SEC Company Response from US ENERGY CORP (USEG) (CIK 0000101594) (BSIN) — Jul 20, 2010
US ENERGY CORP (USEG) (CIK 0000101594)
Date: July 20, 2010 · CIK: 0000101594 · Accession: 0000101594-10-000052
AI Filing Summary & Sentiment
Reasoning
Letter
Division of Corporation Finance United States Securities and Exchange Commission Filed March 12, 2010 Definitive Proxy Statement on Schedule 14A Filed April 29, 2010 Form 10-Q for the Quarterly Period Ended March 31, 2010
Re: U.S. Energy Corp. - File No. 0-06814
Dear Mr. Morrill:
We are in receipt of your above referenced letter relating to the periodic reports and proxy statement. It is our understanding that on July 6, 2010, you discussed some of the comments with Stephen Rounds, our outside securities counsel. Below is the text of the staff comments, and our proposed responses and the timing thereof, taking into account the discussion with Mr. Rounds.
As an overview and in line with your discussion with Mr. Rounds, we are providing proposed disclosure for the staff’s consideration. When we have come to agreement with the staff on content, we believe it appropriate to make all disclosures on a going forward basis. Exceptions would be reserve determination technologies (comment 2) and filing revised engineering reports, which we propose to file by Form 10-K/A when we have both revised reports in hand (as discussed below) and have resolved with the engineers the reserve determination technologies issue.
General
1.
In light of recent events in the Gulf of Mexico, please review your disclosure to ensure that you have disclosed all material information regarding your potential liability in the event that your employees or your working partners are involved in an event that leads to property damage, personal injury, death or the discharge of hazardous materials into the environment. For example, and without limitation, please address the following:
Page 1 of 10
·
Disclose your insurance coverage with respect to any liability related to any such event. Such disclosure should address the types of claims covered, and the applicable policy limits and deductibles. For example, and without limitations, such disclosure should address your insurance coverage with respect to any liability related to any resulting negative environmental effects.
·
Disclose your related indemnification obligations and those of your customers, if applicable.
Such disclosure should be set forth in the “Business” section of your annual report and in the “Risk Factors” and MD&A sections of your periodic reports, as applicable. Please provide a sample of your proposed disclosure for our review. In responding to this comment, please consider all your current and planned operations, not just those involved in offshore operations.
Response:
The Company’s potential liability exposure lies in five areas: Non-operated oil and gas exploration and production (mostly onshore, with some offshore-shallow water wells); a non-operated mineral property in the permitting-exploration stage (the Mt. Emmons molybdenum property in Colorado); a residential multi-family housing complex in Wyoming (owned and operated by the Company through a wholly-owned subsidiary); the operation of our corporate aircraft, and property damage and liability associated with the ownership of other corporate assets.
We propose to make all the following disclosures for the next Form 10-K for year ending December 31, 2010. The additional risk factor would be disclosed in the next filed Form 10-Q (for period ended June 30, 2010).
New Risk Factor:
Insurance may be insufficient to cover future liabilities. Our business is focused in three areas, each of which presents potential liability exposure: Oil and gas exploration and development; permitting and limited exploration of the Mt. Emmons molybdenum property; and a residential multi-family housing complex in Gillette, Wyoming. We also have potential exposure in connection with the Company’s corporate aircraft and general liability and property damage associated with the ownership of other corporate assets. We rely on the operators of our oil and gas and mineral properties to obtain and maintain liability insurance for our working interest in the properties. We maintain insurance policies for the liability of and damage to our multifamily housing complex, corporate aircraft and general corporate assets.
We also have separate policies for liability and environmental exposures of the water treatment plant at the Mt. Emmons project. These policies provide coverage for bodily injury and property damage as well as costs to remediate events adversely impacting the environment.
Page 2 of 10
We would be liable for claims in excess of coverage. If uncovered liabilities are substantial, payment thereof could adversely impact the Company’s cash on hand, resulting in possible curtailment of operations. See “Business – Insurance” elsewhere in this Report. As of the date of this Report, we know of no claims related to any of our properties.
New Business Disclosure:
Insurance
The Company has the following insurance coverage:
General
A general liability policy provides $1 million of liability coverage per occurrence, $2 million general aggregate limit and a $10 million commercial excess liability policy. These policies cover bodily injury and property damage, but do not cover all potential liabilities for Company activities. Accordingly, we have additional policies related to other areas of our business.
Oil and Gas Exploration and Development
Pursuant to the Joint Operating Agreements (“JOAs”) between the Company and each operator of the properties where we hold working interests, each working interest owner is responsible for paying its share of costs and expenses related to operations. The liability of the parties is several, not joint or collective, and the relationship between the parties is not a partnership. None of the JOAs provide for indemnification between the parties.
The JOAs also require the operator to obtain and maintain liability insurance for the benefit of all the working interest owners (premiums are paid pro rata by the working interest owners). Policies currently in place provide $1 million per event, $2 million general aggregate liability coverage, $1 million auto insurance, excess coverage (overlaying the preceding) of $5 million to $20 million and $5 million to $15 million for “operator’s extra expense” (control of well). Premiums are paid by the working interest owners pro rata to ownership.
The Company is currently seeking bids on well control, general liability and property loss over and above the amount carried by the operators of the Company’s oil and gas and mineral properties.
Page 3 of 10
Mt. Emmons
The Company is responsible for all costs to operate the water treatment plant at the Mt. Emmons project until Thompson Creek Metals (“TCM”) elects to exercise its option to own an interest in the property. We maintain an insurance policy for our benefit in the amounts of $1 million per event, $2 million aggregate general liability, $1 million automobile liability, $10 million environmental impairment liability, and $10 million excess liability (an upper limit on the coverage other than environmental).
U.S. Energy is an additional insured under TCM’s policies with respect to operations at Mt. Emmons not related to the water treatment plant, with policy limits of $1 million per event, $2 million general aggregate liability, and excess liability of $10 million.
We believe the above insurance is sufficient in the current permitting-exploration stage of the Mt. Emmons project. Additional insurance will be obtained as the level of activity in exploration and development expands.
Corporate Aircraft
The Company maintains a $20 million per event liability policy on its corporate aircraft. We also maintain physical damage insurance, $200,000 and $4.0 million, on the aircraft which approximates their replacement value.
Remington Village
We have a policy covering $1 million each event, $2 million general aggregate liability and a $9 million of excess liability policy. The deductibles are $1,000 ($5,000 retained limited) per event. We maintain $20.4 million of coverage for the real property written on a Special Form/Replacement Cost basis.
New MD&A Disclosure under Liquidity and Capital Resources:
We have liability insurance coverage in amounts deemed sufficient and in line with industry standards for the location, stage, and type of operations in oil and gas, mineral property development (the Mt. Emmons molybdenum project), and the Remington Village housing complex. Payment of substantial liabilities in excess of coverage could require diversion of internal capital away from regular business, which could result in diminished operations. We have property loss insurance on all major assets equal to the approximate replacement value of the assets.
Form 10-K for the Fiscal year Ended December 31, 2009
Properties
Oil and Natural Gas, page 27
Page 4 of 10
2.
We note that you have made material additions to your reserve estimates. Please provide a discussion of the technologies you used to establish the appropriate level of certainty for reserves estimates from material properties included in the total reserves disclosed, pursuant to Item 1202(a)(6) of Regulation S-K.
Response:
The Company does not employ reserve engineers. We rely on well data provided by the operators of each of our oil and gas properties. Changes to reserve estimates are calculated by independent reserve engineers (the same ones that report on the operators’ reserves, but separately engaged by us for our internal and SEC reporting needs).
Specifically in response to this comment 2, we note that the subject Form 10-K has the following disclosure:
“Item 2 – Properties
Oil and Natural Gas
The following table sets forth our net proved reserves as of the dates indicated. Our reserve estimates as of December 31, 2009 are based on reserve reports prepared by Ryder Scott Company, L.P. (“Ryder Scott”), and Cawley, Gillespie & Associates, Inc. (“CGA”). Our reserve estimates as of December 31, 2008 are based on a reserve report prepared by Ryder Scott Company, L.P. Ryder Scott and CGA are nationally recognized independent petroleum engineering firms. Ryder Scott is a Texas Registered Engineering Firm (F-1580) and CGA is a Texas Registered Engineering Firm (F-693). Ryder Scott prepared the estimates related to our Gulf Coast Basin, including Louisiana and Texas properties and CGA prepared the estimates or our North Dakota properties. The reserve estimates were based upon the review by the relevant engineering firm(s) of production histories and other geological, economic, ownership and engineering data, as provided by us and by the operators. Copies of these reports are filed as exhibits to this Annual Report.
We do not have in-house geological, geophysical and reserve engineering expertise. We therefore primarily rely on the operators of our producing wells who provide production data to our contract reserve engineers. Once the reserve engineers have reviewed all data and established preliminary reserves for the operators of the wells for which we rely on the operator, they also prepare a standalone report for us.”
We submit that current disclosure is sufficient. Please advise if you concur. If you do not, please provide guidance for different disclosure that would be consistent with the fact that we do not employ reservoir engineers.
Page 5 of 10
Exhibit 99.1, Report of Ryder Scott Company, L.P.
3.
The closing paragraph states in part that the report “was prepared for the exclusive use and sole benefit of U.S. Energy Corp., and may not be put to other use without our prior written consent for such use.” As Item 1202(a)(8) of Regulation S-K requires the report, please obtain and file a revised version which retains no language that could suggest either a limited audience or a limit on potential investor reliance.
4.
We refer you to Items 1202(a)(8)(iv); 1202(a)(8)(viii) of Regulation S-K. Please obtain and file a revised report from Ryder Scott which includes the following:
·
a statement that the consultant has used all methods and procedures as it considered necessary under the circumstances to prepare the report;
·
a discussion of the possible effects of regulation on the ability of the registrant to recover the estimated reserves; and
·
a statement that the assumptions, data, methods, and procedures used in the report are appropriate for the purpose served by the report.
5.
In the revised report you obtain, ensure that there is appropriate disclosure of the relevant benchmark prices and weighted average prices from the total company reserve report. See Item 1202(a)(8)(v) of Regulation S-K. Such weighted average prices should be provided by the geographic area required to be provided in the reserves table, pursuant to Item 1202(a)(2) of Regulation S-K.
Response to Comments 3, 4 and 5:
We have reviewed this request with Ryder Scott but as of the date of this response, we have not received a revised report from Ryder Scott. We propose filing this report on Form 10-K/A, as soon as we receive Ryder Scott’s revised report.
Exhibit 99.2, Report of Cawley, Gillespie & Associates, Inc.
6.
Disclose the qualifications of the technical person primarily responsible for overseeing the preparation of the reserves estimates. Refer to Item 1202(a)(7) of Regulation S-K.
7.
The report states that the methods employed in estimating reserves are described in page 4 of the Appendix. The Appendix describes four methods generally but does not indicate which methods were actually used to estimate your reserves. Please obtain a revised report that specifically indentifies the methods used to prepare your reserves.
Page 6 of 10
8.
We note the statements in the report on page 2 that state “Possible environmental liability related to the properties has not been investigated nor considered,” and “The possible effects of changes in legislation or other Federal or State restrictive actions which could affect the reserves and economics have not been considered.” Please obtain a revised report that provides a discussion of the possible effects of regulation on the ability of the registrant to recover the estimated reserves, pursuant to Item 1202(a)(8)(vi).
Response to Comments 6, 7 and 8:
We have received a revised report from Cawley Gillespie, attached to this letter (with changes highlighted by Cawley), with changes requested by the staff. We believe the changes are responsive, and propose filing Cawley, Gillespie’s revised report by Form 10-K/A at the same time we receive Ryder Scott’s revised report (see response to comments 3, 4 and 5).
Definitive Proxy Statement on Schedule 14A filed April 29, 2010
Business Experience and Other Directorships of Directors and Officers, page 15
9.
Revise the biographical sketch for Mr. Conrad to identify the three oil and gas drilling funds with which he has served as Co-General Partner for the past five years.
Response:
We propose including the following disclosure in the Company’s next proxy statement:
For the past five years, Mr. Conrad has been, directly or indirectly a managing member of three privately-held oil and gas partnerships. The partnerships, and his interest in them, are as follows:
·
Mr. Conrad is a co-managing member of Conrad Wildes Development GP, L.L.C. (the “Development LLC”). The Development LLC is the general partner of the Conrad Wildes Development Program, LTD
·
Mr. Conrad is the co-managing member of Conrad Wildes Oil & Gas II, LLC and W. S. Vecta Exploration, LLC.
There is no relationship between U.S. Energy and these two partnerships.
In 2007, U.S. Energy Corp. entered into a Transfer Agreement with Wildes Exploration Mid-Miocene, LP (“WEMM”). Mr. Conrad owns approximately 50% of WEMM which is entitl
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CORRESP
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corresp.htm
July 20, 2010
Parker Morrill
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-4628
Re: U.S. Energy Corp. - File No. 0-06814
Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 12, 2010
Definitive Proxy Statement on Schedule 14A
Filed April 29, 2010
Form 10-Q for the Quarterly Period Ended March 31, 2010
Dear Mr. Morrill:
We are in receipt of your above referenced letter relating to the periodic reports and proxy statement. It is our understanding that on July 6, 2010, you discussed some of the comments with Stephen Rounds, our outside securities counsel. Below is the text of the staff comments, and our proposed responses and the timing thereof, taking into account the discussion with Mr. Rounds.
As an overview and in line with your discussion with Mr. Rounds, we are providing proposed disclosure for the staff’s consideration. When we have come to agreement with the staff on content, we believe it appropriate to make all disclosures on a going forward basis. Exceptions would be reserve determination technologies (comment 2) and filing revised engineering reports, which we propose to file by Form 10-K/A when we have both revised reports in hand (as discussed below) and have resolved with the engineers the reserve determination technologies issue.
General
1.
In light of recent events in the Gulf of Mexico, please review your disclosure to ensure that you have disclosed all material information regarding your potential liability in the event that your employees or your working partners are involved in an event that leads to property damage, personal injury, death or the discharge of hazardous materials into the environment. For example, and without limitation, please address the following:
Page 1 of 10
·
Disclose your insurance coverage with respect to any liability related to any such event. Such disclosure should address the types of claims covered, and the applicable policy limits and deductibles. For example, and without limitations, such disclosure should address your insurance coverage with respect to any liability related to any resulting negative environmental effects.
·
Disclose your related indemnification obligations and those of your customers, if applicable.
Such disclosure should be set forth in the “Business” section of your annual report and in the “Risk Factors” and MD&A sections of your periodic reports, as applicable. Please provide a sample of your proposed disclosure for our review. In responding to this comment, please consider all your current and planned operations, not just those involved in offshore operations.
Response:
The Company’s potential liability exposure lies in five areas: Non-operated oil and gas exploration and production (mostly onshore, with some offshore-shallow water wells); a non-operated mineral property in the permitting-exploration stage (the Mt. Emmons molybdenum property in Colorado); a residential multi-family housing complex in Wyoming (owned and operated by the Company through a wholly-owned subsidiary); the operation of our corporate aircraft, and property damage and liability associated with the ownership of other corporate assets.
We propose to make all the following disclosures for the next Form 10-K for year ending December 31, 2010. The additional risk factor would be disclosed in the next filed Form 10-Q (for period ended June 30, 2010).
New Risk Factor:
Insurance may be insufficient to cover future liabilities. Our business is focused in three areas, each of which presents potential liability exposure: Oil and gas exploration and development; permitting and limited exploration of the Mt. Emmons molybdenum property; and a residential multi-family housing complex in Gillette, Wyoming. We also have potential exposure in connection with the Company’s corporate aircraft and general liability and property damage associated with the ownership of other corporate assets. We rely on the operators of our oil and gas and mineral properties to obtain and maintain liability insurance for our working interest in the properties. We maintain insurance policies for the liability of and damage to our multifamily housing complex, corporate aircraft and general corporate assets.
We also have separate policies for liability and environmental exposures of the water treatment plant at the Mt. Emmons project. These policies provide coverage for bodily injury and property damage as well as costs to remediate events adversely impacting the environment.
Page 2 of 10
We would be liable for claims in excess of coverage. If uncovered liabilities are substantial, payment thereof could adversely impact the Company’s cash on hand, resulting in possible curtailment of operations. See “Business – Insurance” elsewhere in this Report. As of the date of this Report, we know of no claims related to any of our properties.
New Business Disclosure:
Insurance
The Company has the following insurance coverage:
General
A general liability policy provides $1 million of liability coverage per occurrence, $2 million general aggregate limit and a $10 million commercial excess liability policy. These policies cover bodily injury and property damage, but do not cover all potential liabilities for Company activities. Accordingly, we have additional policies related to other areas of our business.
Oil and Gas Exploration and Development
Pursuant to the Joint Operating Agreements (“JOAs”) between the Company and each operator of the properties where we hold working interests, each working interest owner is responsible for paying its share of costs and expenses related to operations. The liability of the parties is several, not joint or collective, and the relationship between the parties is not a partnership. None of the JOAs provide for indemnification between the parties.
The JOAs also require the operator to obtain and maintain liability insurance for the benefit of all the working interest owners (premiums are paid pro rata by the working interest owners). Policies currently in place provide $1 million per event, $2 million general aggregate liability coverage, $1 million auto insurance, excess coverage (overlaying the preceding) of $5 million to $20 million and $5 million to $15 million for “operator’s extra expense” (control of well). Premiums are paid by the working interest owners pro rata to ownership.
The Company is currently seeking bids on well control, general liability and property loss over and above the amount carried by the operators of the Company’s oil and gas and mineral properties.
Page 3 of 10
Mt. Emmons
The Company is responsible for all costs to operate the water treatment plant at the Mt. Emmons project until Thompson Creek Metals (“TCM”) elects to exercise its option to own an interest in the property. We maintain an insurance policy for our benefit in the amounts of $1 million per event, $2 million aggregate general liability, $1 million automobile liability, $10 million environmental impairment liability, and $10 million excess liability (an upper limit on the coverage other than environmental).
U.S. Energy is an additional insured under TCM’s policies with respect to operations at Mt. Emmons not related to the water treatment plant, with policy limits of $1 million per event, $2 million general aggregate liability, and excess liability of $10 million.
We believe the above insurance is sufficient in the current permitting-exploration stage of the Mt. Emmons project. Additional insurance will be obtained as the level of activity in exploration and development expands.
Corporate Aircraft
The Company maintains a $20 million per event liability policy on its corporate aircraft. We also maintain physical damage insurance, $200,000 and $4.0 million, on the aircraft which approximates their replacement value.
Remington Village
We have a policy covering $1 million each event, $2 million general aggregate liability and a $9 million of excess liability policy. The deductibles are $1,000 ($5,000 retained limited) per event. We maintain $20.4 million of coverage for the real property written on a Special Form/Replacement Cost basis.
New MD&A Disclosure under Liquidity and Capital Resources:
We have liability insurance coverage in amounts deemed sufficient and in line with industry standards for the location, stage, and type of operations in oil and gas, mineral property development (the Mt. Emmons molybdenum project), and the Remington Village housing complex. Payment of substantial liabilities in excess of coverage could require diversion of internal capital away from regular business, which could result in diminished operations. We have property loss insurance on all major assets equal to the approximate replacement value of the assets.
Form 10-K for the Fiscal year Ended December 31, 2009
Properties
Oil and Natural Gas, page 27
Page 4 of 10
2.
We note that you have made material additions to your reserve estimates. Please provide a discussion of the technologies you used to establish the appropriate level of certainty for reserves estimates from material properties included in the total reserves disclosed, pursuant to Item 1202(a)(6) of Regulation S-K.
Response:
The Company does not employ reserve engineers. We rely on well data provided by the operators of each of our oil and gas properties. Changes to reserve estimates are calculated by independent reserve engineers (the same ones that report on the operators’ reserves, but separately engaged by us for our internal and SEC reporting needs).
Specifically in response to this comment 2, we note that the subject Form 10-K has the following disclosure:
“Item 2 – Properties
Oil and Natural Gas
The following table sets forth our net proved reserves as of the dates indicated. Our reserve estimates as of December 31, 2009 are based on reserve reports prepared by Ryder Scott Company, L.P. (“Ryder Scott”), and Cawley, Gillespie & Associates, Inc. (“CGA”). Our reserve estimates as of December 31, 2008 are based on a reserve report prepared by Ryder Scott Company, L.P. Ryder Scott and CGA are nationally recognized independent petroleum engineering firms. Ryder Scott is a Texas Registered Engineering Firm (F-1580) and CGA is a Texas Registered Engineering Firm (F-693). Ryder Scott prepared the estimates related to our Gulf Coast Basin, including Louisiana and Texas properties and CGA prepared the estimates or our North Dakota properties. The reserve estimates were based upon the review by the relevant engineering firm(s) of production histories and other geological, economic, ownership and engineering data, as provided by us and by the operators. Copies of these reports are filed as exhibits to this Annual Report.
We do not have in-house geological, geophysical and reserve engineering expertise. We therefore primarily rely on the operators of our producing wells who provide production data to our contract reserve engineers. Once the reserve engineers have reviewed all data and established preliminary reserves for the operators of the wells for which we rely on the operator, they also prepare a standalone report for us.”
We submit that current disclosure is sufficient. Please advise if you concur. If you do not, please provide guidance for different disclosure that would be consistent with the fact that we do not employ reservoir engineers.
Page 5 of 10
Exhibit 99.1, Report of Ryder Scott Company, L.P.
3.
The closing paragraph states in part that the report “was prepared for the exclusive use and sole benefit of U.S. Energy Corp., and may not be put to other use without our prior written consent for such use.” As Item 1202(a)(8) of Regulation S-K requires the report, please obtain and file a revised version which retains no language that could suggest either a limited audience or a limit on potential investor reliance.
4.
We refer you to Items 1202(a)(8)(iv); 1202(a)(8)(viii) of Regulation S-K. Please obtain and file a revised report from Ryder Scott which includes the following:
·
a statement that the consultant has used all methods and procedures as it considered necessary under the circumstances to prepare the report;
·
a discussion of the possible effects of regulation on the ability of the registrant to recover the estimated reserves; and
·
a statement that the assumptions, data, methods, and procedures used in the report are appropriate for the purpose served by the report.
5.
In the revised report you obtain, ensure that there is appropriate disclosure of the relevant benchmark prices and weighted average prices from the total company reserve report. See Item 1202(a)(8)(v) of Regulation S-K. Such weighted average prices should be provided by the geographic area required to be provided in the reserves table, pursuant to Item 1202(a)(2) of Regulation S-K.
Response to Comments 3, 4 and 5:
We have reviewed this request with Ryder Scott but as of the date of this response, we have not received a revised report from Ryder Scott. We propose filing this report on Form 10-K/A, as soon as we receive Ryder Scott’s revised report.
Exhibit 99.2, Report of Cawley, Gillespie & Associates, Inc.
6.
Disclose the qualifications of the technical person primarily responsible for overseeing the preparation of the reserves estimates. Refer to Item 1202(a)(7) of Regulation S-K.
7.
The report states that the methods employed in estimating reserves are described in page 4 of the Appendix. The Appendix describes four methods generally but does not indicate which methods were actually used to estimate your reserves. Please obtain a revised report that specifically indentifies the methods used to prepare your reserves.
Page 6 of 10
8.
We note the statements in the report on page 2 that state “Possible environmental liability related to the properties has not been investigated nor considered,” and “The possible effects of changes in legislation or other Federal or State restrictive actions which could affect the reserves and economics have not been considered.” Please obtain a revised report that provides a discussion of the possible effects of regulation on the ability of the registrant to recover the estimated reserves, pursuant to Item 1202(a)(8)(vi).
Response to Comments 6, 7 and 8:
We have received a revised report from Cawley Gillespie, attached to this letter (with changes highlighted by Cawley), with changes requested by the staff. We believe the changes are responsive, and propose filing Cawley, Gillespie’s revised report by Form 10-K/A at the same time we receive Ryder Scott’s revised report (see response to comments 3, 4 and 5).
Definitive Proxy Statement on Schedule 14A filed April 29, 2010
Business Experience and Other Directorships of Directors and Officers, page 15
9.
Revise the biographical sketch for Mr. Conrad to identify the three oil and gas drilling funds with which he has served as Co-General Partner for the past five years.
Response:
We propose including the following disclosure in the Company’s next proxy statement:
For the past five years, Mr. Conrad has been, directly or indirectly a managing member of three privately-held oil and gas partnerships. The partnerships, and his interest in them, are as follows:
·
Mr. Conrad is a co-managing member of Conrad Wildes Development GP, L.L.C. (the “Development LLC”). The Development LLC is the general partner of the Conrad Wildes Development Program, LTD
·
Mr. Conrad is the co-managing member of Conrad Wildes Oil & Gas II, LLC and W. S. Vecta Exploration, LLC.
There is no relationship between U.S. Energy and these two partnerships.
In 2007, U.S. Energy Corp. entered into a Transfer Agreement with Wildes Exploration Mid-Miocene, LP (“WEMM”). Mr. Conrad owns approximately 50% of WEMM which is entitl