HomeMy WebLinkAboutContract 45288 4 f'S'EMMY,-
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WRMW.
CANTEY HANGERLL.P
TRN
RALPH K,OUGGINS CA TEY HANGER PLAZA
817,877,2824 600 WEST 6TH STREET",SUITE 300
EMAIL GGI S NTEMANGER.COM ORT WORTHj TEXAS 76,x,02-.,3685
817.8" 7'.2 800 MET 214 7 , 1
FAX,817,877,2807
December 19, 2013
Fob Worth Local, Development or orat
c/o Danny Scarth
President
100,0 Throckmorton Street
Fort Worth, Texas 76102
Attention Sarah Ful enwide , City Attorney
Ladies and Gentlemen,
Thank you for contacting ( 'Attorneys"') pursuing claims ns
Chesapeake ("Chesapeake"')
and its affiliates ("'Total"), for underpayment of royalties due under various oil and gas
leases to which the Fort Worth Local Development Corporation
and Chesapeake and/or Total are Lessee or successor Lessee. We agree to represent the
FWLDC against Chesapeake and Total for the purpose of recover"nunderpayment
of royalties under the Leases and pursuing i "
der those same Leases on a contingency tee basis.
You agre e that we do, not and cannot guarantee a successful outcome of any c a
While we plan to vigorously prosecute any claims FWLDC may have, you also
acknowledge that the Attorneys fittle o trot over the a 1s o by a court of
its docket and that dockets are generally crowded.
legal In consideration of the services to rendered to the Attorneys,
FWLDC assigns grants to the Attorneys as fees 33 % of any and all amounts or
value received by FWLDC, whether by way of settlement, or judgment from a court. I
addition, FWLDC agrees to pay from its, portion of any recovery the data expenses
incurred by Attorneys. These include filing fees, court costs, deposi-Ition costs, costs for
te "
stify
ing and consulting experts, discovery, and damage calcination costs, copying costs
MIRITAS LAW FIRMS WORLDWIDE RECEIVED JAN 14 2014
Fort Worth Local Development Corporation
December 19,20113
Page 2 of 3
(x,10 per page) and Attomeys' 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,
FWLDC agrees to pay the attorneys the amount awarded by the court and colliected as the
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attorneys' fees for the legal services rendered in lieu of one-third of any and all amounts
or value received by FWLDC.
In lieu of the proposed contingency fee arrangement, you understand, that
Attu Sys 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 FNVLD,C 'i's
4 MI
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,. I
Any offers of settlement will be promptly communicated to F and no
settlement of FVVLDC's claims will be made without FV&DC's prior approval.
FWLDC may discharge us as attorneys at any time. However, 1fFWLDC elects, to:
discharge us as attorneys, it agrees that Atttarneys, will retain an interest in FWI.,L1C's
claims as set forth in paragraph 1, provided we have not been discharged for malfeasance
or negligence that materially damaged FWLD,C's claims,
FWLDC 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
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prosecutes professional misconduct by Texas attorneys. Although not every complaint or
dispute with an att involves professional misconduct, the Ot'ficc of General Counsel
orney
of the State Bar will provide information on how to file a complaint,. Please call 1-801O"
93249001 for mom,, 'Information.
FWLI) 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 pnvxlege. 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 'I's
critical to preserve potentially relevant information nformation once litigation is reasonably
Fort Wort,Local Development Corporation
December 19, 2013
Page 3 of 3
antic 0 ,ated or commenced because the failure to comply with those rules can 'have dire
, IP
consequences ('Including sanctions ranging from monetary penalties to much more severe
penalties, 'including disr�issal of the action). If it has not already done so, i is essential,
01 A inforn�a�kia�a x P that F'V&DC immediately preserves until furthcr notice any pertaining to any
issue, including 0 of the leases at all external or internal communicat ions conceming those
lases. 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 zf you would like assistance In
I
Instituting a litigation hold.
FWLDC agrees that Attorneys' communications, with FWLDC with respect to this
matter shall be made through Sarah J. Fullenwider, City Attorney, and/or Gerald Pruitt,
Deputy City Attorney.
FWLLIC agrees that Attorneys may, at their sole discretion, engage or employ
1P a I
other: attorneys, including John Cardwell, to work with Attom/ eys in connecuon with the
engagement. Attorneys agree that all fees and expenses owed to such attorneys,
including John Cardwell, will bE', the sole responsibiliy of Atorn ys and Mh a
t FWLD,C
shall have no responsibility whatsoever for such fees orexpenses.
Th s Agreement contains all of the terms of the financial arrangement between
FWT.DC and the Attorneys and can only be modified by a written document signed by an
authorized representati've of F'WLDC and by the Attorneys,.
xs The en a e ectiv, e Octobe-r 1, 2013.
Fort girth GSA. velo... nt C9TpATat1Qn:
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By* VMM z
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.......................
� Ralph H. Ltugglj
...........................
President
A� � �.� to Lorna. and legality:
01,7411c,
Sarah , Fullen-widez
ftorney Of Oft F O
A Y� �� 60100
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f y Secretary 00
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