Horizontal Products Company Energy Services, Inc. v. Heart Land Drilling, Inc.
Midland County, Texas
Breach of Contract. Failure to pay invoices on oil well drilling motors rented by HPC to Heart Land Drilling.
- Lead counsel for plaintiff HPC Energy services prosecuting claim for un-paid invoices on rented drilling motors.
- Total invoices not paid by Heart Land Drilling over $500,000.
- Learned that Heart Land Drilling was selling off assets (oil rigs), Kruse Energy Auctioneers in Midland, Texas, through depositions of Heart Land Drilling owners.
Obtained Temporary Restraining Order preventing sale of any assets outside ordinary course of business, including oil rigs and equipment necessary for operations. October 2019.
Prosecuted and obtained Temporary Injunction even though Heart Land Drilling principals failed to appear at injunction hearing after being served with subpoena. Used deposition testimony of Heart Land Drilling principals and operations manager to meet burden of proof. October 2019.
- Compelled depositions of corporate representatives for discovery of evidence to prove alter ego theory for holding principals personally liable on Heart Land Drilling corporate debt
- Heart Land Drilling filed voluntary petition in bankruptcy under Chapter 7 United States Bankruptcy Code on morning of corporate representative depositions scheduled to be taken in Abilene, Texas per court order. December 2019.