Preview
CAUSE NO. DC-l6-01439
IN THE DISTRICT COURT OF
§§§§§§§§§§§§§§§§
TRO-X, L.P.,
Plaintifl",
EAGLE OIL & GAS CO., DALLAS COUNTY, TEXAS
STERLING MI -RO PARTNERS, L.P.,
EAGLE LEASING AND INVESTMENT
CORR, PATRICK STERLING BOLIN, as
co-trustee of the Eagle Employee Overriding
Royalty Trust, WARREN T. AYRES, as co-
trustee of the Eagle Employee Overriding
Royalty Trust; and COG OPERATING, LLC
Defendants. 116TH JUDICIAL DISTRICT
ORDER ON PLAINTIFF TRO-X, L.P.’S MOTION TO COMPEL DISCOVERY FROM COG
OPERATING LLC
ON THIS DAY, came to be heard, Plaintiff TRO-X, L.P.’s Motion to Compel Discovery
from COG Operating, LLC, (the “Motion”). Having considered the Motion, COG Operating,
LLC’s Response to Plaintiff’ s Motion to Compel Discovery, the supporting evidence, and the
arguments of counsel, the Court is of the opinion that the objections addressed in the Motion
should be SUSTAINED, SUSTAINED 1N PART or OVERRULED as provided below:
Objection
Objection Objection
Request for Production Sustained
Sustained
Overruled
in Part
General Objection 1
General Objection 3
REQUEST FOR PRODUCTION NO 1: A11 documents
and communications with Eagle regarding the Working
interests.
REQUEST FOR PRODUCTION NO 2: All documents
and communications with Eagle regarding the Back-in
working interests.
ORDER DENYING/GRANTING PLAINTIFF ’S MOTION TO COMPEL DISCOVERY
FROM COG OPERATING, LLC PAGE 1
Obj ection
Objection Objection
Request for Productlon Sustained
Sustained
Overruled
in Part
REQUEST FOR PRODUCTION NO 3: A11 documents,
including, but not limited to, bank statements, cancelled
checks, check stubs, check images, Wire transfer
documentation, or debit or credit memos, reflecting
payments to Eagle in consideration for the purchase or
assignment of the working interests.
REQUEST FOR PRODUCTION NO 4: All valuations
performed by or for COG regarding the working interests
before or after COG’s purchase of the working interests
from Eagle.
REQUEST FOR PRODUCTION NO 5: A11 valuations
performed by or for any person or entity regarding the
working interests before or after the purchase of the
working interests from Eagle.
REQUEST FOR PRODUCTION NO 6: All documents
reflecting or regarding any payments received by COG as
a result of the sale of the working interests to any third
parties. This request includes, without limitation,
correspondence, contracts, agreements, deeds,
assignments, bank statements, cancelled checks, check
stubs, check images, wire transfer documentation, or
debit or credit memos.
REQUEST FOR PRODUCTION NO 7: A11 documents
and communications exchanged between Eagle and COG
regarding the Back-in working interests.
REQUEST FOR PRODUCTION NO 8: All documents
and communications exchanged between Eagle and COG
regarding the working interests.
REQUEST FOR PRODUCTION NO 9: A11 documents
and communications exchanged between Eagle Partners
and COG regarding the working interests.
REQUEST FOR PRODUCTION NO. 10: All documents
and communications exchanged between Eagle Partners
and COG regarding the Back-in working interests.
REQUEST FOR PRODUCTION NO l 1: Any and all
documents, including, but not limited to, bank statements,
cancelled checks, check stubs, check images, wire
transfer documentation, or debit or credit memos
reflecting or regarding payments to Eagle Partners in
exchange for the working interests.
REQUEST FOR PRODUCTION NO 12: The Purchase
and Sale Agreement entered into on or about December MOOT — PRODUCED APRIL 14, 2023
10, 2013.
ORDER ON PLAINTIFF’S MOTION TO COMPEL DISCOVERY
FROM COG OPERATING, LLC PAGE 2
Obj ection
Objection Objection
Request for Production Sustained
Sustained
Overruled
in Part
REQUEST FOR PRODUCTION NO 13: A11 documents
and communications between Eagle or Eagle Partners
and COG regarding the Purchase and Sale Agreement
entered into on or about December 10, 2013.
REQUEST FOR PRODUCTION NO l4: A11 documents
or communications with Eagle or Eagle Partners that
references or refers to TRO-X.
REQUEST FOR PRODUCTION NO. 15: All documents
relating to sale or production proceeds received by COG
related to the Working Interests. This request includes,
without limitation, any documents or communications
related to a sale of the Working Interests and all
statements reflecting production from the working
interests, bank statements, cancelled checks, check stubs,
check images, wire transfer documentation, or debit or
credit memos relating to production proceeds arising
from the Working interests.
REQUEST FOR PRODUCTION NO 16: A11
communications with Sterling Mi-Ro relating to
payments or proceeds provided to Sterling Mi-Ro as a
result of Overriding Royalty Interests in the Wells.
REQUEST FOR PRODUCTION NO l7: All documents
relating to production proceeds provided by COG to
Sterling Mi-Ro for the Overriding Royalty Interests. This
request includes, without limitation, all statements
reflecting production from the working interests, bank
statements, cancelled checks, check stubs, check images,
wire transfer documentation, or debit or credit memos
relating to production proceeds arising from the Working
interests with Sterling Mi-Ro relating to payments or
proceeds provided to Sterling Mi-Ro as a result of
Overriding Royalty Interests in the Wells.
REQUEST FOR PRODUCTION NO 18: All
communications with Eagle relating to payments or
proceeds provided to Eagle or Sterling Mi-Ro as a result
of Overriding Royalty Interests in the Wells.
REQUEST FOR PRODUCTION NO 19: A11
communications with or documents provided to Eagle or
Sterling Mi-Ro relating to the Wells.
REQUEST FOR PRODUCTION NO 20: A11 documents
and communications with Sterling Mi- RO regarding the
Overriding Royalty Interests.
ORDER ON PLAINTIFF ’S MOTION TO COMPEL DISCOVERY
FROM COG OPERATING, LLC PAGE 3
Obj ection
Objection Objection
Request for Production Sustained
Sustained
Overruled
in Part
REQUEST FOR PRODUCTION NO 21: A11 documents
and communications with Eagle regarding the Overriding
Royalty Interests.
IT IS SO ORDERED this day of , 2023.
HON. TONYA PARKER
ORDER ON PLAINTIFF ’S MOTION TO COMPEL DISCOVERY
FROM COG OPERATING, LLC PAGE 4
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.
Meredith Salsman on behalf of Elizabeth Tiblets
Bar No. 24066194
meredith.salsman@klgates.com
Envelope ID: 76372410
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER ON PLAINTIFF TRO-X, L.P
MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC
Status as of 6/7/2023 1:18 PM CST
Associated Case Party: MARK WHlTTlNGTON
Name BarNumber Email Timestam pSubmitted Status
Shana O'Neal soneal@cbtd.com 6/7/2023 11:17:49 AM SENT
Associated Case Party: EAGLE OIL & GAS CO
Name BarNumber Email TimestampSubmitted Status
David S.Coale dcoale@lynnllp.com 6/7/2023 11:17:49 AM SENT
Michael K.Hurst mhurst@lynnllp.com 6/7/2023 11:17:49 AM SENT
Kay Ridenour kridenour@lynnllp.com 6/7/2023 11:17:49 AM SENT
Jonathan R. Childers jchilders@lynnllp.com 6/7/2023 11:17:49 AM SENT
Deborah G.Hankinson dhankinson@hankinsonlaw.com 6/7/2023 11:17:49 AM SENT
Jennifer Stagen jstagen@hankinsonlaw.com 6/7/2023 11:17:49 AM SENT
Brett David Kutnick 796913 bkutnick@jw.com 6/7/2023 11:17:49 AM SENT
Jodi Taylor jtaylor@|ynnllp.com 6/7/2023 11:17:49 AM SENT
Scot Brown swbrown@lynnllp.com 6/7/2023 11:17:49 AM SENT
NATALIE STALLBOHM nstallbohm@lynnllp.com 6/7/2023 11:17:49 AM SENT
Bennett Hampilos bhampilos@lynnllp.com 6/7/2023 11:17:49 AM SENT
Gina Flores gflores@lynnllp.com 6/7/2023 11:17:49 AM SENT
Jamie R.Drillette jdrillette@lynnllp.com 6/7/2023 11:17:49 AM SENT
Associated Case Party: TRO-X, L.P.
Name BarNumber Email TimestampSubmitted Status
Sam Stennis sstennis@cbtd.com 6/7/2023 11:17:49 AM SENT
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.
Meredith Salsman on behalf of Elizabeth Tiblets
Bar No. 24066194
meredith.salsman@klgates.com
Envelope ID: 76372410
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER ON PLAINTIFF TRO-X, L.P
MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC
Status as of 6/7/2023 1:18 PM CST
Associated Case Party: TRO-X, L.P.
Wallace B.Jefferson wjefferson@adjtlaw.com 6/7/2023 11:17:49 AM SENT
Rachel A.Ekery rekery@adjtlaw.com 6/7/2023 11:17:49 AM SENT
William ClarkLea clarklea@yahoo.com 6/7/2023 11:17:49 AM SENT
Elizabeth AFitch efitch@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Melanie Plowman mplowman@adjtlaw.com 6/7/2023 11:17:49 AM SENT
Robert B.Dubose rdubose@adjtlaw.com 6/7/2023 11:17:49 AM SENT
Ivy Sweeney isweeney@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Kelsey Kraner kkraner@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Rosie Ramos rramos@cbtd.com 6/7/2023 11:17:49 AM SENT
Rhian Jones rjones@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Leland C.de la Garza ldelagarza@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Jesse Beck jbeck@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Alisha DVance avance@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Andrea Wilson awilson@hallettperrin.com 6/7/2023 11:17:49 AM SENT
Associated Case Party: Sterling Mi-Ro Partners, L.P. (Non-Party)
Name BarNumber Email TimestampSubmitted Status
Aaron Z. Tobin atobin@condontobin.com 6/7/2023 11:17:49 AM SENT
Kendal BReed kreed@condontobin.com 6/7/2023 11:17:49 AM SENT
Associated Case Party: STERLING Ml-RO PARTNERS, L.P. ( STERLING Ml-RO
)
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.
Meredith Salsman on behalf of Elizabeth Tiblets
Bar No. 24066194
meredith.salsman@klgates.com
Envelope ID: 76372410
Filing Code Description: Non-Signed Proposed Order/Judgment
Filing Description: PROPOSED ORDER ON PLAINTIFF TRO-X, L.P
MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC
Status as of 6/7/2023 1:18 PM CST
Associated Case Party: STERLING Ml-RO PARTNERS, L.P. ( STERLING Ml-RO
)
Name BarNumber Email TimestampSubmitted Status
Leah KLanier llanier@condontobin.com 6/7/2023 11:17:49 AM SENT
Associated Case Party: COG OPERATING, LLC
Name BarN umber Email TimestampSubmitted Status
Elizabeth Tiblets elizabeth.tiblets@klgates.com 6/7/2023 11:17:49 AM SENT
Tylynn Payne tylynn.payne@klgates.com 6/7/2023 11:17:49 AM SENT
Meredith Salsman meredith.salsman@klgates.com 6/7/2023 11:17:49 AM SENT
Nicki Cook nicki.cook@klgates.com 6/7/2023 11:17:49 AM SENT
Preview
CAUSE NO. DC-l6-01439 IN THE DISTRICT COURT OF §§§§§§§§§§§§§§§§ TRO-X, L.P., Plaintifl", EAGLE OIL & GAS CO., DALLAS COUNTY, TEXAS STERLING MI -RO PARTNERS, L.P., EAGLE LEASING AND INVESTMENT CORR, PATRICK STERLING BOLIN, as co-trustee of the Eagle Employee Overriding Royalty Trust, WARREN T. AYRES, as co- trustee of the Eagle Employee Overriding Royalty Trust; and COG OPERATING, LLC Defendants. 116TH JUDICIAL DISTRICT ORDER ON PLAINTIFF TRO-X, L.P.’S MOTION TO COMPEL DISCOVERY FROM COG OPERATING LLC ON THIS DAY, came to be heard, Plaintiff TRO-X, L.P.’s Motion to Compel Discovery from COG Operating, LLC, (the “Motion”). Having considered the Motion, COG Operating, LLC’s Response to Plaintiff’ s Motion to Compel Discovery, the supporting evidence, and the arguments of counsel, the Court is of the opinion that the objections addressed in the Motion should be SUSTAINED, SUSTAINED 1N PART or OVERRULED as provided below: Objection Objection Objection Request for Production Sustained Sustained Overruled in Part General Objection 1 General Objection 3 REQUEST FOR PRODUCTION NO 1: A11 documents and communications with Eagle regarding the Working interests. REQUEST FOR PRODUCTION NO 2: All documents and communications with Eagle regarding the Back-in working interests. ORDER DENYING/GRANTING PLAINTIFF ’S MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC PAGE 1 Obj ection Objection Objection Request for Productlon Sustained Sustained Overruled in Part REQUEST FOR PRODUCTION NO 3: A11 documents, including, but not limited to, bank statements, cancelled checks, check stubs, check images, Wire transfer documentation, or debit or credit memos, reflecting payments to Eagle in consideration for the purchase or assignment of the working interests. REQUEST FOR PRODUCTION NO 4: All valuations performed by or for COG regarding the working interests before or after COG’s purchase of the working interests from Eagle. REQUEST FOR PRODUCTION NO 5: A11 valuations performed by or for any person or entity regarding the working interests before or after the purchase of the working interests from Eagle. REQUEST FOR PRODUCTION NO 6: All documents reflecting or regarding any payments received by COG as a result of the sale of the working interests to any third parties. This request includes, without limitation, correspondence, contracts, agreements, deeds, assignments, bank statements, cancelled checks, check stubs, check images, wire transfer documentation, or debit or credit memos. REQUEST FOR PRODUCTION NO 7: A11 documents and communications exchanged between Eagle and COG regarding the Back-in working interests. REQUEST FOR PRODUCTION NO 8: All documents and communications exchanged between Eagle and COG regarding the working interests. REQUEST FOR PRODUCTION NO 9: A11 documents and communications exchanged between Eagle Partners and COG regarding the working interests. REQUEST FOR PRODUCTION NO. 10: All documents and communications exchanged between Eagle Partners and COG regarding the Back-in working interests. REQUEST FOR PRODUCTION NO l 1: Any and all documents, including, but not limited to, bank statements, cancelled checks, check stubs, check images, wire transfer documentation, or debit or credit memos reflecting or regarding payments to Eagle Partners in exchange for the working interests. REQUEST FOR PRODUCTION NO 12: The Purchase and Sale Agreement entered into on or about December MOOT — PRODUCED APRIL 14, 2023 10, 2013. ORDER ON PLAINTIFF’S MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC PAGE 2 Obj ection Objection Objection Request for Production Sustained Sustained Overruled in Part REQUEST FOR PRODUCTION NO 13: A11 documents and communications between Eagle or Eagle Partners and COG regarding the Purchase and Sale Agreement entered into on or about December 10, 2013. REQUEST FOR PRODUCTION NO l4: A11 documents or communications with Eagle or Eagle Partners that references or refers to TRO-X. REQUEST FOR PRODUCTION NO. 15: All documents relating to sale or production proceeds received by COG related to the Working Interests. This request includes, without limitation, any documents or communications related to a sale of the Working Interests and all statements reflecting production from the working interests, bank statements, cancelled checks, check stubs, check images, wire transfer documentation, or debit or credit memos relating to production proceeds arising from the Working interests. REQUEST FOR PRODUCTION NO 16: A11 communications with Sterling Mi-Ro relating to payments or proceeds provided to Sterling Mi-Ro as a result of Overriding Royalty Interests in the Wells. REQUEST FOR PRODUCTION NO l7: All documents relating to production proceeds provided by COG to Sterling Mi-Ro for the Overriding Royalty Interests. This request includes, without limitation, all statements reflecting production from the working interests, bank statements, cancelled checks, check stubs, check images, wire transfer documentation, or debit or credit memos relating to production proceeds arising from the Working interests with Sterling Mi-Ro relating to payments or proceeds provided to Sterling Mi-Ro as a result of Overriding Royalty Interests in the Wells. REQUEST FOR PRODUCTION NO 18: All communications with Eagle relating to payments or proceeds provided to Eagle or Sterling Mi-Ro as a result of Overriding Royalty Interests in the Wells. REQUEST FOR PRODUCTION NO 19: A11 communications with or documents provided to Eagle or Sterling Mi-Ro relating to the Wells. REQUEST FOR PRODUCTION NO 20: A11 documents and communications with Sterling Mi- RO regarding the Overriding Royalty Interests. ORDER ON PLAINTIFF ’S MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC PAGE 3 Obj ection Objection Objection Request for Production Sustained Sustained Overruled in Part REQUEST FOR PRODUCTION NO 21: A11 documents and communications with Eagle regarding the Overriding Royalty Interests. IT IS SO ORDERED this day of , 2023. HON. TONYA PARKER ORDER ON PLAINTIFF ’S MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC PAGE 4 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. Meredith Salsman on behalf of Elizabeth Tiblets Bar No. 24066194 meredith.salsman@klgates.com Envelope ID: 76372410 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER ON PLAINTIFF TRO-X, L.P MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC Status as of 6/7/2023 1:18 PM CST Associated Case Party: MARK WHlTTlNGTON Name BarNumber Email Timestam pSubmitted Status Shana O'Neal soneal@cbtd.com 6/7/2023 11:17:49 AM SENT Associated Case Party: EAGLE OIL & GAS CO Name BarNumber Email TimestampSubmitted Status David S.Coale dcoale@lynnllp.com 6/7/2023 11:17:49 AM SENT Michael K.Hurst mhurst@lynnllp.com 6/7/2023 11:17:49 AM SENT Kay Ridenour kridenour@lynnllp.com 6/7/2023 11:17:49 AM SENT Jonathan R. Childers jchilders@lynnllp.com 6/7/2023 11:17:49 AM SENT Deborah G.Hankinson dhankinson@hankinsonlaw.com 6/7/2023 11:17:49 AM SENT Jennifer Stagen jstagen@hankinsonlaw.com 6/7/2023 11:17:49 AM SENT Brett David Kutnick 796913 bkutnick@jw.com 6/7/2023 11:17:49 AM SENT Jodi Taylor jtaylor@|ynnllp.com 6/7/2023 11:17:49 AM SENT Scot Brown swbrown@lynnllp.com 6/7/2023 11:17:49 AM SENT NATALIE STALLBOHM nstallbohm@lynnllp.com 6/7/2023 11:17:49 AM SENT Bennett Hampilos bhampilos@lynnllp.com 6/7/2023 11:17:49 AM SENT Gina Flores gflores@lynnllp.com 6/7/2023 11:17:49 AM SENT Jamie R.Drillette jdrillette@lynnllp.com 6/7/2023 11:17:49 AM SENT Associated Case Party: TRO-X, L.P. Name BarNumber Email TimestampSubmitted Status Sam Stennis sstennis@cbtd.com 6/7/2023 11:17:49 AM SENT 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. Meredith Salsman on behalf of Elizabeth Tiblets Bar No. 24066194 meredith.salsman@klgates.com Envelope ID: 76372410 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER ON PLAINTIFF TRO-X, L.P MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC Status as of 6/7/2023 1:18 PM CST Associated Case Party: TRO-X, L.P. Wallace B.Jefferson wjefferson@adjtlaw.com 6/7/2023 11:17:49 AM SENT Rachel A.Ekery rekery@adjtlaw.com 6/7/2023 11:17:49 AM SENT William ClarkLea clarklea@yahoo.com 6/7/2023 11:17:49 AM SENT Elizabeth AFitch efitch@hallettperrin.com 6/7/2023 11:17:49 AM SENT Melanie Plowman mplowman@adjtlaw.com 6/7/2023 11:17:49 AM SENT Robert B.Dubose rdubose@adjtlaw.com 6/7/2023 11:17:49 AM SENT Ivy Sweeney isweeney@hallettperrin.com 6/7/2023 11:17:49 AM SENT Kelsey Kraner kkraner@hallettperrin.com 6/7/2023 11:17:49 AM SENT Rosie Ramos rramos@cbtd.com 6/7/2023 11:17:49 AM SENT Rhian Jones rjones@hallettperrin.com 6/7/2023 11:17:49 AM SENT Leland C.de la Garza ldelagarza@hallettperrin.com 6/7/2023 11:17:49 AM SENT Jesse Beck jbeck@hallettperrin.com 6/7/2023 11:17:49 AM SENT Alisha DVance avance@hallettperrin.com 6/7/2023 11:17:49 AM SENT Andrea Wilson awilson@hallettperrin.com 6/7/2023 11:17:49 AM SENT Associated Case Party: Sterling Mi-Ro Partners, L.P. (Non-Party) Name BarNumber Email TimestampSubmitted Status Aaron Z. Tobin atobin@condontobin.com 6/7/2023 11:17:49 AM SENT Kendal BReed kreed@condontobin.com 6/7/2023 11:17:49 AM SENT Associated Case Party: STERLING Ml-RO PARTNERS, L.P. ( STERLING Ml-RO ) 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. Meredith Salsman on behalf of Elizabeth Tiblets Bar No. 24066194 meredith.salsman@klgates.com Envelope ID: 76372410 Filing Code Description: Non-Signed Proposed Order/Judgment Filing Description: PROPOSED ORDER ON PLAINTIFF TRO-X, L.P MOTION TO COMPEL DISCOVERY FROM COG OPERATING, LLC Status as of 6/7/2023 1:18 PM CST Associated Case Party: STERLING Ml-RO PARTNERS, L.P. ( STERLING Ml-RO ) Name BarNumber Email TimestampSubmitted Status Leah KLanier llanier@condontobin.com 6/7/2023 11:17:49 AM SENT Associated Case Party: COG OPERATING, LLC Name BarN umber Email TimestampSubmitted Status Elizabeth Tiblets elizabeth.tiblets@klgates.com 6/7/2023 11:17:49 AM SENT Tylynn Payne tylynn.payne@klgates.com 6/7/2023 11:17:49 AM SENT Meredith Salsman meredith.salsman@klgates.com 6/7/2023 11:17:49 AM SENT Nicki Cook nicki.cook@klgates.com 6/7/2023 11:17:49 AM SENT