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Full title: BNC Certificate of Mailing. (Related document(s):2928 Generic Order) No. of Notices: 203. Notice Date 07/01/2021. (Admin.) (Entered: 07/01/2021)

Document posted on Jun 30, 2021 in the bankruptcy, 31 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

tice by first class mail was sent to the following persons/entities by the Bankruptcy Noticing Center on Jul 01, 2021: cip ID Recipient Name and Address + Blue Ribbon Technology Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Corporate Services (Bermuda) Ltd., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Energy Production Services-Canada Ltd., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Energy Services, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Spec-Rent Services, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J VLC, LLC, 3990 Rogerdale Road, Houston, TX 77042-5142 + C&J Wells Services Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ CJ Holding Co., 3990 Rogerdale Road, Houston, TX 77042-5142+ ESP Completion Technologies LLC, 3990 Rogerdale Road, Houston, TX 77042-5142+ KVS Transportation, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ Mobile Data Technologies Ltd., 3990 Rogerdale Road, Houston, TX 77042-5142+ Tellus Oilfield Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ Tiger Cased Hole Services Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ Total E&S, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142Alan J. Stone, Milbank,6363 Woodway, Suite 1100, Houston, TX 77057-1796+ Kirkland & Ellis LLP and Kirkland & Ellis Internat, 300 North LaSalle, Chicago, IL 60654-3427+ Locke Lord LLP, 600 Travis Street, Ste. 2800, Houston, TX 77002-2914+ Marc Kieselstein, Kirkland & Ellis, 300 North LaSalle, Chicago, IL 60654-5412+ Muskat, Mahony, Devine & Moses, LLP, 1201 Louisiana St., Suite 850, Houston, TX 77002, UNITED STATES 77002-5627+ Nicole M Misner, Klein DeNatale et al, 4550 California Ave, 2nd Flr, Bakersfield, CA 93309-7012+ Rhonda Luginbyhl, Burdett Morgan Williamson & Boykin, 701 Taylor, Ste. 440, Amarillo, TX 79101-2424+ Richard E. Donahoo, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Roy Barrera, III, Golden & Barrera, PC, 424 East Nueva, San Antonio, TX 78205-3422+ Sarah B. Schlehr, 150 E. Olive Ave, Burbank, CA 91502-1846+ Sonia Pflaster, 150 East Olive Ave, Suite 214, Burbank, CA 91502-1850+ Stephen T. Schwarzbach, Jr., Kirkland & Ellis, 600 Travis, Ste 3300, Houston, TX 77002-2926+ Thomas D Maxson, 625 Liberty Avenue, Pittsburgh, PA 15222-3110Tyson Lomazow, Milbank, Tweed, Haldey McCloy, 28 Liberty Street, New York, NY 10005-1413+ Vinson & Elkins L.L.P., Houston, 1001 Fannin Street, Suite 2500, Houston, TX 77002-6710+ Walker & Patterson, P.C., P.O. Box 61301, Houston, TX 77208-1301 + Yasin Daneshfar, Becker & Poliakoff, P.A., 1 East Broward Blvd Ste 1800, Fort Lauderdale, FL 33301-1876+ AG Energy Credit Opportunities Fund, LP, c/o Angelo Gordon & Co LP, 245 Park Avenue, 26th Floor, New York, NY 10167-2699sfee + AG Energy Credit Opportunities Investments Fund LP, c/o Angelo, Gordon & Co LP, 245 Park Avenue, 26th Floor, New York,David Grant Crooks, Fox Rothschild LLP, 5420 LBJ Frwy., Suite 1200, Dallas, TX 75240-6215+ Linebarger Goggan Bl Loving County, 711 Nava

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS ENTERED HOUSTON DIVISION 06/29/2021 WEST WILMINGTON OIL FIELD § CLAIMANTS, § § Creditor-Appellants, § § VS. § CIVIL ACTION NO. H-20-3014 § CJ HOLDING CO., et al., § § Debtor-Appellees. § MEMORANDUM AND OPINION The bankruptcy court denied the creditor-appellants’ motion to file late proofs of claim. The appellants were plaintiffs in a wage-related putative class action against C&J Well Services, Inc. in the Central District of California. C&J Well Services filed for bankruptcy. The automatic stay applied to the California wage litigation. Soon after, Nabors Corporate Services agreed to indemnify C&J Well Services for the California wage litigation. The indemnification agreement spurred the creditor-appellants and debtors to seek an agreed order lifting the bankruptcy stay so that the creditor-appellants could pursue their claims in the California district court. The bankruptcy court granted the order and factored the indemnification agreement and the California wage litigation into the debtors’ reorganization plan. Shortly before the agreed order was entered, the named plaintiffs in the California wage litigation, Brandyn Ridgeway and Tim Smith, timely filed two class proofs of claim. Twenty-seven of the creditor-appellants timely filed individual proofs of claim. Sixty-seven other creditor-appellants did not file individual proofs of claim. Nabors reserved its right to object to the class proofs of claim.

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For the next two years, the parties litigated, appealed, mediated, and otherwise attempted to settle the California wage litigation. Those two years produced a patchwork of orders and decisions from the California district court, the Ninth Circuit Court of Appeals, and the Texas bankruptcy court. The orders and decisions did not address or clarify whether the creditor-appellants needed to file individual proofs of claim or whether they could rely on the previously filed class proofs of claim. The position Nabors took by negotiating for a global resolution of the California wage litigation, while reserving its objection to claims by any creditor-appellant who did not file an individual proof of claim, reflects the uncertain status of the need for individual as opposed to classwide proofs of claim. When it became clear that the parties could not settle the California wage litigation, Nabors objected in the Texas bankruptcy court to the claims from the creditor-appellants who had not previously filed individual proofs. The creditor-appellants moved to file late proofs of claim. The bankruptcy court granted Nabors’ objection and denied the creditor-appellants’ motion. The creditor-appellants timely appealed. This court has jurisdiction under 28 U.S.C. § 158(a). Based on the record, the briefing, and the arguments of counsel presented at an oral hearing, the bankruptcy court’s order denying the creditor-appellants’ motion to file late proofs of claim is reversed. This case is remanded to the bankruptcy court for proceedings consistent with this ruling. The reasons for this ruling are set out below. I. Background A. The Wage Litigation Brandyn Ridgeway and Tim Smith, former employees of Nabors Completion and Production Services Co., worked at the West Wilmington oilfield. (ROA 8283–84). In April 2015, Ridgeway and Smith filed a putative class action against Nabors Completion, asserting 2

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claims for failure to pay prevailing wages under California Labor Code §§ 1194, 1771, 1774, et seq.; waiting-time penalties under California Labor Code § 203; unfair competition under the California Business and Professions Code § 17200; inaccurate wage statements under California Labor Code § 226(a); and penalties under the California Private Attorney General Act, Cal. Lab. Code § 2699, et seq. (ROA 8141, 8283–311). Nabors Completion removed the case to a California federal district court and moved to compel arbitration. (ROA 8141, 7747–49, 7750–72). The arbitration agreement contained a class-action waiver, which Nabors sought to enforce. The district court denied the motion to compel after finding the arbitration agreement unenforceable. (ROA 7593, 7611). In October 2015, Nabors Completion appealed to the Ninth Circuit Court of Appeals. (ROA 8141). The California district court stayed proceedings while the appeal was pending. (See Ridgeway & Smith, et al. v. Nabors Completion & Prod. Servs. Co., et al., No. 2:15-cv-03436, Docket Entry No. 77 (C.D. Cal. Jan. 27, 2016)). B. The Merger, Bankruptcy, and Indemnity Agreement Shortly before the California wage litigation began, in March 2015, Nabors Completion merged with C&J Energy, Ltd., to become C&J Well Services, Inc. (ROA 8283–84, 7459–60). In July 2016, C&J Well Services filed for bankruptcy in the Southern District of Texas.1 (ROA 454–64). C&J Well Services filed a notice of bankruptcy in the California district court and Ninth Circuit, resulting in a stay of the wage litigation, which was then on appeal in the Ninth Circuit. (ROA 8053–108). 1 The debtors that filed for bankruptcy are CJ Holding Co., Blue Ribbon Technology Inc., C&J Corporate Services (Bermuda) Ltd., C&J Energy Production Services-Canada Ltd., C&J Energy Services, Inc., C&J Energy Services Ltd., C&J Spec-Rent Services, Inc., C&J VLC, LLC, C&J Well Services Inc., ESP Completion Technologies LLC, KVS Transportation, Inc., Mobile Data Technologies Ltd., Tellus Oilfield Inc., Tiger Cased Hole Services Inc., and Total E&S, Inc. (ROA 3823). 3

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In September 2016, the Texas bankruptcy court entered a bar-date order, which established November 8, 2016, as the deadline for creditors to file proofs of claim. (ROA 695–725, 731–36). C&J Well Services filed a bar-date notice informing creditors of the deadline to file proofs of claim. (ROA 731–36). The bar-date notice made clear that a creditor who failed to file a proof of claim would be “forever barred, estopped, and enjoined from asserting” claims against C&J Well Services. (ROA 735). C&J Well Services served the bar-date notice on the named plaintiffs. Counsel for C&J Well Services stated at oral argument that it also served the bar-date notice on the absent putative class members in the California wage litigation. (ROA 726–3718, 4465–7455). The day before the bar date, the named plaintiffs in the California wage litigation, Ridgeway and Smith, each filed a proof of claim as the representatives of the putative class members. (ROA 8142). Ridgeway and Smith each asserted the total amount of class damages, $14,029,348, in their proofs of claim. (ROA 8357). Twenty-seven putative class members also filed individual proofs of claim. (ROA 8142, 8357–58). In December 2016, Nabors Corporate Services entered into a settlement agreement with C&J Well Services. (ROA 8439–43, 7460). Nabors previously had contracted to indemnify C&J Well Services. (ROA 8439–43). Nabors agreed to continue indemnifying C&J Well Services for certain unsecured claims, including claims from the California wage litigation. (ROA 7514–18, 8439–43). The settlement agreement gave Nabors “standing to object [in the bankruptcy court] to any proof of claim for which it has indemnified” C&J Well Services. (ROA 7460). The bankruptcy court incorporated the settlement agreement into the debtor’s reorganization plan. (ROA 4271–72). Shortly thereafter, the bankruptcy court confirmed the debtors’ second joint-reorganization plan. (ROA 4319–75, 4245–385). The plan provided that: 4

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Except as provided herein or otherwise agreed, any and all Proofs of Claim Filed after the Bar Date shall be deemed disallowed and expunged as of the Effective Date without any further notice to or action, order, or approval of the Bankruptcy Court, and holders of such Claims may not receive any distributions on account of such Claims, unless on or before the Confirmation Hearing such late Claim has been deemed timely Filed by a Final Order. (ROA 4362). The plan enjoined parties from collecting on prebankruptcy claims against the debtors: Except as otherwise expressly provided in the Plan . . . , all Entities who have held, hold, or may hold Claims or Interests that have been released, discharged, or are subject to exculpation are permanently enjoined, from and after the Effective Date, from . . . commencing or continuing in any manner any action or other proceeding of any kind on account of or in connection with or with respect to any such Claims or Interests; (ROA 4365). C. Relief from the Automatic Stay and the Reorganization Plan Injunction Before the bar date, counsel for the debtors informed counsel for the creditor-appellants that Nabors would indemnify C&J Well Services for the California wage-litigation claims, and that the indemnification would provide the basis for relief from the automatic bankruptcy stay. (ROA 8262). The parties filed an agreed motion for relief from the bankruptcy stay. (ROA 8263, 8342). In February 2017, the bankruptcy court entered the agreed order, giving Ridgeway and Smith relief from the bankruptcy stay and from the reorganization-plan injunction. (ROA 4459–64). The order permitted Ridgeway and Smith to pursue the California wage litigation: [N]otwithstanding the automatic stay and the injunctive provisions contained in the Debtors’ chapter 11 plan [Docket No. 1045] (the “Plan”) and Section 524(a) of the Bankruptcy Code, Brandyn Ridgeway and Tim Smith (“Movants”), on behalf of themselves and all non-exempt workers currently or formerly employed by Nabors Completion & Production Services Co. n/k/a C&J Well Services, Inc. (“Well Services”) within the State of California performing work in the West Wilmington Oil Fields in execution of a contract or contracts between the City of Long Beach and Tidelands Oil Production Co. (all such non-exempt workers, including Movants, the “Putative Class Members”), shall be permitted to proceed to trial and judgment on or settlement of the litigation styled Brandyn Ridgeway and Tim Smith, et al. v. Nabors Completion & Production Services Co., et al., currently pending in 5

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the Central District Court of California under Case No. 2:15-cv-03436-DDP-VBKx (the “Litigation”). (ROA 4460). The order also stated that, if a judgment or settlement amount “exceed[ed] the amount of funds available” from insurance policies or third parties, Ridgeway, Smith, and the putative class members would have “no right to collect” from the debtors “absent further order” of the bankruptcy court. (ROA 4461). The parties reserved their rights to challenge “the validity of the purported ‘class’ proofs of claim” filed by Ridgeway and Smith. (ROA 4461). D. The Ninth Circuit Reversal A year later, in February 2018, the Ninth Circuit reversed and remanded the California federal district court’s order denying the C&J Well Services motion to compel arbitration. (ROA 7681–85). The Ninth Circuit held that Ridgeway’s and Smith’s arbitration agreements with C&J Well Services, which included class-arbitration waivers, were enforceable. (ROA 7683). The Ninth Circuit remanded to the district court to “consider the limited issue of whether to certify Plaintiffs’ Private Attorneys General Act claims.” (ROA 7683). On remand, the California federal district court dismissed Ridgeway’s and Smith’s individual and class claims but retained jurisdiction over the Private Attorneys General Act claims. Ridgeway v. Nabors Completion & Prod. Servs. Co., No. 15-CV-3436, 2018 WL 3569341 (C.D. Cal. July 23, 2018). After the Ninth Circuit’s decision, in March 2018, 96 putative class members in the California wage litigation initiated individual arbitration proceedings. (ROA 8142–43, 8194, 8444–92). Ridgeway, Smith, and 27 putative class members had timely filed individual proofs of claim in the bankruptcy court. (ROA 8248–50). Sixty-seven other putative class members had not filed proofs of claim. (ROA 7468–77, 8142–43, 8184, 8248–50). None of the putative class members sought leave from the bankruptcy court before initiating individual arbitrations. 6

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In May 2018, Nabors filed a status report with the California federal court stating its intention to object to and seek to enjoin the arbitrations started by putative class members who had not timely filed individual proofs of claim with the bankruptcy court. (ROA 8271). Nabors and the creditor-appellants also discussed a global mediation to resolve the outstanding wage-related claims. (ROA 8271). In October 2018, Nabors objected to the late-filed individual proofs of claim. (ROA 7456–81). Nabors also argued that the California wage-litigation creditors who were members of the putative class could not rely on Ridgeway’s and Smith’s class proofs of claim because the Ninth Circuit’s opinion had barred class certification. (ROA 7464). Nabors asked the bankruptcy court to permit only “Ridgeway, Smith, and the Individual Claimants [who had filed proofs of claim] to proceed to arbitration, and judgment on, or settlement of, the Pre-Petition Litigation.” (ROA 7465). The California wage-litigation creditors argued that the bankruptcy court’s order lifting the stay gave all of them the right to pursue individual arbitrations. (ROA 7453, 7692). E. The Bankruptcy Court’s Orders The bankruptcy court sustained the objection Nabors asserted to the proofs of claim, holding that a class-wide proof of claim was not allowed, and that only the wage-litigation plaintiffs who had filed timely individual proofs of claim could arbitrate their individual claims. (ROA 8199–8202, 8549–52). The bankruptcy court suggested that it would consider a motion for leave to file late individual proofs of claim for the 67 wage-litigation putative class members who had not already filed them. (ROA 8201–02). These individuals filed a motion requesting leave to file late proofs of claim based on excusable neglect. (ROA.8220–50). The bankruptcy court denied the motion, holding that they had not shown excusable neglect. (ROA 8695–98). The bankruptcy court found that the record was “so poor as to essentially be non-existen[t]”; there was 7

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potential prejudice to the debtor, because the Nabors “indemnification might not be honored” and “other folks” might seek to file late proofs of claim; the delay was “within the reasonable control” of the creditors; and the reason for the delay was “attorney incompetence.” (ROA 8696–97). The California wage-litigation class-member creditors appealed. (ROA 8708–14). The parties certified a nearly 10,000-page record, both parties filed briefs, and this court held a hearing in which the parties presented their arguments. (Docket Entry No. 4). II. The Legal Standards A. The Standard of Review “When reviewing a bankruptcy court’s decision . . . a district court functions as a[n] appellate court and applies the standard of review generally applied in federal court appeals.” In re Renaissance Hosp. Grand Prairie Inc., 713 F.3d 285, 293 (5th Cir. 2013) (citation and quotation marks omitted). The court reviews the bankruptcy court’s factual findings for clear error but reviews de novo its conclusions of law and resolution of mixed questions of law and fact. In re San Patricio Cty. Cmty. Action Agency, 575 F.3d 553, 557 (5th Cir. 2009). The bankruptcy court’s expertise and knowledge of the case deserves this court’s respect and, when appropriate, deference. B. Excusable Neglect To qualify as a Chapter 11 bankruptcy creditor, a claimant must file a proof of claim by the bar date. Fed. R. Bankr. P. 3003(c)(2); In re ValuePart, 802 F. App’x 143, 146 (5th Cir. 2020). A bankruptcy court may grant leave to file a late proof of claim if “the failure to act was the result of excusable neglect.” Fed. R. Bankr. P. 9006(b)(1). Excusable neglect covers “situations in which the failure to comply with a filing deadline is attributable to negligence.” Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380, 394 (1993). Inadvertence, ignorance of the rules, and mistakes about the rules “do not usually 8

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constitute ‘excusable’ neglect,” but the concept is “elastic” and “is not limited strictly to omissions caused by circumstances beyond the control of the movant.” Id. at 392; see also Halicki v. La. Casino Cruises, Inc., 151 F.3d 465, 469 (5th Cir. 1998) (“[A] misconstruction of the rules—especially when their language is plain—will rarely satisfy the ‘excusable neglect’ standard.”); see also McCurry v. Adventist Health Sys./Sunbelt, 298 F.3d 586, 592 (6th Cir. 2002) (“[N]either strategic miscalculation nor counsel’s misinterpretation of the law warrants relief from a judgment.”). Courts consider four factors when determining whether there is excusable neglect: (1) “whether the movant acted in good faith”; (2) “the danger of prejudice” to the debtor; (3) “the length of the delay and its potential impact on judicial proceedings”; and (4) “the reason for the delay, including whether it was within the reasonable control of the movant.” In re Prism Graphics, Inc., 666 F. App’x 355, 356–57 (5th Cir. 2016) (quoting Pioneer, 507 U.S. at 395). No one factor controls. See In re 50-Off Stores, Inc., 220 B.R. 897, 901 (Bankr. W.D. Tex. 1998). The excusable-neglect “determination is at bottom an equitable one, taking account of all relevant circumstances surrounding the party’s” error. Prism, 666 F. App’x at 357 (quoting Pioneer, 507 U.S. at 395). III. Analysis A. Good Faith The record does not show that the creditor-appellants acted in bad faith. See In re Eagle Bus Mfg., Inc., 62 F.3d 730, 737 (5th Cir. 1995) (“[The debtor] does not argue that the Claimants acted in bad faith. Indeed, the record is devoid of anything to suggest that the parties acted in any way other than in good faith.”). 9

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B. Danger of Prejudice to the Debtor The second factor favors the creditor-appellants. “Under Pioneer, the central inquiry is whether the debtor will be prejudiced,” not indemnifying parties. Id. at 737–38 (emphasis in original). Courts may also account for potential prejudice to “the other unsecured creditors and . . . future judicial proceedings.” In re ValuePart, Inc., 802 F. App’x at 148. Courts examine several factors when determining whether late-filed proofs of claim will prejudice the debtor, including the size of the claims, whether the reorganization plan was confirmed with an expectation of the claims, and whether the claims will disrupt the “economic model” on which the reorganization plan was built. In re Enron Creditors Recovery Corp., 370 B.R. 90, 101 (Bankr. S.D.N.Y. 2007) (quoting In re Keene Corp., 188 B.R. 903, 910 (Bankr. S.D.N.Y. 1995)). Courts are less likely to find that a debtor is prejudiced by late-filed claims when the debtor “expected” the claims before the bankruptcy court approved its reorganization plan. In re Eagle Bus Mfg., Inc., 62 F.3d at 737–38 (“We note that [the debtor’s] reorganization plan was negotiated and approved after [the debtor] had notice of these claims. This is not a situation where the debtor’s plan was formulated, negotiated, and confirmed before notice was given of a substantial late claim.”). The record does not show that allowing the late-filed claims is likely to prejudice the bankruptcy debtors or creditors. Nabors agreed to indemnify C&J Well Services for certain unsecured claims, including the prebankruptcy California wage-litigation claims. The bankruptcy court confirmed the reorganization plan based on the indemnification agreement. (ROA 4271–72, 4275, 4377–80). The order granting the creditor-appellants relief from the bankruptcy stay also made clear that recovery would come from a third party such as Nabors, or insurers, not the debtors or other creditors. (ROA 4461). The bankruptcy court suggested that the Nabors indemnification 10

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agreement “might not be honored,” but the record does not show that Nabors has refused or is likely to refuse to indemnify the debtors. (ROA 8683). And if Nabors does refuse to indemnify the debtors, the record does not show that the refusal would alter the current distribution or require creditors to return “amounts already paid out under the confirmed [p]lan.” In re O’Brien Env’t Energy, Inc., 188 F.3d 116, 128 (3d Cir. 1999). The reorganization plan also contains a disputed-claims reserve fund in case an indemnitor refuses to reimburse the debtors. (ROA 7514). This record evidence supports finding that allowing the late-filed claims will not harm the debtors or other creditors. The record shows that the indemnitor, Nabors, as well as the debtors expected the creditor-appellants’ claims. See In re Northstar Offshore Grp., LLC, No. 16-34028, 2018 WL 4443201, at *4 n.3 (Bankr. S.D. Tex. Sept. 14, 2018) (“[The debtor’s] plan specifically anticipated the possibility that a post-confirmation proof of claim could be filed.”); In re O’Brien Env’t Energy, Inc., 188 F.3d at 128 (“This is not a case where the debtor was surprised or caught unaware by the assertion of a claim that it had not anticipated.”). The California wage litigation preceded the bankruptcy by over a year. The debtors listed the lawsuit claims in their statements of financial affairs. (ROA 657); see In re Wallace, Rush, Schmidt, Inc., No. 17-10698, 2018 WL 3954184, at *4 (Bankr. E.D. La. Aug. 14, 2018) (“The tort suits were filed well before the bankruptcy case was commenced, and the debtor knew about the tort claimants, so these claims are not a surprise to the debtor.”). In In re Eagle Bus, 62 F.3d at 737–38, the Fifth Circuit found no prejudice to the debtor in allowing late-filed claims when they were expected. Here, the late-filed claims were not only expected, they were factored into the confirmed reorganization plan, and a third party indemnitor is expected to cover them. See also In re Alexander’s Inc., 176 B.R. 715, 722 (Bankr. S.D.N.Y. 11

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1995) (“Debtors and other creditors will be prejudiced because the Proof of Claim was filed after the Debtors’ Plan was formulated, negotiated and confirmed. . . . [A]llowance of [claimant’s] claim would disrupt the ‘economic model’ on which all parties reached their agreements.”). Ridgeway and Smith each submitted timely class proofs of claim that listed the total amount of classwide damages as $14,029,348. (ROA 8357). The Nabors settlement agreement with the debtors covered the California wage-litigation claims. (ROA 8439–8442). The bankruptcy court incorporated the settlement agreement into the confirmation order. (ROA 4271–72, 4275, 4377–80). After confirmation, the bankruptcy court authorized the creditors and debtors to “estimate” that Nabors would indemnify the debtors for Ridgeway’s and Smith’s claims when determining the “Disputed Claims Reserve.” (ROA 7514). The bankruptcy court valued Smith’s and Ridgeway’s claims as class representatives at $14,029,348.87 each, for a total of $28,058,697.74.2 (ROA 7518). The bankruptcy court instructed the debtors and creditors to set aside three percent of the “asserted face amounts” of each disputed claim, including Ridgeway’s and Smith’s class claims, in case Nabors failed to satisfy “its indemnification obligations.” (ROA 7514); see also In re Spring Ford Indus., Inc., No. 02-15015, 2003 WL 21785960, at *5 (Bankr. E.D. Pa. July 25, 2003) (“[N]o prejudice has been found . . . where a reserve fund was set aside for disputed claims.” (citing In re Wheeling-Pittsburgh Steel Corp., 128 B.R. 391, 393 (Bankr. W.D. Pa. 1991))). Nabors argues that allowing the creditor-appellants to file late individual proofs of claim will spur other creditors to file late proofs of claim. The record does not show that allowing these late-filed claims will “precipitate the filing of many more” late-filed claims. In re 50-Off Stores, 2 At oral argument, counsel noted that the $28,058,697.74 figure is double the actual value of the creditor-appellants’ claims. Counsel for the creditor-appellants agreed that he could recover, at most, $14,029,348.87 for the creditor-appellants. 12

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Inc., 220 B.R. at 903 n.11. The record does not show others seeking relief from the bar date. See In re O’Brien Env’t Energy, Inc., 188 F.3d at 128 (“[T]o the extent [the debtor] argues that allowance of this claim would open the floodgates to other future claims against them, [the debtor] has not alleged that any other creditor promptly sought to be excused from the March 8 order so as to now be entitled to relief on the basis of excusable neglect.”); In re Beltrami Enters., Inc., 178 B.R. 389, 392 (Bankr. M.D. Pa. 1994) (finding no prejudice when “[n]o evidence was placed on the record to indicate that there were hordes of claimants ready to file claims should [the moving creditor] be allowed to file its claim late.”). Nor does the record reveal similar outstanding wage-related claims against the debtors. See In re Enron Creditors Recovery Corp., 370 B.R. 90, 102 (Bankr. S.D.N.Y. 2007) (“[T]he cumulative effect of allowing [the creditor’s] late-filed guaranty claim, when viewed at the time of the late-filed claim, may well have resulted in a flood of similar late-filed guaranty claims, which would have disrupted the economic model upon which the plan was formulated and negotiated.”). Nabors argues that the debtors would suffer because they would “incur costs for bankruptcy counsel related to the 67 new cases.” (Docket Entry No. 10 at 22). In general, the “costs of litigation should not be considered prejudicial to the debtor as a result of allowing claims to be filed late.” In re Smith, 200 B.R. 135, 138 (Bankr. S.D. Miss. 1996); see also In re Wooten, 620 B.R. 351, 356 (Bankr. D.N.M. 2020) (“[T]he accrual of attorney’s costs and fees of objecting to and defending against [a creditor’s] claim” is not prejudicial); In re Bruno Mach. Corp., No. 05-20412, 2007 WL 2071747, at *3 (N.D.N.Y. July 12, 2007) (“[T]he fact that the debtor had to spend money litigating the late claim . . . [is not] a ground for prejudice under Pioneer.”). The record does not show that the costs of the debtor’s employee-representatives attending additional 13

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arbitrations is unfairly prejudicial. The record shows that the repetitive nature of the proceedings, the ready availability of remote video appearances, and the likelihood that the employer can record their testimony once for repeated use significantly reduce the likely costs and burden of the arbitrations. See In re O’Brien Env’t Energy, Inc., 188 F.3d at 127 (the need to “expend significant employee time” does not generally qualify as prejudice (citing In re Pettibone Corp., 162 B.R. 791 (Bankr. N.D. Ill. 1994))). C. Length of Delay and Its Potential Impact The third factor favors the creditor-appellants. The Fifth Circuit has held that, in bankruptcy, “time is the essence of prejudice.” In re ValuePart, Inc., 802 F. App’x at 148 (quoting Pyramid Mobile Homes, Inc. v. Speake (In re Pyramid Mobile Homes, Inc.), 531 F.2d 743, 746 (5th Cir. 1976)). The Fifth Circuit has found that a bankruptcy court did not abuse its discretion in denying leave to file a proof of claim that was 42 days late. See In re DLH Master Land Holding, LLC, 464 F. App’x 316, (cid:22)(cid:20)(cid:27)(cid:237)(cid:20)(cid:28) (5th Cir. 2012); see also Kollinger v. Hoyle (In re Kollinger), 551 F. App’x 104, 108 (5th Cir. 2013) (“[N]o excuse justifies failing to file a brief for ten months.”). However, the Fifth Circuit has held that the length of delay is less critical once the debtor’s reorganization plan has been confirmed. Late-filed claims may “be resolved” after confirmation “without necessitating the involvement of the bankruptcy court.” In re Eagle Bus Mfg., Inc., 62 F.3d at 739. Reorganization plans typically “contemplate[] that resolution of [late-filed] claims” will “continue even after the plan’s confirmation,” id, and the plan here so provided. Courts also tend to find a delay excusable if the nonmovant incidentally caused the delay. Id. The delay between the bar date and the creditor-appellants’ motion to file late proofs of claim is two years and nine months. (ROA 731–36, 8220–50). That is a long time. The Ninth Circuit decision precluding class treatment was not issued until February 2018, 15 months after 14

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the bar date. The bankruptcy court did not rule that its February 2017 order precluded class-wide proofs of claim until July 2019, two years and eight months after the bar date. That was when it first became clear that the creditor-appellants needed to file individual proofs of claim. They sought leave to file late claims one month later. See In re Eagle Bus. Mfg., Inc., 62 F.3d at 740 (finding excusable neglect when a delay was six to eight months); Chemetron Corp. v. Jones, 72 F.3d 341, 350 (3d Cir. 1995) (remanding to determine excusable neglect when the motion to file late proof of claim came two years after the plan was confirmed). Ridgeway and Smith each filed a class proof of claim before the bar date, and 27 putative class members filed individual proofs of claim before the bar date. (ROA 8142, 8357–58). In February 2017, the bankruptcy court gave the creditor-appellants relief from the bankruptcy stay to pursue the class claims in California federal district court. (ROA 4459–64). In February 2018, the Ninth Circuit’s decision told Ridgeway and Smith for the first time that they could not pursue the claims as a class action. (ROA 7681–85). A month later, in March 2018, the creditor-appellants initiated 96 individual arbitrations. (ROA 8142–43, 8194, 8444–92). The bankruptcy court’s order lifting the stay permitted Ridgeway and Smith to pursue individual and class claims through “trial and judgment” or “settlement.” (ROA 4460). The order did not preclude the creditor-appellants from pursuing individual arbitration claims. (ROA 7465). Nor did it limit individual arbitration claims to the creditor-appellants who had previously filed individual proofs of claim. In May 2018, Nabors objected in the bankruptcy court to claims from the 67 creditor-appellants who had not filed individual proofs of claim. (ROA 8271). Soon after, the parties tried to settle the outstanding claims through mediation. (ROA 8271–72). The parties conducted informal discovery and claims analysis, haggled over mediators, mediated in December 2018, but 15

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failed to resolve the claims. (ROA 8274). The parties continued to negotiate until February 2019, when the creditor-appellants filed a motion asking the bankruptcy court to interpret the order lifting the bankruptcy stay and injunction. (ROA 7539–48). In July 2019, the bankruptcy court held that the agreed order permitted only the creditor-appellants who had filed individual proofs of claim to pursue their arbitration claims. (ROA 8550). A month later, the creditor-appellants moved for leave to file late proofs of claim. (ROA 8220–50); see In re Wallace, Rush, Schmidt, Inc., No. 17-10698, 2018 WL 3954184, at *4 (Bankr. E.D. La. Aug. 14, 2018) (“[I]t appears from the record that once [the creditor-appellants] understood that they needed to file proofs of claim, they did so fairly quickly.”). Delays from allowing the late-filed claims to proceed will not significantly affect the bankruptcy proceedings. The bankruptcy court built in time for Ridgeway and Smith to litigate their individual and class claims in the California federal court. (ROA 4459–64). Arbitrations have already begun for some of the 29 creditor-appellants who timely filed proofs of claim. At oral argument, counsel for the creditor-appellants informed the court that these arbitrations are moving quickly: (cid:120) the first 27 arbitrations are scheduled, and 8 are finished; (cid:120) the final arbitration hearings take roughly one day to complete; (cid:120) liability is often resolved in favor of the creditor-appellant in a dispositive motion, leaving only damages for the final arbitration hearing; (cid:120) corporate representatives appear by video; (cid:120) prerecorded testimony may suffice; and (cid:120) the same 9 arbitrators will hear all 96 arbitrations. 16

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The arbitrations will likely move quicker as the arbitrators and parties proceed. Allowing the late-filed claims will not extend the delay far beyond the time contemplated in the order or create unfair prejudice. D. Reasons for Delay The fourth factor also favors the late-filed proofs of claim. Courts are less likely to find excusable neglect when the reason for delay was within the movant’s “reasonable control,” In re ValuePart, Inc., 802 F. App’x at 148, although excusable neglect is not “limited to errors caused by circumstances beyond the late filing party’s control,” United States v. Clark, 51 F.3d 42, 43 (5th Cir. 1995). Courts examine the nonmovant’s role in causing the delay, In re O’Brien Env’t Energy, 188 F.3d at 128, and whether “confusion or ambiguity existed regarding the need to file,” In re Eagle Bus Mfg., Inc., 62 F.3d at 740. Counsel for the creditor-appellants explained that he filed 29 individual proofs of claim, instead of 96, because, unlike counsel for C&J Well Services, he did not have contact information for each absent putative class member. The California district court had stayed class discovery while its arbitration ruling was on appeal to the Ninth Circuit. (See Ridgeway & Smith, et al. v. Nabors Completion & Prod. Servs. Co., et al., No. 2:15-cv-03436, Docket Entry No. 77 (C.D. Cal. Jan. 27, 2016)). The record shows reason for confusion about whether the creditor-appellants needed to file individual proofs of claim before the bar date, rather than relying on class-wide proofs of claim. Ridgeway and Smith each filed class proofs of claim after the California federal district court held that the contested arbitration agreements were unenforceable. (ROA 8142, 8357). Class treatment was partially precluded a year later, after the Ninth Circuit reversed the district court’s decision and held that the arbitration agreements, with their class-action waivers, were enforceable. But 17

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the Ninth Circuit’s decision did not eliminate all uncertainty over whether aggregate litigation was appropriate. Ridgeway and Smith had filed claims under California’s Private Attorneys General Act, which allows private citizens to represent a group of people. Lawsuits under the Act are “representative suits,” but they are not treated as class actions. Baumann v. Chase Inv. Servs. Corp., 747 F.3d 1117, 1123 (9th Cir. 2014) (“[A] PAGA suit is fundamentally different than a class action.”). The Ninth Circuit remanded to the district court to determine whether “to certify Plaintiffs’ PAGA claims.” (ROA 7685). The bankruptcy court’s agreed order lifting the stay appears to have added to the uncertainty. The order gave the creditor-appellants the right to “proceed to trial and judgment on or settlement of the” California wage litigation. (ROA 4460). The order was entered before the Ninth Circuit’s decision and contemplated class litigation in the California federal district court. (ROA 4460 (referring to the creditor-appellants as “Class Members” and explaining that “[t]he term Class Members shall not include any person who would have been a Class Member but elected to opt out of class treatment.”)). The order did not clearly preclude individual arbitrations or limit individual arbitrations to those who had timely filed individual proofs of claim. As late as October 2018, Nabors appeared to agree that the order lifting the stay allowed individual arbitrations. Nabors requested that “Ridgeway, Smith, and the Individual Claimants” who filed proofs of claim be allowed to “proceed to arbitration, and judgment on, or settlement of, the Pre-Petition Litigation.” (ROA 7465). The delay was prolonged by the continued negotiations attempting a global settlement, efforts that continued well beyond the bar date. See In re Eagle Bus Mfg., Inc., 62 F.3d at 738 (“If [the debtor] had in fact believed that these claims were barred it would not have allowed the Claimants to participate in the ADR and would not have negotiated with them for several months 18

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after passage of the bar date.”). Before the bar date, counsel for the debtors informed counsel for the creditor-appellants that Nabors would likely indemnify C&J Well Services for the California wage-litigation claims, and that the indemnification would be a ground for relief from the automatic bankruptcy stay. (ROA 8262). Beyond the bar date, the parties continued to negotiate an agreed motion for relief from the bankruptcy stay, (ROA 8263, 8342), which the bankruptcy court granted, (ROA 4459–64). After the Ninth Circuit’s ruling precluding class treatment, Nabors continued to negotiate with the creditor-appellants. From May 2018 through February 2019, Nabors agreed to a “global mediation” of the wage-litigation claims, including the claims of those who had not filed individual proofs of claim before the bar date. (ROA 8231). Nabors participated in informal discovery and claims analysis, proposed and rejected mediators, participated in mediation, and continued negotiating after mediation failed. (ROA 8271–78); see In re Northstar Offshore Grp., LLC, 2018 WL 4443201, at *3 (“[I]t would be inequitable to find prejudice to [the debtor] while it simultaneously negotiated in good faith with [the claimant] past the claims bar date and anticipated that the failure to reach a compromise would lead to a dispute between the parties.”); In re Smith, 200 B.R. at 137 (“The ongoing discovery and correspondence between counsel also indicates a full awareness that the claims were being pursued.”). Nabors argues that the creditor-appellants are the victims of their own “legally risky” class-wide-proof-of-claim strategy. (Docket Entry No. 10 at 14). While some courts have held that a class proof of claim is not allowed under Federal Rules of Bankruptcy Procedure 3001(b) and 7023, see, e.g., In re FIRSTPLUS Fin., Inc., 248 B.R. 60, 69 (Bankr. N.D. Tex. 2000), those courts are “in the minority with this view,” In re Vanguard Nat. Res., LLC, No. 17-30560, 2017 WL 5573967, at *4 (Bankr. S.D. Tex. Nov. 20, 2017) (citation omitted). The majority of federal courts 19

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hold that “a class proof of claim is permissible under the Bankruptcy Code and Federal Rules of Bankruptcy Procedure,” and that “Bankruptcy Rule 9014 allows bankruptcy courts to apply Bankruptcy Rule 7023 and Rule 23 to any stage of a contested matter, including the filing of a proof of claim.” Id.; see also In re Am. Reserve Corp., 840 F.2d 487, 488 (7th Cir. 1988); Reid v. White Motor Corp., 886 F.2d 1462, 1470 (6th Cir. 1989); In re Trebol Motors Distrib. Corp., 220 B.R. 500, 502 (B.A.P. 1st Cir. 1998); Gentry v. Siegel, 668 F.3d 83, 88–89 (4th Cir. 2012). The Fifth Circuit has not addressed this question, but it has held that bankruptcy courts have discretion as to whether to apply Rule 23 to contested matters. See In re TWL Corp., 712 F.3d 886, 892 (5th Cir. 2013); see also In re Think Fin., LLC, No. 17-33964, 2018 WL 9801454, at *6 (Bankr. N.D. Tex. Aug. 30, 2018) (allowing a class proof of claim and applying Rule 23). The record and applicable law suggest that, if the creditor-appellants’ use of class-wide proofs of claim and delay in filing individual proofs of claim was neglect, it was excusable. First, the majority of federal courts have allowed class-wide proofs of claim. Second, Rule 3001(b) allows a creditor or its authorized agent to file a proof of claim. A minority of courts view hold that a self-appointed class representative does not qualify as an “authorized agent” under Rule 3001(b). See, e.g., In re FIRSTPLUS Fin., Inc., 248 B.R. at 67 (“A putative class representative is not, nor can he be transformed by the court into, an authorized agent within the purview of Bankruptcy Rule 3001(b).”). Ridgeway and Smith’s counsel represent each putative class member, removing the authorized-agent concerns highlighted by these courts. Third, before the bar date, Nabors and the debtors informed the creditor-appellants that they would likely not be subject to the bankruptcy stay because Nabors had indemnified the debtors for the California wage-litigation claims. (ROA 8262). 20

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Fourth, the underlying California litigation was styled as a class action. While the California district court had not certified a class, it had denied the C&J Well Services motion to compel arbitration, eliminating the primary barrier to class certification. As noted above, the bankruptcy court and the parties appeared to assume that the California wage litigation would proceed in class form when the class-wide proofs of claim were filed. IV. Conclusion The bankruptcy court’s order denying the creditor-appellants’ motion to file late proofs of claim is reversed. This case is remanded to the bankruptcy court for proceedings consistent with this ruling. SIGNED on June 29, 2021, at Houston, Texas. _______________________________ Lee H. Rosenthal Chief United States District Judge 21

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re: Case No. 16-33590-drj Holding Co. Chapter 11 in Debbye Debtors CERTIFICATE OF NOTICE strict/off: 0541-4 User: gkel Page 1 of 10 te Rcvd: Jun 29, 2021 Form ID: pdf002 Total Noticed: 2 e following symbols are used throughout this certificate: bol Definition Addresses marked '+' were corrected by inserting the ZIP, adding the last four digits to complete the zip +4, or replacing an incorrect ZIP. USPSregulations require that automation-compatible mail display the correct ZIP. Addresses marked '#' were identified by the USPS National Change of Address system as requiring an update. While the notice was still deliverathe notice recipient was advised to update its address with the court immediately. Addresses marked '##' were identified by the USPS National Change of Address system as undeliverable. Notices will no longer be delivered bythe USPS to these addresses; therefore, they have been bypassed. The debtor's attorney or pro se debtor was advised that the specified notice wasundeliverable. tice by first class mail was sent to the following persons/entities by the Bankruptcy Noticing Center on Jul 01, 2021: cip ID Recipient Name and Address + Blue Ribbon Technology Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Corporate Services (Bermuda) Ltd., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Energy Production Services-Canada Ltd., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Energy Services, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J Spec-Rent Services, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ C&J VLC, LLC, 3990 Rogerdale Road, Houston, TX 77042-5142 + C&J Wells Services Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ CJ Holding Co., 3990 Rogerdale Road, Houston, TX 77042-5142+ ESP Completion Technologies LLC, 3990 Rogerdale Road, Houston, TX 77042-5142+ KVS Transportation, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ Mobile Data Technologies Ltd., 3990 Rogerdale Road, Houston, TX 77042-5142+ Tellus Oilfield Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ Tiger Cased Hole Services Inc., 3990 Rogerdale Road, Houston, TX 77042-5142+ Total E&S, Inc., 3990 Rogerdale Road, Houston, TX 77042-5142Alan J. Stone, Milbank, Tweed et al., 28 Liberty Street, NYC, NY 10005-1413+ Bethany Simmons, Loeb & Loeb LLP, 345 Park Avenue, New York, NY 10154-1895Christine R. Etheridge, IKON Financial Services, 1738 Bass Road, P.O.Box 13708, Macon,, GA 31208-3708+ Crady, Jewett & McCulley, LLP, c/o William R. Sudela, 2727 Allen Parkway, Suite 1700, Houston, TX 77019-2125+ Daniel Scott Lockwood, Kennedys CMK, LLP, 3821 Juniper Trace, Suite 101, Austin, TX 78738-5514+ Douglas R Cameron, HANSON BAKER LUDLOW DRUMHELLER PS, 2229 112TH Avenue NE, Suite 200, Bellevue, WA 98004-29+ Douglas R. Gooding, Choate Hall & Stewart LLP, Two International Place, Boston, MA 02110-4120+ Geoffrey G Wright, Attorney at Law, 4121 Washington Road, McMurray, PA 15317-2595+ Greenberg Traurig, LLP, c/o David R. Eastlake, Greenberg Traurig, LLP, 1000 Louisiana Street, Suite 1700, Houston, TX 77002-5001+ Jennifer Castillo, Hall Estill, 100 N. Broadway, Suitre 2900, OKC, OK 73102-8865+ Jonathan D. Marshall, Choate Hall & Stewart LLP, Two International Place, Boston, MA 02110-4120+ Jones Gill LLP, 6363 Woodway, Suite 1100, Houston, TX 77057-1796+ Kirkland & Ellis LLP and Kirkland & Ellis Internat, 300 North LaSalle, Chicago, IL 60654-3427+ Locke Lord LLP, 600 Travis Street, Ste. 2800, Houston, TX 77002-2914+ Marc Kieselstein, Kirkland & Ellis, 300 North LaSalle, Chicago, IL 60654-5412+ Muskat, Mahony, Devine & Moses, LLP, 1201 Louisiana St., Suite 850, Houston, TX 77002, UNITED STATES 77002-5627+ Nicole M Misner, Klein DeNatale et al, 4550 California Ave, 2nd Flr, Bakersfield, CA 93309-7012+ Rhonda Luginbyhl, Burdett Morgan Williamson & Boykin, 701 Taylor, Ste. 440, Amarillo, TX 79101-2424+ Richard E. Donahoo, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Roy Barrera, III, Golden & Barrera, PC, 424 East Nueva, San Antonio, TX 78205-3422+ Sarah B. Schlehr, 150 E. Olive Ave, Burbank, CA 91502-1846+ Sonia Pflaster, 150 East Olive Ave, Suite 214, Burbank, CA 91502-1850+ Stephen T. Schwarzbach, Jr., Kirkland & Ellis, 600 Travis, Ste 3300, Houston, TX 77002-2926+ Thomas D Maxson, 625 Liberty Avenue, Pittsburgh, PA 15222-3110Tyson Lomazow, Milbank, Tweed, Haldey McCloy, 28 Liberty Street, New York, NY 10005-1413+ Vinson & Elkins L.L.P., Houston, 1001 Fannin Street, Suite 2500, Houston, TX 77002-6710+ Walker & Patterson, P.C., P.O. Box 61301, Houston, TX 77208-1301

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+ Yasin Daneshfar, Becker & Poliakoff, P.A., 1 East Broward Blvd Ste 1800, Fort Lauderdale, FL 33301-1876+ AG Energy Credit Opportunities Fund, LP, c/o Angelo Gordon & Co LP, 245 Park Avenue, 26th Floor, New York, NY 10167-2699sfee + AG Energy Credit Opportunities Investments Fund LP, c/o Angelo, Gordon & Co LP, 245 Park Avenue, 26th Floor, New York, NY10167-2699 AIP Products Company Inc, PO Box 14088, Odessa, TX 79768-4088#+ ASM Capital V, L.P., 7600 Jericho Turnpike, Suite 302, Woodbury, NY 11797-1705#+ ASM SPV, L.P., 7600 Jericho Turnpike, Suite 302, Woodbury, NY 11797-1705+ Abel Perez, Jr., 1800 Bering Drive, Suite 305, Houston, TX 77057-3156+ Active Industrial Solutions, Ltd., c/o Matthew D. Cavenaugh, Jackson Walker L.L.P., 1401 McKinney St., Suite 1900, Houston, TX77010-1900 + Allen LeCain, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Amado Garcia, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Amegy West, 16623 Aldine Westfield Road, Houston, TX 77032-1351+ Anastacio Calderon, 16133 Ventura Blvd., Suite 1200, Encinco, CA 91436-2416+ Andrews County Tax Office, et al, c/o Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-08+ Andrews Independent School District, et al, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX79408-0817 + Antonio Lopez, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Argo Partners, 12 West 37th Street, 9th floor, New York, NY 10018-7381+ Ariba, Inc., c/o Brown & Connery, LLP, Donald K. Ludman, 6 North Broad Street, Suite 100 Woodbury, NJ 08096-4635+ Asuncion Romero, Estate of Aide Romero, Deceased, 2909 Hillcroft Avenue, Suite 575, Houston, TX 77057-5815+ Asuncion Romero, Individually, 2909 Hillcroft Avenue, 575, Houston, TX 77057-5815+ Asuncion Romero, a/n/f of S.R., 2909 Hillcroft Avenue, Suite 575, Houston, TX 77057-5815+ Baker Receivables Solutions, LLC, 20501 Katy Fwy # 214, Katy, TX 77450-1942+ Belden Blaine Raytis LLP, c/o T. Scott Belden, 5016 California Ave, Bakersfield, CA 93309-1649+ Brazos County, Lee Gordon, P O Box 1269, Round Rock, TX 78680-1269+ Brian Winchester, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ CIT Bank, N.A., c/o Michael Schein, Vedder Price P.C., 1633 Broadway, 47th Floor, New York, NY 10019-6708+ CRG Financial LLC, 100 Union Avenue, Cresskill, NJ 07626-2141+ Camden Machine & Tool, Inc., c/o J. Seth Moore, One Galleria Tower, 13355 Noel Rd., Ste. 1900, Dallas, TX 75240-6674+ Carbo Ceramics, Inc., c/o Gardere Wynne Sewell LLP, Jason B. Binford, 2021 McKinney Avenue, Ste. 1600, Dallas, TX 75201-3340+ Carl Marks Advisory Group, LLC, c/o Charles Boguslaski, 900 Third Avenue, 33rd Floor, New Yori, NY 10022-4775sfor + Certex USA Inc., Hain Capital Investors, LLC, 301 Route 17 North 7th Floor, Rutherford, NJ 07070-2575+ Cherokee Debt Acquisition, LLC, c/o Bowery Investment Management, LLC, 1325 Avenue of the Americas, 28th Floor, New York, NY10019-6583 + Cindy Marchello, c/o Alan Gerger, 2211 Norfolk St., Suite 517, Houston, TX 77098-4051+ City of Belfield, North Dakota, Wauson Probus, Attn: Anabel King, 1 Sugar Creek Ctr. Blvd., Ste. 880 Sugar Land, Tx 77478-3557City of Greenville, c/o Tab Beall, Perdue Brandon Fielder Collins & Mott, PO Box 2007, Tyler, TX 75710-2007+ Clean Tank, Inc., PO Box 547, Hockley, TX 77447-0547 + Cleburne ISD, c/o Perdue Brandon Fielder et al, Elizabeth Banda Calvo, 500 E Border Street, Suite 640, Arlington, TX 76010-7457+ Colleen Pudlo, 34 Gingerbread Lane, Yarmouth Port, MC 02675-1109+ Conway MacKenzie Management Services, LLC, Conway MacKenzie, Inc., 1301 McKinney Street, Suite 2025, Houston, TX 77010-30+ Corre Opportunites II Master Master Fund, LP, 12 East 49th Street, Suite 4003, New York, NY 10017-8222+ Corre Opportunites Qualified Master Fund, LP, 12 East 49th Street, Suite 4003, New York, NY 10017-8222+ Cummins Chevrolet Buick GMC Cadillac, Inc., P.O. Box 31, Weatherford, OK 73096-0031+ CyrusOne LLC, c/o Marvin E Sprouse III, Glenn Rogers PLLC, 11610 Bee Caves Rd, Suite 220 Austin, TX 78738-5457+ DJ's Glass Plus Inc., 3700 Hwy 374, Green River, WY 82935-9623+ David Gutierrez, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ David Navarro, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Del rio, Linebarger Goggan Blair & Sampson LLP, PO Box 3064, Houston, TX 77253-3064+ Delia Nunez, c/o Jon J. Bailey, 311 W. Harris Street, San Angelo, TX 76903-6338+ Devaughn Ware, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Diane Kennedy, c/o Daniel JT Sciano, Tinsman & Sciano, Inc., 10107 McAllister Frwy., San Antonio, TX 78216-4648+ Donlin Recano & Company Inc, 6201 15th Avenue, Brooklyn, NY 11219-5411+ Duane Brown, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Dwayne Newton, NEWTON JONES & SPAETH, 3405 Marquart, Houston, Tx 77027-6505+ EOG Resources, Inc., c/o Leah T. Rudnicki, Hall Estill, 100 N. Broadway, Suite 2900 Oklahoma City, OK 73102-8865+ EOTT Holdings, LLC, c/o Okin Adams LLP, 1113 Vine Street, 201, Houston, TX 77002-1045+ Ector CAD, 711 Navarro, Ste. 300, San Antonio, TX 78205-1749+ Edgar Romero, 2909 Hillcroft Avenue, Suite 575, Houston, TX 77057-5815+ Eduardo Figueroa, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047Eli Leal, Jr., 7951 East IH 20, Odessa, TX 79765, ECTOR + Elizabeth Weller Hunt County, c/o, Linebarger Goggan Blair & Sampson, LLC, 2777 N. Stemmons Frwy, Suite 1000 Dallas, TX75207-2328

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+ Ellwood Crankshaft and Machine Company, 2727 Freedland Road, Hermatage, PA 16148-9027+ Esperanza Soto, 2909 Hillcroft Avenue, Suite 575, Houston, TX 77057-5815+ Esperanza Soto, Individually, 2909 Hillcroft Avenue, Suite 575, Houston, TX 77057-5815+ Fair Harbor Capital, LLC, PO Box 237037, New York, NY 10023-0028+ Fayette County, Dimmit County and Karnes County, c/o John T Banks, Perdue Brandon Fielder Collins & Mott, 3301 Northland Dr., Su505, Austin, TX 78731-4954 + Fermin Vela, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Flotek Industries, Inc., c/o Snow Spence Green LLP, 2929 Allen Parkway, Ste. 2800, Houston, TX 77019-7125+ Frank Ronquillo, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Fred Michelotti, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Green Tweed and Co, 1325 Avenue of the Americas, 28th Floor, New York, NY 10019-6583+ Greene's Investments, Inc., c/o Alan Gerger, 2211 Norfolk St., Suite 517, Houston, TX 77098-4051Greenville Independent School District, c/o Tab Beall, Perdue Brandon Fielder Collins & Mott, PO Box 2007, Tyler, TX 75710-2007+ Grimes CAD, Lee Gordon, P O Box 1269, Round Rock, TX 78680-1269+ Guadalupe Soto, 2909 Hillcroft Avenue, Suite 575, Houston, TX 77057-5815+ Gulf Coast Repair and Machine Shop, Inc., c/o Ronald A. Simank, Schauer & Simank, P.C., 615 N. Upper Broadway, Suite 700 CorpusChristi, TX 78401-0857 + Harold Rose, III, c/o The Callahan Law Firm, Attn: Casey Brown, 440 Louisiana Street, Suite 2050 Houston, Tx 77002-1648+ Harold Rose, Jr, Attn: The Callahan Law Firm, Attn: Casey Brown, 440 Louisiana Street, Suite 2050 Houston, TX 77002-1648+ Harris CapRock Communications, Inc., c/o Curtis W. McCreight, Hoover Slovacek LLP Galleria Tower II, 5051 Westheimer, Suite 120Houston, TX 77056-5839 + Hether Bargsley, 404 North Green St., Longview, TX 75601-6405+ Holcim US, Inc. d/b/a LafargeHolcim (US), c/o Armistead M. Long, 400 E. Kaliste Saloom Road, Suite 4200, Lafayette, La 70508-8522+ Holt Texas, Ltd. dba Holt CAT, c/o Barton, East & Caldwell, P.L.L.C., 700 North St. Mary's St., Ste. 1825, San Antonio, TX 78205-354+ Hunter Stephen Kennedy, c/o Daniel JT Sciano, Tinsman & Sciano, Inc., 10107 McAllister Frwy., SAN ANTONIO, TX 78216-4648+ Iraan-Sheffield Independent School District, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, T79408-0817 + Iron Mountain Information Management, LLC, One Federal Street, 7th Floor, Boston, MA 02110-2003+ Janice Young, 101 E. Whaley St., Longview, TX 75601-6411 + Jesus Rosales, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Jimmy Hudson, Jr., Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ John Kelly, 3218 Williams Glen Drive, Sugar Land, Tx 77479-2442+ Johnson County, c/o Perdue Brandon Fielder et al, Elizabeth Banda Calvo, 500 E Border Street, Suite 640, Arlington, TX 76010-7457+ Jolene Wise United States Securities & Exchange Co, 175 W. Jackson Blvd., Suite 900, Chicago, IL 60604-2815+ Jose Murguia, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Juan Cisneros, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Juan Medrano, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Juan Patino, c/o Shaun Setareh, Suite 907, 9454 Wilshire Blvd., Beverly Hills, CA 90212-2911+ Julian Hollins, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ KPMG LLP, 700 Louisiana Street, Houston, Tx 77002-2729 + Karen, Johnnie et al Rowden, c/o David Frisby P.C., 1917 Hemphill Street, Fort Worth, TX 76110-1525+ Kenneth LeMasters, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Kern County Treasurer-Tax Collector, c/o Linda Delgado, 1115 Truxtun Avenue, 2nd Floor, Bakersfield, CA 93301-4630+ Lee County, c/o Diane W. Sanders, Linebarger Goggan Blair & Sampson, LLP, P.O. Box 17428, Austin, TX 78760-7428#+ Liberty Oilfield Services, LLC, c/o David Grant Crooks, Fox Rothschild LLP, 5420 LBJ Frwy., Suite 1200, Dallas, TX 75240-6215+ Linebarger Goggan Bl Loving County, 711 Navarro Street, Suite 300, San Antonio, TX 78205-1749+ Liquidity Solutions, Inc., 1 University Plaza, Suite 312, Hackensack, NJ 07601, UNITED STATES 07601-6205#+ MKP Enterprises, LLC d/b/a Double M Trucking, c/o Blake Hamm, Snow Spence Green LLP, 2929 Allen Parkway, Suite 2800, HoustoTX 77019-7125 + Maria Elena Soto, 2909 Hillcroft Avenue, Suite 575, Houston, TX 77057-5815+ Martin County Appraisal District, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-0+ Martin County Tax Office, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-0817+ Martin Soto, 118 W. Pecan Blvd, McAllen, TX 78501-9557 + Mathew Negrete, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Melissa Bell, 101 E. Whaley St., Longview, TX 75601-6411 + Mesquite Oil Tools, Inc., c/o Dax D. Voss, Field, Manning, Stone, Hawthorne & Aycoc, 2112 Indiana Avenue, Lubbock, TX 79410-144+ Michael Encinias, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Michigan Unemployment Insurance Agency, 3030 W. Grand Blvd., Ste. 9-600, Detroit, MI 48202-6030+ Microsoft Corporation and Microsoft Licensing GP, c/o Maria A. Milano, Riddell Williams P.S., 1001 4th Ave., Suite 4500 Seattle, WA98154-1065 + Midland CAD, Lee Gordon, P O Box 1269, Round Rock, TX 78680-1269+ Midland County, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-0817+ Midland County Utility District, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-081+ Montague County, Linebarger Goggan Blair & Sampson, LLP, c/o Elizabeth Weller, 2777 N Stemmons Frwy Ste 1000, Dallas, TX

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75207-2328 + Morgan, Lewis & Bockius, LLP, 1111 Pennsylvania Avenue NW, Washington, DC 20004-2578+ Newport Partners, Corp., 3348 Peden Road, Suite 820, Fort Worth, TX 76179-5563+ North American Sealing Solutions, LLC, c/o Craig E. Power and Misty A. Segura, 1221 Lamar Street, 16th Floor, Houston, TX 77010,UNITED STATES 77010-3039 m + Official Committee of Unsecured Creditors, Greenberg Traurig, LLP, c/o Shari L. Heyen, 1000 Louisiana Street, Suite 1700, Houston, T77002-5001 + Ogletree Deakins, Ogletree, Deakins, Nash, Smoak & Stewart, 1909 K Street, NW, Suite 1000, Washington, D.C., DC 20006-1134+ Oracle America, Inc., Buchalter Nemer, c/o Shawn M. Christiansoon, 55 Second Street, 17th Floor, San Francisco, Ca 94105-3493+ Pablo P. Gomez, c/o Walker & Patterson, P.C., P.O. Box 61301, Houston, TX 77208-1301+ Permian Equipment Rentals, LLC, P.O. Box 61730, Midland, TX 79711-1730+ Plano Machine and Instruments, Inc., Hoover Slovacek LLP, c/o Curtis W. McCreight, Galleria Tower II, 5051 Westheimer, Suite 1200Houston, TX 77056-5839 + Quellen Andrews, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Ramiro Ortiz, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047Ray Filoteo, PO Box 776, Lebec, CA 93243-0776 + Raymond Ramos, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Robert Edmundson Office of Attorney General, Penns, Office of Attorney General, Pennsylvania, 564 Forbes Avenue, Pittsburgh, PA15219-2908 + Rocking C Transport LLC, c/o Patel Gaines, PLLC, 221 West Exchange Avenue, Suite 206A, Fort Worth, TX 76164-8194+ Ruben Preciado, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Salvador Arias, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Scurry County Tax Office, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-0817+ SelecTransportation Resources, LLC, Johnson Deluca Kurisky & Gould, P.C., 1221 Lamar, Suite 1000, Houston, TX 77010-3050+ Sharp Iron Group, LLC, Hoover Slovacek LLP, c/o Curtis W. McCreight, Galleria Tower II, 5051 Westheimer, Suite 1200 Houston, TX77056-5839 sfee + Silver Oak Capital LLC, as agent and on behalf of AG Cataloochee, c/o Angelo Gordon & Co LP, 245 Park Avenue, 26th Floor New YoNY 10167-2699 #+ Smart Sand, Inc., c/o David Grant Crooks, Fox Rothschild LLP, 5420 LBJ Freeway, Suite 1200, Dallas, TX 75240-6215+ Summit Truck Group, c/o Roger S. Cox, Underwood, P.O. Box 9158, Amarillo, TX 79105-9158+ Sutton County Appraisal District, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-08+ TN Dept of Revenue, c/oTN Atty General, Bankruptcy Div, PO Box 20207, Nashville, TN 37202-4015+ TNT Ind., Inc., c/o J. Seth Moore, One Galleria Tower, 13355 Noel Rd., Ste. 1900, Dallas, TX 75240-6674+ Taylor Body Works, Inc., P.O. Box 14078, Odessa, TX 79768-4078+ Teledyne Cable Solutions, 1026 N Williamson Blvd., Daytona Beach, FL 32114-7113+ Terrell CAD, Linebarger Goggan Blair & Sampson LLP, 711 Navarro Street, Suite 300, San Antonio, TX 78205-1749+ Texas Ad Valorem Taxing Jurisdictions, c/o Lee Gordon, P.O. Box 1269, Round Rock, TX 78680-1269+ Texas Taxing Entities, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-0817Tidewater Logistics Corp., Bonds Ellis Eppich Schafer Jones, c/o H. Brandon Jones, Bonds Ellis Eppich Schafer Jones LLP, 420Throckmorton St. Suite 1000 Fort Worth, TX 76008 + Tim Smith, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Timothy Lester, 12717 US Highway 19 South, Roanoke, WV 26447-8234+ Todd Gibson, Donahoo & Associates, PC, 440 W. First Street, Suite 101, Tustin, CA 92780-3047+ Upton County Appraisal District, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-08+ Venturi Oil Tools, LLC, Attn: Ann Guilbeau, PO Box 263, Scott, LA 70583-0263+ Victoria County, c/o Diane W. Sanders, Linebarger Goggan Blair & Sampson, LLP, P.O. Box 17428, Austin, TX 78760-7428+ Walker Wilcox Matousek, LLP, 1001 McKinney St., Suite 2000, Houston, TX 77002-6439Will Cascadden, 4000, 421-7 Avenue SW, Calgary, CANADA + Wink-Loving Independent School District, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX79408-0817 + Wise County, Linebarger Goggan Blair & Sampson, LLP, c/o Elizabeth Weller, 2777 N Stemmons Frwy Ste 1000, Dallas, TX 75207-23+ Worldwide Equipment, Inc., c/o Bowery Investment Management, LLC, 1325 Avenue of the Americas, 28th Floor, New York, NY10019-6583 + XCLAIM Inc., XCLAIM Inc., 2261 Market Street #4385, San Francisco, CA 94114-1612+ Yoakum County Tax Office, C/O Laura J. Monroe, Perdue, Brandon, Fielder, Collins & Mott, PO Box 817, Lubbock, TX 79408-0817TAL: 203 tice by electronic transmission was sent to the following persons/entities by the Bankruptcy Noticing Center. ctronic transmission includes sending notices via email (Email/text and Email/PDF), and electronic data interchange (EDI). Electronic transmission is in Easterndard Time. cip ID Notice Type: Email Address Date/Time Recipient Name and Address+ Email/Text: jking@offermanking.com Jun 29 2021 20:10:00 AA Investments, LLC, c/o James W. King, 642Wellington Place, Beaumont, TX 77706-3206 + Email/Text: bnkatty@aldineisd.org

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2520 W.W. Thorne Drive, Houston, Tx 77073-3406 + Email/Text: bsearles@pierceoneill.com Jun 29 2021 20:10:00 Cabot Oil & Gas Corporation, c/o Jesse R. PiercPierce & O'Neill, LLP, 4203 Montrose Bouleva Houston, TX 77006-5427 + Email/Text: mark.weisbart@txitrustee.com Jun 29 2021 20:10:00 Clarksburg Mack Sales & Service Inc., c/o MarA. Weisbart, 12770 Coit Road, Suite 541, Dalla TX 75251-1366 + Email/Text: legal@tannorpartners.com Jun 29 2021 20:10:00 Coil Tubing Technology Inc., c/o Tannor PartneCredit Fund, LP, 555 Theodore Fremd Avenue, Suite C209, Rye, NY 10580-1437 + Email/Text: CreditNotices@contrariancapital.com Jun 29 2021 20:10:00 Custom Alloy Corporation, c/o Contrarian FundLLC, 411 West Putnam Ave, Suite 425, Greenwich, CT 06830-6263 + Email/Text: houston_bankruptcy@LGBS.com Jun 29 2021 20:11:00 Cypress Fairbanks ISD, Linebarger, Goggan, Bl& Sampson, attn: Tara L. Grundemeier, P O Bo 3064, Houston, Tx 77253-3064 Email/Text: ra-li-occ-esbkpt-hbg@pa.gov Jun 29 2021 20:10:00 Department of Labor and Industry, CollectionsSupport Unit, 651 Boas St. Room 702, Harrisbu PA 17121 + Email/Text: richard.wallace@solidcounsel.com Jun 29 2021 20:11:00 Equipment Depot, Ltd., c/o Richard J. Wallace, Scheef & Stone, LLP, 500 N. Akard, Ste. 2700, Dallas, TX 75201-3306 Email/Text: houston_bankruptcy@LGBS.com Jun 29 2021 20:11:00 Fort Bend Co WCID #02, c/o Tara L. Grundemeier, Linebarger Goggan Blair & Sampson LLP, P.O. Box 3064, Houston, TX 77253-3064 Email/Text: houston_bankruptcy@LGBS.com Jun 29 2021 20:11:00 Fort Bend County, c/o Tara L. Grundemeier, PoOffice Box 3064, Houston, TX 77253-3064 + Email/Text: ar@grayreed.com Jun 29 2021 20:10:00 Gray Reed & McGraw, P.C., Attn: Joe Virene,1300 Post Oak Blvd., Suite 2000, Houston, TX 77056-8000 + Email/Text: arapoport@haincapital.com Jun 29 2021 20:11:00 Hain Capital Group, 301 Route 17 North, 7thFloor, Rutherford, NJ 07070-2575 Email/Text: houston_bankruptcy@LGBS.com Jun 29 2021 20:11:00 Harris County, c/o Tara L. Grundemeier, PostOffice Box 3064, Houston, TX 77253-3064 + Email/Text: dallas.bankruptcy@LGBS.com Jun 29 2021 20:11:00 Hood CAD, Linebarger Goggan Blair & SampsLLP, c/o Elizabeth Weller, 2323 Bryan Street St 1600, Dallas, TX 75201-2637 Email/Text: LDRBankruptcy.EBN@la.gov Jun 29 2021 20:10:00 Louisiana Department of Revenue, BankruptcySection, Collections Division, Attn: Florence Bonaccorso-Saenz, 617 N. Third St., Office 780 Post Office Box 66658, Baton Rouge, LA 70896-6658 Email/Text: BANKRUPTCY@DOR.MS.GOV Jun 29 2021 20:11:00 Mississippi Department of Revenue, LegalDivision, Post Office Box 22828, Jackson, MS 39225-2828 Email/Text: houston_bankruptcy@LGBS.com Jun 29 2021 20:11:00 Montgomery County, c/o Tara L. Grundemeier,Post Office Box 3064, Houston, TX 77253-306 Email/Text: OT-USA-NOVBankruptcy@nov.com Jun 29 2021 20:10:00 National Oilwell Varco, L.P., 7909 ParkwoodCircle Drive, Houston, TX 77036, UNITED STATES + Email/Text: pwp@pattiprewittlaw.com Jun 29 2021 20:11:00 Natural Gas Pipeline Company of America, LLc/o Law Ofc Patricia Williams Prewitt, 10953 Vista Lake Ct., Navasota, TX 77868, UNITED STATES 77868-6981 + Email/Text: dallas.bankruptcy@LGBS.com Jun 29 2021 20:11:00 Parker CAD, Linebarger Goggan Blair & Sampson, LLP, c/o Elizabeth Weller, 2323 Brya

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Street Ste 1600, Dallas, TX 75201-2637 + Email/Text: barnetbjr@msn.com Jun 29 2021 20:11:00 Robert Nunez, c/o Barnet B. Skelton, Jr., 712 MStreet, Suite 1610, Houston, TX 77002-3264 Email/Text: legal@tannorpartners.com Jun 29 2021 20:10:00 Tannor Partners Credit Fund LP, 150 GRANDSTREET, SUITE 401, WHITE PLAINS, NY 10601 + Email/Text: tross@trcmllc.com Jun 29 2021 20:11:00 TR Capital Management, LLC, PO BOX 633,Woodmere, NY 11598-0633 + Email/Text: legal@tannorpartners.com Jun 29 2021 20:10:00 Trieagle Energy LP, c/o Tannor Partners CreditFund, LP, 555 Theodore Fremd Ave, Suite C20 Rye, NY 10580-1437 + Email/Text: dvidal@gpd.com Jun 29 2021 20:11:00 Trinity Industries Leasing Company, 2525 NortStemmons Freeway, Dallas, TX 75207-2401 TAL: 26 BYPASSED RECIPIENTS e following addresses were not sent this bankruptcy notice due to an undeliverable address, *duplicate of an address listed above, *P duplicate of aferred address, or ## out of date forwarding orders with USPS. cip ID Bypass Reason Name and Address Deirdre Carey Brown Fried, Frank, Harris, Shriver & Jacobson LLP Loeb & Loeb Aaron Hill Abel Perez, Jr. Abel Raya Adan Arroyo Alfredo De La Garza Alief Independent School District AlixPartners, LLP Alonzo McCowan American Home Assurance Company Angelo, Gordon & Co., L.P. Anthony Avila Applied Maintenance Supplies & Solutions LLC Armando Hernandez Ashland Inc Atascosa County Badger Mining Corp. Beau Pre' Holdings, LLC Bexar County, Linebarger Goggan et al Blake Swearengin Blue Ribband Holdings Limited, c/o John Cornwell, Munsch Hardt, 700 Milam Street, HoustonBradford Capital Management, LLC Brandon Hicks Brandon Whitman Brandyn Ridgeway Brian Fiamengo Brian Washington Bruckner Truck Sales, Inc. California Franchise Tax Board Carlos Gonzalez Carole Kelley Certain Texas Taxing Entities Charles Denham Charles Thompson Chemoil Corporation Cherokee Debt Acquisition, LLC City of Miami General Employees' and Sanitation Em Clinton Gentry

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Cody Rhoades Cogne Specialty Steel USA, Inc Conroe Machine, LLC Conway MacKenzie, Inc. Coors Tek, Inc. CoorsTek, Inc. Cortland Capital Market Services LLC Craig Stevens Crowley Fleck PLLP hld D.E. Shaw Galvanic Portfolios, L.L.C. and Nantahal Daniel Hurtado Daniel Jimenez Daniel Martinez Deshawn Richards Desmond Smith Dillon Thompson Dustin Moore EZE Trucking Holdings, Inc., c/o Carl Dore', Jr., Dore' Law Group, P.C., 17171 Park Row, Suite 160, Houston, UNITEDSTATES Eliseo Campos Ventura Elizabeth Neuman Emilio Barbosa Entech Consulting Corporation Eric Carr Eric Mathiesen Eric Roesler Ernest Alexander Ernesto Cruz Esteban Castillo Evercore Group L.L.C. Evercore Group LLC FMC Technologies, Inc. Fernando Carrillo Fernando Romo Fisher & Phillips LLP Francisco Chaidez Fred Reinhardt Gary Smith George Valdivia Grant Thornton LLP Greg Hines H-D Advanced Manufacturing Co. Helmer Marroquin Hernan Velasquez Hidalgo County Hose of South Texas Hunting Titan, Inc., c/o Carl Dore', Jr., Dore' Law Group, P.C., 17171 Park Row, Suite 160, HoustonIndian Creek Fabricators, Inc. Internal Revenue Service Ioka Tauanuu Irwin Debbye J.W. Hughes Excavation Inc. James Helms James Young Janice Young Jared Locarnini Jasmine Garcia Jason Harris Jason Woods Javier Andres Lopez Jeffery Irwin Jeremy Wildvank Jerome Fatulegaee

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Jim Wells CAD Joel Villanueva John Cole Johnathan Franks Jorge Hernandez Jose Garcia Jose Medina Jose Morones Jose Pompa Joshua Carter Joshua Escoto Juan Vaca Julio Moreno Justin Bish Karnes City ISD Kevin Black Kroff Well Services Inc. Lafarge North America, Inc. d/b/a LafargeHolcim US Lance Mackey Larry Gonzales Larry Tatum Lawrance Horn Liberty Mutual Insurance Company Louis Bretado M. Brandon DeMarco and Lana DeMarco MCA Mason Creek Owner LLC Mark Adams McMullen County Melissa Hopkins Miguel Angel Rodriguez Miguel Santillian Rodriguez Moises Cervantes Moody's Investors Services, Inc. NORTH PENN PIPE & SUPPLY, INC. Nabors Corporate Services, Inc. Nabors International Management Limited Natasha Pitts Nick Duke Nueces County Octavio Campuzano Pecos County Pine Tree ISD, Lee Gordon, P O Box 1269, Round Rock Plano Machine & Instrument, Inc. Plentywood Sanitation c/o SKiLs Inc. Quincy Bass R.A.M. Transit Lines Incorporated Raheem Stephens Raymond Gonzales Raymond Parker, Jr Reliance Industrial Products USA Ltd Reliance Well Services, LLC Rene Landa Richard Arzola Richard Salinas Robert Butler Robert McCowan Robert Swearengin Robin Gardiner, Amie Augenstein, 711 N. Carancahua, Ste 514, Corpus ChristiRogelio Fiscal Roy Walker Ryan Washburn SAP America Inc

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SWM International Inc. d/b/a Specialty Welding & M Sarah M Davis Scottie Payne Sean Tindell Shellist Lazarz Slobin LLP Site-West Development Southeastern Freight Lines Inc Southern Facility Services & Construction, Inc. Stanley's Machining & Tool Corporation Steering Committee of Prepetition Lenders Stotler Company, Inc. SuccessFactors Inc Texas Comptroller of Public Accounts Texas Pride Fuels, Ltd. Thomas Check Thomas Owens Tim Smith Tom Green County Appraisal District Toyota Industries Commercial Finance Tresman Latimer Tyler Michiels U.S. Energy Development Corporation Unifirst Corporation United States of America Univar USA Inc Unsecured Claims Representative Val Verde County Vernon Robert Boscher Vikki Nicole Lindsey Ward County Wells Fargo Vendor Financial Services, LLC Western States Converters & Transmissions Inc. Westland Transport, Inc. Whitebox Advisors LLC William Featherly Ziad Abu Al-Ragheb, c/o John Cornwell, Munsch Hardt, 700 Milam Street, Houston*+ C&J Energy Services Ltd., 3990 Rogerdale Road, Houston, TX 77042-5142*+ Donlin, Recano & Company, Inc., 6201 15th Avenue, Brooklyn, NY 11219-5411##+ Brandan K. Oliver, Faegr Baker Daniels, LLP, 1700 Lincoln Street, Suite 3200, Denver, CO 80203-4532##+ Katten Muchin Rosenman LLP, Houston, 1301 McKinney St Ste 3000, Houston, TX 77010-3033##+ Corre Opportunities Fund, L.P., 1370 Avenue of the Americas, 29th Floor, New York, NY 10019-4602##+ D & I Silica, LLC, Three Riverway, Suite 1350, Houston, TX 77056-1982##+ Estate of Suzzie Queue, c/o Jason Thompson, The Thompson Law Firm, 10107 McAllister Frwy., SAN ANTONIO, TX78216-4648 ##+ Gator Environmental & Rentals, Inc., c/o Tye C. Hancock, Thompson & Knight LLP, 333 Clay St., Suite 3300, Houston, TX77002-4104 ##+ Gonzales County, c/o David Aelvoet, Linebarger Goggan Blair & Sampson LLP, 711 Navarro, Ste. 300, San Antonio, TX78205-1749 ##+ PFP Industries, LLC, c/o Sears, Bennett & Gerdes, LLP, 9700 Richmond Ave., Ste. 222, Houston, TX 77042, US 77042-4625##+ ProBilling and Funding Service, c/o Bowery Investment Management, LLC, 1325 Avenue of the Americas,, 28th Floor, NewYork, NY 10019-6583 ##+ Sonar Credit Partners III, LLC, 80 Business Park Drive, Suite 208, Armonk, NY 10504-1701TAL: 201 Undeliverable, 2 Duplicate, 10 Out of date forwarding addressNOTICE CERTIFICATION Joseph Speetjens, declare under the penalty of perjury that I have sent the attached document to the above listed entitiesthe manner shown, and prepared the Certificate of Notice and that it is true and correct to the best of my information alief. eeting of Creditor Notices only (Official Form 309): Pursuant to Fed .R. Bank. P.2002(a)(1), a notice containing the

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mplete Social Security Number (SSN) of the debtor(s) was furnished to all parties listed. This official court copy containse redacted SSN as required by the bankruptcy rules and the Judiciary's privacy policies. te: Jul 01, 2021 Signature: /s/Joseph Speetjens

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