EXAMPLES OF CLIENTS MR. DUGGINS HAS REPRESENTED OR IS CURRENTLY REPRESENTING

• Berkshire Hathaway Corporation
• Exxon Mobil Corporation
• Sabre Corporation
• Moncrief Oil
• Gloria Moncrief
• Tom O. Moncrief
• Six Flags Entertainment
• 6666 Ranch

EXAMPLES OF CASES ON WHICH MR. DUGGINS HAS WORKED

• Co-counsel for Union Pacific Resources in a jury trial in state court on a breach of contract claim against U.S. Steel. A favorable judgment for $10 million (plus $3 million in attorneys’ fees) was affirmed on appeal.
• Served as co-counsel for Tennessee Gas Pipeline Company in the jury trial of an action in Zapata County to determine Tennessee’s duties under a take-or-pay contract with Coastal Oil & Gas Corporation. Coastal sought a judgment against Tennessee in excess of $700 million.  Tennessee successfully recovered a jury verdict defeating Coastal’s claims.
• Served as lead counsel for Tennessee Gas Pipeline Company in the defense of a claim by Trans Texas Natural Gas for breach of a take-or-pay contract seeking in excess of $800 million. Tennessee recovered a favorable summary judgment defeating the Plaintiff’s principal claim.  While that ruling was on appeal, the litigation was favorably settled.
• Served as co-lead trial counsel for Tennessee Gas Pipeline Company in a proceeding pending before the Federal Regulatory Energy Commission involving Tennessee’s rights to pass on and recover stranded costs incurred in connection with its termination of various gas contracts. After a multi-week trial before an Administrative Law Judge, the proceeding was settled on a favorable basis.
• Represented Burlington Northern Railroad in insurance coverage litigation against several large domestic insurers, as well as various syndicates at Lloyds, to recover over $250 million in losses Burlington Northern had sustained in connection with its settlement of a prior anti-trust suit. After receiving favorable summary judgment rulings, the matter was settled on a very satisfactory basis for Burlington Northern.
• Represented Santa Fe Railroad in insurance coverage litigation against several large domestic insurers, as well as various syndicates at Lloyds, to recover over $300 million in losses Santa Fe had sustained in connection with its settlement of a prior anti-trust suit. After prevailing on summary judgment rulings in the District Court, the matter was settled on a favorable basis to Santa Fe.
• Represented Union Pacific Resources in a securities action filed in federal court in connection with Union Pacific’s hostile takeover attempt of Pennzoil. Handled a temporary injunction hearing to obtain additional disclosures from Pennzoil.  Before the Court ruled, Union Pacific Resources withdrew its tender offer.
• Served as co-counsel for Sabre Corporation in breach of contract and anti-trust actions brought against it by American Airlines. American claimed over $1 billion in damages.  Both cases settled favorably after the jury trial of the state court action had begun.
• Represented Waffle House in an insurance coverage claim in Fort Worth state court to recover losses Waffle House had sustained in resolving an underlying judgment. Prepared briefs and argued an appeal of an adverse summary judgment in which the Court of Appeals reversed the trial court and rendered judgment in favor of Waffle House finding coverage for the loss.
• Represented the City of Fort Worth and the Fort Worth Independent School District in suits filed in state court against Chesapeake Exploration and Total E&P for underpayment of royalties in connection with hundreds of oil and gas leases. Both cases were settled favorably with Chesapeake and Total making over $20 million in cash payments, as well as entering into amendments of the disputed leases that have resulted in both the City and the School District receiving substantial additional value in the form of higher royalties.
• Represented Wells Fargo Bank in litigation it filed in state court seeking declarations that certain investor owned life insurance policies having death benefits in excess of $40 million were valid and enforceable obligations. Obtained several favorable summary judgments and then recovered $3 million in attorneys’ fees in a jury trial.
• Co-counsel for Berkshire Hathaway in class actions filed to challenge its proposed acquisition of BNSF Railway. The class actions were ultimately dismissed with no payment by Berkshire Hathaway.
• Represented the Board of Directors of XTO Energy in class actions filed in Fort Worth state court challenging its merger with Exxon Mobil Corporation. Following depositions, the merger was consummated and the class actions were dismissed.
• Represented the former directors of a failed public company from claims brought against them by a bankruptcy trustee on behalf of Goldman Sachs, Bank of America, and other creditors. Following depositions of the parties, the trial court entered several favorable rulings and ultimately dismissed the case.  The trial court’s judgment was affirmed on appeal.
• Represented Williamson-Dickie in a suit against Chartis in which Williamson-Dickie sought coverage for losses attributable to environmental contamination. While the matter was pending in federal court, Williamson-Dickie reached a favorable settlement.