On August 12, 2015 a
Party Discovery
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
CAUSE NO. 2015-47031
QRE OPERATING, LLC )
)
Plaintiff, ) IN THE DISTRICT COURT OF
)
ve. )
) HARRIS COUNTY, TEXAS
ROGER D. PARSONS, IN HIS )
CAPACITY AS TRUSTEE OF THE )
LL&E ROYALTY TRUST, ) 133 JUDICIAL DISTRICT
)
Defendant. )
NOTICE OF SUBPOENA
PLEASE TAKE NOTICE, pursuant to Texas Rule of Civil Procedure 205.2, that counsel
for QRE Operating, LLC intends to serve a Subpoena, in the form attached hereto, on BRI
Consulting Group, Inc. (“BRI Consulting”). The Subpoena, as described in Exhibit A, seeks: qd)
all documents, including but not limited to communications, referring or relating to any audit
BRI Consulting performed related to the Jay Field on behalf of the Trust or Trustee; (2) all
documents, including but not limited to communications, referring or relating to the Jay Field
and/or the Conveyance of Overriding Royalty Interest dated June 28, 1983, by and between the
Louisiana Land & Exploration Company and Alvin E. Jones; and, (3) all documents, including
but not limited to communications, referring or relating to Quantum Resources Management,
LLC, QRE Operating, LLC and/or QR Energy, L.P.
The Subpoena requests that BRI Consulting produce the requested documents by
February 24, 2016 to:
Latham & Watkins LLP
Attn: Johanna Spellman
330 N. Wabash Ave., Suite 2800
Chicago, IL 60611
It is not necessary for BRI Consulting Group, Inc. to appear if the production of
documents is sent to Latham & Watkins LLP by Federal Express Account No. 0606-6040-9 on
or before February 24, 2016.
Dated: January 27, 2016Respectfully submitted,
y
By “ 2 L — , VY
Jéhanna Spellman, ‘admitted pro hac vice
330 N. Wabash Ave., Suite 2800
Chicago, IL 60611
Telephone: (312) 777-7039
Facsimile: (312) 993-9767
Email: johanna.spellman@lw.com
Attorney for Plaintiff QRE Operating, LLCCERTIFICATE OF SERVICE
Thereby certify that on January 27, 2016, a copy of the above and foregoing PLAINTIFF
QRE OPERATING, LLC’S NOTICE OF SUBPOENA has been served by U.S. mail upon:
David A. Stephan
10000 North Central Expressway
Suite 400
Dallas, Texas 75231
(214) 890-4085
dstephan @simonattys.com
Craig T. Mierzwa
Marjan Neceski
37000 Woodward Avenue
Suite 250
Bloomfield Hills, Michigan 48304
(248) 720-0290
cmierzwa@simonattys.com
mmneceski@simonattys.com
BRI Consulting Group, Inc.
1616 S. Voss Road, Suite 845
Houston, Texas 77057
Telephone: (713) 468-3606
Johanna Spellman, adfnitfed pro hac vice
One of the Attorneys for Plaintiff
Preview
CAUSE NO. 2015-47031 QRE OPERATING, LLC ) ) Plaintiff, ) IN THE DISTRICT COURT OF ) ve. ) ) HARRIS COUNTY, TEXAS ROGER D. PARSONS, IN HIS ) CAPACITY AS TRUSTEE OF THE ) LL&E ROYALTY TRUST, ) 133 JUDICIAL DISTRICT ) Defendant. ) NOTICE OF SUBPOENA PLEASE TAKE NOTICE, pursuant to Texas Rule of Civil Procedure 205.2, that counsel for QRE Operating, LLC intends to serve a Subpoena, in the form attached hereto, on BRI Consulting Group, Inc. (“BRI Consulting”). The Subpoena, as described in Exhibit A, seeks: qd) all documents, including but not limited to communications, referring or relating to any audit BRI Consulting performed related to the Jay Field on behalf of the Trust or Trustee; (2) all documents, including but not limited to communications, referring or relating to the Jay Field and/or the Conveyance of Overriding Royalty Interest dated June 28, 1983, by and between the Louisiana Land & Exploration Company and Alvin E. Jones; and, (3) all documents, including but not limited to communications, referring or relating to Quantum Resources Management, LLC, QRE Operating, LLC and/or QR Energy, L.P. The Subpoena requests that BRI Consulting produce the requested documents by February 24, 2016 to: Latham & Watkins LLP Attn: Johanna Spellman 330 N. Wabash Ave., Suite 2800 Chicago, IL 60611 It is not necessary for BRI Consulting Group, Inc. to appear if the production of documents is sent to Latham & Watkins LLP by Federal Express Account No. 0606-6040-9 on or before February 24, 2016. Dated: January 27, 2016Respectfully submitted, y By “ 2 L — , VY Jéhanna Spellman, ‘admitted pro hac vice 330 N. Wabash Ave., Suite 2800 Chicago, IL 60611 Telephone: (312) 777-7039 Facsimile: (312) 993-9767 Email: johanna.spellman@lw.com Attorney for Plaintiff QRE Operating, LLCCERTIFICATE OF SERVICE Thereby certify that on January 27, 2016, a copy of the above and foregoing PLAINTIFF QRE OPERATING, LLC’S NOTICE OF SUBPOENA has been served by U.S. mail upon: David A. Stephan 10000 North Central Expressway Suite 400 Dallas, Texas 75231 (214) 890-4085 dstephan @simonattys.com Craig T. Mierzwa Marjan Neceski 37000 Woodward Avenue Suite 250 Bloomfield Hills, Michigan 48304 (248) 720-0290 cmierzwa@simonattys.com mmneceski@simonattys.com BRI Consulting Group, Inc. 1616 S. Voss Road, Suite 845 Houston, Texas 77057 Telephone: (713) 468-3606 Johanna Spellman, adfnitfed pro hac vice One of the Attorneys for Plaintiff