Free Amended Complaint - District Court of Federal Claims - federal

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 1 of 27

Exhibit 1 The conveyances made in 1935 and 1936 from Bodcaw Lumber and Grant Timber to Good Pine Oil are described as follows: (a) Sale of Minerals from Bodcaw Lumber Company of Louisiana, Inc. to Good Pine Oil Company, Inc. dated November 12, 1932, recorded in Conveyance Book 168, Folio 419, Entry No. 63721, in the records of Natchitoches Parish; (b) Sale of Minerals from Grant Timber & Mfg. Company of La., Inc. to Good Pine Oil Company, Inc., dated November 16, 1932, recorded in Conveyance Book WW, Folio 552, Entry No. 25943, in the records of Grant Parish; (c) Sale of Minerals from Grant Timber & Mfg. Company of La., Inc. to Good Pine Oil Company, Inc., dated November 16, 1932, recorded in Conveyance Book 42, Folio 255, Entry No. 25548, in the records of Winn Parish; and (d) Sale of Minerals from Bodcaw Lumber Company of Louisiana, Inc. to Good Pine Oil Company, Inc. dated November 16, 1932, recorded in Conveyance Book 42, Folio 259, Entry No. 25552, in the records of Winn Parish; (e) Sale of Minerals from Bodcaw Lumber Company of La., Inc. to Good Pine Oil Company, Inc., dated May 3, 1934, recorded in Conveyance Book 171, Folio 72, Entry No. 65277, in the records of Natchitoches Parish; (f) Sale of Minerals from Bodcaw Lumber Company of La., Inc. to Good Pine Oil Company, Inc., dated May 3, 1934, recorded in Conveyance Book 44, Folio 26, Entry No. 26708, in the records of Winn Parish.

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 2 of 27

Exhibit 2 (a) Sale of lands by Bodcaw Lumber Company of Louisiana, Inc. to the United States

of America dated February 11, 1936, recorded in Conveyance Book 173, Folio 400, Entry No. 66862, in the records of Natchitoches Parish; sale made subject to prior sales of minerals; and (b) Sale of lands by Grant Timber & Manufacturing Company of Louisiana, Inc. to

the United States of America, dated November 28, 1934, recorded in Conveyance Book ZZ, Folio 359, Entry No. 27363, in the records of Grant Parish; sale made subject to prior sales of minerals; and (c) Sale of lands by Grant Timber and Manufacturing Company of Louisiana, Inc. to

the United States of America, dated March 26, 1935, recorded in Conveyance Book 53, Folio 78, Entry No. 27600, in the records of Grant Parish; sale made subject to prior sales of minerals; and (d) Sale of lands by Grant Timber & Manufacturing Company of Louisiana, Inc. to

the United States of America, dated November 28, 1934, recorded in Conveyance Book 44, Folio 131, Entry No. 26836, in the records of Winn Parish; sale made subject to prior sales of minerals; and (e) Sale of lands by Bodcaw Lumber Company of Louisiana, Inc. to the United States

of America, dated December 20, 1934, recorded in Conveyance Book 44, Folio 160, Entry No. 26887, in the records of Winn Parish; sale made subject to prior sales of minerals; and (f) Sale of lands by Grant Timber & Manufacturing Company of Louisiana, Inc. to

the United States of America, dated March 26, 1935, recorded in Conveyance Book 44, Folio 413, Entry No. 27139, in the records of Winn Parish; sale made subject to prior sales of minerals; and (g) Sale of lands by Bodcaw Lumber Company of Louisiana, Inc. to the United States

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 3 of 27

of America, dated June 12, 1935, recorded in Conveyance Book 44, Folio 546, Entry No. 27280, in the records of Winn Parish; sale made subject to prior sales of minerals; and (h) Sale of lands by Grant Timber & Manufacturing Company of Louisiana, Inc. to

the United States of America, dated March 26, 1935, recorded in Conveyance Book 44, Folio 419, Entry No. 27140, in the records of Winn Parish, Louisiana; sale made subject to prior sales of minerals; and (i) Judgment in favor of the United States of America against Bodcaw Lumber

Company of Louisiana, Inc., dated January 28, 1937, recorded in Conveyance Book 48, Folio 22, Entry No. 29731, in the records of Winn Parish; judgment subject to prior sales of minerals; and (j) Judgment in favor of the United States of America against Bodcaw Lumber

Company of Louisiana, Inc., dated January 28, 1937, recorded in Conveyance Book 177, Folio 612, Entry No. 69177, in the records of Natchitoches Parish; judgment subject to prior sales of minerals.

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 4 of 27

Exhibit 3

(a)

Conveyance of Minerals from Good Pine Oil Company, Inc. to William C. Brown, et al., dated December 29, 1941, recorded in Conveyance Book 69, Folio 519, Entry No. 35127, in the records of Grant Parish;

(b)

Conveyance of Minerals from Good Pine Oil Company, Inc. to William C. Brown, et al., dated December 29, 1941, recorded in Conveyance Book 54, Folio 324, Entry No. 34486, in the records of Winn Parish;

(c)

Conveyance of Minerals from Good Pine Oil Company, Inc. to William C. Brown, et al., dated December 29, 1941, recorded in Conveyance Book 188, Folio 547, Entry No. 76585, in the records of Natchitoches Parish;

(d)

Conveyance of Minerals from William C. Brown, et al., to Nebo Oil Company Inc., dated January 20, 1942, recorded in Conveyance Book 71, Folio 181, Entry No. 35377, in the records of Grant Parish;

(e)

Conveyance of Minerals from William C. Brown, et al., to Nebo Oil Company, Inc. dated January 20, 1942, recorded in Conveyance Book 71, Folio 195, Entry No. 35378, in the records of Grant Parish;

(f)

Conveyance of Minerals from William C. Brown, et al., to Nebo Oil Company, Inc., dated January 20, 1942, recorded in Conveyance Book 56, Folio 1, Entry No. 34722, in the records of Winn Parish;

(g)

Conveyance of Minerals from William C. Brown, et al., to Nebo Oil Company, Inc. dated January 20, 1942, recorded in Conveyance Book 56, Folio 18, Entry No. 34723, in the records of Winn Parish;

(h)

Conveyance of Minerals from William C. Brown, et al., to Nebo Oil Company,

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 5 of 27

Inc., dated January 20, 1942, recorded in Conveyance Book 189, Folio 370, Entry No. 76995, in the records of Natchitoches Parish; (i) Conveyance of Minerals from William C. Brown, et al., to Nebo Oil Company, Inc., dated January 20, 1942, recorded in Conveyance Book 189, Folio 382, Entry No. 76996, in the records of Natchitoches Parish; (j) Acknowledgment by Joe Smith, h/o Anita O'Neal Smith, to Nebo Oil Company, Inc., dated June 19, 1952, recorded in Conveyance Book 101, Folio 3, Entry No. 48538, in the records of Grant Parish; Conveyance Book 74, Folio 51, Entry No. 49817, in the records of Winn Parish; and Conveyance Book 217, Folio 80, Entry No. 97514, in the records of Natchitoches Parish (husband acknowledged in this document that property conveyance in (d), (e), (f), (g), (h) and (i) above was the separate property of his wife); (k) Acknowledgment by H.I. Kenney, h/o Grace Wagner Kenney, to Nebo Oil Company, Inc., dated June 18, 1952, recorded in Conveyance Book 101, Folio 5, Entry No. 48539, in the records of Grant Parish; Conveyance Book 74, Folio 52, Entry No. 49818, in the records of Winn Parish; and Conveyance Book 217, Folio 82, Entry No. 97515, in the records of Natchitoches Parish (husband acknowledged in this document that property conveyed in (d), (e), (f), (g), (h) and (i) above was the separate property of his wife); (l) Acknowledgment by S. J. Seeger, h/o Helen B. Seeger, to Nebo Oil Company, Inc., dated July 31, 1944, recorded in Conveyance Book 195, Folio 369, Entry No. 82455, in the records of Grant Parish (husband acknowledged in this document that property conveyed in (h) and (i) above was the property of his

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 6 of 27

wife); (m) Acknowledgment by Mary Seeger O'Boyle, et al., being the heirs of S. J. Seeger, deceased h/o Helen B. Seeger, to Nebo Oil Company, Inc., dated November 13, 1954, recorded in Conveyance Book 104, Folio 433, Entry No. 50887, in the records of Grant Parish; and Conveyance Book 235, Folio 717, Entry No. 175422, in the records of Winn Parish (heirs of deceased husband acknowledged in this document that property conveyed in (d), (e), (f) and (g) above was the separate property of his wife); (n) Certificate of Amendment of Certification of Incorporation (name change) from Nebo Oil Company, Inc. to Bodcaw Company, dated April 4, 1960, recorded in Conveyance Book 119, Folio 39, Entry No. 56054, in the records of Grant Parish; Conveyance Book 87, Folio 221, Entry 56325, in the records of Winn Parish; and Conveyance Book 238, Folio 401, Entry No. 111325, in the records of Natchitoches Parish; (o) Certificate of Agreement of Merger (Bodcaw Company merged into IPB, Inc., and IPB, Inc. changed its name to Bodcaw Company), dated October 10, 1979, recorded in Conveyance Book 226, Folio 84, Entry 84739, in the records of Grant Parish; Conveyance Book 143, Folio 608, Entry No. 110749, in the records of Winn Parish; and Conveyance Book 356, Folio 491, Entry No. 157257, in the records of Natchitoches Parish; all as further evidenced by (y) below; (p) Certificate of Ownership and Merger filed by Bodcaw Company, dated October 10, 1979, recorded in Conveyance Book 226, Folio 85, Entry No. 84740, in the records of Grant Parish; Conveyance Book 143, Folio 609, Entry No. 110750, in

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 7 of 27

the records of Winn Parish; and Conveyance Book 356, Folio 492, Entry No. 157258, in the records of Natchitoches Parish; (q) Mineral Deed from Bodcaw Company to Placid Oil Company, dated October 11, 1979, recorded in Conveyance Book 224, Folio 812, Entry No. 84742, in the records of Grant Parish; Conveyance Book 143, Folio 620, Entry No. 110752, in the records of Winn Parish; and Conveyance Book 356, Folio 508, Entry No. 157260, in the records of Natchitoches Parish; (r) Assignment, Conveyance and Bill of Sale from Placid Oil Company to Placid International Oil Limited, and in turn from Placid International Oil Limited to Louisiana-Hunt Petroleum Corporation and Rosewood Resources (POC), Inc., dated June 13, 1983, recorded in Conveyance Book 259, Folio 139, Entry No. 93374, in the records of Grant Parish; Conveyance Book 158, Folio 550, Entry No. 122732, in the records of Winn Parish; and Conveyance Book 388, Folio 19, Entry No. 167876, in the records of Natchitoches Parish; (s) Certificate of Ownership, Merger Name Change from Rosewood Resources (POC), Inc. to Rosewood Resources, Inc., dated December 31, 1984, recorded in Mortgage Book 134, Folio 880, Entry No. 44105, in the records of Grant Parish; Conveyance Book 172, Folio 553, Entry No. 134394, in the records of Winn Parish; and Conveyance Book 420, Folio 49, Entry No. 176881, in the records of Natchitoches Parish; (t) Certificate of Merger and Name Change from Louisiana-Hunt Petroleum Corporation to Hunt Petroleum Corporation, dated January 31, 1986, recorded in Conveyance Book 215, Folio 574, Entry 64469, in the records of Grant Parish;

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 8 of 27

Conveyance Book 182, Folio 542, Entry 141085, in the records of Winn Parish; and Conveyance Book 442, Folio 127, Entry No. 182279, in the records of Natchitoches Parish; (u) Assignment and Conveyance from Rosewood Resources, Inc. to Kingfisher Resources, Inc., dated April 24, 1996, recorded in Conveyance Book 338, Folio 395, Entry No. 117748, in the records of Grant Parish; Conveyance Book 217, Folio 757, Entry No. 163185, in the records of Winn Parish; and Oil and Gas Book 296, Folio 836, Entry No. 230814, in the records of Natchitoches Parish; and (v) Conveyance and Assumption Agreement from OXY USA, Inc. and Placid Oil Company to Petro-Hunt, L.L.C., executed April 6, 1998, recorded in Conveyance Book 348, Folio 191, Entry No. 121619, in the records of Grant Parish; Conveyance Book 227, Folio 85, Entry No. 169509, in the records of Winn Parish; and Conveyance Book 529, Folio 653, Entry No. 209089, in the records of Natchitoches Parish.

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 9 of 27

EXHIBIT 4

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 10 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 11 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 12 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 13 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 14 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 15 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 16 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 17 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 18 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 19 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 20 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 21 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 22 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 23 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 24 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 25 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 26 of 27

Case 1:00-cv-00512-FMA

Document 51-3

Filed 06/25/2008

Page 27 of 27