Question
From:(redacted)
Sent:Tuesday, April 11, 2006 12:01 PM
To:Verne, B. Michael
Subject:802.3
Dear Mike,
I amanalyzing an acquisition of oil and gas reserves and some associated assets. Iwould appreciate it if you would confirm that I have correctly separated theassets into exempt and non-exempt categories for the purpose of valuing thenon-exempt assets to determine whether an HSR filing is required:
Exemptunder 802.3, provided that total value is $500 million or less
leaseson the land containing the oil and gas reserves, along with Seller's rights inassociated agreements, permits and licenses
oiland gas wells
equipmentused in conjunction with the oil and gas wells (excluding pipelines as definedin 802.3(c)(1) and (2))
vehiclesand other personal property located on the land, where integral and exclusiveto the exploration/production assets
oiland gas reserves
governmentpermits and licenses associated with the oil and gas wells, land leases andassociated equipment
filesand records associated with the oil and gas wells and all associatedexploration/production assets
fieldprocessing plants that serve the oil and gas reserves being acquiredexclusively
Non-exemptunder 802.3
vehiclesand other personal property located on the land, where not integral andexclusive to the exploration/production assets
filesand records, permits and licenses not integral and exclusive to the oil and gaswells and exploration/production assets
processingplants not exclusive to the oil and gas reserves being acquired