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Full title: Declaration re: - Declaration of Douglas J. Brickley in Support of Confirmation of Third Amended Joint Chapter 11 Plan (Filed By Castex Energy 2005 Holdco, LLC, Castex Energy 2005, LLC, Castex Energy Partners, LLC, Castex Offshore, Inc. ).(Related document(s):294 Amended Chapter 11 Plan) (O'Connor, Ryan) (Entered: 05/26/2021)

Document posted on May 25, 2021 in the bankruptcy, 17 pages and 0 tables.

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Specifically, the Debtors have obtained negotiated resolutions with the United States, the Committee, numerous Holders of Claims, and other interested parties that will relieve the Debtors’ estates of significant P&A Obligations and fund the Liquidating Trust with certain Liquidating Trust Assets.These financial commitments and undertakings set forth in the Plan, Settlement Term Sheet, and related Plan Documents demonstrate the interest and support for restructuring the Debtors’ financial affairs from various parties in interest, including the Prepetition Lenders, the United States, and the Committee.(regardless of whether such interests are held directly or indirectly), predecessors, successors, and assigns, subsidiaries, and each of their current officers, members, managers, directors, equity holders (regardless of whether such interests are held directly or indirectly), principals, members, employees, agents, managed accounts or funds, management companies, fund advisors, investment advisors, advisory board members, financial advisors, partners (including both general and limited partners), attorneys, accountants, investment bankers, consultants, representatives and other professionals, such Persons’ respective heirs, executors, estates, and nominees, in each case in their capacity as such, and any and all other Persons or entities that may purport to assert any cause of action derivatively, by or through the foregoing entities; provided, for the avoidance of doubt, John Stoika, Jonathan Wilson, Aaron Killian, Ashley Green and Castex Energy, Inc. and its Affiliates and subsidiaries, and any current or former employee, officer, director, shareholder, member, manager, director, equity holder or representative of Castex Energy, Inc. or its Affiliates or subsidiaries, in any capacity (including with respect to serving as an officer, director or employee of the Debtors), shall not be Released Parties. The Plan defines Exculpated Parties at collectively, and in each case in their capacities as such during the Chapter 11 Cases, (a) the Debtors, (b) the members of the Creditors’ Committee, if any, (c) the Prepetition Agent, (d) the Prepetition Lenders, and (e) with respect to the foregoing Persons, each of their Affiliates, and each such Entity’s directors, managers, officers, employees, attorneys, accountants, investment bankers, consultants, representatives and other professionals, in each case solely during the Chapter 11 Cases; provided, for the avoidance of doubt, John Stoika, Jonathan Wilson, Aaron Killian, Ashley Green and Castex Energy, Inc. and its Affiliates and subsidiaries, and any current or former employee, officer, director, shareholder, member, manager, director, equity holder or representative of Castex Energy, Inc. or its Affiliates or subsidiaries, in any capacity (including with respect to serving as an officer, director or employee of the Debtors), shall not be Exculpated Parties. The Debtors have worked with their

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: § § Case No. 21-30710 CASTEX ENERGY 2005 HOLDCO, § LLC, et al., § Chapter 11 § Debtors.1 § (Jointly Administered) DECLARATION OF DOUGLAS J. BRICKLEY IN SUPPORT OF CONFIRMATION OF THIRD AMENDED JOINT CHAPTER 11 PLAN Pursuant to 28 U.S.C. § 1746, I, Douglas J. Brickley, hereby submit this declaration (this “Declaration”)2 under penalty of perjury: 1. I am the Chief Restructuring Officer in the above-captioned Chapter 11 Cases, as appointed and employed by the Debtors pursuant to the Court’s order [ECF # 200]. In such capacity, I am generally familiar with the Debtors’ day-to-day operations, financial affairs, and books and records. Except as otherwise indicated herein, all facts set forth in this Declaration are based on upon my personal knowledge of the Debtors’ operations, assets, and finances, information learned from my review of relevant documents; information supplied to me by other members of the Debtors’ management and their advisors; or my opinion based on my experience, knowledge, and information concerning the Debtors’ operations, financial condition, and restructuring efforts. I am over the age of eighteen (18) and authorized to submit this Declaration on behalf of the Debtors in support of Confirmation of the Third Amended Joint Chapter 11 Plan, 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, as applicable, are: Castex Energy 2005 Holdco, LLC (6832); Castex Energy 2005, LLC (6832); Castex Energy Partners, LLC (6832); and Castex Offshore, Inc. (8432). The Debtors’ mailing address is One Memorial City Plaza, 800 Gessner Rd., Suite 925, Houston, Texas 77024. 2 Capitalized terms used in this Declaration but not defined herein shall have the meanings ascribed to them in (i) the Plan [ECF # 294] as modified and supplemented; (ii) Disclosure Statement [ECF # 206]; or (iii) the Disclosure Statement Approval Order [ECF # 214].

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as amended, supplemented, and restated from time to time. If called upon to testify, I could and would competently testify to the facts set forth herein. 2. I was engaged by the Debtors prior to the Petition Date. After the Petition Date, I was successful in negotiating and finalizing an agreement to use cash collateral and working with the Debtors’ management and retained Professionals to develop a business plan. I also helped lead the Debtors’ restructuring efforts during the Chapter 11 Cases, and was involved in negotiating and drafting the Plan, Disclosure Statement, and Liquidation Trust Agreement, among other Plan Documents. I have reviewed and am familiar with the terms and conditions of the Plan, Disclosure Statement, Liquidation Trust Agreement, and all other Plan Documents filed in connection with the Plan. I. BACKGROUND A. Introduction 3. On the Petition Date, the Debtors filed these Chapter 11 Cases under chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the Southern District of Texas, Houston Division (the “Court”). The Chapter 11 Cases have been consolidated for procedural purposes only and are being jointly administered pursuant to Bankruptcy Rule 1015(b). [ECF # 18]. 4. Since the Petition Date, the Debtors have operated their business and managed their property as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No request for the appointment of a trustee or examiner has been made in the Bankruptcy Cases. The United States Trustee for the Southern District of Texas appointed an Official Committee of Unsecured Creditors on March 10, 2021 [ECF # 75] (the “Committee”).

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B. The Debtors’ Plan 5. On March 8, 2021, the Debtors filed their Joint Chapter 11 Plan [ECF # 65] and their Disclosure Statement in Support of Joint Chapter 11 Plan [ECF # 66]. Amended versions of the Plan and Disclosure Statement were filed on April 19, 2020 [ECF #s 186 and 187, respectively] and April 22, 2021 [ECF #s 205 and 206, respectively]. The Second Amended Joint Chapter 11 Plan [ECF # 205] was solicited by the Debtors to Holders of Claims and Interests in accordance with the Court’s Order Conditionally Approving (I) Adequacy of the Disclosure Statement; (II) Form of Solicitation Materials; and (III) Procedures for Soliciting and Voting on the Joint Chapter 11 Plan [ECF # 214] (the “Disclosure Statement Approval Order”). Thereafter, the Debtors continued to negotiate with parties in interest, entered into that certain global settlement term sheet (the “Settlement Term Sheet”) and filed their Third Amended Joint Chapter 11 Plan [ECF # 294] (the “Plan”), for which they now seek Confirmation. 6. The Plan is the result of extensive, arms-length negotiations between the Debtors, the Committee, the Prepetition Lenders, Holders of Claims, the United States, and various other interested parties. The Plan and related Plan Documents were negotiated in- and out-of-Court during the Chapter 11 Cases. 7. With respect to implementing the Plan, the Debtors have achieved significant results in restructuring their financial affairs while providing for meaningful distributions to Holders of Allowed Claims by both the Post-Effective Date Debtors, and the Liquidation Trust to be established pursuant to the Plan. Specifically, the Debtors have obtained negotiated resolutions with the United States, the Committee, numerous Holders of Claims, and other interested parties that will relieve the Debtors’ estates of significant P&A Obligations and fund the Liquidating Trust with certain Liquidating Trust Assets. I believe such resolutions provide the Debtors with

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sufficient liquidity to pay accrued administrative expenses incurred during the Chapter 11 Cases, fund the Liquidating Trust, and achieve Consummation of the Plan without the need for further reorganization. Accordingly, the Plan will ensure that the Debtors or the Liquidating Trustee, as applicable, service their remaining P&A Obligations and make meaningful distributions Holders of Allowed Claims under the Plan. 8. These financial commitments and undertakings set forth in the Plan, Settlement Term Sheet, and related Plan Documents demonstrate the interest and support for restructuring the Debtors’ financial affairs from various parties in interest, including the Prepetition Lenders, the United States, and the Committee. In fact, based on my review of the Ballot Summary regarding voting on the Plan, the Prepetition Lenders, as Holders of Claims in Class 3 under the Plan, have unanimously accepted the Plan, and they have reaffirmed their votes to accept the Plan as modified and supplemented after solicitation. As a result, I believe the Plan is in the best interests of the Debtors and Holders of Claims and Interests, and should be confirmed by this Court. II. CONFIRMATION REQUIREMENTS UNDER 11 U.S.C. § 1129 9. I have worked with the Debtors’ Professionals and various creditor constituencies throughout the Chapter 11 Cases to formulate the Plan, negotiate the Settlement Term Sheet, and obtain the other financial commitments that support the Plan. Based on my understanding of the Plan, the achievements that have occurred throughout these Chapter 11 Cases, and the discussions and advice I have received from the Debtors’ Professionals concerning the requirements for confirming the Plan, I believe the Plan satisfies all the requirements of section 1129 of the Bankruptcy Code, and should therefore be confirmed.

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A. Applicable Confirmation Requirements i. 11 U.S.C. § 1129(a)(1): The Plan Complies With Title 11 10. I have been advised and have come to understand that the Plan needs to classify Claims and Interests under section 1122 of the Bankruptcy Code. The classification scheme in the Plan classifies Claims with common priority and rights against the applicable estates together. 11. To comply with section 1122, Article III of the Plan designates the following eight (8) Classes of Claims and Interests with respect to the Debtors:
Table 1 on page 5. Back to List of Tables
Class Claims and Interests Status Voting Rights
Class 1 Other Secured Claims Unimpaired No (Presumed to Accept)
Class 2 Priority Non-Tax Claims Unimpaired No (Presumed to Accept)
Class 3 Secured Debt Claims Impaired Yes
Class 4 General Unsecured Claims Impaired Yes
Class 5 Intercompany Claims Impaired No (Deemed to Reject)
Class 6 Section 510(b) Claims Impaired No (Deemed to Reject)
Class 7 Intercompany Interests Unimpaired No (Presumed to Accept)
Class 8 Existing Interests Impaired No (Deemed to Reject)
12. I have also been advised and come to understand that there are certain requirements for a Plan that are set forth in section 1123 of the Bankruptcy Code. In addressing the section 1123 requirements, Article II of the Plan provides for treatment of unclassified Claims; Article III of the Plan identifies all Claims and Interests that are Impaired and provides for treatment of Claims and Interests; Article III also provides for the same treatment of each creditor in the same Class of Claims that are Impaired under the Plan; Article IV provides for adequate means for

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implementation of the Plan; and Article V of the Plan provides for the assumption or rejection of Executory Contracts and Unexpired Leases. 13. Releases by the Debtors. I have also been advised and come to understand that the Plan meets the requirements to provide releases for the Released Parties. The Plan provides for a release of the Released Parties3 and their respective assets and properties, by the Debtors, in their respective individual capacities and as debtors-in-possession, as more fully set forth in Article VII.E of the Plan (the “Debtor Release”). 14. The Debtor Release was the product of comprehensive and arm’s-length negotiations among the Debtors, the Committee, and the Prepetition Lenders. Additionally, the Debtors’ Professionals conducted an independent evaluation of potential claims and causes of action upon my request, specifically against the directors for breach of fiduciary duties including claims for gross negligence, willful misconduct, and actual fraud. The Debtors did not discover any evidence that could support a claim for breach of fiduciary duty and/or claims for gross negligence, willful misconduct, or actual fraud. Indeed, the results of the Debtors’ investigation indicated that no successful claim or cause of action could be successfully prosecuted against the 3 The Plan defines “Released Parties” as collectively, (a) the members of the Creditors’ Committee, if any, (b) the Prepetition Agent and Prepetition Lenders, (c) Lender NewCo, (d) the Liquidating Trustee; and (e) with respect to each of the Debtors, the Post-Effective Date Debtors, and each of the foregoing Persons in clauses (a) through (d), each of their current and former Affiliates, and each such Entity’s and its current and former Affiliates’ current directors, managers, officers, equity holders (regardless of whether such interests are held directly or indirectly), predecessors, successors, and assigns, subsidiaries, and each of their current officers, members, managers, directors, equity holders (regardless of whether such interests are held directly or indirectly), principals, members, employees, agents, managed accounts or funds, management companies, fund advisors, investment advisors, advisory board members, financial advisors, partners (including both general and limited partners), attorneys, accountants, investment bankers, consultants, representatives and other professionals, such Persons’ respective heirs, executors, estates, and nominees, in each case in their capacity as such, and any and all other Persons or entities that may purport to assert any cause of action derivatively, by or through the foregoing entities; provided, for the avoidance of doubt, John Stoika, Jonathan Wilson, Aaron Killian, Ashley Green and Castex Energy, Inc. and its Affiliates and subsidiaries, and any current or former employee, officer, director, shareholder, member, manager, director, equity holder or representative of Castex Energy, Inc. or its Affiliates or subsidiaries, in any capacity (including with respect to serving as an officer, director or employee of the Debtors), shall not be Released Parties. Plan, at I.A.

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directors. Any prosecution of the Claims and Causes of Action against the Released Parties would be time-consuming and a waste of Liquidation Trust Assets that would be better used to fund potential P&A Obligations. 15. I do not believe that any valid Claims or Causes of Action exist against any of the Released Parties. Moreover, given that these Causes of Action belong to the Debtors themselves, it is plainly within the purview of the Debtors to release their own Causes of Action. Additionally, the Plan, including the Debtor Release, was negotiated by sophisticated entities that were represented by able counsel and advisors. Accordingly, the Debtor Release is fair, equitable, justified, and in the best interests of the Debtors’ estates. 16. Release by Third Parties. I have also been advised and come to understand that Article VII.F of the Plan meets the requirements of the Bankruptcy Code and case law in this circuit to provide for the release by the Releasing Parties of the Released Parties4 from all Claims and Causes of Action by Releasing Parties that do not affirmatively opt out of such release on its respective Ballot (the “Third Party Release”). I believe the Third Party Release is narrowly tailored and reflects the arm’s-length, good-faith negotiations that resulted in the Plan and global settlement with the Committee and the Prepetition Lenders, both of which are in the best interest of the Debtors, their estates and all stakeholders. 4 The Plan defines the Releasing Parties as collectively, (a) the Holders of all Claims or Interests that vote to accept the Plan in accordance with the order approving the Disclosure Statement on a conditional basis, (b) the Holders of all Claims or Interests whose vote to accept or reject the Plan is solicited but that do not vote either to accept or to reject the Plan in accordance with the order approving the Disclosure Statement on a conditional basis, (c) the Holders of all Claims or Interests that vote, or are deemed, to reject the Plan but do not opt out of granting the releases set forth herein in accordance with the order approving the Disclosure Statement on a conditional basis, and (d) the Holders of all Claims and Interests that were given notice of the opportunity to opt out of granting the releases set forth herein but did not opt out in accordance with the order approving the Disclosure Statement on a conditional basis.

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17. Further, I believe that the Third Party Release is consensual as the following language was included in all Ballots sent to the classes entitled to vote and the Notice of Consensual Releases in the Plan and Opt-Out sent to non-voting classes. ARTICLE VII OF THE PLAN CONTAINS RELEASE, EXCULPATION, AND INJUNCTION PROVISIONS, AND ARTICLE VII.F CONTAINS A THIRD-PARTY RELEASE. THUS, YOU ARE ADVISED TO REVIEW AND CONSIDER THE PLAN CAREFULLY BECAUSE YOUR RIGHTS MIGHT BE AFFECTED THEREUNDER. ALL HOLDERS OF CLAIMS OR INTERESTS THAT DO NOT (A) ELECT TO OPT OUT OF THE RELEASES CONTAINED IN THE PLAN OR (B) TIMELY FILE WITH THE BANKRUPTCY COURT ON THE DOCKET OF THE CHAPTER 11 CASES AN OBJECTION TO THE RELEASES CONTAINED IN ARTICLE VII OF THE PLAN THAT IS NOT RESOLVED BEFORE CONFIRMATION WILL BE DEEMED TO HAVE EXPRESSLY, UNCONDITIONALLY, GENERALLY, INDIVIDUALLY, AND COLLECTIVELY CONSENTED TO THE RELEASE AND DISCHARGE OF ALL CLAIMS AND CAUSES OF ACTION AGAINST THE DEBTORS AND THE RELEASED PARTIES. 18. I believe that the Holders of Claims in the Voting Classes were clearly advised of the opportunity to opt out of the Third Party Release and provided with the opportunity to act accordingly. Additionally, the Notice of Consensual Releases in the Plan and Opt-Out was mailed to all Non-Voting Classes and advised of the opportunity to opt out of the Third Party Release. 19. In addition to being consensual, I believe the Third Party Release specifically lists claims and potential Causes of Action to be release so as to put the Releasing Parties on notice of the potential claims released. Second, the Third Party Release is integral to the Plan and a condition of the comprehensive settlement therein. The Third Party Release appropriately offers certain protections to parties that constructively participated in the Debtors’ restructuring process. Third, with respect to consideration received for the Third Party Release, the directors continued to stay engaged throughout the Debtors’ Chapter 11 Cases providing significant industry knowledge and expertise that allowed the Debtors to navigate and negotiate a consensual deal

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between the Committee, the United States, and the Prepetition Lenders while providing a framework to address P&A Obligations. Additionally, the directors forwent any type of “retention” bonus for staying involved with the Debtors and providing the above-mentioned services to the Debtors. The directors merely received their standard board fee compensation which did not accurately reflect the amount of time, work, and attention the directors gave to these Chapter 11 Cases. In light of the consideration, concessions and support by the Released Parties under the Plan, the Third Party Release is appropriate and should be approved by this Court. 20. Exculpation. I have also been advised and come to understand that the Plan meets the requirements of the Bankruptcy Code and case law in this circuit to provide exculpation of the Exculpated Parties.5 I believe that the Exculpation is appropriate under applicable law because it was proposed in good faith, was formulated following extensive arm’s-length negotiations with key constituents, is a key element of the Plan, and is appropriately limited in scope, as it will have no effect on the liability of any Person or Entity that results from any such act or omission that is determined by a Final Order to have constituted actual fraud, gross negligence, willful misconduct, or criminal conduct. 21. Injunction. I have also been advised and come to understand that Article VII.D of the Plan provides for an injunction permanently enjoining all entities from (a) commencing or continuing in any manner any action or other proceeding of any kind against the Debtors or the Liquidating Trust, or their property, with respect to any such Claim, (b) the enforcement, 5 The Plan defines Exculpated Parties at collectively, and in each case in their capacities as such during the Chapter 11 Cases, (a) the Debtors, (b) the members of the Creditors’ Committee, if any, (c) the Prepetition Agent, (d) the Prepetition Lenders, and (e) with respect to the foregoing Persons, each of their Affiliates, and each such Entity’s directors, managers, officers, employees, attorneys, accountants, investment bankers, consultants, representatives and other professionals, in each case solely during the Chapter 11 Cases; provided, for the avoidance of doubt, John Stoika, Jonathan Wilson, Aaron Killian, Ashley Green and Castex Energy, Inc. and its Affiliates and subsidiaries, and any current or former employee, officer, director, shareholder, member, manager, director, equity holder or representative of Castex Energy, Inc. or its Affiliates or subsidiaries, in any capacity (including with respect to serving as an officer, director or employee of the Debtors), shall not be Exculpated Parties. Plan, at I.A.

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attachment, collection or recovery by any manner or means of any judgment, award, decree or order with respect to any such Claim against the Debtors or the Liquidating Trust, or their property, (c) creating, perfecting, or enforcing any encumbrance of any kind against the Debtors or the Liquidating Trust, or their property, with respect to such Claim, (d) asserting any right of subrogation of any kind against any obligation due to the Debtors or the Liquidating Trust, or the property of the Debtors, the Estates or the Liquidating Trust with respect to any such Claim or (e) asserting any right of setoff or recoupment against the Debtors, the Estates or the Liquidating Trust. The injunction is necessary to preserve and enforce the releases and exculpation granted by the Plan and is narrowly tailored to achieve that purpose. ii. 11 U.S.C. § 1129(a)(2): Plan Proponent’s Compliance with Title 11 22. The Debtors have operated their business under Court supervision during the Chapter 11 Cases, and all of the Debtors’ actions were closely monitored by the Committee and Prepetition Lenders. The Debtors have worked with their Professionals to make sure the Debtors have complied with orders entered by the Court and the various provisions of the Bankruptcy Code. Specifically, the Debtors obtained the Court’s conditional approval of the Disclosure Statement before soliciting acceptances or rejections of the Plan. In accordance with the solicitation procedures set forth in the Disclosure Statement Approval Order, the Debtors served copies of the Plan, the Disclosure Statement, the General Notice, and the approved Ballots to all Holders of Claims and Interests in the Voting Classes. Additionally, the Debtors served a Notice of Consensual Releases in the Plan and Opt-Out and provided an opportunity for non-voting creditors to indicate their assent or opposition to the Plan releases in accordance with the Procedures for Complex Chapter 11 Cases in the Southern District of Texas.

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iii. 11 U.S.C. § 1129(a)(3): Plan is Proposed in Good Faith 23. As set forth above, the Plan proposed by the Debtors is the result of extensive arm’s-length negotiations with the Prepetition Lenders, the Committee, the United States, and other interested parties. The Plan has not been proposed by any means forbidden by law or for any improper purpose. The actions contemplated by the Plan are necessary to achieve the restructuring described by the Plan under the Debtors’ financial circumstances, and will provide the Debtors with the best solution for exiting from the Chapter 11 Cases and adequately meeting their future obligations, as applicable. As a result, I believe the Debtors have proposed the Plan in good faith and with the legitimate and honest purposes of restructuring their financial affairs to provide recoveries to Holders of Allowed Claims under the Plan. iv. 11 U.S.C. § 1129(a)(4): Disclosure and Approval of Payments 24. All fees and expenses incurred by Professionals in these Chapter 11 Cases prior to the Confirmation Date, including any compensation paid by the Debtors pursuant to the Court’s Order Approving Procedures for the Interim Compensation and Reimbursement of Expenses of Professionals [ECF # 181], will be subject to the final approval of the Court. Pursuant to Article II.B of the Plan, requests for payment of Professional Compensation Claims must be filed with the Court on or before sixty (60) days after the Effective Date of the Plan. The Plan further provides that only the amount of the Professional Compensation Claims that are ultimately Allowed by the Court will be paid. 25. As set forth in the proposed Confirmation Order, with respect to fees and expenses incurred after the Confirmation Date, the Debtors will pay the reasonable and documented legal fees and expenses of Professionals related to implementation of the Plan and Consummation incurred by the Debtors from and after the Confirmation Date in the ordinary course without any

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further notice or approval of the Court. Accordingly, any payment made or to be made by the Debtors for services or for costs and expenses incurred in connection with the Chapter 11 Cases, or in connection with the Plan and incident to the Chapter 11 Cases, has been approved by, or will be subject to the approval of, the Court as reasonable. v. 11 U.S.C. § 1129(a)(5): Disclosure of Management and Payments to Insiders 26. The Debtors have adequately disclosed the identities of the directors and officers who are Insiders of the Debtors. Article IV.B of the Plan provides that, on the Effective Date, the Chief Restructuring Officer of the Debtors shall be discharged and released from any further obligation or duty to the Debtors. After the Effective Date, the Liquidating Trustee shall have the sole authority to manage the operations of the Post-Effective Date Debtors and wind up the affairs of the Debtors. vi. 11 U.S.C. § 1129(a)(6): Regulatory Rate Approval 27. The Debtors’ businesses do not involve the establishment of rates over which any governmental regulatory commission has or will have jurisdiction after Confirmation of the Plan. vii. 11 U.S.C. § 1129(a)(7): Best Interest of Creditors Test 28. I have reviewed the Debtors’ Schedules and estimated the liquidation value of the Debtors’ assets in a hypothetical Chapter 7 liquidation. Due to the Prepetition Lenders’ liens and security interests in substantially all assets of the Debtors and the amount of the Secured Debt Claim ($199,585,956) coupled with the limited value of the Debtors’ assets, the recovery available to unsecured creditors, including the Prepetition Lenders’ deficiency claim,6 would be minimal. Therefore, the distribution of value to Holders of Allowed Claims under the Plan is significantly higher than those creditors would receive in a chapter 7 liquidation of the Debtors. 6 The Prepetition Lenders are waiving their deficiency claim under the Plan contributing to a higher recovery for general unsecured claims.

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viii. 11 U.S.C. § 1129(a)(8): Acceptance of Plan By All Classes 29. Article III of the Plan provides that Claims in Classes 3 and 4 are Impaired under the Plan. I have reviewed the Ballot Summary with respect to voting on the Plan. Class 3 voted unanimously to accept the Plan, and all Holders of Secured Debt Claims in Class 3 reaffirmed their votes to accept the Plan as amended, modified, and supplemented after solicitation, including with respect to the Settlement Term Sheet. Holders of General Unsecured Claims in Class 4 voted to reject the Plan. Accordingly, the Debtors seek Confirmation of the Plan under section 1129(b) of the Bankruptcy Code, as described in further detail below. ix. 11 U.S.C. § 1129(a)(9): Treatment of Priority Claims 30. I have been advised and come to understand that the Bankruptcy Code requires certain treatment of priority claims. Under Article II.A of the Plan, and except as otherwise provided in the Bar Date Order or agreed to by the Holder of an Allowed Administrative Claim, all Holders of Allowed Administrative Claims will be paid an amount of Cash equal to the amount of their Allowed Administrative Claims. Article II.D of the Plan provides that Allowed Priority Tax Claims will be treated in accordance with section 1129(a)(9)(C) of the Bankruptcy Code, except to the extent that a Holder of an Allowed Priority Tax Claim agrees to less favorable treatment. Finally, under Article III.C.2 of the Plan, Holders of Allowed Priority Non-Tax Claims will be paid in full in Cash or such other treatment as is consistent with the requirements of section 1129(a)(9) of the Bankruptcy Code, except to the extent that a Holder of an Allowed Priority Non-Tax Claim agrees to a less favorable treatment. x. 11 U.S.C. § 1129(a)(10): Acceptance of Plan by Impaired Classes 31. Pursuant to Article III of the Plan, Classes 3, 4, 5, 6 and 8 are Impaired under the Plan. As stated above, I have reviewed the Ballot Summary with respect to voting on the Plan.

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Holders of Secured Debt Claims in Class 3 voted unanimously to accept the Plan. Holders of General Unsecured Claims voted to reject the Plan. No Ballots were received for Claims or Interests in Class 5, 6, or 8. xi. 11 U.S.C. § 1129(a)(11): Feasibility of the Plan 32. Based on the terms of the Plan, the agreements with various parties in interest incorporated into the Plan, and the Debtors’ own projections, I believe the Plan is feasible and not likely to be followed by a chapter 7 liquidation or need for further reorganization of the Debtors. The Debtors have worked with their advisors to develop a comprehensive business plan and strategy that contemplates conservative, achievable targets and allows the Debtors, Post-Effective Date Debtors, or Liquidating Trustee, as applicable, to make the applicable distributions to Holders of Allowed Claims in accordance with their Claims administration responsibilities under the Plan. The actions contemplated by the Plan and Plan Documents, including the funding of the Liquidating Trust Assets, take into account the Debtors’ sources and uses of funds and revenues from operations. Accordingly, the Plan is feasible and allows the Debtors to have the necessary liquidity and cash flow to exit the Chapter 11 Cases as Post-Effective Date Debtors. xii. 11 U.S.C. § 1129(a)(12): Payment of All Bankruptcy Fees 33. Article XI.B of the Plan provides that, until the Chapter 11 Cases are closed, all fees incurred under 28 U.S.C. § 1930(a) will be paid by the Liquidating Trust for each quarter, including any fraction thereof. xiii. 11 U.S.C. § 1129(a)(13): Continuation of Retiree Benefits 34. The Debtors do not maintain a retirement plan as defined by section 1114 of the Bankruptcy Code, and therefore the Plan does not require the payment of retiree benefits.

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xiv. 11 U.S.C. § 1129(a)(14): Domestic Support Obligations 35. The Debtors are not required to pay any domestic support obligations, either under a judicial or administrative order or by statute, and therefore section 1129(a)(14) of the Bankruptcy Code is inapplicable. xv. 11 U.S.C. § 1129(a)(15): Objection to Plan Confirmation by a Holder of an Unsecured Claim 36. The Debtors are not individuals, and therefore section 1129(a)(15) of the Bankruptcy Code is inapplicable. xvi. 11 U.S.C. § 1129(a)(16): Restrictions on Transfers of Property by Nonprofit Entities 37. The Debtors operate as moneyed, for-profit businesses, and therefore section 1129(a)(16) of the Bankruptcy Code is inapplicable. xvii. 11 U.S.C. § 1129(b) 38. I have been advised and come to understand that section 1129(b) of the Bankruptcy Code requires that a plan be fair and equitable, and not discriminate unfairly with respect to each class of claims or interests that is impaired under, and has not accepted the plan. As described in Section XX.B of the Debtors’ Disclosure Statement, the Debtors’ Plan satisfies these requirements. Specifically, the Plan is fair and equitable to the extent that the Holder of any Claim or Interest that is junior to the Claims of such Class will not receive or retain any property under the Plan on account of such junior Claim or Interest. Further, as described herein, the Plan does not unfairly discriminate with respect to any Class of Claims or Interests because no Class is afforded treatment which is disproportionate to the treatment afforded other Classes of equal rank. Accordingly, based on the advice I received from the Debtors’ Professionals and my experience as an estate fiduciary in other chapter 11 bankruptcy cases, I do believe that the Plan meets requirements to

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effect a “cramdown” consistent with the provisions of section 1129 of the Bankruptcy Code, notwithstanding the non-acceptance by Impaired Classes, and specifically General Unsecured Claims within Class 4. xviii. 11 U.S.C. § 1129(c) 39. The Plan is a joint plan for the Debtors, and is the only plan filed by any party in these Chapter 11 Cases. xix. 11 U.S.C. § 1129(d) 40. The primary purpose of the Plan is not avoidance of taxes or avoidance of the requirements of securities laws. There have been no objections filed by any Governmental Unit asserting such purpose. xx. 11 U.S.C. § 1129(e) 41. The Debtors’ Chapter 11 Cases are not “small business cases” within the meaning of the Bankruptcy Code. B. Conclusion 42. In light of the foregoing, I believe the Debtors have demonstrated the Plan provisions comply with the applicable provisions of the Bankruptcy Code and Bankruptcy Rules, including sections 1122, 1123, and 1129 of the Bankruptcy Code. Accordingly, the Plan is reasonable and appropriate, and should be confirmed by the Court. III. EXECUTORY CONTRACTS AND UNEXPIRED LEASES 43. I have consulted with the Debtors’ Professionals and management representatives regarding all of the Debtors’ Executory Contracts and Unexpired Leases to determine which Executory Contracts and Unexpired Leases are necessary for the Post-Effective Date Debtors’ operations. The results are set forth in the Schedule of Assumed Contracts filed by the Debtors in

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the Plan Supplement and attached as an Exhibit to the Plan, as may be modified and supplemented. With regard to all Executory Contracts and Unexpired Leases excluded from the Debtors’ Schedule of Assumed Contracts, the Debtors determined that such agreements were overly burdensome and no longer necessary for the Post-Effective Date Debtors in connection with their businesses and should therefore be rejected. 44. The Debtors’ decisions regarding which Executory Contracts and Unexpired Leases to assume or reject constitutes a sound exercise of their business judgement, and such assumptions or rejections should therefore be approved by the Court. I declare under penalty of perjury that all of the foregoing statements in the Declaration are true and correct. Dated: May 26, 2021. CASTEX ENERGY 2005 HOLDCO, LLC, et al. By: /s/ Douglas J. Brickley Douglas J. Brickley Chief Restructuring Officer

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