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Full title: Supplemental Notice of Perfection of Mechanic's Lien by Danos LLC Pursuant to 11 U.S.C. 546(B)(2). (Related document(s):299 Notice) Filed by Danos LLC (Attachments: # 1 Exhibit A # 2 Exhibit B) (Young-John, Megan) (Entered: 06/10/2021)

Document posted on Jun 9, 2021 in the bankruptcy, 4 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

[Relates to Docket No. 299] Danos LLC f/k/a Danos & Curole Marine Contractors, LLC (“Danos”), by and through the undersigned counsel, hereby supplements the Notice of Perfection of Mechanic’s Lien by Danos LLC Pursuant to 11 U.S.C. § 546(b)(2) at Docket No.The rights and powers of a trustee under sections 544, 545, and 549 of this title are subject to any generally applicable law that— (A) permits perfection of an interest in property to be effective against an entity that acquires rights in such property before the date of perfection; or (B) provides for the maintenance or continuation of perfection of an interest in property to be effective against an entity that acquires rights in such property before the date on which action is taken to effect such maintenance or continuation.Accordingly, when applicable law requires seizure of property or commencement of an action to accomplish perfection, or maintenance or continuation of perfection of an interest in property, the claimant may file a notice with the Bankruptcy Court, in lieu of such seizure or commencement.Pursuant to 11 U.S.C. §546(b)(2), Danos hereby provides notice to the Debtors, the Debtors’ counsel, the Office of the United States Trustee, and other parties in interest, of Danos’ rights as a perfected lienholder in the improvements to the offshore rigs pursuant to the Louisiana mineral property mechanic’s lien law.Accordingly, by reason of this Notice, the Debtors and other parties in interest are estopped from claiming that enforcement of Danos’ mineral lien was not timely commenced pursuant to applicable state law.

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION § In re: § Chapter 11 § CASTEX ENERGY 2005 HOLDCO, LLC, § Case No. 21-30710 (MI) et al., § § (Jointly Administered) Debtors.1 § SUPPLEMENTAL NOTICE OF PERFECTION OF MECHANIC’S LIEN BY DANOS LLC PURSUANT TO 11 U.S.C § 546(B)(2) [Relates to Docket No. 299] Danos LLC f/k/a Danos & Curole Marine Contractors, LLC (“Danos”), by and through the undersigned counsel, hereby supplements the Notice of Perfection of Mechanic’s Lien by Danos LLC Pursuant to 11 U.S.C. § 546(b)(2) at Docket No. 299 (the “Original Notice”) that Danos filed on May 27, 2021 and provides notice of its rights as a lienholder and intent to take action to continue perfection of its mineral lien under 11 U.S.C. §§ 362(b)(3) and 546(b)(2). 1. In the Original Notice, Danos provided notice for a lien affidavit that had been recorded in Vermilion Parish, Louisiana for a total of $303,731.26 (the “Original Lien Affidavit”). Danos also filed lien affidavits in Plaquemines and Terrebonne Parishes, Louisiana for a total of $5,029.27 for which Danos is now providing notice. True and correct copies of the lien affidavits recorded in Plaquemines and Terrebonne Parish in the State of Louisiana are attached hereto as Exhibit A and Exhibit B, respectively (collectively, the “Supplemental Lien Affidavits”). 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.

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2. Section 546(b) of chapter 11 of Title 11 of the United States Code (the “Bankruptcy Code”) provides that: The rights and powers of a trustee under sections 544, 545, and 549 of this title are subject to any generally applicable law that— (A) permits perfection of an interest in property to be effective against an entity that acquires rights in such property before the date of perfection; or (B) provides for the maintenance or continuation of perfection of an interest in property to be effective against an entity that acquires rights in such property before the date on which action is taken to effect such maintenance or continuation. 3. Accordingly, when applicable law requires seizure of property or commencement of an action to accomplish perfection, or maintenance or continuation of perfection of an interest in property, the claimant may file a notice with the Bankruptcy Court, in lieu of such seizure or commencement. When work occurs on the Outer Continental Shelf, the law of the adjacent state applies. In this case, Louisiana state law applies to Danos’ work performed in the Gulf of Mexico. World Hospitality, Ltd. v. Shell Offshore, Inc., 699 F. Supp. 111 (S.D. Tex. 1988) (holding that based on the “Outer Continental Shelf Lands Act’s importation of adjacent ‐ state law to perfect a supplier’s lien on an owner’s mineral leasehold interest”); Union Texas Petroleum Corp. v. PLT Engineering, Inc., 895 F.2d. 1043, 1050 (5th Cir. 1990) (holding that the Outer Continental Lands Act’s “[c]ongressionally mandated choice of law provision requiring that the substantive law of the adjacent state is to apply even in the presence of a choice of law provision in the contract to the contrary”). 4. In this case, Danos has statutory mineral liens for the labor performed on the Debtors’ production platforms. Danos completed its work within the statutorily permissible time to record its liens and/or the filing of this notice. La. R.S., 9:4865 (“one hundred-eighty days after the last activity or event which gives rise to the privilege” claimant must file “a statement of

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privilege in the mortgage records of the parish where the operating interest subject to the privilege is located”). Pursuant to the Original Lien Affidavit and the Supplemental Lien Affidavits, the amount due and owing to Danos up and through the Petition Date is at least $308,760.53. The scope of work was performed in accordance with the contract and pursuant to the Debtors’ specifications. 5. Pursuant to 11 U.S.C. §546(b)(2), Danos hereby provides notice to the Debtors, the Debtors’ counsel, the Office of the United States Trustee, and other parties in interest, of Danos’ rights as a perfected lienholder in the improvements to the offshore rigs pursuant to the Louisiana mineral property mechanic’s lien law. La. R.S., 9:4862, et seq. 6. Danos is filing this notice to preserve, perfect, maintain and continue its rights to assert a lien under Louisiana state law in order to comply with the requirements of Louisiana’s oil well lien act and Section 546(b)(2) of the Bankruptcy Code. This notice constitutes the legal equivalent of having recorded a mineral lien in the recorder’s office for the parish where the property in question is located. Accordingly, by reason of this Notice, the Debtors and other parties in interest are estopped from claiming that enforcement of Danos’ mineral lien was not timely commenced pursuant to applicable state law. Danos intends to enforce its rights to the fullest extent permitted by applicable law. 7. The filing of this notice shall not be deemed to be a waiver of Danos’ rights it exercised to record its lien as an exception to the stay pursuant to section 362(b)(3) of the Bankruptcy Code. The Bankruptcy Code excludes from the automatic stay “any act to perfect, or to maintain or continue the perfection of, an interest in property to the extent that the trustee’s rights and powers are subject to such perfection under section 546(b) of this title or to the extent that such act is accomplished within the period provided under section 547(e)(2)(A) of this title.”

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8. The filing of this notice shall further not be construed as an admission that such filing is required under the Bankruptcy Code, Louisiana state law, or any other applicable law. Danos reserves all rights to amend and/or supplement this notice as necessary. Dated: June 10, 2021 Houston, Texas PORTER HEDGES LLP By: /s/ Megan Young-John Megan Young-John (TX 24088700) 1000 Main St., 36th Floor Houston, Texas 77002 Telephone: (713) 226-6000 Facsimile: (713) 226-6248 myoungjohn@porterhedges.com COUNSEL FOR DANOS LLC

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