Motion-Secondary: ANKOR E&P HOLDINGS CORPORATION vs. YAZOO VENTURE LLC

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                                BACHTELL ENTERPRISES, LLC,                                            IN THE DISTRICT COURT OF




Vv,

ANKOR E&P HOLDINGS CORPORATION,


Vv,                                                                     HARRIS COUNTY, TEXAS

YAZOO      VENTURE,    LLC,
CRAFT      OPERATING    COMPANY II, LLC,
CRAFT      OPERATING    COMPANY IV, LLC,
CRAFT      OPERATING    COMPANY XV, LLC,
CRAFT      OPERATING    COMPANY XVI, LLC,
CRAFT      OPERATING    COMPANY XXV, LLC,
CRAFT      OPERATING    COMPANY XXX, LLC,
                            ON COMPANY, LLC, §
                                                      §                  61ST JUDICIAL DISTRICT



            ANKOR’S RESPONSE AND MOTION                    TO TAKE JUDICIAL NOTICE

TO THE HONORABLE JUDGE OF SAID COURT:

        Plaintiff, ANKOR      E&P   Holdings   Corporation     (“ANKOR”)     files this its Response   to

Defendants Yazoo Venture, LLC, Craft Operating Company II, LLC, Craft Operating Company

IV, LLC,    Craft Operating Company      XV,   LLC,       Craft Operating Company    XVI,    LLC,   Craft

Operating   Company    XXV,    LLC,   Craft Operating       Company   XXX,    LLC,   Craft   Exploration




LLC (collectively, for ease of reference, the “Defendants”), as well as its own Motion to Take




        Defendants request that the Court take judicial notice of Ala. Code § 9-17-82 (1975) and

the testimony and proceedings before the State Oil and Gas Board of Alabama (““AOGB”).              As a
threshold         matter,      ANKOR         does        not     oppose         Defendants’      requests.

                                        NKOR’s Exhibit List as well.

        Specifically, Defendants ask the Court to take judicial notice of: (1) the testimony and

proceedings before the AOGB          on February 18, 2011; (2) the testimony and proceedings before

the AOGB    on September 29, 2011; and (3) the testimony and proceedings before the AOGB                  on




        In addition to this testimony and proceedings, ANKOR              requests that the Court take

judicial notice    of Orders   and   correspondence     from   the AOGB      on the following   dates:   (1)

September 21, 2010; (2) February 18, 2011; (3) June 20, 2012; and (4) February 25-29, 2016.

Copies of the Orders and correspondence for each of these dates is attached hereto as Exhibits A,




        Accordingly,        ANKOR    requests that the Court take judicial notice of the Orders          and




                                                     OHNSON               URISKY
                                                    A Professional Corporation

                                                       /s/ Millard A. Johnson
                                                        Millard A. Johnson

                                                        mjohnson@jdkglaw.com
                                                        Brad L. DeLuca




                                                        ssherman@jdkglaw.com
                                                        Stacy L. Paltiyevich
                                                        spaltiyevich@jdkglaw.com
Houston, Texas 77010

                                                 (713) 652-5130 — Fax

                                            ATTORNEYS       FOR    ANKOR     E&P   HOLDINGS




                               CERTIFICATE OF SERVICE

       The undersigned hereby certifies that a true and correct copy of the foregoing document
was served on all counsel of record in accordance on the 7th day of January, 2020 in accordance




        van.moeller@arlaw.com
       Aaron McLeod
       aaron.mcleod@arlaw.com
         DAMS   AND
       LyondellBasell Tower
       1221 McKinney St., Suite 4400
       Houston, Texas 77010
       Facsimile: (713) 652-5152

       Attorneys for Defendants




                                                   /s/ MillardA.   Johnson
                                                   Millard A. J