and industrial wastes resulting in environmental contamination to the Plaintiffs' potable water
supplies. (Docket No. 41, at
Plaintiffs Tammy Manning and Tammy Hadlick filed complaints with the
Pennsylvania Department of Environmental Protection ( DEP ) on or about December 20, 2011,
alleging that recent gas well drilling activities had affected their water supply wells. Plaintiff
Scott Henry filed a similar complaint with the DEP on or about January 2, 2012. The DEP
proceeded to conduct a sixteen-month-long investigation of the water quality in and around the
Manning, Hadlick and Henry properties in response to their complaints.
On April 24, 2013, the DEP sent letters to Ms. Manning, Ms. Hadlick and Mr.
Henry regarding the conclusions of its investigation into the possible degradation of their water
supply wells located in Franklin Township, Susquehanna County. The DEP concluded that its
investigation does not indicate that gas well drilling has impacted [Ms. Manning's/Ms.
Hadlick's/Mr. Henry's] water supply. True and correct copies of the April 24, 2013 DEP letters are attached hereto as Exhibit A.
On August 1, 2013, WPX sent a letter to William J. Dubanevich, counsel for the Plaintiffs, advising him that WPX was going to stop providing a temporary water supply to the
Mannings, and that it planned to remove the water buffalo and ancillary equipment from the
Manning property. WPX also asked that Mr. Dubanevich contact WPX on or before August 30,
2013, to coordinate the logistics for removal of the temporary water supply system on the
Manning property. A true and correct copy of the August 1, 2013 WPX letter is attached hereto
as Exhibit B. On August 1, 2013, WPX sent a similar letter to Ms. Hadlick and Mr. Henry
with the same information. True and correct copies of the August 1, 2013 WPX letters are
attached hereto as Exhibit C.
Case 3:12-cv-00646-ARC Document 44 Filed 11/04/13 Page 2 of 8