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Case 5:12-cv-01319-D Document 45 Filed 03/26/15 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF OKLAHOMA
Chieftain Royalty Company, on behalf )
of itself and all others similarly situated, )
)
Plaintiff,
)
)
v.
)
)
Laredo Petroleum, Inc.,
)
)
Defendant.
)
_________________________________ )
Case No. CIV-12-1319-D
CLASS REPRESENTATIVE’S MOTION FOR APPROVAL OF
ATTORNEYS’ FEES, REIMBURSEMENT OF LITIGATION EXPENSES
AND CASE CONTRIBUTION AWARD
Class Representative, Chieftain Royalty Company, individually and on behalf of
the Settlement Class preliminarily certified by the Court’s Order dated December 29,
2014 (Dkt. No. 40), and Nix, Patterson & Roach, LLP and Barnes & Lewis, LLP
(collectively, “Class Counsel”) respectfully file this Motion for Approval of Attorneys’
Fees, Reimbursement of Litigation Expenses and Case Contribution Award (the
“Motion”), and hereby move this Court for entry of an Order approving:
1.
Class Counsel’s request for attorneys’ fees;
2.
Class Counsel’s request for reimbursement of Litigation Expenses; and
3.
Class Representative’s request for a Case Contribution Award.
Class Representative and Class Counsel base this Motion on the Memorandum of
Law in Support of this Motion and exhibits thereto, the Declaration of Bradley E.
Beckworth and Robert N. Barnes on Behalf of Class Counsel, the applicable law, and all
Case 5:12-cv-01319-D Document 45 Filed 03/26/15 Page 2 of 3
pleadings, declarations, and records on file in this matter, which are respectfully
incorporated by reference as if set forth fully herein. Class Representative and Class
Counsel will submit a Proposed Order Awarding Attorneys’ Fees, Litigation Expenses
and Case Contribution Award (the “Proposed Fee Order”) to the Court, along with their
reply submission, if any, on or before April 23, 2015.
Accordingly, Class Representative and Class Counsel respectfully request the
Court enter the Proposed Fee Order granting the relief listed above and grant any further
relief to which the Court finds Class Representative and Class Counsel entitled.
Dated: March 26, 2015
Respectfully submitted,
/s/ Bradley E. Beckworth
Bradley E. Beckworth, OBA #19982
Jeffrey J. Angelovich, OBA #19981
Susan Whatley, OBA #30960
Lisa Baldwin
Texas Bar No. 24069334
NIX PATTERSON & ROACH, LLP
205 Linda Drive
Daingerfield, TX 75638
(903) 645-7333
(903) 645-4415 (facsimile)
Robert N. Barnes, OBA #537
Patranell Britten Lewis, OBA #12279
BARNES & LEWIS, LLP
720 NW 50th Street, Suite 200 B
Oklahoma City, OK 73118
Telephone: (405) 843-0363
Facsimile: (405) 843-0790
E-mail: rbarnes@barneslewis.com;
plewis@barneslewis.com
CLASS COUNSEL AND
ATTORNEYS FOR CLASS
REPRESENTATIVE
2
Case 5:12-cv-01319-D Document 45 Filed 03/26/15 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that I authorized the electronic filing of the foregoing with the
Clerk of the Court using the CM/ECF system, which will send email notification of such
filing to all registered parties.
I certify under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
DATED: March 26, 2015.
/s/ Bradley E. Beckworth
Bradley E. Beckworth
3
Thursday, March 26, 2015 1:55 PM
This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT
RESPOND to this e-mail because the mail box is unattended.
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U.S. District Court
Western District of Oklahoma[LIVE]
Notice of Electronic Filing
The following transaction was entered by Beckworth, Bradley on 3/26/2015 at 1:51 PM CDT and filed
on 3/26/2015
Case Name:
Chieftain Royalty Company v. Laredo Petroleum Inc
Case Number:
5:12-cv-01319-D
Filer:
Chieftain Royalty Company
WARNING: CASE CLOSED on 04/30/2013
Document Number: 45
Docket Text:
MOTION for Attorney Fees Class Representative's Motion for Approval of Attorneys'
Fees, Reimbursement of Litigation Expenses and Case Contribution Award by
Chieftain Royalty Company. (Beckworth, Bradley)
5:12-cv-01319-D Notice has been electronically mailed to:
Bradley Earl Beckworth bbeckworth@nixlawfirm.com, andreab@nixlawfirm.com,
shelley@nixlawfirm.com, susanwhatley@nixlawfirm.com, treyduck@nixlawfirm.com
Mark D Christiansen mark.christiansen@mcafeetaft.com, Marianne.Jackson@mcafeetaft.com,
sandy.lewis@mcafeetaft.com
Patranell Britten Lewis plewis@barneslewis.com, abarnes@barneslewis.com,
lbeebe@barneslewis.com, lrosales@barneslewis.com
Robert N Barnes rbarnes@barneslewis.com, abarnes@barneslewis.com, lbeebe@barneslewis.com,
lrosales@barneslewis.com
5:12-cv-01319-D Notice has been delivered by other means to:
The following document(s) are associated with this transaction:
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Document description:Main Document
Original filename:n/a
Electronic document Stamp:
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