HomeMy WebLinkAboutContract 45030 (2)CANTEY HANGER LLP
ATTORNEYS
RALPH H. DUGGINS
DIRECT: 817.877.2824
EMAIL: RDUGGINS@CANTEYHANGER.COM
October 3, 2013
City of Fort Worth
c/o Tom Higgins
City Manager
1000 Throckmorton Street
Fort Worth, Texas 76102
Attention: Sarah J. Fullenwider, City Attorney
Ladies and Gentlemen:
Ch.)" OECMARY
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CANTEY HANGER PLAZA
600 WEST 6TH STREET, SUITE 300
FORT WORTH, TEXAS 76102-3685
817.877.2800 - METRO 214.978.4199
FAX: 817.877.2807
Thank you for contacting me ("Attorneys") about pursuing claims against
Chesapeake Exploration, L.L.C., its affiliates ("Chesapeake") and Total E & P USA, Inc.
and its affiliates ("Total") for underpayment of royalties due under various oil and gas
leases to which the City of Fort Worth is Lessor and Chesapeake and/or Total are Lessee
or successor Lessee. We agree to represent the City against Chesapeake and Total for the
purpose of recovering any underpayment of royalties under the Leases and otherwise
pursuing rights the City has or may have under those same Leases on a contingency fee
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basis.
You agree that we do not and cannot guarantee a successful outcome of any claim.
While we plan to vigorously prosecute any claims the City may have, you also
acknowledge that the Attorneys have little control over the administration by a court of
its docket and that dockets are generally crowded.
In consideration of the legal services to be rendered to the City by the Attorneys,
the City assigns and grants to the Attorneys as fees 3 3 -1 /3 % of any and all amounts or
value received by the City, whether by way of settlement, or judgment from a court. In
addition, the City agrees to pay from its portion of any recovery the costs and expenses
incurred by. Attorneys. These include filing fees, court costs, deposition costs, costs for
testifying and consulting experts, discovery, and damage calculation costs, copying costs
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City of Fort Worth
October 3, 2013
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($.10 per page) and Attorneys' travel expenses Because the claims against Chesapeake
and Total are claims for which a court may award attorneys' fees, if attorneys' fees are
awarded and are greater than the amount owed under this contingency fee arrangement,
the City agrees to pay the attorneys the amount awarded by the court and collected as the
attorneys' fees for the legal services rendered in lieu of one-third of any and all amounts
or value received by the City.
In lieu of the proposed contingency fee arrangement, you understand that
Attorneys could have been hired on an hourly basis and that an engagement on an hourly
basis would have required payment of fees regardless of whether or not the City is
successful in the pursuit of its claims and that a contingency fee, if owed, may result in
the payment of attorneys' fees that are greater than those that would have been paid if the
matter had been handled on an hourly basis.
Any offers of settlement will be promptly communicated to the City and no
settlement of the City's claims will be made without the City's prior approval.
The City may discharge us as attorneys at any time. However, if the City elects to
discharge us as attorneys, it agrees that Attorneys will retain an interest in the City s
claims as set forth in paragraph 1, provided we have not been discharged for malfeasance
or negligence that materially damaged the City's claims.
The City acknowledges it has a copy of the Texas Lawyers Creed and understands
that Attorneys are committed to abide by that Creed. The State of Bar investigates and
prosecutes professional misconduct by Texas attorneys. Although not every complaint or
dispute with an attorney involves professional misconduct, the Office of General Counsel
of the State Bar will provide information on how to file a complaint. Please call 1-800-
932-1900 for more information.
The City agrees to cooperate with the Attorneys by making staff familiar with the
Leases and the payment of royalties and records pertaining to those matters available to
Attorneys upon reasonable notice. Please remember that most communications between
City officials and the Attorneys relating to the claims against Chesapeake and Total are
confidential and protected from disclosure by the attorney -client privilege. That privilege
can potentially be lost, and some or all communications between us may be discovered, if
the communications are disclosed to a third party.
Under Texas and Federal Rules of Civil Procedure and Rules of Evidence, it is
critical to preserve potentially relevant information once litigation is reasonably
City of Fort Worth
October 3, 2013
Page 3 of
anticipated or commenced because the failure to comply with those rules can have dire
consequences (including sanctions ranging from monetary penalties to much more severe
penalties, including dismissal of the action). If it has not already done so, it is essential
that the City immediately preserves until further notice any information pertaining to any
of the leases at issue, including all external or internal communications concerning those
leases. In the event you have not already issued a litigation hold in this matter, we
request that you immediately do so. As part of that hold, please take care to discontinue
any routine deletion or archival processes that might inadvertently delete or destroy any
electronic or other information. Please let me know if you would like assistance in
instituting a litigation hold.
The City agrees that Attorneys' communications with the City with respect to this
matter shall be made through Sarah J. Fullenwider, City Attorney, and/or Gerald Pruitt,
Deputy City Attorney.
The City agrees that Attorneys may, at their sole discretion, engage or employ
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other attorneys, including John Cardwell, to work with Attorneys in connection with the
engagement. Attorneys agree that all fees and expenses owed to such attorneys,
including John Cardwell, will be the sole responsibility of Attorneys and that the City
shall have no responsibility whatsoever for such fees or expenses.
This Agreement contains all of the terms of the financial arrangement between the
City and the Attorneys and can only be modified by a written document signed g by an
authorized representative of the City and by the Attorneys.
The engagement is effective October 1, 2013.
City of Fort Worth
By:
Tom Higgins
City Manager
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roved as to form and legality:
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Sarah/J. Fullenwider
Attorney
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Ralph H. Duggins