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: [email protected]; [email protected] 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. ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. 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 [email protected], [email protected], [email protected], [email protected], [email protected] Mark D Christiansen [email protected], [email protected], [email protected] Patranell Britten Lewis [email protected], [email protected], [email protected], [email protected] Robert N Barnes [email protected], [email protected], [email protected], [email protected] 5:12-cv-01319-D Notice has been delivered by other means to: The following document(s) are associated with this transaction: Page 1 of 2 Document description:Main Document Original filename:n/a Electronic document Stamp: [STAMP dcecfStamp_ID=1041971380 [Date=3/26/2015] [FileNumber=2980418-0 ] [1ce99bb4c1478ffb697ded2e9e6a90a723770e57b77515d032e5fa48888267f194c 41646e99c9220f649a374d443a0043392ebc20233ebe7a412b805e3561027]] Page 2 of 2
© Copyright 2024