On August 12, 2015 a
Order
was filed
involving a dispute between
Parsons, Roger D (In His Capacity As Trustee Of The Ll & E Royalty Tr,
and
Bank Of New York Mellon,
Bank Of New York Mellon Trust Company N A,
Breitburn Energy Partners Lp,
Breitburn Management Company Llc,
Conocophillips Company,
Maverick Natural Resources, Llc As Trustee Of Ll&E Royalty Trust,
Qr Energy Lp,
Quantum Resources Management Llc,
Stifel Nicolaus & Company Inc,
Maverick Natural Resources Llc,
Parsons, Roger D (In His Capacity As Trustee Of The Ll & E Royalty Tr,
The Louisiana Land And Exploration Company Llc,
for HOMEOWNERS ASSOCIATION
in the District Court of Harris County.
Preview
2/8/2016 8:35:46 AM
Chris Daniel - District Clerk
Harris County
Envelope No: 8994987
By: RODRIGUEZ, JIMMY E
Filed: 2/8/2016 8:35:46 AM
NO. 2015-47031
QRE OPERATING, LLC, IN THE DISTRICT COURT OF
y
Plaintiff,
WwDATX
v. HARRIS COUNTY, TEXAS
ROGER D. PARSONS, IN HIS CAPACITY
AS TRUSTEE OF THE LL&E ROYALTY +
TRUST,
Defendant. 133RD JUDICIAL DISTRICT
ORDER GRANTING
PLAINTIFF’S MOTION TO PERMIT WITHDRAWAL OF ATTORNEY
On this day, came on to be considered Plaintiff QRE Operating, LLC’s Motion to Permit
Withdrawal of Attorney, and after considering same, and the applicable law, said motion is
hereby GRANTED. It is therefore
ORDERED that Thomas J. Heiden and the law firm of Latham & Watkins LLP are
hereby withdrawn as attorney of record for Plaintiff QRE Operating, LLC.
Signed this [0 day of , 2016.
DGE JACLANEL Nee
RECORDER'S MERORANDUKT
1S instrument is of poor quali
at the ime of magn2/8/2016 8:35:46 AM
‘Chris Daniel - District Clerk Harris County
Envelope No. 8994987
By: JIMMY RODRIGUEZ
Filed: 2/8/2016 8:35:46 AM
NO, 2015-47031
QRE OPERATING, LLC, § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
§
v. § HARRIS COUNTY, TEXAS
§
ROGER D. PARSONS, IN HISCAPACITY §
AS TRUSTEE OF THE LL&E ROYALTY = §
TRUST, §
§
Defendant. go 133RD JUDICIAL DISTRICT
PLAINTIFF’S MOTION TO PERMIT WITHDRAWAL OF ATTORNEY
Plaintiff QRE Operating, LLC files this Motion to Permit Withdrawal of Attomey,
pursuant to Texas Rule of Civil Procedure 10. Plaintiff moves to permit attorney Thomas J.
Heiden and the law firm of Latham & Watkins LLP to withdraw from representation of Plaintiff
in this matter. As explained in a Notice of Appearance of Counsel filed contemporancously
herewith, Geoff A. Gannaway, Joe W. Redden, and Joel Towner of the law firm of Beck Redden
LLP will represent Plaintiff going forward. Plaintiff approves the withdrawal and substitution,
which are not sought for delay only.Respectfully submitted,
BECK REDDEN LLP
By: /s/ Geoff A. Gannaway
Geoff A. Gannaway
State Bar No. 24036617
Joe W. Redden, Jr.
State Bar No. 16660600
Joel Towner
State Bar No. 24083978
1221 McKinney Street, Suite 4500
Houston, Texas 77010
Tel: 713-951-3700
Fax: 713-951-3720
Email: ggannaway@beckredden.com
Email: jredden@beckredden.com
Email: jtowner@beckredden.com
ATTORNEYS FOR PLAINTIFF
QRE OPERATING, LLC
CERTIFICATE OF CONFERENCE
T have conferred with opposing counsel, who was-unable to agree to the relief sought
herein.
By: /s/ Geoff A. Gannaway
Geoff A. GannawayCERTIFICATE OF SERVICE
T hereby certify that I caused a true and correct copy of the foregoing instrument to be
served on counsel of record in accordance with Rules 21 and 21a of the Texas Rules of Civil
Procedure on this 8th day of February, 2016, by facsimile and email:
David A. Stephan, Esq.
SIMON PLC
10000 North Central Expressway, Suite 400
Dallas, Texas 75231
Facsimile: 214-890-9249
Craig T. Mierzwa, Esq.
Marjan Neceski, Esq.
Simon PLC
37000 Woodward Avenue, Suite 250
Bloomfield Hills, Michigan 48304
Facsimile: 248-720-0291
By: /s/ Geoff A. Gannawi
Geoff A. Gannaway
Document Filed Date
February 10, 2016
Case Filing Date
August 12, 2015
Category
HOMEOWNERS ASSOCIATION
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
2/8/2016 8:35:46 AM Chris Daniel - District Clerk Harris County Envelope No: 8994987 By: RODRIGUEZ, JIMMY E Filed: 2/8/2016 8:35:46 AM NO. 2015-47031 QRE OPERATING, LLC, IN THE DISTRICT COURT OF y Plaintiff, WwDATX v. HARRIS COUNTY, TEXAS ROGER D. PARSONS, IN HIS CAPACITY AS TRUSTEE OF THE LL&E ROYALTY + TRUST, Defendant. 133RD JUDICIAL DISTRICT ORDER GRANTING PLAINTIFF’S MOTION TO PERMIT WITHDRAWAL OF ATTORNEY On this day, came on to be considered Plaintiff QRE Operating, LLC’s Motion to Permit Withdrawal of Attorney, and after considering same, and the applicable law, said motion is hereby GRANTED. It is therefore ORDERED that Thomas J. Heiden and the law firm of Latham & Watkins LLP are hereby withdrawn as attorney of record for Plaintiff QRE Operating, LLC. Signed this [0 day of , 2016. DGE JACLANEL Nee RECORDER'S MERORANDUKT 1S instrument is of poor quali at the ime of magn2/8/2016 8:35:46 AM ‘Chris Daniel - District Clerk Harris County Envelope No. 8994987 By: JIMMY RODRIGUEZ Filed: 2/8/2016 8:35:46 AM NO, 2015-47031 QRE OPERATING, LLC, § IN THE DISTRICT COURT OF § Plaintiff, § § § v. § HARRIS COUNTY, TEXAS § ROGER D. PARSONS, IN HISCAPACITY § AS TRUSTEE OF THE LL&E ROYALTY = § TRUST, § § Defendant. go 133RD JUDICIAL DISTRICT PLAINTIFF’S MOTION TO PERMIT WITHDRAWAL OF ATTORNEY Plaintiff QRE Operating, LLC files this Motion to Permit Withdrawal of Attomey, pursuant to Texas Rule of Civil Procedure 10. Plaintiff moves to permit attorney Thomas J. Heiden and the law firm of Latham & Watkins LLP to withdraw from representation of Plaintiff in this matter. As explained in a Notice of Appearance of Counsel filed contemporancously herewith, Geoff A. Gannaway, Joe W. Redden, and Joel Towner of the law firm of Beck Redden LLP will represent Plaintiff going forward. Plaintiff approves the withdrawal and substitution, which are not sought for delay only.Respectfully submitted, BECK REDDEN LLP By: /s/ Geoff A. Gannaway Geoff A. Gannaway State Bar No. 24036617 Joe W. Redden, Jr. State Bar No. 16660600 Joel Towner State Bar No. 24083978 1221 McKinney Street, Suite 4500 Houston, Texas 77010 Tel: 713-951-3700 Fax: 713-951-3720 Email: ggannaway@beckredden.com Email: jredden@beckredden.com Email: jtowner@beckredden.com ATTORNEYS FOR PLAINTIFF QRE OPERATING, LLC CERTIFICATE OF CONFERENCE T have conferred with opposing counsel, who was-unable to agree to the relief sought herein. By: /s/ Geoff A. Gannaway Geoff A. GannawayCERTIFICATE OF SERVICE T hereby certify that I caused a true and correct copy of the foregoing instrument to be served on counsel of record in accordance with Rules 21 and 21a of the Texas Rules of Civil Procedure on this 8th day of February, 2016, by facsimile and email: David A. Stephan, Esq. SIMON PLC 10000 North Central Expressway, Suite 400 Dallas, Texas 75231 Facsimile: 214-890-9249 Craig T. Mierzwa, Esq. Marjan Neceski, Esq. Simon PLC 37000 Woodward Avenue, Suite 250 Bloomfield Hills, Michigan 48304 Facsimile: 248-720-0291 By: /s/ Geoff A. Gannawi Geoff A. Gannaway