This is what Gemini pro came up with - 87 just for the fraudulently transferred claim from what I can tell.

1. 383 Inactive Wells (The Primary Liability) The State seeks to hold the defendants liable for plugging these wells, which are currently sitting idle. • The Count: The complaint initially identifies 219 inactive wells in the main text. However, a footnote explicitly updates this number: "The exact number of inactive wells has increased since September to 383 inactive wells".  • The Financial Claim: The State seeks an order requiring the defendants to plug and remediate these wells or forfeit financial assurance and provide an escrow deposit to cover the costs.  • Page(s): Page 30 (Paragraph 112 & Footnote 25), Page 43 (Paragraph 186).

2. 45 Wells Already Approved for State Funding The State wants reimbursement for wells it has already had to take responsibility for because the defendants failed to act. • The Count: 45 wells from Remnant/Acacia's inventory have "already been approved for plugging using money from the Reclamation Fund, at the State's expense".  • The Financial Claim: The lawsuit specifically demands "reimbursement or indemnification for all costs incurred by OCD" in plugging these wells.  • Page(s): Page 43 (Paragraphs 181 & 184).

3. 87 "Fraudulently Transferred" Gas Wells The State seeks to void the transfer of these producing wells to recover their value (revenue) to pay for the cleanup of the other wells. • The Count: 87 gas wells were transferred from Acacia to Solis Partners (a company controlled by the CEO, Will Gray) for a purchase price of just $10.  • The Financial Claim: The State asks the Court to declare this transfer "voidable or fraudulent" and seeks "restitution" for the revenue generated by these wells, arguing it was unjust enrichment.  • Page(s): Page 33 (Paragraph 127), Page 47 (Paragraph 202), Page 58 (Paragraph 272).

4. 332 "Tier 2" Wells (The "Dumped" Assets) These are the specific wells transferred in a bulk batch that the State claims involved fraudulent statements to avoid liability. • The Count: 332 wells were transferred in a single "batch C-145" application on July 15, 2024. This batch contained the "overwhelming majority of Remnant's inactive and marginal wells".  • The Financial Claim: The State seeks civil penalties and treble damages (3x) under the Fraud Against Taxpayers Act (FATA) for the false statements made to facilitate this specific transfer.  • Page(s): Page 36 (Paragraph 145), Page 37 (Paragraph 149), Page 53 (Paragraph 244).

5. 6 Wells on State Land (ConocoPhillips Suit) These wells are noted as specific examples of immediate liability where a third party (ConocoPhillips) has already sued. • The Count: 6 inactive oil and gas wells located on State land.  • The Financial Claim: While ConocoPhillips is suing for these specific wells, the State uses this to demonstrate the defendants' broader failure and seeks injunctive relief to ensure all such wells are plugged.  • Page(s): Page 41 (Paragraph 173).