6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 1 of 14 EXHIBIT 9
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1 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 1 of 14 EXHIBIT 9 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA JOHN CECIL, on behalf of himself and all others similarly situated, Plaintiff, Civil Action No. 16-CV KEW vs. BP AMERICA PRODUCTION COMPANY (f/k/a Amoco Production Company) (including BP Amoco Corporation, ARCO, BP Exploration, Inc., BP Corporation North America, Inc., and BP Energy Company), Defendant. DECLARATION OF DANIEL T. REINEKE VALUATION OF PAST AND FUTURE SETTLEMENT BENEFITS I, Daniel T. Reineke, declare as follows: 1. Class Counsel engaged my services as an expert to aid in evaluating the damages incurred from Defendants alleged underpayment of royalties and in evaluating the proposed Settlement, including the value of past benefits and discounted present value of the future royalties provision in the Settlement Agreement. Settlement Agreement, ECF No at As such, I have personal knowledge of and am competent to provide the facts stated in this declaration. 2. I have a Bachelor of Science Degree from Colorado School of Mines and am a registered Petroleum Engineer, No , in the State of Oklahoma. I possess over 43 years of oil and natural gas industry experience in both the Mid-Continent and Rocky Mountain Regions of the United States. During that time, I have served as operator, drilling engineer, 1
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5 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 5 of 14 CV DANIEL T. REINEKE 3/1/2018 EDUCATION: Bachelor of Science Degree in Petroleum Engineering Colorado School of Mines, May 1975 PROFESSIONAL: Registered Professional Engineer - Oklahoma PE #15820 Utah PE # AFFILIATIONS: ADDRESS: Member Society of Petroleum Engineers BUSINESS 6900 North Classen Blvd. Oklahoma City, OK PHONE: PHONE: BUSINESS CELL
6 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 6 of 14 PROFESSIONAL HISTORY: Employment Summary 05/72-09/79 Roughneck Circle A Drilling Company, Gillette, Summer job while in college. 05/73-09/73 Roughneck Brinkerhoff Drilling Company, Vernal, Utah, and Riverton, Wyoming. Summer job while in college. 05/74-09/74 Student Engineer, CONOCO, New Orleans, Louisiana. Assigned to drilling department with duties of drilling engineer. 05/75-06/76 CONOCO, Houston, Texas Drilling Engineer. 06/76-02/78 Kansas - Nebraska Natural Gas Company District Engineer. 02/78-09/79 SAMEDAN Oil Corporation Division Engineer 09/79 - Present Independent Consulting Engineer 03/ C.D. Operating Company, Inc. President CONOCO May 1975 to June 1976 PROFESSIONAL EXPERIENCE Drilling engineer assigned to PES Group in Houston, Texas. Designed drilling procedures for offshore and onshore wells. Supervised wells drilled offshore Louisiana and Rocky Mountain District. Attended industry schools on offshore and onshore drilling practices.
7 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 7 of 14 KANSAS - NEBRASKA NATURAL GAS COMPANY June 1976 to February 1978 District engineer responsible for drilling and production in Kansas, Nebraska, and Colorado. Drilled and completed 40 wells in Council Grove field in Southwest Kansas. Designed and supervised installation of gathering system including compression and treating facilities. Coordinated field operations with gas plant personnel for maximum efficiency in gas production. SAMEDAN OIL CORPORATION February 1978 to September 1979 Division engineer, supervising drilling, completion and production for Mid- Continent Region. Participated in gas contract negotiations, joint interest billing procedures and reservoir analysis on all wells for yearly budget reviews. INDEPENDENT CONSULTING ENGINEER September 1979 to Present Independent consultant, supervising field operations in drilling and completion as well as reservoir analysis, economic evaluation, and gathering system design. Drilled and completed wells ranging from 3,000 ft to 25,000 ft throughout Oklahoma, Kansas and Texas. Assisted clients in negotiating gas sales contracts, lease agreements and operating agreements. Continue to perform engineering consulting for various independent oil companies. C.D. OPERATING COMPANY, INC. March 1987 to 2010 Established C.D. Operating Company in March Owned and operated as many as 88 wells over a 12 year period. C.D. Operating handled all accounting, distribution of revenue, production monitoring and operations. Operated wells in Colorado and Utah on a contract basis. Sold operated Oklahoma production in EXPERT WITNESS TESTIMONY April 1995 to Present Expert witness at District Court, Federal Court, United States Court of Federal Claims, United States Department of Interior and the Oklahoma Corporation Commission, Oil and Gas Division. Case descriptions available on request.
8 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 8 of 14 DANIEL T. REINEKE Litigation in which deposition or testimony was given STYLE: Roderick v XTO CASE NO. 08-CV JTM-KMH COURT: US District Court for the District of Kansas 2 STYLE: COPC v Patrick Lyons, Commissioner of Public Lands, NM CASE NO. D-506-CV COURT: Fifth Judicial District Court, Lea County, NM DATE: STYLE: Chieftain v Apache Corporation CASE NO. CJ HE COURT: District Court of Caddo County, Oklahoma 4 STYLE: Patterson v BP CASE NO CV 9926 COURT: District Court of Denver County, Colorado 5 STYLE: Department of Enforcement v Chestnut Energy Partners CASE NO COURT: Financial Industry Regulation Authority 6 STYLE: Anderson v WPX CASE NO. 12-CV-0040 JB/WPL COURT: US District Court of New Mexico 7 STYLE: Arkalon v Chesapeake Operating CASE NO. CJ COURT: US District Court of Kansas 8 STYLE: Martinez v Angel Exploration CASE NO. CIV F COURT: US District Court for the Western District of Oklahoma
9 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 9 of 14 9 STYLE: Golden State v Western Energy CASE NO J COURT: American Arbitration Association 10 STYLE: Medina v Aquirre and Lane Trucking CASE NO. CJ COURT: District Court of Woods County, Oklahoma 11 STYLE: Kay v Peak Water Systems CASE NO. 4:13-cv-487-DPM COURT: US District Court for the Eastern District of Arkansas 12 STYLE: Fleming v Endeavor CASE NO. CJ COURT: District Court of Nowata County, Oklahoma 13 STYLE: Kronberg v Oasis, et al CASE NO. 4:13-cv--011 COURT: US District Court for the Northern District of North Dakota 14 STYLE: Saindon v Express Energy Services, et al CASE NO COURT: District Court of Harris County, Texas 15 STYLE: Snow v SEECO CASE NO. CV COURT: Circuit Court of Conway County, Arkansas DATE: STYLE: Summa Engineering v Venus CASE NO. CJ COURT: District Court of Grant County, Oklahoma 17 STYLE: Jay Management v Parker Tools CASE NO COURT: District Court of the 87 th Judicial District, Leon County, Texas
10 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 10 of STYLE: Tate v Chesapeake and Cameron CASE NO. 13 DJ COURT: US District Court for the Middle District of Pennsylvania 19 STYLE: Smith v SEECO CASE NO. 14-cv-435-BRW COURT: US District Court for the Eastern District of Arkansas STYLE: Moreno v HES CASE NO. c j COURT: District Court of the 430th Judicial District, Hildago County, Tx. 21 STYLE: Calvert Company v Antoinette Calvert CASE NO. cj COURT: District Court Oklahoma County, Oklahoma STYLE: Colton v Antero CASE NO. 2013CV COURT: District Court Garfield County, Colorado STYLE: Pummill v Cimarex CASE NO. CV COURT: District Court of Grady County, Oklahoma DATE: STYLE: Fitzgerald v Chesapeake CASE NO. CJ COURT: District Court of Beaver County, Oklahoma STYLE: Gagnon v Merit CASE NO. 1:14-CV-832-PAB COURT: US District Court for the District of Colorado DATE: STYLE: Gaedeke v Speed, et al CASE NO. CV M COURT: US District Court for the Western District of Oklahoma DATE: 2015
11 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 11 of STYLE: Trinity Valley v Chesapeake CASE NO. 3:13-CV K COURT: US District Court for the Northern District of Texas DATE: STYLE: Seeligson v Devon CASE NO. Civil Action No. 2:14-cv COURT: US District Court for the Eastern District of Texas, Marshal Division DATE: STYLE: Dorchester v CHK CASE NO. Civil Action No. 4:12-cv-461-KGB COURT: US District Court for the Eastern District of Arkansas, Western Division DATE: STYLE: Exaro v Encana CASE NO. Private Arbitration COURT: Institute for Conflict Prevention and Resolution DATE: STYLE: Parchman v EOG/HESD CASE NO COURT: District Court of Harris County, Texas 32 STYLE: Energy Drilling v Pacific Energy CASE NO. 14CV186-S COURT: US District Court for the District of Wyoming 33 STYLE: Beaner v CHK/SPM CASE NO CVL COURT: District Court of the 218th Judicial District, La Salle County, Tx. 34 STYLE: Dorchester Minerals v Chesapeake Exploration CASE NO. 4:12-cv-461-KGB COURT: US District Court for the Eastern District of Arkansas DATE: STYLE: Enriquez v Geosouthern Energy CASE NO CV COURT: District Court 79 th District Jim Wells County, Tx.
12 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 12 of STYLE: Arnold v Cabot Oil and Gas CASE NO. CV COURT: District Court of Beaver County, Ok STYLE: Whisenant v Strat Land Exploration CASE NO. CJ COURT: District Court of Beaver County, Ok 38 STYLE: Lee et al v COP CASE NO. CIV D COURT: US District Court for the Western District of Oklahoma 39 STYLE: Frank v Crawley Petroleum CASE NO. CIV R COURT: US District Court for the Western District of Oklahoma 40 STYLE: McGehee v Forest Oil CASE NO. CIV C COURT: US District Court for the Western District of Oklahoma STYLE: Lambert v Chevron CASE NO. 14-cv JAR-TJJ COURT: US District Court for the District of Kansas 42 STYLE: Department of Enforcement v Red River Securities CASE NO COURT: Financial Industry Regulation Authority 43 STYLE: Singer v Newfield CASE NO. CIV M COURT: US District Court for the Western District of Oklahoma STYLE: Hackett v XTO, et al CASE NO. CV COURT: District Court of Garvin County, OK -2017
13 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 13 of STYLE: ROCO v EOG CASE NO JAR-GEB COURT: US District Court for the District of Kansas 46 STYLE: Cannon v Encana CASE NO A COURT: Judicial Arbiter Group STYLE: Wytex v Davis Oil CASE NO. CV COURT: District Court of Pittsburg County, OK STYLE: Cooksey v Smith CASE NO. cv COURT: District Court of Woods County, OK 49 STYLE: BDI v Summit Drilling CASE NO. 16-cv-226-CVE-FHM COURT: US District Court for the Northern District of Oklahoma STYLE: Jolley v WPX CASE NO cv COURT: District Court of Garfield County, CO 51 STYLE: NOMAC v USEDC CASE NO. CIV C COURT: US District Court for the Western District of Oklahoma STYLE: Vanderwarker v Wade Works CASE NO cv-070-DLH COURT: US District Court for the Norther District of North Dakota 53 STYLE: Henceroth v CHK CASE NO. 4:15-cv BYP COURT: US District Court for the Northern District of Ohio
14 6:16-cv KEW Document Filed in ED/OK on 10/19/18 Page 14 of STYLE: Stonegate v CHK CASE NO. 4:15-cv COURT: US District Court for the Southern District of Texas 55 STYLE: Retova v Bill Barrett Corporation CASE NO cv COURT: District Court of Denver County, CO 56 STYLE: Hobble v Merit CASE NO cv COURT: District Court of Haskell County, Kansas 57 STYLE: Cosmo Energy v CHK et al CASE NO. cv COURT: District Court of Kingfisher County, OK 58 STYLE: Haney v Multi-Chem et al CASE NO COURT: Court of Common Pleas of Washington County, PA DATE: STYLE: Stamp v Western Oil & Gas CASE NO COURT: DATE: 2018 District Court of Grady County, OK COMPENSATION My hourly rate is $400 per hour for general engineering and consulting services and $500 per hour for deposition and trial testimony.
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