Rosario C. Doriott Dominguez Denver

Education

• J.D., University of Southern California, Gould School of Law, Los Angeles
• B.A., Psychology, Yale University, New Haven

Professional Experience

Current

• Partner, Ryan Law Firm
  • Rosario focuses her practice on litigation and transactional work encompassing federal, Indian, state, and private oil and gas royalty issues, regularly advising companies in connection with the calculation, payment, and reporting of onshore and offshore, oil and gas royalties.
  • Rosario routinely assists companies in reviewing royalty calculations and payments and unbundling third-party fees for the purpose of claiming transportation and processing allowances in compliance with marketable condition requirements. She also routinely assists and defends companies responding to data mining requests, royalty audits, and other related investigations conducted by the Office of Natural Resources Revenue (ONRR), Office of Inspector General, and Department of Justice. She further frequently defends companies in litigation involving Orders to Report and Pay and Orders for Restructured Accounting issued by ONRR (including its delegated State and Indian Tribal partners) and has appeared in numerous cases before the Director of ONRR, the Director of Bureau of Indian Affairs, the Interior Board of Land Appeals, and in the 5^th, 10^th, and D.C. Circuits.
  • Rosario’s most recent notable experience includes:
    • Devon Energy Prod. Co., L.P. v. Gould, 421 F.Supp.3d 1213 (D.Wyo. 2019) (vacating Director of ONRR decision assessing additional royalties and alleging improper transportation deductions under marketable condition rule; first federal court decision holding ONRR Director decision improperly expanded upon underlying order to report and pay and agency failed to properly issue underlying order specifying claims);
    • Continental Resources, Inc. v. Gould, 410 F.Supp.3d 30 (D.D.C. 2019) (setting aside Director of ONRR decision assessing additional royalties and alleging improper valuation; first case holding valuation of unprocessed gas sold at wellhead under percentage-of-proceed contracts as processed gas using residue gas pricing was arbitrary, capricious, plainly erroneous, and inconsistent with regulation);
    • Continental Resources, Inc. v. Jewell, 846 F.3d 1232 (D.C. Cir. 2017) (successful case of first impression, determining proper application of the 180-day and 33-month periods for judicial review under 30 U.S.C. § 1724 and reversing lower court ruling determining a lessee’s suit to challenge federal royalty demand was time-barred).

Previous

• Associate, Baker & Hostetler LLP
• Associate, Fulbright & Jaworski LLP (Norton Rose Fulbright)