Cudd Pressure Control, Inc. and Cudd Pumping Services, Inc. v. Exco Resources, Inc. and Exco Operating Company, LP

CourtCourt of Appeals of Texas
DecidedMarch 31, 2020
Docket05-16-01518-CV
StatusPublished

This text of Cudd Pressure Control, Inc. and Cudd Pumping Services, Inc. v. Exco Resources, Inc. and Exco Operating Company, LP (Cudd Pressure Control, Inc. and Cudd Pumping Services, Inc. v. Exco Resources, Inc. and Exco Operating Company, LP) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cudd Pressure Control, Inc. and Cudd Pumping Services, Inc. v. Exco Resources, Inc. and Exco Operating Company, LP, (Tex. Ct. App. 2020).

Opinion

AFFIRMED and Opinion Filed March 31, 2020

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-16-01518-CV

CUDD PRESSURE CONTROL, INC. AND CUDD PUMPING SERVICES, INC., Appellants V. EXCO RESOURCES, INC. AND EXCO OPERATING COMPANY, LP, Appellees

On Appeal from the 116th Judicial District Court Dallas County, Texas Trial Court Cause No. DC-14-06427

MEMORANDUM OPINION Before Justices Molberg, Carlyle, and Evans Opinion by Justice Evans On appeal, appellants Cudd Pressure Control, Inc. and Cudd Pumping

Services, Inc. (“Cudd”) assert the trial court erred by: (1) refusing to consider parol

evidence to clarify alleged ambiguities in the Contractor Dedicated Crew Work

Order (“Work Order”); (2) ruling Cudd failed to plead the defense of offset to

appellees EXCO Resources, Inc.’s and EXCO Operating Company, LP’s (“EXCO”)

counterclaim; and (3) concluding Cudd’s failure to provide reconciliation reports under article 6 of the Work Order is a condition precedent that bars Cudd’s defense

to EXCO’s counterclaim. We affirm.

BACKGROUND

A. Factual Background EXCO is involved in the exploration and development of oil and gas reserves.

Cudd provides oil field services such as hydraulic fracture stimulations. In May

2010, EXCO and Cudd entered into a Master Service and Supply Agreement

(“Master Agreement”) for the provision of services. Pursuant to the Master

Agreement, Cudd agreed to supply EXCO with various services related to wells

operated by EXCO.

In October 2011, EXCO and Cudd entered into the Work Order for hydraulic

fracture stimulation in east Texas and northern Louisiana. The Work Order contains

a provision which specifically incorporated the Master Agreement.1 At issue in this

case are three provisions of the Work Order—Articles 6, 18 and 19.

Article 6 of the Work Order addresses billing, reconciliation reports and

invoices:

Company will be billed on a per stage basis at the worksite. The ticket will reflect a flat “per stage” fixed cost charge based on the assumed fixed cost recovery threshold of one contractor crew performing at least two (2) stages (“Fracs”) in a 12 hour day, for an average of forty-four (44) Fracs per month in a twenty (20) day pumping month, and the 1 Article 1 of the Work Order provides: “The terms and conditions of the above referenced Master Service and Supply Agreement shall remain in effect and shall be incorporated into and govern this [Work Order].”

–2– applicable variable and line item costs. Contractor shall provide Company a monthly or quarterly reconciliation report, at Company’s option, clearly showing the difference between the total fixed costs billed during the period and the actual fixed costs due for the period. Any amount billed and paid by Company in excess of the actual fixed costs due will be credited to Company’s account. Company will be invoiced for any additional sums due Contractor as a result of any billing deficits that occurred during the period. All Contractor bills and invoices shall reference this Agreement and the site where the work is performed.

Article 18 of the Work Order addresses pricing and provides as follows:

Pricing shall be determined by combining a Fixed Service Charge with applicable Variable Charges for the services performed by Contractor, in accordance with the pricing tables in sections (a) and (b) below. Thereafter, the service charges, rates, or other remuneration shall be changed only upon mutual agreement by both parties.

The pricing table in section (a) of article 18 provides Cudd’s Fixed Service Charge

is $57,364.000 for a dedicated contractor crew performing 44 Fracs per month on a

12 hour basis.

Article 19 of the Work Order, entitled “Price Adjustments,” describes the

procedures for obtaining adjustments to the pricing described in Article 18.

Specifically, Article 19 provides as follows:

All fixed and variable prices herein shall be fixed for six (6) months. However, for the purpose of maintaining the benefit of the parties’ bargain, Company and Contractor agree that after the expiration of the first six (6) months of this Agreement, Contractor’s fixed and/or variable pricing may be adjusted once every six months to reflect any increase or decrease in the market prices of sand, organic chemicals, diesel fuel, labor, the replacement and recertification costs of Frac irons, Fluid-Ends, and expendables.

The party seeking the price adjustment shall provide thirty (30) days prior written notice of its intent to adjust price to the other party. Each –3– adjustment request shall include: the amount of the proposed adjustment; a written explanation of the need for the adjustment; and reasonable evidence of the percentage change in market price. Exhibit C provides an example of the method used to track changes in the replacement and recertification costs of Frac irons, Fluid-Ends and expendables.

Price adjustments shall become effective no later than thirty (30) days after receipt by the non-requesting party of the price adjustment notice. Should the non-requesting party have reason to challenge the amount of an adjustment request, the nonrequesting party must notify the other party of the reason for its challenge including supporting evidence within fifteen (15) days after receipt of the adjustment notice, and the parties shall negotiate in good faith on the appropriate adjustment amount.

Because the parties acknowledge that this agreement is intended to be cooperative in nature, but that fluctuations in price are inherent in the industry, the challenging party agrees to honor any adjustment request in full during the course of negotiations, and up to five (5) days thereafter. Negotiated price adjustments shall take effect on the fifth day after an agreement has been reached. Notwithstanding anything contained herein to the contrary, in no event shall Contractor be required to disclose any trade secrets or third party supplier pricing not directly billed to the account of company.

Important to our analysis later are the provisions requiring thirty days’ prior written

request for a price change containing evidence of market price and a fifteen day

opportunity to object and negotiate an agreed price increase.

The two-year term of the Work Order expired on December 31, 2012, and

EXCO did not exercise its option to renew the agreement for an additional year. In

–4– February 2013 and without having provided any reconciliation reports, Cudd

invoiced EXCO for $6,734,240.88 for increased costs of fluid ends and frac irons.2

B. Procedural Background

In June 2014, Cudd filed a lawsuit against EXCO alleging causes of action for

breach of contract, promissory estoppel, and mutual mistake and seeking

reimbursement the costs for fluid ends replacement. On September 3, 2015, EXCO

filed a traditional and no-evidence motion for summary judgment on Cudd’s claims.

Cudd filed a response which included the affidavit of Tim Mathews, the Service Line

Vice President for Cudd Energy Services. EXCO objected to certain paragraphs of

Mathews’s affidavit as being inadmissible under the parol evidence rule, irrelevant,

and self-serving. On September 21, 2015, the trial court granted EXCO’s motion as

to the promissory estoppel and mutual mistake claims and denied the motion as to

the breach of contract claim. The trial court also sustained EXCO’s objections to

Mathew’s affidavit and struck the evidence.

In February 2016, Cudd filed an amended petition alleging it was entitled to

“payment of the replacement fluid-ends as a fixed cost, pursuant to Article 6” of the

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Cudd Pressure Control, Inc. and Cudd Pumping Services, Inc. v. Exco Resources, Inc. and Exco Operating Company, LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cudd-pressure-control-inc-and-cudd-pumping-services-inc-v-exco-texapp-2020.