`Van Buren County Circuit Court
`Debbie Gray, Circuit Clerk
`2017-Aug-03 15:58:26
`71CV-10-299
`C20D02 : 2 Pages
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`DANNY C. WOOD and
`REBECCA S. WOOD
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`V.
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`KCS RESOURCES, LLC, et al.
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`IN THE CIRCUIT COURT OF VAN BUREN COUNTY, ARKANSAS
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`PLAINTIFFS
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`CASE NO.: CV 2010-299-5
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`DEFENDANTS
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`SEPARATE DEFENDANTS KCS RESOURCES LLC, PETROHAWK
`OPERATING COMPANY, XTO ENERGY INC., AND EXXON MOBIL
`CORPORATIONS’ RESPONSE TO PLAINTIFFS’ PETITION
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`Comes now, KCS Resources LLC, Petrohawk Operating Company, XTO Energy Inc.
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`and Exxon Mobil Corporation (“Separate Defendants”) by and through their undersigned
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`attorneys, and for their Response to Plaintiffs’ Petition, state as follows:
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`1.
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`Separate Defendants move to adopt and incorporate by reference the response
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`filed by all other defendants in opposition to Plaintiffs’ petition, pursuant to Ark. R. Civ. P. 10(c).
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`Pleading in the affirmative, Separate Defendants request that the petition be denied.
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`WHEREFORE, premises considered, Separate Defendants KCS Resources LLC,
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`Petrohawk Operating Company, XTO Energy Inc. and Exxon Mobil Corporation respectfully
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`request that the court deny the Plaintiffs’ petition, and award separate defendants their costs and
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`attorney’s fees and for all other relieve they may be entitled to receive.
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`Respectfully submitted,
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`PPGMR LAW, PLLC
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`/s/ James D. Rankin III
`G. Alan Perkins (AR Bar #91115)
`Alan@ppgmrlaw.com
`James D. Rankin III (AR Bar #93157)
`jim@ppgmrlaw.com
`P.O. Box 251618
`Little Rock, AR 72225-1618
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`Phone: 501-603-9000
`Facsimile: 501-603-0556
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`Attorneys for Defendants, KCS Resources and
`Petrohawk Operating Company, XTO Energy
`Inc. and Exxon Mobil Corporation
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`CERTIFICATE OF SERVICE
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`C. Michael Daily
`Daily & Woods, PLLC
`PO Box 1446
`Fort Smith, AR 72902
`mdaily@dailywoods.com
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`I hereby certify that on this 3rd day of August, 2017, I electronically filed the
`foregoing with the Clerk of the Court, which shall send notification of such filing and service
`will be made via e-mail and US mail to the following:
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`Stephen C. Gardner
`Stephen C. Gardner, P.A.
`PO Box 866
`203 West Third Street
`Russellville, AR 72811
`scg@suddenlink.net
`Attorney for Plaintiffs
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`Howard Yates
`Attorney at Law
`P.O. Box 190
`Morrilton, AR 72110
`hcyatt@suddenlinkmail.com
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`Larry E. Graddy
`Attorney At Law
`P.O. Box 996
`Conway, AR 72033
`larry@faulknercountytitle.com
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`M. Edward Morgan
`Morgan Law Firm, P.A.
`148 Court Street
`Clinton, AR 72031
`eddie@medwardmorgan.com
`M. Charles A. Morgan
`M. Wade Kimmel
`Dunn, Nutter & Morgan, LLP
`3601 Richmond Road
`Texarkana, TX 75503
`camorgan@dnmlawfirm.com
`mwkimmel@dnmlawfirm.com
`Attorneys for Cosden Defendants
`J. Mark Robinette
`Law Offices of Mark Robinette
`PO BOX 251613
`Little Rock, AR 72225
`mrobinette@robinettefirm.com
`Attorney for Ridge Rocktx., LLC
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`/s/ James D. Rankin III
`James D. Rankin III
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`Joel Johnson
`Hayes, Alford & Johnson, PLLC
`700 South 21st Street
`Ft. Smith, AR 72901
`joel@hajattorneys.com
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`Randall Gammill
`P. O. Box 532
`Lonoke, AR 72086
`gammill@centurytel.net
`Attorney for MAP 2006-OK, AN
`OKLAHOMA GENERAL
`PARTNERSHIP
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