Attached files
file | filename |
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8-K - FORM 8-K - STONE ENERGY CORP | h69739e8vk.htm |
Exhibit 99.1
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF LOUISIANA
LAFAYETTE-OPELOUSAS DIVISION
WESTERN DISTRICT OF LOUISIANA
LAFAYETTE-OPELOUSAS DIVISION
IN RE: STONE ENERGY CORPORATION
|
) | Civil Action No. | 05-2166 (Lead) | |||
SHAREHOLDER DERIVATIVE LITIGATION.
|
) | 05-2167 (Member) | ||||
) | 06-0171 (Member) | |||||
) | ||||||
) | ||||||
) | Judge Tucker L. Melançon | |||||
) | ||||||
) | Magistrate Judge C. Michael Hill | |||||
) |
NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF
SHAREHOLDER DERIVATIVE ACTIONS
SHAREHOLDER DERIVATIVE ACTIONS
TO:
|
ALL OWNERS OF STONE ENERGY CORPORATION (STONE ENERGY) COMMON STOCK AS OF FEBRUARY 12, 2010 (CURRENT STONE ENERGY SHAREHOLDERS) |
PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY. YOUR RIGHTS MAY BE AFFECTED.
This notice has been sent to you pursuant to an Order of the United States District Court for
the Western District of Louisiana (the Court). The purpose of the notice is to advise you of the
proposed settlement, as set forth in a Stipulation of Settlement dated as of February 12, 2010 (the
Stipulation), of the consolidated shareholder derivative litigation pending before the Court and
captioned-above, as well as the shareholder derivative litigation pending in the15th Judicial
District of Lafayette Parish, Louisiana, captioned Gregory Sakhno, Derivatively on Behalf of Stone Energy
Corporation v. David H. Welch, et al., Cause No. 2006-0505-G, (the State Derivative Action),
(collectively, the Derivative Actions), and of the Settlement Hearing. The settlement will fully
resolve the Derivative Actions on the terms set forth in the Stipulation and summarized in this
notice, including the dismissal of the Derivative Actions with prejudice. For a more detailed
statement of the matters involved in the Derivative Actions, the settlement and the terms discussed
in this notice, the Stipulation may be inspected at the Office of the Clerk of the United States
District Court for the Western District of Louisiana located at 800 Lafayette Street, Suite 2100,
Lafayette, LA 70501, during regular business hours of each business day.
You may have the right to object to the settlement, including any award of attorneys fees and
expenses to Derivative Plaintiffs Counsel, in the manner provided herein. If you fail to object in
the manner provided herein at least ten (10) business days prior to the Settlement Hearing, you
will be deemed to have waived your objections and will be bound by the Judgment to be entered and
the releases to be given, unless otherwise ordered by the Court.
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This notice is not intended to be an expression of any opinion by the Court with respect to
the merits of the claims made in the Derivative Actions, but is merely to advise you of the
pendency and settlement of the Derivative Actions.
I. DEFINITIONS USED IN THIS NOTICE
1. Current Stone Energy Shareholders means persons who owned Stone Energy common stock as of
February 12, 2010, and who continue to hold their Stone Energy common stock as of the date of the
final settlement approval hearing, excluding the Individual Defendants, the officers and directors
of Stone Energy, members of their immediate families, and their legal representatives, heirs,
successors, or assigns, and any entity in which Individual Defendants have or had a controlling
interest.
2. Derivative Plaintiffs means collectively, Robert Farer, Priscilla Fisk, and Joint Pension
Fund, Local No. 164, I.B.E.W. (collectively, the Federal Derivative Plaintiffs) and Gregory
Sakhno (the State Derivative Plaintiff).
3. Derivative Plaintiffs Counsel means collectively, (i) co-lead counsel
Barrack, Rodos & Bacine, Robbins Umeda LLP, and Faruqi & Faruqi, LLP; co-liaison counsel Broussard & David
and Kenneth W. DeJean; and Kroll Heineman & Giblin, LLC (collectively, Federal Derivative
Plaintiffs Counsel); and (ii) The Warner Law Firm and Guilliot & St. Pe, LLC (collectively,
State Derivative Plaintiffs Counsel).
4. Effective Date means the first date by which all of the events and conditions specified
in ¶5.1 of the Stipulation have been met and have occurred, as summarized in Section X of this
notice.
5. Fee and Expense Award means the agreed upon Fee and Expense Award that the
Individual Defendants shall pay or cause its insurers to pay to Derivative Plaintiffs Counsel, as
defined below, in recognition of the material and substantial benefits conferred on Stone Energy by
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the corporate governance measures instituted by Stone Energy as a result, in substantial and
material part, of the filing and prosecution of the Derivative Actions.
6. Individual Defendants means collectively, Peter K. Barker, Kenneth H. Beer,
Robert A. Bernhard, D. Peter Canty, George R. Christmas, B.J. Duplantis, John P. Laborde, Richard
A. Pattrozzi, James H. Prince, David R. Voelker, and David H. Welch.1
7. Related Persons means each of the Released Parties (as defined in ¶9 below) past or
present directors, officers, employees, partners, members, principals, agents, insurers,
co-insurers, reinsurers, controlling shareholders, attorneys, accountants or auditors, personal or
legal representatives, predecessors, successors, parents, subsidiaries, divisions, joint ventures,
assigns, spouses, heirs and related or affiliated entities, and entity in which any of the Released
Parties has a controlling interest, any members of any Individual Defendants immediate family, or
any trust of which any Individual Defendant or Stone Energy is the settlor or which is for the
benefit of Stone Energy or any Individual Defendant and/or member(s) of any Individual Defendants
family.
8. Released Claims shall collectively mean any and all claims, rights, and causes of action,
whether based on federal, state, local, statutory, or common law or any other law, rule, or
regulation, including Unknown Claims (as defined in ¶12 below), that have been or could have been
asserted by Derivative Plaintiffs or shareholders of Stone Energy derivatively on behalf of Stone
Energy against the Released Persons (as defined in ¶10 below) relating to, arising out of, or
derived from the allegations, facts, transactions, or claims contained in any of the complaints
filed in any of the Derivative Actions.
9. Released Parties means Stone Energy and each of the Individual Defendants.
1 | Derivative Plaintiffs also named James H. Stone and Raymond B. Gary as individual defendants. Messrs. Stone and Gary have since passed away. On February 11, 2010, counsel for the Individual Defendants filed a Statement of Death in acknowledgement of such events. |
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10. Released Persons means each and all of the Released Parties and each of their
Related Persons.
11. Settling Parties means, collectively, Stone Energy, the Individual Defendants, the
Federal Derivative Plaintiffs, and the State Derivative Plaintiffs, individually and derivatively
on behalf of Stone Energy.
12. Unknown Claims means any Released Claims that any Settling Party or Related Person does
not know or suspect to exist in his, her, or its favor at the time of the release of the Released
Persons which, if known by him, her, or it, might have affected his, her, or its settlement with
and release of the Released Persons, or might have affected his, her, or its decision not to object
to the settlement. With respect to any and all Released Claims, the Settling Parties each stipulate
and agree that, upon the Effective Date, the Settling Parties each shall be deemed to have, and by
operation of the Judgment shall have, expressly waived the provisions, rights, and benefits of
California Civil Code §1542, which provides:
A general release does not extend to claims which the creditor does not know or suspect to
exist in his or her favor at the time of executing the release, which if known by him or
her must have materially affected his or her settlement with the debtor.
The Settling Parties each shall expressly waive, and by operation of the Judgment shall have,
expressly waived any and all provisions, rights, and benefits conferred by any law of any state or
territory of the United States, or principle of common law, which is similar, comparable or
equivalent to California Civil Code §1542. The Settling Parties each may hereafter discover facts
in addition to or different from those that he, she, or it now knows or believes to be true with
respect to the subject matter of the Released Claims, but, upon the Effective Date, the Settling
Parties each shall be deemed to have, and by operation of the Judgment shall have, fully, finally,
and forever settled and released any and all Released Claims, known or unknown, suspected or
unsuspected, contingent or non-contingent, which now exist, or heretofore have existed, upon any
theoryof law or
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equity now existing or coming into existence in the future, including, but not limited to, conduct
which is negligent, intentional, with or without malice, or a breach of any duty, law or rule,
without regard to the subsequent discovery or existence of such different or additional facts. The
Settling Parties each acknowledge that the foregoing waiver was separately bargained for and a key
element of the settlement of which this release is a part.
II. THE DERIVATIVE ACTION
The Derivative Plaintiffs brought suit against the Individual Defendants solely on behalf of
Stone Energy and solely for the benefit of Stone Energy and not for any recovery for the direct
benefit of any shareholders. The Derivative Plaintiffs generally alleged, among other things, that
the Individual Defendants breached their fiduciary duties by issuing a series of false and
misleading public statements regarding Stone Energys proved oil and gas reserves, and used
improper methodologies to allegedly overvalue and artificially inflate Stone Energys reported
reserves. Derivative Plaintiffs sought, among other things, damages, disgorgement by the Individual
Defendants, and corporate governance reforms to be implemented by Stone Energy.
III. INDIVIDUAL DEFENDANTS AND STONE ENERGYS DENIALS OF
WRONGDOING
Each Individual Defendant, as well as Stone Energy, has denied and continues to deny each and
all of the claims and contentions alleged in the Derivative Actions. Each Individual Defendant has
expressly denied and continues to deny all charges of wrongdoing or liability against each of them
arising out of any of the conduct, statements, acts or omissions alleged, or that could have been
alleged, in the Derivative Actions. The Individual Defendants and Stone Energy also have denied and
continue to deny, inter alia, the allegations that Stone Energy, the Derivative Plaintiffs, or the
Current Stone Energy Shareholders, have suffered damages or were harmed by the conduct alleged in
the Derivative Actions. Nonetheless, the Individual Defendants and Stone Energy have concluded
that further conduct of the Derivative Actions would be protracted and expensive, and that it is
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desirable that the Derivative Actions be fully and finally settled in the manner and upon the terms
and conditions set forth in the Stipulation. The Individual Defendants and Stone Energy also have
taken into account the uncertainty and risks inherent in any litigation, especially in complex
cases like the Derivative Actions. Further, the Individual Defendants and Stone Energy believe the
settlement is in the best interests of Stone Energy and its shareholders. The Individual Defendants
and Stone Energy have, therefore, determined that it is desirable and beneficial to them that the
Derivative Actions be settled in the manner and upon the terms and conditions set forth in the
Stipulation.
The Stipulation shall not be deemed an admission of the validity or infirmity of any claim
against any Individual Defendant or the liability or non-liability of any Individual Defendant, or
an admission of insurance coverage under any policy, and may not be used in any proceeding for any
purpose except to enforce the terms of the Stipulation.
IV. CLAIMS OF THE DERIVATIVE PLAINTIFFS AND BENEFITS OF SETTLEMENT
Derivative Plaintiffs believe that the claims asserted in the Derivative Actions have merit.
Derivative Plaintiffs and Derivative Plaintiffs Counsel recognize and acknowledge, however, the
significant risk, expense, and length of continued proceedings necessary to prosecute the
Derivative Actions against the Individual Defendants through trial and through possible appeals.
Derivative Plaintiffs and Derivative Plaintiffs Counsel have also taken into account the uncertain
outcome and the risk of any litigation, especially in complex actions such as the Derivative
Actions, as well as the difficulties and delays inherent in such litigation. Derivative Plaintiffs
and Derivative Plaintiffs Counsel are also mindful of the inherent problems of proof and possible
defenses to the claims asserted in such actions. Based on a thorough investigation of the facts and
analysis of applicable law, Derivative Plaintiffs and Derivative Plaintiffs Counsel believe that
the settlement is fair, reasonable, and adequate, and in the best interests of Stone Energy and its
shareholders.
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V. THE SETTLEMENT HEARING
The Settlement Hearing will be held before the Honorable Tucker L. Melançon on March 23, 2010
at 1:30 p.m. at the United States District Court for the Western District of Louisiana for the
purpose of determining: (i) whether the settlement is fair, reasonable, and adequate, and should be
finally approved by the Court; (ii) whether a Judgment should be entered dismissing the Federal
Derivative Action with prejudice; and (iii) whether the Derivative Plaintiffs Counsels requested
Fee and Expense Award should be approved. The Settlement Hearing may be continued by the Court at
the Settlement Hearing or at any adjourned session thereof without further notice.
VI. THE SETTLEMENT
The
settlement was reached in good faith by the Settling Parties after
engaging in arms-length
negotiations conducted in good faith and with the assistance of the Honorable Nicolas Politan
(Ret.). The terms and conditions of the proposed settlement are set forth fully in the Stipulation
described above. The Stipulation has been filed with the Court and is also available for viewing on
the websites of Robbins Umeda LLP at www.robbinsumeda.com, Barrack, Rodos & Bacine at
www.barrack.com, and Faruqi & Faruqi, LLP at www.faruqilaw.com. The following is only a summary of
its terms.
Stone Energy acknowledges that the filing and prosecution of the Derivative Actions materially
and substantially contributed to the corporate governance measures set forth in Exhibit B to the
Stipulation.
In summary, these corporate governance measures: (i) revised the charter for the Reserves
Committee of the Stone Energy Board of Directors, in part, to provide its members greater
responsibility and accountability; (ii) created an anonymous reporting policy that allows Stone
Energys officers and employees an avenue to report any potentially illegal or unethical conduct;
and
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(iii) created an anonymous hotline as a separate avenue for reporting potentially illegal or
unethical
conduct.
Stone Energy believes that the institution of the corporate governance measures in Exhibit B
to the Stipulation has been effective in preventing the type of wrongdoing alleged in the
complaints in the Derivative Actions, namely, issues concerning the Companys estimation of its
reserves.
VII. DISMISSAL AND RELEASES
If the Court approves the settlement, the Settling Parties will ask the Court at the
Settlement Hearing to enter the Judgment dismissing the Federal Derivative Action with prejudice in
accordance with the terms of the Stipulation. Promptly thereafter, State Derivative Plaintiff shall
file a dismissal with prejudice of all claims asserted by him against the Individual Defendants in
the State Derivative Action.
Upon the entry of the Judgment, Derivative Plaintiffs, individually and derivatively on behalf
of Stone Energy, Derivative Plaintiffs Counsel, and Stone Energy shall have, and by operation of
the Judgment shall be deemed to have, fully, finally, and forever released, relinquished and
discharged all Released Claims (including Unknown Claims) and any and all claims arising out of,
relating to, or in connection with the Settlement or resolution of the Derivative Action against
the Released Persons. Further, upon entry of the Judgment, Stone Energy, each of the Individual
Defendants, and the Related Persons shall be deemed to have, and by operation of the Judgment shall
have, fully, finally, and forever released, relinquished, and discharged Derivative Plaintiffs and
Derivative Plaintiffs Counsel from all claims, arising out of, relating to, or in connection with
their institution, prosecution, assertion, settlement, or resolution of the Derivative Actions or
Released Claims.
VIII. APPLICATION FOR THE FEE AND EXPENSE AWARD
In recognition of the substantial benefits conferred on Stone Energy by the corporate
governance measures instituted by Stone Energy, the Settling Parties reached an agreement with the assistance
of
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Judge Politan as to a fair and reasonable amount of attorneys fees and reimbursement of expenses
for Derivative Plaintiffs Counsel. Accordingly, Individual Defendants have agreed to pay or cause
their insurers to pay to Derivative Plaintiffs Counsel $300,000 (the Fee and Expense Award) for
Derivative Plaintiffs Counsels attorneys fees and reimbursement of expenses.
Derivative Plaintiffs Counsel shall request approval of the Fee and Expense Award at the
Settlement Hearing. To date, Derivative Plaintiffs Counsel have neither received any payment for
their services in conducting the Derivative Actions, nor have they been reimbursed for their
out-of-pocket expenses incurred. Derivative Plaintiffs Counsel believe that the Fee and Expense
Award requested is within the range of fees and expenses awarded to Derivative Plaintiffs Counsel
under similar circumstances in litigation of this type. Stone Energy shareholders are not
personally liable for the Fee and Expense Award.
IX. THE RIGHT TO OBJECT AND/OR BE HEARD AT THE HEARING
Any Current Stone Energy Shareholder may object and/or appear and show cause, if he, she, or
it has any concern why the settlement of the Derivative Actions should not be approved as fair,
reasonable, and adequate, or why a judgment should not be entered thereon, or why the Fee and
Expense Award should not be awarded to Derivative Plaintiffs Counsel; provided, however, unless
otherwise ordered by the Court, no Current Stone Energy Shareholder shall be heard or entitled to
contest the approval of the terms and conditions of the Settlement, or, if approved, the judgment
to be entered thereon approving the same, or the attorneys fees and expenses to be awarded to
Derivative Plaintiffs Counsel unless that shareholder has, at least ten (10) business days prior
to the Settlement Hearing: (1) filed with the Clerk of the Court a written objection to the
settlement setting forth: (a) the nature of the objection; (b) proof of ownership of Stone Energy common stock
through the date of the Settlement Hearing, including the number of shares of Stone Energy common
stock and the date of purchase; and (c) any documentation in support of such objection; and (2) if
a
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Current Stone Energy Shareholder intends to appear and requests to be heard at the Settlement
Hearing, such shareholder must have, in addition to the requirements of (1) above, filed with the
Clerk of the Court: (a) a written notice of such shareholders intention to appear; (b) a statement
that indicates the basis for such appearance; and (c) a statement identifying any witnesses the
shareholder intends to call at the Settlement Hearing and the subjects of their testimony. If a
Current Stone Energy Shareholder files a written objection and/or written notice of intent to
appear, such shareholder must also simultaneously serve copies of such notice, proof, statement and
documentation, together with copies of any other papers or briefs such shareholder files with the
Court (either by hand delivery or by first class mail) upon each of the following:
Clerk of the Court
|
CLIFFORD THAU | |
U.S. District Court, Western District of
|
HILARY L. PRESTON | |
Louisiana
|
VINSON & ELKINS LLP | |
800 Lafayette Street, Suite 2100
|
666 Fifth Avenue, 26th Floor | |
Lafayette, LA 70501
|
New York, NY 10103 | |
Telephone: (212) 237-0000 | ||
DANIEL E. BACINE
|
Facsimile: (212) 237-0100 | |
MARK R. ROSEN |
||
CHAD CARDER
|
Counsel for individual defendants Kenneth H. | |
BARRACK, RODOS & BACINE
|
Beer, David H. Welch and James H. Prince | |
3300 Two Commerce Square |
||
2001 Market Street
|
ARTHUR S. GREENSPAN | |
Philadelphia, PA 19103
|
RICHARDS KIBBE & ORBE LLP | |
Telephone: (215) 963-0600
|
One World Financial Center | |
Facsimile: (215) 963-0838
|
29th Floor | |
New York, NY 10281 | ||
Co-Lead Counsel for Plaintiffs and Counsel
|
Telephone: (212) 530-1800 | |
for plaintiff Joint Pension Fund, Local No.
|
Facsimile: (212) 530-1801 | |
164, I.B.E.W |
||
Counsel for individual defendants James H. | ||
Stone, John P. Laborde, Peter K. Barker, | ||
George R. Christmas, Richard A. Pattarozzi, | ||
David R. Voelker, Raymond B. Gary, Robert A | ||
Bernhard, B.J. Duplantis | ||
THOMAS A. ROBERTS | ||
BARRASSO USDIN KUPPERMAN | ||
FREEMAN & SARVER, LLC | ||
909 Poydras Street | ||
Suite 2400 |
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New Orleans, Louisiana 70112 | ||
Telephone: (504) 589-9731 | ||
Facsimile: (504) 589-9701 | ||
Counsel for individual defendant D. Peter Canty | ||
THOMAS P. PRESTON | ||
BLANK ROME LLP | ||
Chase Manhattan Centre | ||
1201 Market Street Suite 800 | ||
Wilmington, Delaware 19801 | ||
Telephone: (302) 425-6478 | ||
Facsimile: (302) 425-6464 | ||
Counsel for Stone Energy Corporation |
Any Current Stone Energy Shareholder who does not make his, her, or its objection in the
manner provided herein shall be deemed to have waived such objection and shall forever be
foreclosed from making any objection to the fairness, reasonableness, or adequacy of the settlement
as incorporated in the Stipulation and the Fee and Expense Award to Derivative Plaintiffs Counsel,
unless otherwise ordered by the Court, but shall otherwise be bound by the judgment to be entered
and the releases to be given.
X. CONDITIONS FOR SETTLEMENT
The settlement is conditioned upon the occurrence of certain events described in the
Stipulation. Those events include the occurrence of the Effective Date, which requires, among other
things: (1) entry of the requested Judgment by the Court; and (2) expiration of the time to appeal
from or alter or amend the Judgment. If, for any reason, any one of the conditions described in the
Stipulation is not met and the Effective Date does not occur, the Stipulation might be terminated
and, if terminated, will become null and void, and the parties to the Stipulation will be restored
to their respective positions as of February 12, 2010.
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XI. EXAMINATION OF PAPERS AND INQUIRIES
This notice contains only a summary of the terms of the settlement. For a more detailed
statement of the matters involved in the Derivative Actions, reference is made to the Stipulation
which may be inspected at the Office of the Clerk, Office of the Clerk of the United States
District Court for the Western District of Louisiana located at 800 Lafayette Street, Suite 2100,
Lafayette, LA 70501, during business hours of each business day.
Any other inquiries regarding the settlement or the Derivative Actions should be addressed
to one of the following:
BRIAN J. ROBBINS
|
CLIFFORD THAU | |
KEVIN A. SEELY
|
HILARY L. PRESTON | |
ARSHAN AMIRI
|
VINSON & ELKINS LLP | |
ROBBINS UMEDA LLP
|
666 Fifth Avenue, 26th Floor | |
600 B Street, Suite 1900
|
New York, NY 10103 | |
San Diego, CA 92101
|
Telephone: (212) 237-0000 | |
Telephone: (619) 525-3990
|
Facsimile: (212) 237-0100 | |
Facsimile: (619) 525-3991 |
||
Counsel for individual defendants Kenneth H. | ||
Co-Lead Counsel for Plaintiffs and Counsel
|
Beer, David H. Welch and James H. Prince | |
for plaintiff Priscilla Fisk |
||
ARTHUR S. GREENSPAN | ||
NADEEM FARUQI
|
RICHARDS KIBBE & ORBE LLP | |
BETH A. KELLER
|
One World Financial Center | |
FARUQI & FARUQI, LLP
|
29th Floor | |
369 Lexington Avenue, 10th Floor
|
New York, NY 10281 | |
New York, NY 10017
|
Telephone: (212) 530-1800 | |
Telephone: (212) 983-9330
|
Facsimile: (212) 530-1801 | |
Facsimile: (212) 983-9331 |
||
Counsel for individual defendants James H. | ||
Co-Lead Counsel for Plaintiffs and Counsel
|
Stone, John P. Laborde, Peter K. Barker, | |
for plaintiff Robert Farer
|
George R. Christmas, Richard A. Pattarozzi, | |
David R. Voelker, Raymond B. Gary, Robert A | ||
DANIEL E. BACINE
|
Bernhard, B.J. Duplantis | |
MARK R. ROSEN |
||
CHAD CARDER
|
THOMAS A. ROBERTS | |
BARRACK, RODOS & BACINE
|
BARRASSO USDIN KUPPERMAN | |
3300 Two Commerce Square
|
FREEMAN & SARVER, LLC | |
2001 Market Street
|
909 Poydras Street | |
Philadelphia, PA 19103
|
Suite 2400 | |
Telephone: (215) 963-0600
|
New Orleans, Louisiana 70112 | |
Facsimile: (215) 963-0838
|
Telephone: (504) 589-9731 |
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Facsimile: (504) 589-9701 | ||
Co-Lead Counsel for Plaintiffs and Counsel |
||
for plaintiff Joint Pension Fund, Local No.
|
Counsel for individual defendant D. Peter Canty | |
164, I.B.E.W |
||
THOMAS P. PRESTON | ||
RICHARD C. BROUSSARD
|
BLANK ROME LLP | |
BROUSSARD & DAVID |
||
600 Jefferson Street, Suite 700
|
Chase Manhattan Centre | |
Post Office Box 3524
|
1201 Market Street Suite 800 | |
Lafayette, LA 70502
|
Wilmington, Delaware 19801 | |
Telephone: (337) 233-2323
|
Telephone: (302) 425-6478 | |
Facsimile: (337) 233-2353
|
Facsimile: (302) 425-6464 | |
Co-Liaison Counsel for Plaintiffs and Counsel
|
Counsel for Stone Energy Corporation | |
for plaintiffs Robert Farer and Priscilla Fisk |
||
KENNETH W. DEJEAN |
||
417 West University Avenue |
||
Post Office Box 4325 |
||
Lafayette, LA 70502 |
||
Telephone: (337) 235-5294 |
||
Facsimile: (337) 235-1095 |
||
Co-Liaison Counsel for Plaintiffs and Counsel |
||
for plaintiff Joint Pension Fund, Local No. |
||
164, I.B.E.W. |
||
VINCENT M. GIBLIN, T.A. |
||
KROLL HEINEMAN & GIBLIN, LLC |
||
Metro Corporate Campus One |
||
99 Wood Avenue South, Suite 307 |
||
Iselin, NJ 08830 |
||
Telephone: (732) 491-2100 |
||
Facsimile: (732) 491-2120 |
||
Counsel for plaintiff Joint Pension Fund, Local |
||
No. 164, I.B.E.W. |
||
PAUL T. WARNER |
||
THE WARNER LAW FIRM |
||
11123 McCracken Lane, Suite A |
||
Cypress, TX 77429 |
||
Telephone: (281) 664-7777 |
||
Facsimile: (281) 664-7774 |
||
Counsel for State Derivative Plaintiff
Gregory |
||
Sakhno |
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KENNETH D. ST. PE |
||
GUILLIOT & ST. PE, LLC |
||
428 Jefferson Street |
||
Post Box 2877 |
||
Lafayette, LA 70502 |
||
Telephone: (337) 232-8177 |
||
Facsimile: (337) 232-7012 |
||
Liaison counsel for State Derivative
Plaintiff |
||
Gregory Sakhno |
PLEASE DO NOT TELEPHONE THE COURT OR STONE ENERGY REGARDING THIS
NOTICE.
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