IN THE DISTRICT COURT OF OKLAHOMA COUNTY
STATE OF OKLAHOMA
WYATT CONLEY )
Plaintiff,
v. )
BCE-MACH LLC; MACH NATURAL ) CASE NO.: CJ-2026-
RESOURCES LP; MACH RESOURCES, )
LLC; AND BAYOU CITY ENERGY )
MANAGEMENT, LLC. )
Defendants )
PLAINTIFF'S ORIGINAL PETITION
NOW COMES, Wyatt Conley, complaining of BCE-Mach LLC, Mach Natural Resources LP, Mach Resources, LLC, and Bayou City Energy Management LLC, Defendants herein, and for his cause of action, would show the Court as follows:
I. PARTIES
1.1 Plaintiff, Wyatt Conley, is a resident of the state of Oklahoma and brings suit in his individual capacity.
1.2 BCE-Mach LLC, (hereinafter referred to as "MACH"), is a foreign limited liability company, doing business, engaging in business, and transacting business in the State of Oklahoma, with its Principal Executive Offices located at 14201 Wireless Way, Suite 300, Oklahoma City, Oklahoma and may be served with process by serving its Oklahoma registered agent for service, The Corporation Company, 1833 S. Morgan Rd., Oklahoma City, OK 73128.
1.3 Defendant, Mach Natural Resources LP (hereinafter referred to as “MACH”), is a foreign limited partnership, doing business, engaging in business, and transacting business in the State of Oklahoma, with its Principal Executive Offices located at 14201 Wireless Way, Suite 300, Oklahoma City, Oklahoma and may be served with process by serving its Oklahoma registered agent for service, Greg Dewey, 14201 Wireless Way, Suite 300, Oklahoma City, OK 73134.
1.4 Defendant, Mach Resources LLC (hereinafter referred to as “MACH”), is a foreign limited liability company, doing business, engaging in business, and transacting business in the State of Oklahoma, with its Principal Executive Offices located at 14201 Wireless Way, Suite 300, Oklahoma City, Oklahoma and may be served with process by serving its Oklahoma registered agent for service, Greg Dewey, 14201 Wireless Way, Suite 300, Oklahoma City, OK 73134.
1.5 Bayou City Energy Management LLC, (hereinafter referred to as "MACH"), is a foreign limited liability company, doing business, engaging in business, and transacting business in the State of Oklahoma, and having no registered agent for service in Oklahoma, may be served with process by serving its Texas registered agent for service, William W McMullen, 1201 Louisiana Street, Suite 3308, Houston, TX 77002.
II. JURISDICTION AND VENUE
2.1 This is a negligence action involving an incident that occurred on February 24, 2026 at an oil and gas wellsite in Canadian County. The site was controlled and
operated by Defendants, and the negligence resulted in personal injuries to Plaintiff.
2.2 During the period relevant to this lawsuit, BCE-Mach, LLC, conducted its business in Oklahoma and maintained its Principal Executive Offices at 14201 Wireless Way, Suite 300, Oklahoma City, Oklahoma. As such, venue is proper in Oklahoma County pursuant to 12 O.S. § 134.
2.3 During the period relevant to this lawsuit, Mach Natural Resources LP conducted its business in Oklahoma and maintained its Principal Executive Offices at 14201 Wireless Way, Suite 300, Oklahoma City, Oklahoma. As such, venue is proper in Oklahoma County pursuant to 12 O.S. § 134.
2.4 During the period relevant to this lawsuit, Mach Resources LLC conducted its business in Oklahoma and maintained its Principal Executive Offices at 14201 Wireless Way, Suite 300, Oklahoma City, Oklahoma. As such, venue is proper in Oklahoma County pursuant to 12 O.S. § 134.
2.5 Throughout the relevant period of this suit, Bayou City Energy Management LLC, in partnership with Mach Resources, conducted its business in Oklahoma and owns significant oil and gas assets there.
2.6 This Court has jurisdiction because all Defendants committed tortious acts within the state of Oklahoma and regularly derive substantial revenue from commerce in Oklahoma, including in Oklahoma County, such that the Court may exercise jurisdiction on any basis consistent with the Constitution of this state and the Constitution of the
United States.
2.7 The amount in controversy is within the jurisdictional limits of this Court.
III. BACKGROUND FACTS
3.1 On February 24, 2026, Wyatt Conley was seriously injured while working at the McBee 3MH and 2MH well site location. The McBee 3MH and 2MH wells were owned and operated by MACH. Both wells had been drilled, fracked, and were in the process of being brought into production by MACH. As the owner and operator of the wells, MACH had a non-delegable duty to maintain control over the wells and the well site, including all surface equipment. On the day of the incident, MACH failed to control the temperature of hydrocarbons from the wellhead to the production facility, resulting in an uncontrolled pressure release and an explosion that injured the Plaintiff.
3.2 As the owner and operator of the wells and wellsite location, including the surface equipment, MACH had a duty to design, install, and implement a completion program that ensured the proper and safe flow of hydrocarbons from the wellhead through the flow lines to the production facility. Because MACH engaged in completion procedures during the winter in Oklahoma, MACH knew or should have known that wax and hydrates would likely form in this high-pressure, low-temperature environment and should have designed, constructed, and implemented a completion program that maintained the safe temperature of hydrocarbons to ensure smooth and unrestricted flow from the wellhead to the production facility. MACH’s failure to design and implement a completion program that adequately controlled the wells resulted in uncontrolled pressure that over-pressurized the system, leading to the explosion that catastrophically injured the Plaintiff.
3.3 At the time of the incident, Plaintiff was present at the site and working for Well Werks Energy.
IV. CAUSES OF ACTION AGAINST MACH
4.1 At the time of the incident, MACH was the owner and operator of the wells in Canadian County, Oklahoma, where the incident took place, and had control over all completion activities. MACH maintained or allowed a dangerous condition to exist on the property. This dangerous condition posed an unreasonable risk of harm to Mr. Conley and the entire Well Werks Energy crew. MACH knew or should have known about the danger and failed to exercise ordinary care to protect Mr. Conley by warning him of the hazard or by making the condition reasonably safe. MACH did not use ordinary care in its actions. It failed to exercise the level of care that a prudent owner or operator would under similar circumstances. Additionally, MACH was negligent in failing to properly inspect and maintain its premises in a reasonably safe condition, and in failing to properly train, instruct, and supervise its employees and agents. The negligence described above was a direct cause of Mr. Conley's injuries.
4.2 The well-head, valves, flowline, and all component parts were owned and installed by MACH.
4.3 The work being carried out at the wellsite was hazardous. By allowing work to be performed there without proper supervision, rules, safety policies, and procedures, MACH breached its duty to establish rules and regulations to ensure worker safety, especially when the work environment is complex, hazardous, or when the associated dangers are not immediately obvious. Additionally, the work was extremely dangerous
and posed significant risks, classifying it as an ultra-hazardous activity. Therefore, MACH is strictly liable for Mr. Conley's injuries.
A. NEGLIGENCE, NEGLIGENCE PER SE AND GROSS NEGLIGENCE
4.4 As a result of the conduct described above and the items listed below, MACH, through its employees, representatives, and agents, committed acts of omission and commission. These acts collectively and individually constituted negligence, negligence per se, gross negligence, and recklessness, which were proximate causes of Mr. Conley’s injuries, including physical pain, mental anguish, and damages he suffered. This negligence and gross negligence include, but are not limited to, the following:
• Failing to ensure that the completion operation was conducted in a safe and prudent manner;
• Failing to provide a safe workplace;
• Failing to properly supervise the work being done at the time of the incident;
• Failing to ensure that the equipment being used in the completion operations was working, was well maintained, in good working order, not defective and used properly;
• Allowing hazardous conditions to exist at the time of the incident;
• Failing to prepare a reasonably safe well plan;
• Failing to ensure that all workers were properly trained;
• Failing to warn of a dangerous condition on the wellsite;
• Failing to properly train its company men to supervise the completion operations;
• Failing to ensure that its company men, who they placed in a position to control, direct and supervise the completion operations, were properly trained;
• Failure to develop safety policies and procedures to be implemented on its wellsite for the work to be performed;
• Failing to properly supervise the work being performed on the wellsite in question;
• Failing to properly design a completions program that would prevent the over-pressurization of flow-lines; and
• Designing, installing and maintaining a completion program that failed to control the wells and its component parts.
B. PREMISES LIABILITY
4.5 On the date of the incident, Mr. Conley was on the property and wellsite location for the mutual benefit of himself and MACH. MACH exercised actual and contractual control over the premises on that date and has exercised such control continuously before and since. Therefore, MACH was not only the owner of the wellsite but also a possessor of the premises at the time of Mr. Conley's injury and damages. While on the premises, Mr. Conley was injured by a defective and dangerous condition that created an unreasonable risk of harm to him and others, and this condition was caused by MACH. MACH breached its duty of ordinary care by creating the dangerous condition, failing to adequately warn Mr. Conley, and not making the condition reasonably safe. This breach of duty directly caused Mr. Conley's injuries, including physical pain, mental anguish, and damages.
C. MACH FAILED TO TRAIN ITS EMPLOYEES AND/OR AGENTS
4.6 MACH was responsible for directing, supervising, and controlling the completion operations that included work provided by Well Werks Energy. Despite this responsibility, MACH failed both to provide any training and to train its own employees and/or agents on the proper procedures for the completion operations conducted on the wells in question. By virtue of a contract, MACH was obligated to direct, supervise, and control the work of Well Werks Energy. However, MACH did not provide any training to its employees and/or agents on how to direct, supervise, and control the operations of Well Werks Energy. If MACH had provided proper training to its employees and/or agents, it would have had personnel and equipment at the wellsite to properly direct, supervise, and control the completion operations of the wells in question.
D. MACH FAILED TO TRAIN THE “COMPANY MEN”
4.7 At the time of the incident, MACH provided a wellsite consultant who was on-site and primarily responsible for fulfilling MACH’s contractual duty to oversee the completion operations occurring at that time. MACH failed to train the wellsite consultant on the proper procedures for the wells in question. If MACH had properly trained the wellsite consultant on the correct procedures, the incident would not have happened.
E. MACH FAILED TO SUPERVISE THE COMPLETION OPERATIONS
4.8 MACH was responsible for directing, supervising, and controlling the completion operations at wellsite in question. Despite this responsibility, MACH failed to have properly trained employees on-site to supervise the completion operations. MACH should have had properly trained employees present to properly supervise, direct, and control the completion operations. Had MACH fulfilled its contractual duty to supervise the completion operations, it would have recognized the dangerous condition that existed on the rig location.
F. MACH FAILED TO PROVIDE RULES AND REGULATIONS
4.9 The work being done at the wellsite was extremely dangerous. By allowing work to proceed without rules and regulations for worker safety, MACH breached its duty to provide safety rules and regulations, especially since the work was complex, hazardous, or involved dangers not obvious or common knowledge. MACH specializes in completing wells and possesses much greater knowledge than anyone else involved in how to perform completion operations safely. However, MACH did not provide any rules or regulations for well control. The duty MACH had over the wells and wellbore control is a nondelegable duty.
G. MACH FAILED TO FURNISH SAFE INSTRUMENTALITIES
4.10 MACH supplied the equipment and components used in the completion of the wells in question. MACH failed to exercise ordinary care in providing reasonably safe equipment and components for use during completion operations. The equipment
and/or components installed and supplied by MACH were not sufficient to control the pressures involved. By failing to supply and install the proper equipment and/or components, MACH did not provide safe tools for the location in question.
H. STRICT LIABILITY FOR ULTRAHAZARDOUS ACTIVITIES
4.11 The work being conducted at the wellsite location was extremely hazardous and fraught with danger; and therefore, constituted an ultrahazardous activity under Oklahoma law. As such, MACH is strictly liable for the injuries to Mr. Conley, the physical pain, mental anguish and the damages he suffered.
I. MACH BREACHED THE SERVICE CONTRACT
4.12 The work performed on the wells in question was conducted under a master service agreement between MACH and Well Werks Energy. The contract outlined obligations and responsibilities, including provisions designed to ensure safety measures for all workers involved in the operations. In conducting its completion operations, MACH breached the contract. This breach resulted in injuries to Mr. Conley, as well as physical pain, mental anguish, and damages he endured. As workers under the contract, Mr. Conley was an intended beneficiary of the contractual obligations.
J. MACH IS NEGLIGENT FOR THE CONDUCT OF THE "COMPANY MEN"
4.13 MACH was negligent through its agent, servant, ostensible agent, agent by estoppel, or borrowed employee, “Company Men,” who were acting within the course, scope, and authority of such an agency relationship and on behalf of and for the benefit
of MACH. Therefore, MACH is vicariously liable for the negligence of the "Company Men" based on the theory of respondeat superior.
V. DAMAGES
5.1 As a result of the event in question, Mr. Conley was struck by shrapnel which caused severe injuries and has incurred damages which include:
a. Physical pain and mental anguish sustained in the past;
b. Physical pain and mental anguish that, in reasonable probability, Mr. Conley will sustain in the future;
c. Loss of earnings sustained in the past;
d. Loss of earning capacity that, in reasonable probability, Mr. Conley will sustain in the future;
e. Physical impairment sustained in the past;
f. Physical impairment that, in reasonable probability, Mr. Conley will sustain in the future;
g. Medical care expenses in the past; and
h. Medical care expenses that, in reasonable probability, Mr. Conley will incur in the future.
5.2 Mr. Conley has been, and will be, damaged, in a sum deemed just and fair by the jury. Nearly all of the elements of damages for personal injury are unliquidated and, therefore, not subject to precise computation. Plaintiff seeks to recover damages in an amount found by the jury to be supported by the evidence and appropriate under all of the circumstances.
VI. PRE-JUDGMENT AND POST-JUDGMENT INTEREST
6.1 Plaintiff seeks pre-judgment and post-judgment interest as allowed by law.
VII. JURY DEMAND
7.1 Plaintiff requests a trial by jury.
VIII. PRAYER
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendants be cited to appear and answer herein, that this cause be set for trial before a jury, that Plaintiff recover judgment of and from the Defendants for his actual damages in such amount as the evidence may show and the jury may determine to be proper, together with pre-judgment interest, post-judgment interest, costs of suit, and such other and further relief to which Plaintiff may show himself to be justly entitled.
Respectfully submitted,
By: ______________________________________
Mr. Jeffrey G. Wigginsnton, OBA 20579
[email protected]
Mr. David L. Rumley, (PHV pending)
Texas Bar No. 00791581
[email protected]
Ross W. Evans (PHV pending)
Texas Bar No. 24064771
[email protected]
WIGINGTON RUMLEY DUNN & BLAIR, L.L.P.
123 N. Carrizo Street
Corpus Christi, TX 78401
Telephone: (361) 885-7500
Facsimile: (361) 885-0487
-And-
Mr. Cody Gayer, OBA 30086
CG Law
[email protected]
311 N. Harvey Ave. STE 200
Oklahoma City, OK 73102
Telephone: (405) 747-4210
Facsimile: (405) 832-1175
JURY TRIAL DEMANDED
ATTORNEYS FOR PLAINTIFF
ATTORNEY LIEN CLAIMED
