§
Defendant. § 133RD JUDICIAL DISTRICT
DEFENDANT ROGER D. PARSONS’, IN HIS CAPACITY AS TRUSTEE OF THE
LL&E ROYALTY TRUST, FIRST SET OF REQUESTS FOR PRODUCTION TO
MAVERICK NATURAL RESOURCES, LLC
To: Maverick Natural Resources, LLC by and through its attorneys of record, Geoff A.
Gannaway, Allison Standish Miller, and Joel T. Towner of Beck Redden LLP, 1221
McKinney Street, Suite 4500, Houston, Texas 77010.
Pursuant to Rule 196 of the Texas Rules of Civil Procedure, Roger D. Parsons, solely in
his capacity as trustee of the LL&E Royalty Trust (“Defendant” or “LL&E Trust”),
Defendant/Counter-Plaintiff/Third-Party Plaintiff, in the above styled and numbered cause, serves
this First Set of Requests for Production upon Maverick Natural Resources, LLC. The responses
to these Requests shall be made separately and fully in writing. Maverick’s responses shall be
served upon the undersigned counsel for LL&E Trust within thirty (30) days after service of these
Requests as required by Rule 196.2 of the Texas Rules of Civil Procedure.
To the extent Maverick’s responses include documents previously produced by another
party, Maverick is asked to identify the prior production by production date and bates-range rather
than produce the documents again.
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 1
Respectfully submitted,
THE KIM LAW FIRM
John H. Kim
Texas State Bar No. 00784393
David A. McDougald
Texas State Bar No. 13570525
4309 Yoakum Blvd., Suite 2000
Houston, Texas 77006
Telephone: (713) 522-1177
Facsimile: (713) 809-6793
Email: jhk@thekimlawfirm.com
Email: david@thekimlawfirm.com
ATTORNEYS FOR DEFENDANT/COUNTER-
PLAINTIFF/THIRD-PARTY PLAINTIFF, ROGER D.
PARSONS, IN HIS CAPACITY AS TRUSTEE OF THE
LL&E ROYALTY TRUST
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 2
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing instrument was delivered to
all counsel of record in accordance with Texas Rules of Civil Procedure 21a on this 22nd day of
June 2021.
Geoff A. Gannaway
Joe W. Reddin, Jr.
Allison Standish Miller
Beck Redden LLP
1221 McKinney Street, Suite 4500
Houston, Texas 77010
ggannaway@beckredden.com
jredden@beckredden.com
amiller@beckredden.com
ATTORNEYS FOR PLAINTIFF
BREITBURN OPERATING, LP, QRE OPERATING, LLC AND THIRD-PARTY
DEFENDANTS BREITBURN MANAGEMENT, LLC, BREITBURN ENERGY PARTNERS,
LP, QR ENERGY, LP, AND MAVERICK NATURAL RESOURCES, LLC
W. Stephen Benesh
Bracewell LLP
111 Congress Avenue, Suite 2300
Austin, Texas 78701-4043
steve.benesh@bracewelllaw.com
ATTORNEYS FOR THIRD-PARTY DEFENDANT
THE BANK OF NEW YORK MELLON TRUST CO., N.A.
Andrew R. Harvin
Peter B. Wells
Doyle, Restrepo, Harvin & Robbins, L.L.P.
440 Louisiana, Suite 2300
Houston, Texas 77002
aharvin@drhrlaw.com
pwells@drhrlaw.com
ATTORNEYS FOR THIRD-PARTY DEFENDANT
STIFEL, NICOLAUS & CO.
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 3
Joseph G. Thompson III
Andrew Raber
Porter Hedges LLP
1000 Main Street, 36th Floor
Houston, Texas 77002
joe.thompson@porterhedges.com
araber@porterhedges.com
ATTORNEYS FOR THIRD-PARTY DEFENDANT
CONOCOPHILLIPS COMPANY
__________________
JOHN H. KIM
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 4
INSTRUCTIONS
1. Pursuant to TEX. R. CIV. P. 193.5, you are under an affirmative duty to supplement
your responses to all discovery requests with information that you may acquire after filing your
written response, if such information makes it known to you that your previous response was
incorrect or incomplete when made, or, if the answer though correct and complete when made, is
no longer true and complete and circumstances are such that a failure to amend would be in
substance misleading. You are hereby requested to agree to so supplement any of your written
responses to these discovery requests, and in the absence of any written objection to this request,
it will be presumed that you have agreed to do so.
2. In accordance with TEX. R. CIV. P 196.4, Defendant hereby requests that THE
RESPONSIVE DATA OR INFORMATION THAT EXISTS IN ELECTRONIC OR
MAGNETIC FORM BE PRODUCED IN NATIVE FORMAT WITH ALL METADATA
INTACT.
3. All duplicates or copies of documents or tangible things are to be provided to the
extent they have handwriting, additions, or deletions of any kind different from the original
document being produced.
4. If any document or tangible thing was, but no longer is, in your possession, custody,
or control, or was known to you but is no longer in existence or within your possession, custody,
or control, state whether it is: (a) missing or lost; (b) destroyed; (c) transferred (voluntarily or
involuntarily) to others; or (d) disposed of in some other manner. In each such instance, explain in
detail the circumstances surrounding the disposition of the document or tangible thing, who
authorized the action taken, who carried it out, and the date of the action taken. Additionally, please
identify each such document or tangible thing including: (a) the type or character of the document
or tangible thing (e.g., letter, memorandum, notes, etc.); (b) title; if any, of the document or tangible
thing; (c) the name and address of the author of the document or tangible thing; (d) the name and
address of the recipient of the document or tangible thing, if any; (e) the names and addresses of
all recipients of the copies of the document or tangible thing, if any; (f) all information contained
in each such document or tangible thing; (g) the date and circumstances under which each such
document or tangible thing ceased to exist or to be in your possession, custody, or control; (h) the
time period during which each such document or tangible thing was maintained; (i) the location of
each such document or tangible thing; and (j) the person or persons from whom each such
document or tangible thing may be obtained.
5. Pursuant to TEX. R. CIV. P. 215, if you fail to comply with proper discovery
requests, the Court may make such orders in regard to the failure as are just, including among
others, an order requiring you or your attorney, or both, to pay reasonable expenses, including
attorneys' fees, caused by the failure.
6. If you object to production or identification of any document or tangible thing or
portion of any document or tangible thing on the ground of a privilege or rule of law, please furnish
a list identifying each document or tangible thing for which the privilege is claimed, together with
the following information: (a) its title; (b) its subject matter; (c) its date; (d) its authors or
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 5
addressor(s); (e) the addressee(s) and recipients(s) of all copies; and (f) the specific reasons why
the document is subject to a claim of privilege.
7. Conoco shall produce all documents and materials described herein which are in its
possession, custody or control, and permit inspection, copying or reproduction thereof by
Defendant, its attorneys or other persons acting on behalf of Defendant at the offices of THE KIM
LAW FIRM, 4309 Yoakum Blvd., Suite 2000, Houston, Texas 77006, at such time as may be
mutually agreed upon by counsel for the parties.
8. The documents produced in response to these Requests shall be produced as they
are kept in the ordinary course of business or organized and labeled to correspond with the
categories in the request.
9. The singular shall include the plural, and the plural the singular, whenever the effect
of doing so is to increase the information responsive to these requests.
10. Each request below shall be deemed to request electronic documents and records.
DEFINITIONS
1. The term “BNYM” means, unless otherwise specified in a particular request, Bank
of New York Mellon, or any employee, agent, officer, director, member, subsidiary, predecessor(s)
in interest, or representative of Bank of New York Mellon, and/or its various attorneys, and each
person acting or authorized to act on behalf of Bank of New York Mellon.
2. The term “BNY Trust” means, unless otherwise specified in a particular request,
Bank of New York Mellon Trust Company, N.A., or any employee, agent, officer, director,
member, subsidiary, predecessor(s) in interest, or representative of Bank of New York Mellon
Trust Company, N.A., and/or its various attorneys, and each person acting or authorized to act on
behalf of Bank of New York Mellon Trust Company, N.A.
3. The term “you,” “your,” “yours,” and “Breitburn” means any one or more of the
following: Plaintiff/Counter-Defendant QRE Operating, LLC, Breitburn Management LLC,
Breitburn Energy Partners, LP, QR Energy LP, and Maverick Natural Resources, LLC, or any
employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative
of QRE Operating, LLC, Breitburn Management LLC, Breitburn Energy Partners, LP, QR Energy
LP, or Maverick Natural Resources, LLC.
4. The term “claim” or “claims” shall include any right(s) to payment or equitable
remedy, whether or not such right(s) is/are reduced to judgment, liquidated, unliquidated, fixed,
contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured or unsecured.
5. The terms “communicate,” “communication” or “communications” refer to
every manner or means of disclosure, transfer or exchange or information, whether orally or by
document, or whether face-to-face, by telephone, mail, personal delivery, text message, email or
otherwise.
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 6
6. The term “concerning” shall include referring to, alluding to, responding to,
concerning, in connection with, commencing on, in mentioning, reflecting, analyzing, constituted,
evidencing or pertaining to.
7. The term “Conoco” mean, unless otherwise specified in a particular request,
ConocoPhillips Company, or any employee, agent, officer, director, member, subsidiary,
predecessor(s) in interest, or representative of ConocoPhillips Company, and/or its various
attorneys, and each person acting or authorized to act on behalf of ConocoPhillips Company.
8. The terms “Defendant” or “LL&E Royalty Trust” means the LL&E Royalty
Trust, its trustees, including Roger D. Parsons, and its agents, servants, employees and attorneys.
9. The term “describe in detail” means to reasonably describe the requested item.
10. The terms “document” and/or “documents” shall have the meaning prescribed by
TEX. R. CIV. P. 192.3(b).
11. The term “identify” when referring:
(a) to a person, means to state his or her full name and present or last known
business or residential address.
(b) to a public or private corporation, partnership, association, or other
organization, or to a governmental agency, means to state its full name and
present or last known pertinent business address.
(c) to a statement or communication, means to identify who made it, who took
or recorded it, and all others, if any, present during the making thereof; to
identify when, where and how it was taken or recorded; and to identify who
has present or last known possession, custody or control thereof.
(d) to a document, means to give a reasonably detailed description thereof,
including, if applicable, when, where and how it was made; to identify who
made it; and to identify who has present or last known possession, custody
or control thereof.
(e) to any other tangible thing, means to give a reasonably detailed description
thereof, including, if applicable, when, where and how it was made; to
identify who made it and to identify who has present or last known
possession, custody or control thereof.
12. As used herein, the term “Lawsuit” refers to the present lawsuit.
13. [intentionally omitted].
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 7
14. The term “Monthly Reports” means Monthly Net Profits Interest royalty reports for
LL&E Royalty Trust.
15. The terms “or” and “and” are intended to mean and/or.
16. As used herein, the term “person” means any natural person, corporation,
partnership, association, joint venture, sole proprietorship, firm or business enterprise, and any
other artificial business or legal entity, as well as all divisions, sub-divisions, bureaus, offices or
other units hereof.
17. The terms “QR Energy” or “QRE” mean, unless otherwise specified in a particular
request, QR Energy, LP, or any employee, agent, officer, director, member, subsidiary,
predecessor(s) in interest, or representative of QR Energy, LP, and/or its various attorneys, and
each person acting or authorized to act on behalf of QR Energy, LP.
18. The term “Quantum Resources” means, unless otherwise specified in a particular
request, Quantum Resources Management, LLC, or any employee, agent, officer, director,
member, subsidiary, predecessor(s) in interest, or representative of Quantum Resources
Management, LLC, and/or its various attorneys, and each person acting or authorized to act on
behalf of Quantum Resources Management, LLC.
19. The term “Stifel” means, unless otherwise specified in a particular request, Stifel,
Nicolaus & Company, Inc., or any employee, agent, officer, director, member, subsidiary,
predecessor(s) in interest, or representative of Stifel, Nicolaus & Company, Inc., and/or its various
attorneys, and each person acting or authorized to act on behalf of Stifel, Nicolaus & Company,
Inc.
20. The term “Witness Statements” shall have the meaning prescribed by TEX. R. CIV.
P. 192.3(h).
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 8
FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC
REQUEST FOR PRODUCTION NO. 1: The complete well file for each Jay Field well currently
producing, including structured and unstructured data, related to, without limitation, drilling,
completion, geology, logs, engineering, production, regulatory materials, and partner information.
RESPONSE:
REQUEST FOR PRODUCTION NO. 2: The complete well file for each Jay Field well plugged and
abandoned since January 1, 2008, including structured and unstructured data, related to, without
limitation, drilling, completion, geology, logs, engineering, production, regulatory materials, and
partner information.
RESPONSE:
REQUEST FOR PRODUCTION NO. 3: Documents which identify by name all currently producing
Jay Field wells.
RESPONSE:
REQUEST FOR PRODUCTION NO. 4: For the Jay Field, all Field Development Plans, field
development planning, field development analysis, field development strategies, and emails,
documents, and other correspondence, including meeting notes and drafts of all such field
development plans, planning, analysis and strategies, from January 1, 2008 to the present.
RESPONSE:
REQUEST FOR PRODUCTION NO. 5: For the Jay Field, all internal reserve reports, production
curves, decline curves, production estimates and internal reserve estimates (proved reserves,
probable reserves, and possible reserves).
RESPONSE:
TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 9
Preview
CAUSE NO. 2015-47031 QRE OPERATING, LLC § IN THE DISTRICT COURT OF § Plaintiff, § § vs. § HARRIS COUNTY, TEXAS § ROGER D. PARSONS, IN HIS § CAPACITY AS TRUSTEE OF THE § LL&E ROYALTY TRUST § § Defendant. § 133RD JUDICIAL DISTRICT DEFENDANT ROGER D. PARSONS’, IN HIS CAPACITY AS TRUSTEE OF THE LL&E ROYALTY TRUST, FIRST SET OF REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC To: Maverick Natural Resources, LLC by and through its attorneys of record, Geoff A. Gannaway, Allison Standish Miller, and Joel T. Towner of Beck Redden LLP, 1221 McKinney Street, Suite 4500, Houston, Texas 77010. Pursuant to Rule 196 of the Texas Rules of Civil Procedure, Roger D. Parsons, solely in his capacity as trustee of the LL&E Royalty Trust (“Defendant” or “LL&E Trust”), Defendant/Counter-Plaintiff/Third-Party Plaintiff, in the above styled and numbered cause, serves this First Set of Requests for Production upon Maverick Natural Resources, LLC. The responses to these Requests shall be made separately and fully in writing. Maverick’s responses shall be served upon the undersigned counsel for LL&E Trust within thirty (30) days after service of these Requests as required by Rule 196.2 of the Texas Rules of Civil Procedure. To the extent Maverick’s responses include documents previously produced by another party, Maverick is asked to identify the prior production by production date and bates-range rather than produce the documents again. TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 1 Respectfully submitted, THE KIM LAW FIRM John H. Kim Texas State Bar No. 00784393 David A. McDougald Texas State Bar No. 13570525 4309 Yoakum Blvd., Suite 2000 Houston, Texas 77006 Telephone: (713) 522-1177 Facsimile: (713) 809-6793 Email: jhk@thekimlawfirm.com Email: david@thekimlawfirm.com ATTORNEYS FOR DEFENDANT/COUNTER- PLAINTIFF/THIRD-PARTY PLAINTIFF, ROGER D. PARSONS, IN HIS CAPACITY AS TRUSTEE OF THE LL&E ROYALTY TRUST TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument was delivered to all counsel of record in accordance with Texas Rules of Civil Procedure 21a on this 22nd day of June 2021. Geoff A. Gannaway Joe W. Reddin, Jr. Allison Standish Miller Beck Redden LLP 1221 McKinney Street, Suite 4500 Houston, Texas 77010 ggannaway@beckredden.com jredden@beckredden.com amiller@beckredden.com ATTORNEYS FOR PLAINTIFF BREITBURN OPERATING, LP, QRE OPERATING, LLC AND THIRD-PARTY DEFENDANTS BREITBURN MANAGEMENT, LLC, BREITBURN ENERGY PARTNERS, LP, QR ENERGY, LP, AND MAVERICK NATURAL RESOURCES, LLC W. Stephen Benesh Bracewell LLP 111 Congress Avenue, Suite 2300 Austin, Texas 78701-4043 steve.benesh@bracewelllaw.com ATTORNEYS FOR THIRD-PARTY DEFENDANT THE BANK OF NEW YORK MELLON TRUST CO., N.A. Andrew R. Harvin Peter B. Wells Doyle, Restrepo, Harvin & Robbins, L.L.P. 440 Louisiana, Suite 2300 Houston, Texas 77002 aharvin@drhrlaw.com pwells@drhrlaw.com ATTORNEYS FOR THIRD-PARTY DEFENDANT STIFEL, NICOLAUS & CO. TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 3 Joseph G. Thompson III Andrew Raber Porter Hedges LLP 1000 Main Street, 36th Floor Houston, Texas 77002 joe.thompson@porterhedges.com araber@porterhedges.com ATTORNEYS FOR THIRD-PARTY DEFENDANT CONOCOPHILLIPS COMPANY __________________ JOHN H. KIM TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 4 INSTRUCTIONS 1. Pursuant to TEX. R. CIV. P. 193.5, you are under an affirmative duty to supplement your responses to all discovery requests with information that you may acquire after filing your written response, if such information makes it known to you that your previous response was incorrect or incomplete when made, or, if the answer though correct and complete when made, is no longer true and complete and circumstances are such that a failure to amend would be in substance misleading. You are hereby requested to agree to so supplement any of your written responses to these discovery requests, and in the absence of any written objection to this request, it will be presumed that you have agreed to do so. 2. In accordance with TEX. R. CIV. P 196.4, Defendant hereby requests that THE RESPONSIVE DATA OR INFORMATION THAT EXISTS IN ELECTRONIC OR MAGNETIC FORM BE PRODUCED IN NATIVE FORMAT WITH ALL METADATA INTACT. 3. All duplicates or copies of documents or tangible things are to be provided to the extent they have handwriting, additions, or deletions of any kind different from the original document being produced. 4. If any document or tangible thing was, but no longer is, in your possession, custody, or control, or was known to you but is no longer in existence or within your possession, custody, or control, state whether it is: (a) missing or lost; (b) destroyed; (c) transferred (voluntarily or involuntarily) to others; or (d) disposed of in some other manner. In each such instance, explain in detail the circumstances surrounding the disposition of the document or tangible thing, who authorized the action taken, who carried it out, and the date of the action taken. Additionally, please identify each such document or tangible thing including: (a) the type or character of the document or tangible thing (e.g., letter, memorandum, notes, etc.); (b) title; if any, of the document or tangible thing; (c) the name and address of the author of the document or tangible thing; (d) the name and address of the recipient of the document or tangible thing, if any; (e) the names and addresses of all recipients of the copies of the document or tangible thing, if any; (f) all information contained in each such document or tangible thing; (g) the date and circumstances under which each such document or tangible thing ceased to exist or to be in your possession, custody, or control; (h) the time period during which each such document or tangible thing was maintained; (i) the location of each such document or tangible thing; and (j) the person or persons from whom each such document or tangible thing may be obtained. 5. Pursuant to TEX. R. CIV. P. 215, if you fail to comply with proper discovery requests, the Court may make such orders in regard to the failure as are just, including among others, an order requiring you or your attorney, or both, to pay reasonable expenses, including attorneys' fees, caused by the failure. 6. If you object to production or identification of any document or tangible thing or portion of any document or tangible thing on the ground of a privilege or rule of law, please furnish a list identifying each document or tangible thing for which the privilege is claimed, together with the following information: (a) its title; (b) its subject matter; (c) its date; (d) its authors or TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 5 addressor(s); (e) the addressee(s) and recipients(s) of all copies; and (f) the specific reasons why the document is subject to a claim of privilege. 7. Conoco shall produce all documents and materials described herein which are in its possession, custody or control, and permit inspection, copying or reproduction thereof by Defendant, its attorneys or other persons acting on behalf of Defendant at the offices of THE KIM LAW FIRM, 4309 Yoakum Blvd., Suite 2000, Houston, Texas 77006, at such time as may be mutually agreed upon by counsel for the parties. 8. The documents produced in response to these Requests shall be produced as they are kept in the ordinary course of business or organized and labeled to correspond with the categories in the request. 9. The singular shall include the plural, and the plural the singular, whenever the effect of doing so is to increase the information responsive to these requests. 10. Each request below shall be deemed to request electronic documents and records. DEFINITIONS 1. The term “BNYM” means, unless otherwise specified in a particular request, Bank of New York Mellon, or any employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative of Bank of New York Mellon, and/or its various attorneys, and each person acting or authorized to act on behalf of Bank of New York Mellon. 2. The term “BNY Trust” means, unless otherwise specified in a particular request, Bank of New York Mellon Trust Company, N.A., or any employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative of Bank of New York Mellon Trust Company, N.A., and/or its various attorneys, and each person acting or authorized to act on behalf of Bank of New York Mellon Trust Company, N.A. 3. The term “you,” “your,” “yours,” and “Breitburn” means any one or more of the following: Plaintiff/Counter-Defendant QRE Operating, LLC, Breitburn Management LLC, Breitburn Energy Partners, LP, QR Energy LP, and Maverick Natural Resources, LLC, or any employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative of QRE Operating, LLC, Breitburn Management LLC, Breitburn Energy Partners, LP, QR Energy LP, or Maverick Natural Resources, LLC. 4. The term “claim” or “claims” shall include any right(s) to payment or equitable remedy, whether or not such right(s) is/are reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured or unsecured. 5. The terms “communicate,” “communication” or “communications” refer to every manner or means of disclosure, transfer or exchange or information, whether orally or by document, or whether face-to-face, by telephone, mail, personal delivery, text message, email or otherwise. TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 6 6. The term “concerning” shall include referring to, alluding to, responding to, concerning, in connection with, commencing on, in mentioning, reflecting, analyzing, constituted, evidencing or pertaining to. 7. The term “Conoco” mean, unless otherwise specified in a particular request, ConocoPhillips Company, or any employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative of ConocoPhillips Company, and/or its various attorneys, and each person acting or authorized to act on behalf of ConocoPhillips Company. 8. The terms “Defendant” or “LL&E Royalty Trust” means the LL&E Royalty Trust, its trustees, including Roger D. Parsons, and its agents, servants, employees and attorneys. 9. The term “describe in detail” means to reasonably describe the requested item. 10. The terms “document” and/or “documents” shall have the meaning prescribed by TEX. R. CIV. P. 192.3(b). 11. The term “identify” when referring: (a) to a person, means to state his or her full name and present or last known business or residential address. (b) to a public or private corporation, partnership, association, or other organization, or to a governmental agency, means to state its full name and present or last known pertinent business address. (c) to a statement or communication, means to identify who made it, who took or recorded it, and all others, if any, present during the making thereof; to identify when, where and how it was taken or recorded; and to identify who has present or last known possession, custody or control thereof. (d) to a document, means to give a reasonably detailed description thereof, including, if applicable, when, where and how it was made; to identify who made it; and to identify who has present or last known possession, custody or control thereof. (e) to any other tangible thing, means to give a reasonably detailed description thereof, including, if applicable, when, where and how it was made; to identify who made it and to identify who has present or last known possession, custody or control thereof. 12. As used herein, the term “Lawsuit” refers to the present lawsuit. 13. [intentionally omitted]. TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 7 14. The term “Monthly Reports” means Monthly Net Profits Interest royalty reports for LL&E Royalty Trust. 15. The terms “or” and “and” are intended to mean and/or. 16. As used herein, the term “person” means any natural person, corporation, partnership, association, joint venture, sole proprietorship, firm or business enterprise, and any other artificial business or legal entity, as well as all divisions, sub-divisions, bureaus, offices or other units hereof. 17. The terms “QR Energy” or “QRE” mean, unless otherwise specified in a particular request, QR Energy, LP, or any employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative of QR Energy, LP, and/or its various attorneys, and each person acting or authorized to act on behalf of QR Energy, LP. 18. The term “Quantum Resources” means, unless otherwise specified in a particular request, Quantum Resources Management, LLC, or any employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative of Quantum Resources Management, LLC, and/or its various attorneys, and each person acting or authorized to act on behalf of Quantum Resources Management, LLC. 19. The term “Stifel” means, unless otherwise specified in a particular request, Stifel, Nicolaus & Company, Inc., or any employee, agent, officer, director, member, subsidiary, predecessor(s) in interest, or representative of Stifel, Nicolaus & Company, Inc., and/or its various attorneys, and each person acting or authorized to act on behalf of Stifel, Nicolaus & Company, Inc. 20. The term “Witness Statements” shall have the meaning prescribed by TEX. R. CIV. P. 192.3(h). TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 8 FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC REQUEST FOR PRODUCTION NO. 1: The complete well file for each Jay Field well currently producing, including structured and unstructured data, related to, without limitation, drilling, completion, geology, logs, engineering, production, regulatory materials, and partner information. RESPONSE: REQUEST FOR PRODUCTION NO. 2: The complete well file for each Jay Field well plugged and abandoned since January 1, 2008, including structured and unstructured data, related to, without limitation, drilling, completion, geology, logs, engineering, production, regulatory materials, and partner information. RESPONSE: REQUEST FOR PRODUCTION NO. 3: Documents which identify by name all currently producing Jay Field wells. RESPONSE: REQUEST FOR PRODUCTION NO. 4: For the Jay Field, all Field Development Plans, field development planning, field development analysis, field development strategies, and emails, documents, and other correspondence, including meeting notes and drafts of all such field development plans, planning, analysis and strategies, from January 1, 2008 to the present. RESPONSE: REQUEST FOR PRODUCTION NO. 5: For the Jay Field, all internal reserve reports, production curves, decline curves, production estimates and internal reserve estimates (proved reserves, probable reserves, and possible reserves). RESPONSE: TRUSTEE’S FIRST REQUESTS FOR PRODUCTION TO MAVERICK NATURAL RESOURCES, LLC 9