Preview
FILED
1/13/2023 3:28 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Treva Parker-Ayodele DEPUTY
CAUSE NO. DC-21-09308
MELISSA TARVER, Individually and as
§§§§§§§§§§§§§§§§§§§§§§§§§§
Representative of the Estate of DERIC
TARVER, and as next friend of B.T. and
K.T., Minors, RANDY TARVER and
DEBBIE TARVER
IN THE DISTRICT COURT OF
V. DALLAS COUNTY, TEXAS
192ND JUDICIAL DISTRICT
ATMOS ENERGY CORPORATION
and BOBCAT CONTRACTING, LLC
TAMMY BOEHLER, Individually and as
Representative of the Estate of ETHAN
KNIGHT, and CLAY BOEHLER
V.
ATMOS ENERGY CORPORATION and
FESCO, LTD.
MICHAEL GLOVER
V.
ATMOS ENERGY CORPORATION and
BOBCAT CONTRACTING, LLC
DEFENDANT ATMOS ENERGY’S NOTICE OF SUBPOENA DUCES TECUM TO
NON-PARTY S.U.N. ENGINEERING. INC.
Please take notice that Defendant Atmos Energy Corporation intends to serve a subpoena
requiring S.U.N. Engineering, Inc. to, no later than 14 days after service of the subpoena,
produce for inspection and copying all documents responsive to Exhibit A to the attached
Subpoena Duces Tecum, to the law offices of Baker Botts L.L.P, 2001 Ross Avenue, Suite 900,
Dallas, TX 75201.
1104239
DATED: January 13, 2023 Respectfully submitted,
G. Bruce Parkerson
State Bar No. 00793106
PLAUCHE MASELLI PARKERSON LLP
701 Poydras St., Suite 3800
New Orleans, Louisiana 70139
Telephone: (504) 582-1142
Facsimile: (504) 582-1172
bparkers0n@pmpllp.com
ATTORNEY FOR DEFENDANT
ATMOS ENERGY CORPORATION
CERTIFICATE OF SERVICE
I hereby certify that on the 13th day of January 2023, a copy of the foregoing was served
Via electronic email to all counsel of record.
G. Bruce Parkerson
1104239 2
THE STATE OF TEXAS
SUBPOENA FOR WITNESS PURSUANT TO
TEXAS RULE OF CIVIL PROCEDURE 176
CAUSE NO. DC-21-09308
MELISSA TARVER, Individually and as
§§§§§§§§§§§§§§§§§§§§§§§§§§
Representative of the Estate of DERIC
TARVER, and as next friend of B.T. and
K.T., Minors, RANDY TARVER and
DEBBIE TARVER
IN THE DISTRICT COURT OF
V. DALLAS COUNTY, TEXAS
192ND NDICML DISTRICT
ATMOS ENERGY CORPORATION
and BOBCAT CONTRACTING, LLC
TAMMY BOEHLER, Individually and as
Representative of the Estate of ETHAN
KNIGHT, and CLAY BOEHLER
V.
ATMOS ENERGY CORPORATION and
FESCO, LTD.
MICHAEL GLOVER
V.
ATMOS ENERGY CORPORATION and
BOBCAT CONTRACTING, LLC
SUBPOENA DUCES TECUM
To: Any Sheriff or Constable of the State of Texas, or Other Person Authorized to Serve and
Execute Subpoenas as Provided in Texas Rule of Civil Procedure 176.
YOU ARE HEREBY COMMANDED TO SUMMON S.U.N. Engineering, Inc., who
may be served at 10031 E. 52nd Street, Tulsa, OK 74146, to appear before a Notary Public/Court
Reporter at Baker Botts L.L.P., 2001 Ross Avenue, Suite 900, Dallas, TX 75201,
at 9:00 a.m., in order to bring and produce for inspection and copying the
materials described in the attached Exhibit A.
CONTEMPT. FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO
OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A
1104239 3
CONTEMPT 0F THE COURT FROM WHICH THE SUBPOENA Is ISSUED 0R A
DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA Is SERVED, AND
MAY BE PUNISHED BY FINE OR CONFINEMENT, OR BOTH. TEX. R. Cw. P.
176.8(a).
DO NOT FAIL to return this writ to the l92nd Judicial District Court, Dallas County, Texas,
with return thereon, showing the manner of execution.
ISSUED ON , 2023.
Respectfillly submitted,
G. Bruce Parkerson
State Bar No. 00793106
PLAUCHE MASELLI PARKERSON LLP
701 Poydras St., Suite 3800
New Orleans, Louisiana 70139
Telephone: (504) 582-1142
Facsimile: (504) 582-1172
bparkerson@pmpllp.com
ATTORNEY FOR DEFENDANT
ATMOS ENERGY CORPORATION
This subpoena was issued at the request of the Defendant Atmos Energy Corporation, Whose
attorney of record is G. Bruce Parkerson, State Bar No. 00793106, from Plauche Maselli
Parkerson LLP, 701 Poydras St., Suite 3800, New Orleans, Louisiana 70139.
1104239 4
EXHIBIT A
DEFINITIONS AND INSTRUCTIONS
1. The term “person” means any natural person or any legal entity, including,
without limitation, any business or governmental entity or association.
2. The term “document” is defined to be synonymous in meaning and equal in scope
to the usage of the term “documents and tangible things” in Texas Rule of Civil Procedure
192.3(b), including but not limited to papers, books, accounts, drawings, graphs, charts,
photographs, electronic or Videotape recordings, data, and data compilations. A draft or non-
identical copy is a separate document Within the meaning of this term. “Documents” includes
electronic data as described in Rule 196.4, including emails and text messages. Documents
described in Rule 196.4 should be produced in the following format:
a. Non-redacted Microsoft Excel or other spreadsheet files should be produced in native
format. Additionally, other file types not capable of being converted to image format
such as multimedia files, audio files, video files, and drawing files should be
produced in native form. The “FileName” metadata provided for documents
produced in native format will be the original file name of the native document.
b. For all other Electronically Stored Information, please produce either (i) or,
alternatively (ii) below:
i. Multi-page, searchable PDF format with associated OCR text, metadata, and
bibliographic information; or
ii. The following files for each document:
1104239 5
1. Image Files: Group IV single page black and white TIFF images (except
documents containing color should be produced as single page 300 dpi
JPG color image files);
2. Text Files: A document-level text file (extracted text if available in the
native file, or OCR for documents Without extractable text and for
redacted documents), with each text file named as the beginning Bates
number of its corresponding document; and
3. Database load files: A Concordance load file that includes the metadata
fields listed:
BegBates
EndBates
BegAttach (for emails/attachments)
EndAttach (for emails/attachments)
Hashvalue [MDS Hash]
CustodiansAll (all custodians of a produced document)
From
To
CC
BCC
Subject
SentDate
Author (for attachments and loose documents)
FileName [Title] (for attachments and loose documents)
FileCreatedDate (for attachments and loose documents
only)
FileLastModifiedDate (for attachments and loose
documents)
File Extension
LNK (for any native file produced)
3. “Describe” or “identify,” as used in reference to any document(s) or tangible
evidence, includes stating the title or name, date, and author of any document; the common
name, manufacturer, owner and identifying number of any object; the name and address of the
person(s) having possession of the original at the present time; and a statement as to Whether the
1104239 6
party responding has the original or a copy.
4. “You,” “Your,” or “S.U.N. Engineering” refers to S.U.N. Engineering, Inc. and
its agents, officers, employees, representatives, and attorneys, and/or its predecessors in interest,
subsidiaries, affiliates, members and related entities and their agents, officers, employees,
representatives, and attorneys.
5. “Atmos” refers to Atmos Energy Corporation, its agents, officers, employees,
representatives, and attorneys, and/or its predecessors in interest, subsidiaries, affiliates,
members and related entities, and their agents, officers, employees, representatives, and
attorneys.
6. “Gauge Pig” refers to the 24-inch gauge pig manufactured by S.U.N. Engineering,
model number 2CC-SM —
24”, the same model of which was sold to Atmos and used during the
pigging operations in Farmersville, TX in June 2021.
7. “And” and “or” shall each be construed conjunctively and disjunctively so as to
acquire the broadest meaning possible.
8. “Any” and “all” shall each be construed to mean “each and every” so as to
acquire the broadest meaning possible.
9. The document requests herein include any and all responsive documents Within
the possession, custody or control of S.U.N. Engineering, including documents located in the
personal files of any and all past and present directors, officers, agents, representatives,
employees, attorneys, and accountants of S.U.N. Engineering.
10. If, after conducting a reasonable investigation, you cannot provide a fi111 answer
for any request for the production of documents, state that such is the case and answer to the
fullest extent possible, stating what responsive documents or information are available, what
1104239 7
documents or information cannot be provided, why the documents or information are
unavailable, and What efforts were made to obtain the unavailable documents or information.
11. Documents from any single file should be produced in the same order as they
were found in such file, including any labels, files, folders, and/or containers in which such
documents are located in or associated with. If copies of documents are produced in lieu of the
originals, such copies should be legible and bound or stapled in the same manner as the original.
12. If any of the documents requested herein are no longer in S.U.N. Engineering’s
possession, custody or control, identify such requested documents by providing a summary of
the relevant contents and the date and identify who now has possession, custody or control.
13. If any document responsive to these requests has been destroyed, describe the
pertinent contents and date of the documents as well as why and when the documents were
destroyed.
DOCUMENTS TO BE PRODUCED
l. All documents sufficient to show previously known incidents of malfunction of
the Gauge Pig when being used in the manner prescribed by You.
2. All documents sufficient to show any Failure Modes and Effects Analysis
(“FMEA”) performed by You in the research, design, creation, development, and manufacture of
the Gauge Pig.
3. All documents concerning whether the Gauge Pig, and any component thereof,
and any similar products sold by You, could ignite flammable vapors when being used in the
manner prescribed by You.
1104239 8
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.
Godfrey Parkerson
Bar No. 793106
bparkerson@pmpllp.com
Envelope ID: 71796878
Status as of 1/13/2023 4:25 PM CST
Associated Case Party: MELISSA TARVER
Name BarNumber Email TimestampSubmitted Status
Benny Agosto, Jr. bagosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT
Ben Agosto III ben.agosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT
Shari Welch swelch@awtxlaw.com 1/13/2023 3:28:22 PM SENT
Mayra Valdes-Zavala mzavala@awtxlaw.com 1/13/2023 3:28:22 PM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Jennifer DAufricht jaufricht@thompsoncoe.com 1/13/2023 3:28:22 PM SENT
Renee Smith Renee.Smith@thompsoncoe.com 1/13/2023 3:28:22 PM SENT
Steven Joseph Kherkher 11375950 SKherkher—Team@KherkherGarcia.com 1/13/2023 3:28:22 PM SENT
Michael Dale Hudlow 24007403 mhudlow@hdr-law.com 1/13/2023 3:28:22 PM SENT
Robin Clay Hoblit 9743100 hdrccservice@hdr-Iaw.com 1/13/2023 3:28:22 PM SENT
Elva Jasso ejasso@thompsoncoe.com 1/13/2023 3:28:22 PM SENT
Dana Lisenby d|isenby@thompsoncoe.com 1/13/2023 3:28:22 PM SENT
Christopher Hansen chansen@thompsoncoe.com 1/13/2023 3:28:22 PM SENT
Jacob Karam jacob@thekaramlawoffice.com 1/13/2023 3:28:22 PM SENT
Edward AFesteryga edward@awtxlaw.com 1/13/2023 3:28:22 PM SENT
BENNY AGOSTOJR bagosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT
Jessica Pulliam jessica.pulliam@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Susan Kennedy susan.kennedy@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Zachary Stone zachary.stone@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Kristin Sullivan Kristin.Sullivan@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Bruce Parkerson bparkerson@pmpllp.com 1/13/2023 3:28:22 PM 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.
Godfrey Parkerson
Bar No. 793106
bparkerson@pmpllp.com
Envelope ID: 71796878
Status as of 1/13/2023 4:25 PM CST
Case Contacts
Debora Simonson debora.simonson@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Gadi Alvarado-Lopez gadi@thekaramlawoffice.com 1/13/2023 3:28:22 PM SENT
Lena B.Laurenzo llaurenzo@awtxlaw.com 1/13/2023 3:28:22 PM SENT
Ben Agosto Ill ben.agosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT
Lisa Schmidt LSchmidt@PMPllp.com 1/13/2023 3:28:22 PM SENT
Briseida Martinez briseida@thekaramlawoffice.com 1/13/2023 3:28:22 PM SENT
Associated Case Party: ATMOS ENERGY CORPORATION
Name BarNumber Email TimestampSubmitted Status
susan kennedy susan.kennedy@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Jordan Kazlow jordan.kazlow@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Jessica B. Pulliam jessica.pulliam@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Zachary Stone Zachary.Stone@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Salam Shaikh-Khalil salam.sheikh-khalil@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Brook Vaydik brooke.vaydik@bakerbotts.com 1/13/2023 3:28:22 PM SENT
Associated Case Party: BOBCAT CONTRACTING, LLC
Name BarNumber Email TimestampSubmitted Status
Sarah HolleyLong Long EDocsNotifications@wbclawfirm.com 1/13/2023 3:28:22 PM SENT
Associated Case Party: TAMMY BOEHLER
Name BarNumber Email TimestampSubmitted Status
Carmen S.Mitchell cmitchell@mitchellgoff.com 1/13/2023 3:28:22 PM 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.
Godfrey Parkerson
Bar No. 793106
bparkerson@pmpllp.com
Envelope ID: 71796878
Status as of 1/13/2023 4:25 PM CST
Associated Case Party: TAMMY BOEHLER
Heather Teer hteer@mitchellgoff.com 1/13/2023 3:28:22 PM SENT
Associated Case Party: MICHAEL GLOVER
Name BarNumber Email TimestampSubmitted Status
Bobbie Gilbert bgilbert@kv-law.com 1/13/2023 3:28:22 PM SENT
Loren Klitsas klitsas@kv-law.com 1/13/2023 3:28:22 PM SENT
Preview
FILED 1/13/2023 3:28 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Treva Parker-Ayodele DEPUTY CAUSE NO. DC-21-09308 MELISSA TARVER, Individually and as §§§§§§§§§§§§§§§§§§§§§§§§§§ Representative of the Estate of DERIC TARVER, and as next friend of B.T. and K.T., Minors, RANDY TARVER and DEBBIE TARVER IN THE DISTRICT COURT OF V. DALLAS COUNTY, TEXAS 192ND JUDICIAL DISTRICT ATMOS ENERGY CORPORATION and BOBCAT CONTRACTING, LLC TAMMY BOEHLER, Individually and as Representative of the Estate of ETHAN KNIGHT, and CLAY BOEHLER V. ATMOS ENERGY CORPORATION and FESCO, LTD. MICHAEL GLOVER V. ATMOS ENERGY CORPORATION and BOBCAT CONTRACTING, LLC DEFENDANT ATMOS ENERGY’S NOTICE OF SUBPOENA DUCES TECUM TO NON-PARTY S.U.N. ENGINEERING. INC. Please take notice that Defendant Atmos Energy Corporation intends to serve a subpoena requiring S.U.N. Engineering, Inc. to, no later than 14 days after service of the subpoena, produce for inspection and copying all documents responsive to Exhibit A to the attached Subpoena Duces Tecum, to the law offices of Baker Botts L.L.P, 2001 Ross Avenue, Suite 900, Dallas, TX 75201. 1104239 DATED: January 13, 2023 Respectfully submitted, G. Bruce Parkerson State Bar No. 00793106 PLAUCHE MASELLI PARKERSON LLP 701 Poydras St., Suite 3800 New Orleans, Louisiana 70139 Telephone: (504) 582-1142 Facsimile: (504) 582-1172 bparkers0n@pmpllp.com ATTORNEY FOR DEFENDANT ATMOS ENERGY CORPORATION CERTIFICATE OF SERVICE I hereby certify that on the 13th day of January 2023, a copy of the foregoing was served Via electronic email to all counsel of record. G. Bruce Parkerson 1104239 2 THE STATE OF TEXAS SUBPOENA FOR WITNESS PURSUANT TO TEXAS RULE OF CIVIL PROCEDURE 176 CAUSE NO. DC-21-09308 MELISSA TARVER, Individually and as §§§§§§§§§§§§§§§§§§§§§§§§§§ Representative of the Estate of DERIC TARVER, and as next friend of B.T. and K.T., Minors, RANDY TARVER and DEBBIE TARVER IN THE DISTRICT COURT OF V. DALLAS COUNTY, TEXAS 192ND NDICML DISTRICT ATMOS ENERGY CORPORATION and BOBCAT CONTRACTING, LLC TAMMY BOEHLER, Individually and as Representative of the Estate of ETHAN KNIGHT, and CLAY BOEHLER V. ATMOS ENERGY CORPORATION and FESCO, LTD. MICHAEL GLOVER V. ATMOS ENERGY CORPORATION and BOBCAT CONTRACTING, LLC SUBPOENA DUCES TECUM To: Any Sheriff or Constable of the State of Texas, or Other Person Authorized to Serve and Execute Subpoenas as Provided in Texas Rule of Civil Procedure 176. YOU ARE HEREBY COMMANDED TO SUMMON S.U.N. Engineering, Inc., who may be served at 10031 E. 52nd Street, Tulsa, OK 74146, to appear before a Notary Public/Court Reporter at Baker Botts L.L.P., 2001 Ross Avenue, Suite 900, Dallas, TX 75201, at 9:00 a.m., in order to bring and produce for inspection and copying the materials described in the attached Exhibit A. CONTEMPT. FAILURE BY ANY PERSON WITHOUT ADEQUATE EXCUSE TO OBEY A SUBPOENA SERVED UPON THAT PERSON MAY BE DEEMED A 1104239 3 CONTEMPT 0F THE COURT FROM WHICH THE SUBPOENA Is ISSUED 0R A DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA Is SERVED, AND MAY BE PUNISHED BY FINE OR CONFINEMENT, OR BOTH. TEX. R. Cw. P. 176.8(a). DO NOT FAIL to return this writ to the l92nd Judicial District Court, Dallas County, Texas, with return thereon, showing the manner of execution. ISSUED ON , 2023. Respectfillly submitted, G. Bruce Parkerson State Bar No. 00793106 PLAUCHE MASELLI PARKERSON LLP 701 Poydras St., Suite 3800 New Orleans, Louisiana 70139 Telephone: (504) 582-1142 Facsimile: (504) 582-1172 bparkerson@pmpllp.com ATTORNEY FOR DEFENDANT ATMOS ENERGY CORPORATION This subpoena was issued at the request of the Defendant Atmos Energy Corporation, Whose attorney of record is G. Bruce Parkerson, State Bar No. 00793106, from Plauche Maselli Parkerson LLP, 701 Poydras St., Suite 3800, New Orleans, Louisiana 70139. 1104239 4 EXHIBIT A DEFINITIONS AND INSTRUCTIONS 1. The term “person” means any natural person or any legal entity, including, without limitation, any business or governmental entity or association. 2. The term “document” is defined to be synonymous in meaning and equal in scope to the usage of the term “documents and tangible things” in Texas Rule of Civil Procedure 192.3(b), including but not limited to papers, books, accounts, drawings, graphs, charts, photographs, electronic or Videotape recordings, data, and data compilations. A draft or non- identical copy is a separate document Within the meaning of this term. “Documents” includes electronic data as described in Rule 196.4, including emails and text messages. Documents described in Rule 196.4 should be produced in the following format: a. Non-redacted Microsoft Excel or other spreadsheet files should be produced in native format. Additionally, other file types not capable of being converted to image format such as multimedia files, audio files, video files, and drawing files should be produced in native form. The “FileName” metadata provided for documents produced in native format will be the original file name of the native document. b. For all other Electronically Stored Information, please produce either (i) or, alternatively (ii) below: i. Multi-page, searchable PDF format with associated OCR text, metadata, and bibliographic information; or ii. The following files for each document: 1104239 5 1. Image Files: Group IV single page black and white TIFF images (except documents containing color should be produced as single page 300 dpi JPG color image files); 2. Text Files: A document-level text file (extracted text if available in the native file, or OCR for documents Without extractable text and for redacted documents), with each text file named as the beginning Bates number of its corresponding document; and 3. Database load files: A Concordance load file that includes the metadata fields listed: BegBates EndBates BegAttach (for emails/attachments) EndAttach (for emails/attachments) Hashvalue [MDS Hash] CustodiansAll (all custodians of a produced document) From To CC BCC Subject SentDate Author (for attachments and loose documents) FileName [Title] (for attachments and loose documents) FileCreatedDate (for attachments and loose documents only) FileLastModifiedDate (for attachments and loose documents) File Extension LNK (for any native file produced) 3. “Describe” or “identify,” as used in reference to any document(s) or tangible evidence, includes stating the title or name, date, and author of any document; the common name, manufacturer, owner and identifying number of any object; the name and address of the person(s) having possession of the original at the present time; and a statement as to Whether the 1104239 6 party responding has the original or a copy. 4. “You,” “Your,” or “S.U.N. Engineering” refers to S.U.N. Engineering, Inc. and its agents, officers, employees, representatives, and attorneys, and/or its predecessors in interest, subsidiaries, affiliates, members and related entities and their agents, officers, employees, representatives, and attorneys. 5. “Atmos” refers to Atmos Energy Corporation, its agents, officers, employees, representatives, and attorneys, and/or its predecessors in interest, subsidiaries, affiliates, members and related entities, and their agents, officers, employees, representatives, and attorneys. 6. “Gauge Pig” refers to the 24-inch gauge pig manufactured by S.U.N. Engineering, model number 2CC-SM — 24”, the same model of which was sold to Atmos and used during the pigging operations in Farmersville, TX in June 2021. 7. “And” and “or” shall each be construed conjunctively and disjunctively so as to acquire the broadest meaning possible. 8. “Any” and “all” shall each be construed to mean “each and every” so as to acquire the broadest meaning possible. 9. The document requests herein include any and all responsive documents Within the possession, custody or control of S.U.N. Engineering, including documents located in the personal files of any and all past and present directors, officers, agents, representatives, employees, attorneys, and accountants of S.U.N. Engineering. 10. If, after conducting a reasonable investigation, you cannot provide a fi111 answer for any request for the production of documents, state that such is the case and answer to the fullest extent possible, stating what responsive documents or information are available, what 1104239 7 documents or information cannot be provided, why the documents or information are unavailable, and What efforts were made to obtain the unavailable documents or information. 11. Documents from any single file should be produced in the same order as they were found in such file, including any labels, files, folders, and/or containers in which such documents are located in or associated with. If copies of documents are produced in lieu of the originals, such copies should be legible and bound or stapled in the same manner as the original. 12. If any of the documents requested herein are no longer in S.U.N. Engineering’s possession, custody or control, identify such requested documents by providing a summary of the relevant contents and the date and identify who now has possession, custody or control. 13. If any document responsive to these requests has been destroyed, describe the pertinent contents and date of the documents as well as why and when the documents were destroyed. DOCUMENTS TO BE PRODUCED l. All documents sufficient to show previously known incidents of malfunction of the Gauge Pig when being used in the manner prescribed by You. 2. All documents sufficient to show any Failure Modes and Effects Analysis (“FMEA”) performed by You in the research, design, creation, development, and manufacture of the Gauge Pig. 3. All documents concerning whether the Gauge Pig, and any component thereof, and any similar products sold by You, could ignite flammable vapors when being used in the manner prescribed by You. 1104239 8 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. Godfrey Parkerson Bar No. 793106 bparkerson@pmpllp.com Envelope ID: 71796878 Status as of 1/13/2023 4:25 PM CST Associated Case Party: MELISSA TARVER Name BarNumber Email TimestampSubmitted Status Benny Agosto, Jr. bagosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT Ben Agosto III ben.agosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT Shari Welch swelch@awtxlaw.com 1/13/2023 3:28:22 PM SENT Mayra Valdes-Zavala mzavala@awtxlaw.com 1/13/2023 3:28:22 PM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Jennifer DAufricht jaufricht@thompsoncoe.com 1/13/2023 3:28:22 PM SENT Renee Smith Renee.Smith@thompsoncoe.com 1/13/2023 3:28:22 PM SENT Steven Joseph Kherkher 11375950 SKherkher—Team@KherkherGarcia.com 1/13/2023 3:28:22 PM SENT Michael Dale Hudlow 24007403 mhudlow@hdr-law.com 1/13/2023 3:28:22 PM SENT Robin Clay Hoblit 9743100 hdrccservice@hdr-Iaw.com 1/13/2023 3:28:22 PM SENT Elva Jasso ejasso@thompsoncoe.com 1/13/2023 3:28:22 PM SENT Dana Lisenby d|isenby@thompsoncoe.com 1/13/2023 3:28:22 PM SENT Christopher Hansen chansen@thompsoncoe.com 1/13/2023 3:28:22 PM SENT Jacob Karam jacob@thekaramlawoffice.com 1/13/2023 3:28:22 PM SENT Edward AFesteryga edward@awtxlaw.com 1/13/2023 3:28:22 PM SENT BENNY AGOSTOJR bagosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT Jessica Pulliam jessica.pulliam@bakerbotts.com 1/13/2023 3:28:22 PM SENT Susan Kennedy susan.kennedy@bakerbotts.com 1/13/2023 3:28:22 PM SENT Zachary Stone zachary.stone@bakerbotts.com 1/13/2023 3:28:22 PM SENT Kristin Sullivan Kristin.Sullivan@bakerbotts.com 1/13/2023 3:28:22 PM SENT Bruce Parkerson bparkerson@pmpllp.com 1/13/2023 3:28:22 PM 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. Godfrey Parkerson Bar No. 793106 bparkerson@pmpllp.com Envelope ID: 71796878 Status as of 1/13/2023 4:25 PM CST Case Contacts Debora Simonson debora.simonson@bakerbotts.com 1/13/2023 3:28:22 PM SENT Gadi Alvarado-Lopez gadi@thekaramlawoffice.com 1/13/2023 3:28:22 PM SENT Lena B.Laurenzo llaurenzo@awtxlaw.com 1/13/2023 3:28:22 PM SENT Ben Agosto Ill ben.agosto@awtxlaw.com 1/13/2023 3:28:22 PM SENT Lisa Schmidt LSchmidt@PMPllp.com 1/13/2023 3:28:22 PM SENT Briseida Martinez briseida@thekaramlawoffice.com 1/13/2023 3:28:22 PM SENT Associated Case Party: ATMOS ENERGY CORPORATION Name BarNumber Email TimestampSubmitted Status susan kennedy susan.kennedy@bakerbotts.com 1/13/2023 3:28:22 PM SENT Jordan Kazlow jordan.kazlow@bakerbotts.com 1/13/2023 3:28:22 PM SENT Jessica B. Pulliam jessica.pulliam@bakerbotts.com 1/13/2023 3:28:22 PM SENT Zachary Stone Zachary.Stone@bakerbotts.com 1/13/2023 3:28:22 PM SENT Salam Shaikh-Khalil salam.sheikh-khalil@bakerbotts.com 1/13/2023 3:28:22 PM SENT Brook Vaydik brooke.vaydik@bakerbotts.com 1/13/2023 3:28:22 PM SENT Associated Case Party: BOBCAT CONTRACTING, LLC Name BarNumber Email TimestampSubmitted Status Sarah HolleyLong Long EDocsNotifications@wbclawfirm.com 1/13/2023 3:28:22 PM SENT Associated Case Party: TAMMY BOEHLER Name BarNumber Email TimestampSubmitted Status Carmen S.Mitchell cmitchell@mitchellgoff.com 1/13/2023 3:28:22 PM 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. Godfrey Parkerson Bar No. 793106 bparkerson@pmpllp.com Envelope ID: 71796878 Status as of 1/13/2023 4:25 PM CST Associated Case Party: TAMMY BOEHLER Heather Teer hteer@mitchellgoff.com 1/13/2023 3:28:22 PM SENT Associated Case Party: MICHAEL GLOVER Name BarNumber Email TimestampSubmitted Status Bobbie Gilbert bgilbert@kv-law.com 1/13/2023 3:28:22 PM SENT Loren Klitsas klitsas@kv-law.com 1/13/2023 3:28:22 PM SENT