Burlington Resources Oil & Gas Company LP v. Verde Minerals, LLC, Lighthouse Management Group, Inc., and David Weiner, Ancillary Receiver

ACCEPTED
FILED
05-15-00014-CV
DALLAS COUNTY
05-15-00014-CV FIFTH1/5/2015
COURT 12:06:08
OF APPEALS
DALLAS,
PM
TEXAS
FELICIA PITRE
1/7/2015 9:05:26
DISTRICT AM
CLERK
LISA MATZ
CLERK

CAUSE NO. DC13-13916

IN RE: ANCILLARY RECEIVERSHIP OF § IN THE DISTRICT COURT
FILED IN
UNITED STATES INSTALLMENT REALTY § 5th COURT OF APPEALS
COMPANY, A MINNESOTA CORPORATION, § DALLAS, TEXAS
§ 1/7/2015 9:05:26 AM
(Ancillary to the General Receivership § LISA MATZ
of United States Installment Realty Company, § Clerk
DALLAS COUNTY, TEXAS
a Minnesota corporation, and U.S.I. Realty §
Company, a Minnesota corporation, in §
In re Receivership of United States Installment §
Realty Company, a Minnesota corporation, §
No. 27-CV-13-4154, Fourth Judicial §
District Court, Hennepin County, Minnesota) § 101ST JUDICIAL DISTRICT

BURLINGTON RESOURCES OIL & GAS COMPANY LP’S
NOTICE OF APPEAL

TO THE HONORABLE JUDGE OF SAID COURT:

Please take notice that Burlington Resources Oil & Gas Company LP (“Burlington”)

desires to appeal from the Order Approving Ancillary Receiver’s Final Report and Discharging

Ancillary Receiver, and Denying Intervenor’s Plea to the Jurisdiction dated December 19, 2014,

which finally disposes of all pending claims asserted by all parties in this proceeding

(hereinafter, the “Final Judgment”). Burlington further desires to appeal from any and all orders

incorporated, subsumed or merged into the Final Judgment, as well as from any and all previous

adverse orders entered in this proceeding. The trial court never had jurisdiction, as a result, any

and all orders entered in this proceeding are void. Burlington desires to appeal to the Court of

Appeals for the Fifth District, sitting in Dallas.

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Dated: January 5, 2015 Respectfully submitted,

/s/ W. Scott Hastings
Michael V. Powell
Texas Bar No. 16204400
W. Scott Hastings
Texas Bar No. 24002241
Susan E. Adams
Texas Bar No. 24059354
LOCKE LORD LLP
2200 Ross Avenue, Suite 2200
Dallas, Texas 75201-6776
Main Telephone: (214) 740-8000
Main Facsimile: (214) 740-8800

ATTORNEYS FOR INTERVENOR,
BURLINGTON RESOURCES OIL & GAS
COMPANY L.P.

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 CERTIFICATE OF SERVICE

I certify that true and correct copies of the foregoing have been served this the 5th day of
January, 2015, on all counsel of record via email and certified mail, return receipt requested, as
follows:

Mr. Timothy E. Malone
DECKER, JONES, MCMACKIN, MCCLANE, HALL & BATES, P.C.
Burnett Plaza, Unit 46
801 Cherry Street, Suite 2000
Fort Worth, Texas 76102
Attorneys for Verde Minerals, LLC

Mr. Jeffrey R. Ansel
WINTHROP & WEINSTINE, P.A.
Capella Tower, Suite 3500
225 South Sixth Street
Minneapolis, Minnesota 55402
Attorneys for Lighthouse Management Group, Inc.,
as General Receive for United States Installment Realty
Company and for U.S.I. Realty Company

Mr. David Weiner
One Lincoln Center
5400 LBJ Freeway, Suite 1260
Dallas, Texas 75240
Ancillary Receiver in Texas for United States
Installment Realty Company and for U.S.I. Realty
Company

/s/ W. Scott Hastings
W. Scott Hastings

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