AGREED MOTION FOR ENTRY OF FINAL JUDGMENT – Page 1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS

SAN ANGELO DIVISION 

PIONEER NATURAL RESOURCES 

USA, INC.,

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Plaintiff, §

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v.

RANDALL SCOTT HOUSTON, ET AL.,

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Defendants.

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RANDALL SCOTT HOUSTON ET AL.,

Counter-Plaintiffs,

v.

PIONEER NATURAL RESOURCES 

USA, INC.,

Counter-Defendant,

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RANDALL SCOTT HOUSTON ET AL.,

Cross-Plaintiffs,

v.

BRANDON HOUSTON,

Cross-Defendant,

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Civil Action No. 6:22-CV-00012-H

AGREED MOTION FOR ENTRY OF FINAL JUDGMENT

Pioneer Natural Resources USA, Inc. (“Pioneer”) files this Agreed Motion for Partial 

Final Judgment, reflecting the agreement of Pioneer, RRIG Energy, LLC (“RRIG”), Randall 

Scott Houston (“Houston”), Kortnie Dickerson, Individually and as Attorney-in-Fact for 

Case 6:22-cv-00012-H Document 23 Filed 10/07/22 Page 1 of 4 PageID 121
AGREED MOTION FOR ENTRY OF FINAL JUDGMENT – Page 2

Randall Scott Houston (“Dickerson”) and Brandon Houston (all together as the “Parties”), and 

hereby notifies the Court that the Parties have reached a settlement. 

RRIG and Houston have resolved the issues concerning the purchase and sale agreement 

and dismissed the Texas state court action. The result of that resolution is that RRIG claims no 

interest in the suspense money held by Pioneer that accrued prior to May 1, 2022. On October 3, 

2022, but effective as of May 1, 2022, RRIG, Houston, and Brandon Houston executed a 

Stipulation of Interest and Cross-Conveyance; Correction of Assignments (“Stipulation”) setting 

out their ownership of the subject interest. Further, from May 1, 2022 on, RRIG is entitled to fifty 

percent (50%) of Houston’s interest in the profits of mineral and royalty interests of oil and gas 

wells operated by Pioneer. In the Stipulation, Brandon Houston confirmed he does not contest 

RRIG’s interest it obtained from Houston pursuant to the PSA. 

As a result of the resolution of the Texas lawsuit between RRIG and Houston, the execution 

of the Stipulation, and Brandon Houston’s agreement that he is not contesting or otherwise seeking 

to unwind the Texas settlement or any transaction between RRIG and Houston, there is no dispute 

concerning the property interests or royalty payments subject to this interpleader action, and the 

Parties have agreed to dismiss (or have already dismissed) all claims asserted in this interpleader 

action and in competing litigation between the Parties in Texas and Missouri with Prejudice.

Pioneer thus requests that the Court not delay in entry of a final judgment with respect to 

these issues.

Pioneer, therefore, respectfully requests that the Court enter the proposed final judgment 

filed herewith: (1) confirming the respective interests held by RRIG and Houston in the Properties 

managed by Pioneer; (2) disbursing fifty percent (50%) of the suspense money held by Pioneer 

beginning May 1, 2022 to RRIG; (3) disbursing 100% of the suspense money held by Pioneer 

Case 6:22-cv-00012-H Document 23 Filed 10/07/22 Page 2 of 4 PageID 122
AGREED MOTION FOR ENTRY OF FINAL JUDGMENT – Page 3

before May 1, 2022 and 50% of suspense money held by Pioneer beginning May 1, 2022 to 

Houston; (4) entitling Pioneer to recover $8,000.00 out of suspended funds subject to this 

interpleader litigation as its reasonable and necessary attorney’s fees; and (5) disposing of all 

affirmative claims asserted in this action with prejudice.

WHEREFORE, PREMISES CONSIDERED, Pioneer requests that the Court enter the 

agreed order, and all other relief to which it is entitled.

Date Submitted: October 7, 2022

Respectfully,

/s/ Jack Balderson, Jr.

Jack Balderson, Jr.

Texas State Bar No. 24031716

jack@tbtexlaw.com

Jeffrey Tasker

State Bar No. 00795678

jeff@tbtexlaw.com

Tasker & Balderson PLLC

4335 Windsor Centre Trail, Suite 150

Flower Mound, Texas 75028

Tel.: 972-355-5959

Fax: 972-692-8200

Attorneys for Plaintiff Pioneer 

Natural Resources USA, Inc.

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AGREED MOTION FOR ENTRY OF FINAL JUDGMENT – Page 4

AGREED:

/s/ Conrad Hester (w/ permission) /s/ Ben Davidson (w/ permission)

Robert C. Vartabedian

Texas State Bar No. 24053534

rob.vartabedian@alston.com

Conrad D. Hester

Texas State Bar No. 24066562

conrad.hester@alston.com

Meaghan D. Nowell

Texas State Bar No. 24102288

meaghan.nowell@alston.com

Bank of America Tower

301 Commerce Street, Suite 3635

Fort Worth, Texas 76102

Tel.: 682-354-2000

Fax: 682-354-2299

Attorneys for Defendant 

RRIG Energy, LLC 

/s/ Philip Danaher (w/ permission)

Ben Davidson

Texas State Bar No. 05430590

bdavidson@mhbg.com

Will C. Griffis

Texas State Bar No. 24064159

wgriffis@mhbg.com

McClesky, Harriger, Brazill & Graf, 

L.L.P.

5010 University Avenue, Suite 500

Lubbock, Texas 79413

Tel.: 806-796-7300

Fax: 806-796-7305 

Attorneys for Defendant Brandon 

Scott Houston

Philip W. Danaher

Texas State Bar No. 24078395

philip@danaherlawfirm.com

Danaher Law Firm

833 SW Lemans Lane, Suite 116

Lee’s Summit, MO 64082

Tel.: 817-791-4892

Fax: 816-622-1293

Attorneys for Defendants Randall 

Scott Houston and Kortnie 

Dickerson Individually and as 

Agent and Attorney-in-Fact for 

Randall Scott Houston

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing document

has been served upon all counsel of record via the Court’s electronic filing system on this 7th day 

of October, 2022.

/s/ Jack Balderson, Jr.

Jack Balderson

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