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`IN THE CIRCUIT COURT OF VAN BUREN COUNTY, ARKANSAS
`
`DANNY C. WOOD AND REBECCA S. WOOD
`
`PLAINTIFFS
`
`V.S
`
`CV-2010—299-5
`
`KCS RESOURCES, LLC, et aI
`
`DEFENDANTS
`
`
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`PLAINTIFFS' RESPONSE TO COUNTER MOTION FOR SUMMARY JUDMENT
`
`Come now the Plaintiffs, and for their Response to the Counter Motion for
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`summary Judgment filed by Ridge Rocktx, LLC, KCS Resources, LLC, Petrohawk
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`Operating Company, XTO Energy, Inc., Exxon Mobil Corporation, SEECO, |nc., BP
`
`America Production Company, Chesapeake Exploration, BHP Billiton (Fayetteville) LLC,
`
`and the Cosden Defendants, states as follows:
`
`1.
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`Plaintiffs state that they are entitled to Partial Summary Judgment as a
`
`matter of law as set forth in their motion; further, Plaintiffs deny that the evidence clearly
`
`establishes that at the time of the 1929 mineral severances, E.M. Graham and MP.
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`Graham were owners of the entire NW % NW 1A.
`
`2.
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`The Plaintiffs deny that they possess no ownership interest in the minerals
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`underlying the NW % NW 1A of Section 8, Township 9 North, Range 13 West.
`
`3.
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`Further, Plaintiffs allege that there are no genuine issues of material fact
`
`concerning their ownership of the oil, gas and minerals under the subject lands; and that
`
`their Motion for Partial Summary Judgment should be granted; but that there are
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`genuine issues of material fact concerning all other defendants' ownership of the oil, gas
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`and other minerals, and their Counter Motion for Summary Judgment should be denied.
`
`WHEREFORE, premises considered, the Plaintiffs, Danny C. Wood and
`
`Rebecca S. Wood, pray that the defendants Counter Motion for Summary Judgment be
`
`denied; that the Plaintiffs' Motion for Partial Summary Judgment should be granted
`
`finding the Plaintiffs to be the owners of all of the oil, gas and minerals under the subject
`
`lands, together with any and all other relief to which the Court may find them entitled.
`
`DANNY C. WOOD AND REBECCA S. WOOD.
`Plaintiffs”,
`
`Stephen C. Gardner
`
`STEPHEN C. GARDNER, P.A.
`Attorney at Law
`P.O. Box 866
`
`Russellville, AR 72811
`(479)968-5333
`
`
`
`
`
`
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`CERTIFICATE OF SERVICE
`
`I, Stephen C. Gardner, do hereby certify that l have forwarded a copy of the above
`and foregoing pleading to the following on this I,
`2 day of April, 2013.
`
`C. Michael Daily
`Daily & Woods, PLLC
`PO Box 1446
`Fort Smith, AR 72902
`mdaily@dailywoods.com
`
`Gregory lvester
`Perkins & Trotter, PLLC
`PO Box 251618
`Little Rock, AR 72225
`givester@perkinstrotter.com
`
`M. Edward Morgan
`Morgan Law Firm, PA.
`148 Court Street
`Clinton, AR 72031
`eddie@medwardmorgan.com
`
`J. Mark Robinette
`Robinette Law Firm
`PO Box 251613
`
`Little Rock, AR 72225
`mrobinette@robinettefirm.com
`
`Joel D. Johnson
`
`Hayes, Alford & Johnson, PLLC
`PO Box 11470
`
`Fort Smith, AR 72901
`
`ioel@haiattorneys.com
`
`Larry E. Graddy
`Attorney at Law
`PO. Box 996
`Conway, AR 72033
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`
`Charles A. Morgan
`Dunn, Nutter & Morgan, LLP
`3601 Richmond Road
`Texarkana, TX 75503
`camorgan@dnmlawfirm.com
`
`Howard Yates
`Attorney at Law
`PO. Box 190
`Morrilton, AR 72110
`hcyatt@suddenlinkmail.com
`
`Randall L. Gammill
`Gammill & Gammill
`PO Box 532
`
`Hazen, AR 72064
`ammill
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`f a? g; 25%; £2
`
`Stephen C. Gardner
`
`
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