BEFORE THE CORPORATION COMMISSION OF THE STATE OF OKLAHOMA F APPLICANT: REBELLION ENERGY, LLC RELIEF SOUGHT: POOLING CAUSE CD NO. 201700827-T LEGAL DESCRIPTION: SECTION 21, TOWNSHIP 6 NORTH, RANGE 6 WEST, GRADY COUNTY, OKLAHOMA follows: COMES NOW Applicant and shows the Honorable Corporation Commission as 1. Parties: Applicant is Rebellion Energy, LLC, 5416 S. Yale, Ste. 300, Tulsa, Oklahoma 74135, who is the owner of the right to drill a well to the common sources of supply named below underlying the lands described in the caption hereof by virtue of valid and subsisting oil and gas leases owned by Applicant covering portions of said land. The name of each party being made a respondent to this Application is as shown on Exhibit "A", attached hereto and made a part hereof. 2. Allegation of Facts: a. The land described in the caption hereof constitutes a "drilling and spacing unit", as defined by Title 52, Section 87.1, O.S., and as heretofore established by the Commission by order to issue in Cause CD No. 201700494-T for the common sources of supply also named below; within said "drilling and spacing unit", there are two or more separately owned tracts or there are undivided interests separately owned for which the owners have not agreed to pool their oil and gas interests and to drill and develop the "drilling and spacing unit" and common sources of supply as a unit. b. Applicant has conducted a diligent and meaningful search of the local county assessor's records, county treasurer's records, and county deed records regarding the property involved for return addresses on recorded instruments, county probate records and city and county telephone directories and other sources of such information to locate each respondent and has made a bona fide effort to reach an agreement as to the development of the unit with each respondent located by such search. C. Applicant has drilled or proposes to drill a well on said "drilling and spacing unit" to test the common source of supply named below and the avoiding of the drilling of unnecessary well, the prevention of waste, and the protection of correlative rights require that the Commission order all owners to pool their interests and to drill and developthe "drilling and spacing unit" and common source of supply as a unit 3 Legal Authority Title 52, Section 87 1, 0.S. I \REBELLION ENERGY\2259 29 PLG\2259 29 doc
PAGE 2 4. Relief Sought: Applicant requests that the Commission pool the interests and adjudicate the rights and equities of oil and gas owners in the Mississippian, Woodford and Hunton common sources of supply underlying the 640-acre drilling and spacing unit described as Section 21, Township 6 North, Range 6 West, Grady County, Oklahoma all to be upon such terms and conditions as are just and reasonable and which will afford all of such owners the opportunity to recover or receive without unnecessary expense their just and fair share of all hydrocarbon substances produced therefrom; that the Commission make definite provisions for the payment of all actual costs and expenses, not to exceed reasonable costs and expenses of drilling and development, including a reasonable charge for supervision and designate Applicant or some other party as operator of the proposed well and all subsequent wells drilled in the unit; and that the Applicant be given one year to commence operations for the drilling or other operations with respect to the unit covered hereby. WHEREFORE, Applicant prays that, after notice and hearing as required by law, all oil and gas interests be pooled and the rights and equities of all oil and gas owners be adjudicated. Respectfully submitted, BARNES LAW, PLLC 1648 S. Boston Ave., Ste. 100 Tulsa, Oklahoma 74119 ron@barneslawtulsa.com graysonbarneslawtulsa.com 918/382-8686 918/382-8685 facsimile By: 121 Ron M. Barnes OBA #534 Grayson Barnes, OBA #31475 Attorneys for Rebellion Energy, LLC L:\REBELLION ENERGY\2259-29 PLG\2259-29.doc
PAGE 3 CERTIFICATE OF MAILING/CERTIFICATE OF SERVICE The undersigned, of lawful age, being first duly sworn upop.,oath, states: I am the Attorney for the above-named Applicant. I certify that on or before the 51ay of February, 2017 I mailed by Certified United States mail, proper postage prepaid thereon, a copy of the Notice of Hearing on file in this Cause and this Application to the respondents named on the Exhibit "A" attached to this Application, at their respective mailing addresses. That Applicant has, with due diligence and after inquiry of every possible source for information, attempted to locate the names and addresses of all respondents that should be receiving notice of this hearing before the Corporation Commission. For respondents that Applicant does not know and cannot ascertain whether an individual respondent(s) are living or deceased, or respondent(s) with a last known address that are no longer deliverable, or whether a corporation(s) or other business entities respondent(s) are existing, Applicant desires to obtain service by publication upon said respondents whose addresses are unknown or are undeliverable. a " Ron M. Barnes, OBA #534 Grayson Barnes, OBA #31475 - - L:\REBELLION ENERGY\2259-29 PLG\2259-29.doc
PAGE 4 EXHBIT "A" 1. BMNW Resouces, LLC P0 Box 180573 Dallas, TX 75218 2. BOKF Petro Holding, LLC 5956 Sherry Ln, Ste 1100 Dallas, TX 75225 3. Charles RFoster 13309 Lake Clarice Dr Windermere, FL 34786 4. Chesapeake Exploration, LLC, Successor to Canaan Energy Corporation P0 Box 18496 5. Chesapeake Exploration, LLC, Successor to Chesapeake Exploration, LP P0 Box 18496 Oklahoma City, OK 73154 6. Command Investments, Inc do Bert Maxwell, III 15820 Knott Trail Dr, Apt 612 Dallas, TX 75248 7. Connie Morris 8446 State Highway 19 Ada, OK 74820 8. Crawley 1991 Investors, LP 105 N Hudson Ave, Ste 800 9. Crawley Petroleum Corporation 105 N Hudson Ave, Ste 800 10. Eagle Oil & Gas Co 5950 Berkshire Ln, Ste 1100 Dallas, TX 75225 11. Elite Enterprises Limited Partnership do Ronald W Robinson P0 Box 52571 Tulsa, OK 74152 12. Fanny Goldberg Haberfeld do Bruce Malkin 954 Hays Rd Heber Springs, AR 72543 13. Flora Kennedy Cowgill, deceased do Elizabeth Evans Ache 13311 Apple Tree Rd Houston, TX 77079 14. Gasconade Partners do Heritage Trust Company 2802 W Country Club Dr Oklahoma City, OK 73116 15. Genesis Production Co 1100 Raiford Rd, #1301 Carrollton, TX 75007 16. Guardian Energy Consultants, Inc 321 S Frankfort Ave Tulsa, OK 74120 17. Heirs, Successors, Devisees, and Assigns of Jimmie R Wenzel do Jimmie Ray Wenzel, II 1876 Silverstone Blanchard, OK 73010 L:\REBELLION ENERGY\2259-29 PLG\2259-29.doc
PAGE 5 EXHIBIT "A" 18. Heirs, Successors, Devisees, and 26. Latex Petroleum Corp Assigns of Mary Anita Dahl, do Frank A Lodzinski Deceased 18726 White Candle Dr do Mary Ann Voreck Spring, TX 77388 3461 County St 2780 Cement, OK 73017 27. Linda A Martin 818 W Alabama Ave 19. Heirs, Successors, Devisees, and Chickasha, OK 73018 Assigns of Nellye N Parks, deceased do James Parks 28. Mary Ann Vorack P0 Box 1628 3461 County St 2780 Huntsville, AR 72740 Cement, OK 73017 20. Heirs, Successors, Devisees, and Assigns of Robert Owen Penny, deceased do Gary W Penny 2216B 35th St Los Alamos, NM 87544 21. Jaco Production Company P0 Box 82515 Bakersfield, CA 93380 22. James Parks P0 Box 1628 Huntsville, AR 72740 23. Jerry Wayne Speer, Individually, and as Trustee of the Jerry Wayne Speer Revocable Living Trust dated 12/8/2011 2205 13th St SW Great Falls, MT 59404 24. Joe Cassody P0 Box 702516 Tulsa, OK 74170 29. Mollen Holdings, Inc 105 N Hudson Ave, Ste 535 30. Occidental Oil & Gas Corp, Successor to Vintage Petroleum, LLC, Successor to Vintage Petroleum, Inc 5 Greenway Plaza, Ste 110 Houston, TX 77046 31. Pamela K Shropshire and Johnna F Stephens, Co-Trustees of the Linda A Martin Revocable Trust dated 10/31/2013 818 W Alabama Ave Chickasha, OK 73018 32. PDI, Inc 105 N Hudson Ave, Ste 800 33. Royal Rose, LLC 3102 Carolina Ave Chickasha, OK 73018 25. Lana Karen Garcia 12508 SW 4th St Yukon, OK 73099 L:\REBELLION ENERGY\2259-29 PLG\2259-29.doc
PAGE 6 EXHIBIT "A" 34. PW/Geodyne Production Parternship 41. 'I-C do Samson Resources Company 2 W 2nd St Tulsa, OK 74103 35. PW/Geodyne Production Parternship II-D 42. do Samson Resources Company 2 W 2nd St Tulsa, OK 74103 36. cause is uncontested, th 2 W 2nd St Tulsa, OK 74103 37. Terra Rosa Royalty Corporation P0 Box 133155 Spring, TX 77393 38. Unknown Heirs, Successors, Devisees, and Assigns of Carolyn Ann Wittman, now Schmidt 4051 Vetem's Blvd, Ste 202 39. Unknown Heirs, Successors, Devisees, and Assigns of Clifton Voss, deceased do Andrea Elizabeth Voss Finklestein 1001 State St New Orleans, LA 70118 Unknown Heirs, Successors, Devisees, and Assigns of George Wade Wittman, Deceased Unknown Heirs, Successors, Devisees, and Assigns of George Wittman, deceased 43. Unknown Heirs, Successors, Devisees, and Assigns of Helen Lorain Thornburg 44. Unknown Heirs, Successors, Devisees, and Assigns of Hugh J Evans do Elizabeth Ache 13311 Apple Tree Rd Houston, TX 77079 45. Unknown Heirs, Successors, Devisees, and Assigns of Jack Bernard Wittman 40. Unknown Heirs, Successors, Devisees, and Assigns of Elizabeth Kennedy Evans, deceased do Elizabeth Ache 13311 Apple Tree Rd Houston, TX 77079 46. Unknown Heirs, Successors, Devisees, and Assigns of Nellie Wittman, deceased Address Unknown L:\REBELLION ENERGY\2259-29 PLG\2259-29.doc
PAGE 7 EXHIBIT "A" 47. Unknown Heirs, Successors, Devisees, and Assigns of Rema Sessions Emerson do Melissa Keplinger 512 N Caldwell Way Mustang, OK 73064 48. Wendell and Kari Holland P0 Box 30282 Edmond, OK 73003 49. Wyncote Corp do A Dutton Kennedy, III, President P0 Box 1350 Ocean City, NJ 08226 ADDRESS UNKNOWN Helen Barnes If Any Named Person Is Deceased, Then The Known Or Unknown Heirs, Executors, Administrators, Trustees, Devisees, And Assigns, Immediate And Remote Of Such Decedent, Are Made Respondents To This Application. If Any Named Respondent Is A Corporation Which Does Not Continue To Have Legal Existence, Then The Known Or Unknown Successors, Trustees Or Assigns, If Any Of Such Entity, Are Made Respondents To This Application. FOR ADMINISTRATIVE PURPOSES ONLY 50. Alisha Stacy Rebellion Energy, LLC 5416 S. Yale Ave., #300 Tulsa, OK 74135 L:\REBELLION ENERGY\2259-29 PLG\2259-29.doc