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PERFECT & PERSISTENT

Unable to collect for a large job constructing several new O&G drilling pads, the Client

turned to us to file a mineral lien. As usual, we reviewed all the contracts, work orders,
invoices and correspondence between our Client and the recalcitrant Debtor. Then, we

carefully researched all the legal entities with an interest in the well, the mineral lease, or

the property where the well was drilled. Finally, we were diligent in mailing all the notices
to parties required by the State statutes, as well as preparing and filing the mineral lien

before the legal deadline.

This determined Debtor continued to refuse to pay for the work. The Debtor hired an

aggressive “big” law firm. After tireless efforts to collect and multiple telephone calls with
the debtor’s attorney to attempt to avoid litigation, a lawsuit was filed to enforce the lien.

To defend the lawsuit, the big, expensive law firm responded with a long list of

counterclaims and raised every conceivable legal defense. They were particularly focused
on invalidating the mineral lien based on technicalities – improper date filed, late notice,

bad well identification, incorrect well location, wrong parties, wrong amount, improper

forms, and more.

Doré Rothberg McKay files and enforces the most mineral liens nationwide. We also
represent the most O&G service companies.

Pre-trial motions by the Debtor challenged the legality of every corner of the mineral lien
without any success. The judge ruled our lien was proper and legally correct in every

respect. Finally, on the eve of trial, the Debtor asked to settle the matter for the amount of
our original settlement offer, and our Client accepted and got paid.

The formula for success against a Debtor with a reputation as a tough customer? A perfect
lien. Persistence from both you, the Client, and your lawyer against an intimidating

adversary. Perfect & persistent won the day