Reply Brief — Warner-Lambert Co. v. Wakefield, Individually and as Personal Representative, Trustee, and of the Estate of Wakefield

~. OUT. US

3 | - FILED

No. 04-1047 _ APR 13 2005

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1 OFFICE, TEE Chin

In The —

Supreme Court of the Gnited States

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WARNER-LAMBERT COMPANY and PFIZER INC.,

Petitioners,

¥.

MARY ROSE WAKEFIELD, INDIVIDUALLY,

AS PERSONAL REPRESENTATIVE, TRUSTEE,

EXECUTOR OF THE ESTATE OF MICHAEL HOLMES

WAKEFIELD AND MARY LOUISE WAKEFIELD,

Respondent.

r

vy

On Petition For Writ Of Certiorari

To The Oklahoma Court Of Civil Appeals

¢

REPLY ON PETITION FOR

A WRIT OF CERTIORARI

¢

DAVID KLINGSBERG

Counsel of Record

MARIS VEIDEMANIS

KAYE SCHOLER LLP

425 Park Avenue

New York, New York 10022

(212) 836-8000

STEVEN S. ROSENTHAL

KAYE SCHOLER LLP

The McPherson Building

901 Fifteenth Street, N.W.

Suite 1100

Washington, D.C. 20005

(202) 682-3500

RICHARD M. ELDRIDGE

THOMAS E. STEICHEN

ELDRIDGE COOPER STEICHEN & LEACH PLLC

110 West Seventh Street

Suite 200

Tulsa, Oklahoma 74119

(918) 388-5555

Attorneys for Petitioners

COCKLE LAW BRIEF PRINTING CO. (800) 225-6964

OR CALL COLLECT (402) 342.2831

TABLE OF CONTENTS

Page

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PRELIMINARY STATEMENT.......................c0sceeceees 1

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I. RESPONDENT ADMITS THAT THE JURY

WAS TOLD TO CALCULATE PUNITIVE

DAMAGES ON THE BASIS OF WORLD-

WIDE REZULIN SALES AND PROFITS,

AND THE HOLDING OF THE COURT BE-

LOW THAT THIS CALCULATION IS CON-

SISTENT WITH BMW AND STATE FARM

UNDERSCORES THE NEED FOR CER-

I sata ahsiscnceasherdes Sasi athnmineaaacbsanaridansrone 2

II. THE PUNITIVE DAMAGE AWARD IS

UNCONSTITUTIONALLY EXCESSIVE ........ 6

II. PETITIONERS’ ARGUMENTS WERE

PT IEA aridacsiacishcdctnvasesencaearcocnunipeentendas 7

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TABLE OF AUTHORITIES

Page

CASES:

Anchor Hocking, Inc. v. Waddill, 538 U.S. 974

CNIS a accenisisiaeaceceat clue ameaaaacete as Naaiee hdaaacaeae 6

Axen v. American Home Prod. Corp., 158 Or. App.

DOR, G74 Te Bee ok tials anionie 3°

BMW of North America v. Gore, 517 U.S. 559

CRI) ..<aasisssanxscsnsatiaiamecteschiadiaaaicaisialaaiaaammicatanae passim

Board of Dir. of Rotary Int'l v. Rotary Club of

Dascsrbe, 4B) 4225. BST Cee siactsncasissscccuatnescavithassntnecsvisatncs 8

Bocci v. Key Pharm., Inc., 76 P.3d 669 (Or. Ct. App.

DIGI) aicsixnnnsisnniaicssiaciciecsgsesstacaniuataean aaa alae dalla naditaaaedaaaateas 5

Boeken v. Philip Morris, Inc., 2005 WL 737511 (Cal.

CX. Age. Agmtid 3, FI sescsacicucecusn cictnaismadastacinaensennsines 5

Boerner v. Brown & Williamson Tobacco Co., 394

Pek SG (Oa Cie, Fee secsrstsitaecinteteasbesbaeseestestacenceenss 6

Continental Trend Resources, Inc. v. OXY USA Inc.,

101 F.3d 634 (10th Cir. 1996), cert. denied, 520

UG ERR Ca avast aartalatenieans 6

Craig v. Holsey, 590 S.E.2d 742 (Ga. Ct. App. 2003).......... 5

Ford Motor Co. v. Romo, 538 U.S. 1028 (2003)..............0.... 6

Hardeman v. City of Albuquerque, 377 F.3d 1106

(BOs Cite, DDG) vccexsissiccincusittcnchimaps itetandaetpatalataninetiattievcess 8

Harris Trust and Sav. Bank v. Salomon Smith

Barney, inc.,, S30 UB. BEB GI vo ccncnsaccocssssnsseccsccssvesecess 9

Howell v. Mississippi, 125 S. Ct. 856 (2005)..............ccc eee 9

Jenkins v. Georgia, 418 U.S. 153 (1974)... eeeeeeeeeees 8

Johnson v. Ford Motor Co., 45 P.3d 86 (Okla. 2002) .......... 8

ill

TABLE OF AUTHORITIES - Continued

Page

Key Pharms., Inc. v. Edwards, 538 U.S. 974 (2003)........... 6

Oklahoma City Urban Renewal Auth. v. City of

Oklahoma City, __ P.3d __, 2005 WL 44399

(Okla. Jan. 11, 2005)............. OE a eT REM 8

Peters v. Golden Oil Co., 600 P.2d 330 (Okla. 1979)........... 8

Philip Morris USA, Inc. v. Williams, 504 U.S. 801

eka oe aaah eansaceonaiencal 6

Raley v. Ohio, 360 U.S. 423 (1959)................cccssssssecccceeeesees 8

State Farm Mut. Auto. Ins. Co. v. Campbell, 538

IIIT inisthachiintntndestpiahedghosisiansamoiaceustbenesseen passim

Tiger Flats Prod. Co. v. Oklahoma Petroleum, 711

i sald as petoiiabaalianesaiiion 8

U.S. v. Zannino, 895 F.2d 1 (1st Cir.), cert. denied,

OS ee rOetneT 8

White v. Ford Motor Co., 312 F.3d 998 (9th Cir.

LER A a Seen nee ee RN EGA ie eRe ee 6

Williams v. Philip Morris, Inc., 193 Or. App. 527, 92

P.3d 126, review granted, 337 Or. 669, 104 P.3d

601 (2004) ...... aUiiactadaanesgeonaoteiadeadnsdnaieseasiiebicusesakamanaaee 5

STATUTES AND RULES

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PRELIMINARY STATEMENT

Respondent’s Brief in Opposition (“R. Br.”) virtually

ignores the reasons for granting certiorari. Instead,

respondent devotes almost all of her brief to arguing that

certain questions — but not the specific Questions Pre-

sented — were not preserved. As shown in Point III, infra,

the Questions Presented were raised in and specifically

addressed by the court below, and the points in the peti-

tion are all “fairly included” within those questions. Sup.

Ct. R. 14.1(a). What little argument respondent offers on

the issue of whether certiorari should be granted does not

refute petitioners’ showing that the punitive damages

were calculated on the basis of world-wide sales and

profits from an FDA-approved drug, which squarely

conflicts with State Farm Mut. Auto. Ins. Co. v. Campbell,

538 U.S. 408 (2003), and BMW of North America v. Gore,

517 U.S. 559 (1996), and presents significant issues for

this Court’s review.

As discussed in the petition and in the amicus briefs

submitted in support thereof, the context for the Questions

Presented is that a jury was instructed by counsel and

permitted to calculate punitive damages regarding a

prescription drug on the basis of worldwide sales figures,

when those sales were lawful because the drug was ap-

proved for sale by the FDA and foreign regulatory agen-

cies. That result creates a risk of excessive, multiple

punishments based on out-of-state conduct. Moreover, that

conduct lacks the requisite “nexus” to any harm to this

plaintiff and has no relationship to reprehensibility,

because worldwide sales necessarily include sales to

everyone who benefitted from the drug and did not sustain

any harm. That result also allows a jury to become a de

facto national regulator of what prescription drugs may be

sold nationally, contrary to this Court’s holding that a

state may not “use the punitive damages deterrent as a

means of imposing its regulatory policies on the entire

Nation.” BMW, 517 U.S. at 585. That power undermines

the FDA’s expert determination that a drug should be on

2

the market because its benefits outweigh its risks, and

chills the incentive to develop vitally needed medications,

adversely affecting health care. Respondent’s brief simply

ignores these and other important legal and policy consid-

erations, which flow from BMW and State Farm. In

addition, this petition is an ideal vehicle for this Court to

examine the holdings of these two landmark decisions in a

product liability/personal injury case, because plaintiff

argues that those cases apply only where economic injury

was claimed.

ARGUMENT

I. RESPONDENT ADMITS THAT THE JURY WAS

TOLD TO CALCULATE PUNITIVE DAMAGES

ON THE BASIS OF WORLDWIDE REZULIN

SALES AND PROFITS, AND THE HOLDING OF

THE COURT BELOW THAT THIS CALCULA-

TION IS CONSISTENT WITH BMW AND STATE

FARM UNDERSCORES THE NEED FOR CER-

TIORARI

The only “evidentiary support for the award of puni-

tive damages” identified by the Oklahoma Court of Civil

Appeals was “evidence of the dollar amount of world-wide

gross sales of Rezulin — $48 million per month,” and

alleged “expert testimony that [Warner-Lambert’s] profit

margin on Rezulin sales was thirty percent.” App. 17. Such

profits, the court held, “clearly provided a basis for jury

determination” under the Oklahoma punitive damages

statute, 23 OKLA. STAT. § 9.1(C), of “the increased financial

benefit derived by the defendant as a direct result of the

conduct causing the injury to the plaintiff and other

persons or entities.” Jd. Thus, the highest state appellate

court to hear this case expressly found that the punitive

damage award was based on worldwide sales and profits.

That disposes of respondent’s assertion that petitioners

are asking the Court to “speculate” about the basis for the

award. R. Br. at 4.

3

This punitive damage award is directly contrary to

State Farm and BMW. In BMW, 517 U.S. at 572-73, the

Court held that a State “does not have the power ... to

punish [a defendant] for conduct that was lawful where it

occurred and that had no impact on [that State] or its

residents.” Respondent had the burden of showing that the

out-of-state conduct was unlawful. Jd. at 573. But there

was no evidence as to the law of any other state, and the

jury was not asked to apply such law. Thus, there was no

basis on which the jury could have found that all of the

worldwide sales of Rezulin were unlawful. Nor does

respondent even argue that they were. By upholding

punitive damages calculated on the basis of worldwide

sales and profits, the courts below improperly punished

petitioners for conduct — selling Rezulin — that was “lawful

where it occurred” and “had no impact on [Oklahoma] or

its residents.” Jd. at 572-73.

The court below held that the award does not punish

defendants “for conduct legal in other states.” A. 18.

Indeed, respondent asserts that Warner-Lambert’s conduct

was “not legal in any state.” R. Br. at 23. A grant of the

petition is warranted to clarify and re-affirm this Court's

holding that states have no “legitimate concern in impos-

ing punitive damages to punish a defendant” even for

“unlawful acts committed outside of the state’s jurisdic-

tion.... [E]ach State alone can determine what measure

of punishment, if any, to impose on a defendant who acts

within its jurisdiction.” State Farm, 538 U.S. at 421-22.

Axen v. American Home Prod. Corp., 158 Or. App. 292,

316, 974 P.2d 224, 240 (1999), on which respondent relies,

is not to the contrary, because the punitive award in that

case was not calculated on out-of-state sales.

Worldwide sales, which include sales to every diabetic

who benefitted from and had no complications from

Rezulin treatment, also have no “nexus to the specific

harm suffered by the plaintiff,” as required by State Farm,

538 U.S. at 422. No such nexus was identified by the court

below. Respondent ignores the argument.

4

Moreover, basing a punitive award on worldwide sales

violates the Due Process Clause prohibition against

“arbitrary punishments” (id. at 409), for the reasons

explained in the Petition at 21-22. Respondent ignores the

issue. Contrary to BMW, 517 U:S. at 574, petitioners had

no “fair notice” that this arbitrary factor could be used to

calculate punitive damages. No such notice is provided by

23 OKLA. STAT. § 9.1(C), because worldwide sales have no

relationship to any “increased financial benefit” derived

“as a direct result of the conduct causing the injury.” As

respondent correctly states, “global sales” are “wholly

distinct” from “wrongful acts in other states.” R. Br. at 25.

Yet, punitive damages in this case were improperly as-

sessed on the basis of global sales and purported profits.

Petitioners were further denied due process because

there was no evidence of the actual profit margin for

Rezulin while it was on the market, and accordingly there

was no basis for any finding of “financial benefit” to

Warner-Lambert “as a direct result of the conduct causing

the injury.” Respondent’s assertion that Rezulin had a

31.7% profit margin in 1999 is false. R. Br. at 22." Nor

could the jury “infer” the amount of Rezulin profits from

Oklahoma (R. Br. at 23) when there was no evidence of

sales, profits, or prescriptions in Oklahoma.

Respondent’s argument that the punitive award is

justified in light of Warner-Lambert’s alleged “misdeeds”

and “reprehensibility” (R. Br. at 3, 28) further illustrates the

need to clarify and re-emphasize this Court’s decisions. State

Farm held that “[d]ue process does not permit courts, in the

calculation of punitive damages, to adjudicate the merits of

other parties’ hypothetical claims against a defendant

* Exhibit 2946, cited by respondent, was specifically identified at trial

as a “forecast for sales and profitability” that “projected” profit margins,

and therefore is not evidence of actual profits. Respondent correctly states

that Exhibit 2286 shows that Rezulin had $48.7 million “net sales” in

January 1998, but does not mention the testimony that net sales are

simply “sales less rebates and discounts,” not profits. R.3806, Tr. 2104.

5

under the guise of [a] reprehensibility analysis.” 538 U.S.

at 423. Nevertheless, many state courts have used a

“reprehensibility analysis” to approve punitive damages

based on out-of-state conduct, nullifying that principle.’

Respondent’s argument that the jury could properly

consider Warner-Lambert’s “net worth” or “financial condi-

tion” in assessing punitive damages misstates the basis for

the award. R. Br. at 4-5, 24. In summation, respondent’s

counsel did not ask the jury to award punitive damages

based on net worth or financial condition, but on alleged

profits from worldwide Rezulin sales, in a range of $21-$600

million. R.3823, Tr. 3410. Respondent concedes that her

counsel made this argument. R. Br. at 29. And this was the

sole “evidentiary support” for the calculation of punitive

damages found by the Court of Civil Appeals. A. 17.

Respondent argues that evidence of worldwide

Rezulin sales came from Warner-Lambert’s annual reports

that defendants offered at trial. R. Br. at 2. But the fact

that evidence is properly admitted does not mean that it

can be used for an unconstitutional purpose. The only

reference at trial to the sales figures in the annual reports

was by respondent’s counsel during her summation in the

punitive damages phase.

Respondent says that there is no conflict among lower

courts, so that petitioners “merely” argue that the decision

below conflicts with U.S. Supreme Court authority. R. Br.

* See, e.g., Boeken v. Philip Morris, Inc., 2005 WL 737511, at *32-42

(Cal. Ct. App. April 1, 2005) (upholding punitive damages of $50

million, a 9:1 ratio, based on out-of-state conduct); Williams v. Philip

Morris, Inc., 193 Or. App. 527, 559 n.8, 92 P.3d 126, 143 n.8, review

granted, 337 Or. 669, 104 P.3d 601 (2004) (court upheld punitive award

in a 96:1 ratio by holding that “all of the out-of-state conduct . . . led to

actions within Oregon or that were directed to Oregonians [so] Oregon

has the authority to punish defendant for such conduct”); Craig v.

Holsey, 590 S.E.2d 742 (Ga. Ct. App. 2003) (using reprehensibility

analysis to uphold a 22:1 ratio); Bocci v. Key Pharm., Inc., 76 P.3d 669,

674 (Or. Ct. App. 2003) (using same analysis to uphold a 7:1 ratio).

6

at 5. But that decision and the state court cases cited in

n.2, supra, do conflict with appellate decisions that con-

form to State Farm and BMW. See, e.g., White v. Ford

Motor Co., 312 F.3d 998, 1020 (9th Cir. 2002); Continental

Trend Resources, Inc. v. OXY USA Inc., 101 F.3d 634, 637

(10th Cir. 1996), cert. denied, 520 U.S. 1241 (1997). That is

yet another reason why certiorari should be granted.

Notably, contrary to respondent’s assertion that only a

“small fraction” of cases involving Rezulin remain (R. Br.

at 6), thousands of such cases are still pending in the

federal MDL court and various state courts, so these

issues could arise again in the same context.

Il. THE PUNITIVE DAMAGE AWARD IS UNCON-

STITUTIONALLY EXCESSIVE

Respondent argues that State Farm and BMW are

limited to cases involving economic damages. But this

Court has not said that, and in numerous product liability

cases involving physical harm it granted certiorari, va-

cated the punitive damages judgment, and remanded for

reconsideration in light of State Farm.’ Moreover, lower

courts have applied State Farm and BMW to punitive

damage awards in personal injury/product liability cases.

See, e.g., Boerner v. Brown & Williamson Tobacco Co., 394

F.3d 594, 602-03 (8th Cir. 2005) (reducing punitive dam-

ages in product liability case to a 1:1 ratio, based upon

State Farm and BMW analysis). To the extent that the

Oklahoma Court of Civil Appeals and other courts might

accept respondent’s contention that State Farm and BMW

are inapplicable to personal injury cases, that is another

reason for granting certiorari.

* See Philip Morris USA, Inc. v. Williams, 504 U.S. 801 (2003); Key

Pharms., Inc. v. Edwards, 538 U.S. 974 (2003); Anchor Hocking, Inc. v.

Waddill, 538 U.S. 974 (2003); Ford Motor Co. v. Romo, 538 U.S. 1028

(2003). ‘

7

Respondent’s argument that the punitive damage

award was not unconstitutionally excessive because “ijt

was substantially below the lowest recommended range” is

specious. R. Br. at 29. That “recommendation” was made

to the jury by respondent’s counsel, and ranged from $21

million to $600 million, which in itself demonstrates the

unprincipled nature of the basis on which the jury was

told to calculate punitive damages. By the same reasoning,

any punitive damage award would pass muster so long as

it was lower than the top of some outrageous range re-

quested by the plaintiff’s counsel.

Ill. PETITIONERS’ ARGUMENTS WERE PRE-

SERVED

Respondent's argument that Warner-Lambert failed to

preserve its claims of error is frivolous. The first Question

Presented is whether the punitive damage award conflicts

with State Farm and BMW. See Petition at i. Petitioners

made this precise argument at every stage of the proceed-

ings below. See id. at 7. And the argument was not made

in only “three sentences,” as respondent suggests (R. Br. at

19), but in numerous pages in petitioners’ “Brief in Chief”

(opening brief) and reply brief to the Oklahoma Court of

Civil Appeals. Petitioners specifically argued that the

punitive damage award was unconstitutional because it

was based on worldwide sales and had no nexus to any

harm to the plaintiff. See Appellants’ Brief in Chief at 26-

29 and Reply Brief at 22-29. State Farm was mentioned

five times in petitioners’ Brief in Chief and 14 times in the

reply brief. BMW was mentioned twice in the Brief in

Chief and once on reply.

Respondent admits that the Court of Civil Appeals

“addressed [Warner-Lambert’s] arguments under State

Farm that there was an ‘insufficient nexus between the

punitive damages and the actual harm suffered by plain-

tiff,” and also “addressed [Warner-Lambert’s] argument

that the award violated the guidelines outlined in BMW.”

R. Br. at 15. “Where the court below actually passes on a

8

federal question, any inquiry into whether or when the

question was raised for jurisdictional purposes becomes

irrelevant.” Jenkins v. Georgia, 418 U.S. 153, 157 (1974);

Raley v. Ohio, 360 U.S. 423, 436-37 (1959). Respondent

does not even argue that the second Question Presented

(whether the award is unconstitutionally excessive) was

not preserved. Nor did respondent argue below that the

punitive damages issues were not preserved. Thus, “the

record as a whole” shows that the Questions Presented

were “adequately presented in the state system.” Board of

Dir. of Rotary Int'l v. Rotary Club of Duarte, 481 U.S. 537,

549-50 (1987).

Respondent cites Oklahoma cases stating that points

of error not contained in appellate briefs are waived. But

in each case, the appellant neither made any argument on

the claim of error nor cited any authority.‘ In contrast,

petitioners extensively briefed the punitive damages

issues, based on BMW and State Farm, in both of their

briefs to the Court of Civil Appeals.

Petitioners also asked the Oklahoma Supreme Court

to review these issues. Petitioners’ Brief in Chief was

initially filed with the Supreme Court, which then decided

to refer the case to the Court of Civil Appeals. Recognizing

that the Supreme Court has already seen the Brief in

* Oklahoma City Urban Renewal Auth. v. City of Oklahoma City,

___ P.3d __, 2005 WL 44399 (Okla. Jan. 11, 2005) (claim of error not

briefed); Johnson v. Ford Motor Co., 45 P.3d 86 (Okla. 2002) (nine

points of error asserted, but only three briefed); Tiger Flats Prod. Co. v.

Oklahoma Petroleum, 711 P.2d 106 (Okla. 1985) (claim of error merely

alluded to in briefs, without supporting authority); Peters v. Golden Oil

Co., 600 P.2d 330 (Okla. 1979) (appellant cited no authority and made

no argument to convince appellate court to reverse); Hardeman v. City

of Albuquerque, 377 F.3d 1106 (10th Cir. 2004) (appellants indicated in

their post-trial motion that they were not seeking review of a constitu-

tional issue, and thus failed to preserve it); U.S. v. Zannino, 895'F.2d 1

(1st Cir.), cert. denied, 494 U.S. 1082 (1990) (appellant attempted to

“adopt” arguments of co-defendants in brief without providing any

argument of his own).

9

Chief, the certiorari process in Oklahoma does not provide

for full briefing, but rather for a limited 10-page petition

for certiorari. Okla. Sup. Ct. R. 1.179(b). By rule, “[t}he

petition, answer, and reply shall not reach the merits of

the appeal.” Okla. Sup. Ct. Rule 1.179(d).

Respondent argues that petitioners waived their

argument that the trial court refused their requested

instructions based on BMW, 517 USS. at 572-73, to limit

the jury’s focus to Oklahoma transactions. Respondent

ignores U.S. Supreme Court Rule 14.1(a), which provides

that “[t]he statement of any question presented is deemed

to comprise every subsidiary question fairly included

therein.” Under this rule, “[o]nce a federal claim is prop-

erly presented, a party can make any argument in support

of that claim; parties are not limited to the precise argu-

ments they made below.” Harris Trust and Sav. Bank v.

Salomon Smith Barney, Inc., 530 U.S. 238, 245 n.2 (2000).

Respondent admits that after the trial court delivered its

instructions to the jury, her counsel asked the jury to

calculate punitive damages based on the global profits for

Rezulin, triggering the constitutional issue. R. Br. at 29.

The trial court’s refusal to give instructions, based on

BMW, that it could not award punitive damages based on

out-of-state conduct that had no relationship to any harm

to the plaintiff is part of the procedural history “fairly

included” in the first Question Presented.®

Contrary to respondent’s argument (R. Br. at 20),

petitioners are not contending that the Oklahoma punitive

damages statute is unconstitutional on its face, but that it

was “interpreted and applied” in an unconstitutional

manner. Petition at 16. Petitioners argued in their Brief in

Chief (at 27) that the statute should be interpreted as

* Howell v. Mississippi, 125 S. Ct. 856, 858 (2005), cited by

respondent, is distinguishable because the petitioner “did not properly

present his claim” before the state appellate court “as one arising under

federal law.” Petitioner also cites Oklahoma Supreme Court Rule 15,

but that was repealed in 1997.

10

limited to financial benefit in Oklahoma that has a nexus

to harm to this plaintiff. But the Court of Civil Appeals

held that the statute could encompass “world-wide gross

sales.” A. 17. Under that interpretation, the statute is

unconstitutional in light of BMW and State Farm. That

issue arose only after the Court of Civil Appeals failed to

interpret the statute in a constitutional manner. Petition-

ers then raised the issue in their certiorari petition to the

Oklahoma Supreme Court. R. Br. at 2a.

CONCLUSION

For the foregoing reasons, and the reasons set forth in the

petition, the petition for a writ of certiorari should be granted.

Respectfully submitted,

DAVID KLINGSBERG

Counsel of Record

MARIS VEIDEMANIS

KAYE SCHOLER LLP

425 Park Avenue

New York, New York 10022

(212) 836-8000

STEVEN S. ROSENTHAL

KAYE SCHOLER LLP

The McPherson Building

901 Fifteenth Street, N.W.

Suite 1100

Washington, D.C. 20005

(202) 682-3500

RICHARD M. ELDRIDGE

THOMAS E. STEICHEN

ELDRIDGE COOPER STEICHEN

& LEACH PLLC

110 West Seventh Street

Suite 200

Tulsa, Oklahoma 74119

(918) 388-5555

Attorneys for Petitioners