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Full title: Final Application for Compensation for Okin Adams LLP, Debtor's Attorney, Period: 2/26/2021 to 6/30/2021, Fee: $771,812.00, Expenses: $30,857.64. Objections/Request for Hearing Due in 21 days. Filed by Attorney Okin Adams LLP (Attachments: # 1 Exhibit A - Retention Order # 2 Exhibit B - Fee and Expense Detail # 3 Proposed Order) (O'Connor, Ryan) (Entered: 08/26/2021)

Document posted on Aug 25, 2021 in the bankruptcy, 19 pages and 0 tables.

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(as amended and modified, the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-1 of the Bankruptcy Local Rules for the Southern District of Texas (the “Bankruptcy Local Rules”), the Procedures for Complex Chapter 11 Cases in the United States Bankruptcy Court for the Southern District of Texas (the “Complex Case Procedures”) and the Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases Effective as of November 1, 2013 (the “U.S. Trustee Guidelines”).On April 2, 2021, the Court entered its Order Authorizing the Employment and Retention of Okin Adams LLP As Bankruptcy Counsel for the Debtors [ECF # 140] (the “Retention Order”), a copy of which is attached hereto as Exhibit A and incorporated by reference herein.[ECF # 64-2] (the “Okin Declaration”), (i) Okin Adams is a “disinterested person” within the meaning of section 101(14) of the Bankruptcy Code, as required by section 327(a) of the Bankruptcy Code, and does not hold or represent an interest adverse to the Debtors’ estates, and (ii) Okin Adams has no connection to the Debtors, their creditors, or other parties in interest, except as disclosed in the Okin Declaration.As more fully described above, Okin Adams submits that its services to the Debtors fully warrants the final approval of all fees and payment of the outstanding fees requested herein under the twelve factors identified by the Fifth Circuit and as are awarded in similar complex cases in the Southern District of Texas pursuant to the Complex Case Procedures and U.S. Trustee Guidelines.By this Application, Okin Adams respectfully requests that the Court: (i) authorize and direct Okin Adams to draw down $130,039.00 of the remaining Retainer; and (ii) authorize and direct the Liquidating Trustee and Post-Effective Date Debtors, as applicable, to pay all remaining fees and expenses incurred during the Application Period in accordance with the provisions of the Plan less the remaining Retainer and the amounts actually paid to Okin Adams by the Debtors in accordance with the Interim Compensation Order.

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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) FINAL FEE APPLICATION COVER SHEET Name of Applicant: Okin Adams LLP
Table 1 on page 1. Back to List of Tables
Applicant’s professional role in case: Debtors’ Counsel None
Interim or Final Application: Final None
Date order of appointment signed: April 2, 2021 [ECF # 140] None
Beginning End
Time period covered by this Application: 2/26/2021 6/30/2021
Time period covered by prior Applications: N/A N/A
Total amounts awarded in all prior Applications: $0.00 None
Total fees from Petition Date through June 30, 2021: $771,812.00 None
Total professional fees requested from Petition Date
through June 30, 2021:
$771,490.00 None
Total actual professional hours from Petition Date through
June 30, 2021:
1,547.9 None
Average hourly rate for professionals covered by this
Application:
$466.66 None
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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Total paraprofessional fees requested from Petition Date $322.00 through June 30, 2021: Total actual paraprofessional hours from Petition Date 2.3 through June 30, 2021: Average hourly rate for paraprofessionals: $140.00 Reimbursable expenses sought from Petition Date through $30,857.64 June 30, 2021: Total to be paid to priority unsecured creditors: Unknown Anticipated % dividend to priority unsecured creditors: 100% Total to be paid to general unsecured creditors: Unknown Anticipated % dividend to general unsecured creditors: 10 – 20 % Date of Confirmation Hearing: N/A Indicate whether plan has been confirmed: YES ii

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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. § (Jointly Administered) FIRST AND FINAL FEE APPLICATION OF OKIN ADAMS LLP, COUNSEL FOR THE DEBTORS, FOR THE PERIOD FEBRUARY 26, 2021 THROUGH JUNE 30, 2021 THIS APPLICATION SEEKS AN ORDER THAT MAY ADVERSELY AFFECT YOU. IF YOU OPPOSE THE APPLICATION, YOU SHOULD IMMEDIATELY CONTACT THE MOVING PARTY TO RESOLVE THE DISPUTE. IF YOU AND THE MOVING PARTY CANNOT AGREE, YOU MUST FILE A RESPONSE AND SEND A COPY TO THE MOVING PARTY. YOU MUST FILE AND SERVE YOUR RESPONSE WITHIN 21 DAYS OF THE DATE THIS WAS SERVED ON YOU. YOUR RESPONSE MUST STATE WHY THE APPLICATION SHOULD NOT BE GRANTED. IF YOU DO NOT FILE A TIMELY RESPONSE, THE RELIEF MAY BE GRANTED WITHOUT FURTHER NOTICE TO YOU. IF YOU OPPOSE THE APPLICATION AND HAVE NOT REACHED AN AGREEMENT, YOU MUST ATTEND THE HEARING. UNLESS THE PARTIES AGREE OTHERWISE, THE COURT MAY CONSIDER EVIDENCE AT THE HEARING AND MAY DECIDE THE APPLICATION AT THE HEARING. REPRESENTED PARTIES SHOULD ACT THROUGH THEIR ATTORNEY. Okin Adams LLP (“Okin Adams” or “Applicant”), counsel for Castex Energy 2005 Holdco, LLC, et al., the above-captioned debtors (the “Debtors”), hereby files this First and Final Fee Application of Okin Adams LLP, Counsel for the Debtors, for the period February 26, 2021 Through June 30, 2021 (the “Application”), and in support hereof, respectfully states as follows: I. JURISDICTION AND VENUE 1. This Court has jurisdiction over this matter under 28 U.S.C. § 1334. This is a core proceeding under 28 U.S.C. § 157(b)(2)(A). Venue is proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409.

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2. This Application is made pursuant to sections 330 and 331 of title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. (as amended and modified, the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-1 of the Bankruptcy Local Rules for the Southern District of Texas (the “Bankruptcy Local Rules”), the Procedures for Complex Chapter 11 Cases in the United States Bankruptcy Court for the Southern District of Texas (the “Complex Case Procedures”) and the Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases Effective as of November 1, 2013 (the “U.S. Trustee Guidelines”). II. BACKGROUND A. General Background 3. On February 26, 2021 (the “Petition Date”), the Debtors filed voluntary petitions for relief (the “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”). 4. Pursuant to Bankruptcy Code sections 1107(a) and 1108, the Debtors operated their businesses and managed their property as debtors in possession. The United States Trustee for the Southern District of Texas appointed an Official Committee of Unsecured Creditors on March 10, 2021 [ECF # 75]. No request was made for the appointment of a trustee or examiner. 5. The Debtors were engaged in the exploration, development, production and acquisition of oil and natural gas properties located in the Gulf of Mexico, state waters of Louisiana, onshore Louisiana, and onshore Texas. As of the Petition Date, the Debtors owned interests in approximately 182 oil, gas, and related wells, and have estimated proven reserves of approximately 2.3 MMBO (oil and gas condensate) and 38.5 BCFE (natural gas). The Debtors were also a party to numerous joint operating agreements, joint development agreements, 2

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exploration agreements, and area of mutual interest agreements, and owned interests in certain fee lands. 6. On June 3, 2021, the Debtors filed their Fourth Amended Joint Chapter 11 Plan [ECF # 307] (the “Plan”). The Professional Compensation Claim Bar Date established by the Plan is sixty (60) days after the Effective Date – i.e., August 30, 2021. Accordingly, the instant Application is timely. 7. On June 7, 2021, the Court entered the Order Confirming Fourth Amended Joint Chapter 11 Plan [ECF #324] (the “Confirmation Order”).2 8. Pursuant to the Plan and Confirmation Order, the Debtors established a Professional Fee Escrow to be held in trust by the Post-Effective Date Debtors to pay Professional Compensation Claims. See Plan, Art. II.B.3. The Plan further provides that Allowed Professional Compensation Claims will be paid in cash by the Liquidating Trustee from funds held in the Professional Fee Escrow as soon as reasonably practicable after the Professional Compensation Claims are allowed and approved on final basis by the Court. Id. B. Employment and Disinterestedness of Okin Adams 7. Prior to the Petition Date, Okin Adams received an initial retainer from the Debtors in the amount of $150,000 on February 18, 2021, and $75,000 on February 26, 2021 (collectively, the “Retainer”). Immediately prior to filing the Chapter 11 Cases, Okin Adams drew down $94,961.00 from the Retainer for fees and expenses incurred prior to the Petition Date. As of the Petition Date, Okin Adams was not owed any fees and expenses by the Debtors, and $130,039.00 2 Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Plan or Confirmation Order, as applicable. 3

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of the Retainer remained in the client trust account as required by Bankruptcy Local Rule 2016-1(c). 8. On April 2, 2021, the Court entered its Order Authorizing the Employment and Retention of Okin Adams LLP As Bankruptcy Counsel for the Debtors [ECF # 140] (the “Retention Order”), a copy of which is attached hereto as Exhibit A and incorporated by reference herein. 9. To the best of the Debtors’ knowledge, and as set forth in the Retention Order and disclosed in the Declaration of Matthew S. Okin in Support of Debtors’ Application for an Order authorizing the Employment and Retention of Okin Adams LLP as Counsel for the Debtors and Statement Pursuant to Bankruptcy Rule 2016(b) [ECF # 64-2] (the “Okin Declaration”), (i) Okin Adams is a “disinterested person” within the meaning of section 101(14) of the Bankruptcy Code, as required by section 327(a) of the Bankruptcy Code, and does not hold or represent an interest adverse to the Debtors’ estates, and (ii) Okin Adams has no connection to the Debtors, their creditors, or other parties in interest, except as disclosed in the Okin Declaration. 10. Okin Adams may have in the past represented, may currently represented, and likely in the future will represent parties in interest in connection with matters unrelated to the Debtors in these Chapter 11 Cases. In the Okin Declaration, Okin Adams disclosed its connections to parties in interest that it has been able to ascertain using reasonable efforts. 11. Okin Adams performed the services for which it is seeking compensation on behalf of the Debtors and their estates, and not on behalf of any committee, creditor, or other entity. Except to the extent of the payments paid to Okin Adams that were disclosed to the Court in the Okin Declaration, Okin Adams has received no payment and no promises for payment from any 4

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source other than the Debtors for services provided or to be provided in any capacity whatsoever in connection with these Chapter 11 Cases. 12. On April 13, 2021, the Court entered its Order Approving Procedures for the Interim Compensation and Reimbursement of Expenses of Professionals [ECF # 181] (the “Interim Compensation Order”). In accordance with the Interim Compensation Order, Okin Adams has received $568,017.54 from the Debtors as of the filing of this Application for professional fees and reimbursable expenses incurred during the Chapter 11 Cases. 13. The professional services for which Okin Adams requests final allowance and compensation in this Application were performed between the Petition Date and the Effective Date of the Plan – June 30, 2021 (the “Application Period”). Accordingly, by this Application, Okin Adams seeks payment of the remaining $244,652.10, which amount represents the entire amount of unpaid fees and expenses incurred during the Application Period. 14. No agreement or understanding exists between Okin Adams and any other person with respect to the sharing of compensation sought herein, except that the compensation approved by the Court will be shared among Okin Adams’ partners, associates, and personnel as authorized under the Bankruptcy Code. III. FINAL FEE APPLICATION 15. Prior Compensation. Okin Adams has not previously filed a chapter 11 fee application for compensation in the Chapter 11 Cases. 16. Scope of Fee Application. Okin Adams makes this Application pursuant to section 331 of the Bankruptcy Code for approval of compensation for professional services rendered and for reimbursement of out-of-pocket expenses actually and necessarily incurred by Okin Adams in the representation of the Debtors during the Application Period. 5

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17. Compensation sought. From the Petition Date through the Effective Date of June 30, 2021, Okin Adams expended an aggregate total of 1,550.2 hours for professional services rendered on behalf of the Debtors. As such, Okin Adams seeks compensation for the following during the Application Period: Fees $ 771,812.00 Expenses $ 30,857.64 Application Costs $ 10,000.00 TOTAL $ 812,669.64 An accounting of the date such services were rendered and the time expended, together with a description of the services rendered by person and by date is attached hereto as Exhibit B and incorporated herein by reference. Exhibit B also contains a breakdown of the hourly rates charged by Applicant’s personnel, setting forth the number of hours expended by individual attorneys in connection with representation of the Debtors during the Application Period. 18. Expenses. From the Petition Date through June 30, 2021, Okin Adams incurred reimbursable expenses in connection with its representation of the Debtors in the amount of $30,857.64. All of these expenditures represent necessary and reasonable costs incident to the performance of Okin Adams’ services to the Debtors. The reimbursable expenses also are summarized in the attached Exhibit B. The expenses requested in the Application conform to the guidelines as found in Bankruptcy Local Rule 2016-1. 19. Total Compensation Sought. Okin Adams seeks a total final award of $812,669.64 in fees and expenses for services rendered from the Petition Date through June 30, 2021. 6

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20. Summary of Services. During the Application Period, Okin Adams performed work primarily in fourteen different areas: (1) case administration; (2) asset analysis and recovery; (3) asset disposition; (4) relief from stay/adequate protection; (5) meetings of and communications with creditors; (6) fee/employment applications; (7) fee/employment objections; (8) assumption/rejection of leases and contracts; (9) other contested matters; (10) business operations; (11) financing/cash collateral; (12) board of director matters; and (13) claims administration; and (14) plan and disclosure statement. The specific charges in each of these categories are shown on Exhibit B. The professional hours and rates per task for those categories in the Application Period are summarized below. 21. B110 – Case Administration. The work in this category involved various administrative and miscellaneous tasks performed on behalf of the Debtors. These tasks included drafting pleadings and correspondence and engaging in conversations with the client regarding first day motions and hearings, discussing case strategy, receipt and review of notices of court filings, preparation and review of the service lists, schedules and statement of financial affairs and coordination with the Debtors’ employees and other retained professionals regarding the same, drafting witness and exhibit lists, and coordinating and reviewing the Debtors’ monthly operating reports in the Chapter 11 Cases. Okin Adams billed 171.8 hours to this task code with a blended rate of $505.00 for a total amount billed of $86,744.50. 22. B120 – Asset Analysis and Recovery. This category of work involved analysis and research regarding the Debtors’ oil and gas operations and properties, as well as work related to the investigation of potential claims and causes of action against the Debtors’ directors and officers. Also included in this category is extensive work related to the Debtors’ efforts to collect estate funds from creditor Castex Energy, Inc. and preparation for a potential adversary proceeding 7

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regarding the same. Tasks related to these activities involved document review, legal research regarding D&O claims, turnover and setoff issues, and settlement negotiations and correspondence with Castex Energy, Inc. Okin Adams billed 258.1 hours to this task code with a blended rate of $511.00 for a total amount billed of $131,832.50. 23. B130 – Asset Disposition. In connection with the Debtors’ Plan and efforts to obtain creditor consensus and support regarding confirmation of the same, the Debtors disposed of certain oil and gas assets. Such transactions included transfers of certain of the Debtors’ interests in exchange for the purchasers’ assumption of the Debtors’ decommissioning and other liabilities, as well as conveyances made by the Debtors in connection with the settlement of various contested proceedings. Thus, this category includes correspondence and negotiations with the Debtors, their professionals, and interested parties regarding various assets and transactions. It also includes review of transactions documents and prosecution of motions pursuant to Bankruptcy Rule 9019 to approve and effectuate settlements in connection with those transactions. Okin Adams billed 14.6 hours to this task code with a blended rate of $516.00 for a total amount billed of $7,450.00. 24. B140 – Relief from Stay/Adequate Protection. This category of work primarily involved the drafting and prosecution of a motion to lift the automatic stay in relation to certain prepetition litigation involving Apache Corporation, and all ancillary work related thereto. Okin Adams billed 11.5 hours to this task code with a blended rate of $477.00 for a total amount billed of $5,490.00. 25. B150 – Meetings of and Communications with Creditors. The work performed in this category includes various correspondence with creditors and their counsel to discuss, inter alia, bonding issues related to the Debtors’ oil and gas assets, how the Chapter 11 Cases may affect 8

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each creditor’s claim and coordinating with the Committee regarding business operations and production of documents and data. This category also includes work related to the 341 meeting of creditors. Okin Adams billed 22.1 hours to this task code with a blended rate of $555.00 for a total amount billed of $12,275.00. 26. B160 – Fee/Employment Applications. This category involved work performed by Okin Adams with regard to preparing and prosecuting the Debtors’ various applications to retain estate professionals, and all ancillary discussions and work with the Debtors and the other retained professionals regarding fee structure and payments. The work also includes drafting a motion to establish interim compensation procedures, and preparation of monthly fee statements of professionals, as well as drafting a motion to retain and compensate ordinary course professionals. Okin Adams billed 38.2 hours to this task code with a blended rate of $413.00 for a total amount billed of $15,791.50. 27. B170 – Fee/Employment Objections. This category involved work related to the Debtors’ objection to the employment of the Committee’s financial advisor, including reviewing engagement terms, and various correspondence and discussions with Committee counsel to resolve the Debtors’ objection. Okin Adams billed 5.0 hours to this task code with a blended rate of $540.00 for a total amount billed of $2,700.00. 28. B185 – Assumption/Rejection of Leases and Contracts. The work performed in this category involves analysis of the Debtors’ executory contracts and unexpired leases in relation to the Debtors’ disposition of assets, correspondence with parties in interest regarding assumption and assignment of contracts and leases, and the preparation and filing of a motion to assume and assign contracts pursuant to section 365 of the Bankruptcy Code. Okin Adams billed 3.0 hours to this task code with a blended rate of $417.00 for a total amount billed of $1,250.00. 9

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29. B190 – Other Contested Matters. This category involved extensive work performed by Okin Adams with regard to discovery matters, subpoenas, and document production involving the Committee, including establishing and populating a database, reviewing voluminous documents for relevance, and communicating with the Debtors, their Board of Directors, and the Debtors’ other professionals regarding discovery issues. Okin Adams billed 236.6 hours to this task code with a blended rate of $423.00 for a total amount billed of $100,102.50. 30. B210 – Business Operations. The work performed in this category includes correspondence with the Debtors’ professionals and third parties regarding operational and critical vendor issues, the drafting and prosecution of various stipulations and motions pursuant to Bankruptcy Rule 9019 related to critical vendors, and various discussions with BOEM and BSEE regarding the Debtors’ operations and plugging and abandonment liabilities. Okin Adams billed 57.1 hours to this task code with a blended rate of $441.00 for a total amount billed of $25,185.00. 31. B230 – Cash Collateral/Financing. This category involved extensive work related to the preparation of the Debtors’ cash collateral motion for interim and final orders allowing the funding of the Debtors’ operations in the Chapter 11 Cases. As such, this category of work also includes negotiating with the prepetition secured lenders, the Committee and various parties in interest regarding forms of cash collateral orders and budget issues, and all work ancillary to obtain Court authority to use cash collateral. Further, this category includes review of budgets and weekly variance reports, and discussions with the Debtors regarding use of cash collateral and operational proceeds through the Effective Date of the Plan. Okin Adams billed 88.4 hours to this task code with a blended rate of $542.00 for a total amount billed of $47,897.50. 32. B260 – Board of Directors Matters. The work performed in this category related to Okin Adams’ discussions with the Debtors’ board and managers regarding strategy and 10

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administration of the Chapter 11 Cases, resolution of contested matters, and operational issues affecting the Debtors’ oil and gas assets. Okin Adams billed 13.2 hours to this task code with a blended rate of $574.00 for a total amount billed of $7,575.00. 33. B310 – Claims Administration. The work performed in this category is primarily related to analysis of the proofs of claim filed by various creditors and discussions with the Debtors and parties in interest regarding bar date issues, and claims related to the Debtors’ plugging and abandonment obligations. This category also includes work related to payments of prepetition claims of critical vendors. Okin Adams billed 30.8 hours to this task code with a blended rate of $454.00 for a total amount billed of $13,987.50. 34. B320 – Plan and Disclosure Statement. From the outset of these Chapter 11 Cases, the Debtors and their professionals were heavily focused on confirming a chapter 11 plan in the limited amount of time afforded by the milestones in the cash collateral orders. Accordingly, this category of work involved extensive efforts by Okin Adams, beginning promptly after the Petition Date and continuing through the Effective Date, to draft, negotiate, amend and finalize the chapter 11 Plan, disclosure statement, liquidating trust agreement, and all ancillary pleadings, Plan documents and transaction documents related thereto, including that certain settlement term sheet attached to the Plan and approved by the Court pursuant to the Confirmation Order. Okin Adams billed 599.8 hours to this task code with a blended rate of $523.00 for a total amount billed of $313,441.00. IV. JOHNSON FACTORS 35. Bankruptcy courts have relied upon various factors to consider in awarding compensation in a bankruptcy case. See, e.g., Johnson v. Georgia Highway Express, Inc., 874 F.2d 714 (5th Cir. 1974). Okin Adams’ fees and expenses, as requested in this Application, are 11

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reasonable based on the following considerations, as outlined in American Benefit Life Insurance Co. v. Braddock (In re First Colonial Corp. of America), 544 F.2d 1291 (5th Cir. 1977). 36. Time and Labor Required. The time spent from the Petition Date through the Effective Date in assisting, representing, and advising the Debtors in all matters concerning the Chapter 11 Cases totals 1,550.2 hours. The number of hours spent in this case was reasonable given the size of the Chapter 11 Cases and complexity of the issues therein, and in particular the issues related to negotiating and confirming the Debtors’ Plan. The detail of the specific time entries described in Exhibit B reflects the reasonableness of the compensation requested, as all of the services identified were necessary to an adequate and effective representation of the Debtors. 37. Novelty and Difficulty of Work. The Chapter 11 Cases have required Applicant to utilize its bankruptcy, financial, and litigation expertise to assist the Debtors in the administration of the Chapter 11 Cases and negotiations with numerous parties to facilitate a successful Plan confirmation and implement the liquidating trust contemplated therein. 38. Experience, Reputation, and Ability of Attorneys. Okin Adams is reputable, possesses adequate ability to perform the tasks outlined in this Application, and has represented chapter 11 debtors, creditors and committees in numerous bankruptcies similar in size to these Chapter 11 Cases. The attorneys who have provided the bulk of the services in the Chapter 11 Cases possess specialized skills in bankruptcy, business law and litigation to merit the final award of the requested fees during the Application Period. 39. Skill Required. Given the highly regulated nature of the Debtors’ business and the large number of contractual counterparties, the negotiations related to the Plan were complex, time intensive, and required a significant degree of skill and knowledge. Okin Adams believes it has demonstrated the skills required to help the Debtors realize the maximum benefit for their 12

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creditors. Ultimately, the Debtors were able to negotiate a complex, multi-party settlement that resulted in a consensual Plan that addressed the Debtors’ outstanding environmental liabilities to the satisfaction of the United States and provided a potentially modest recovery to all creditor classes. 40. Preclusion of Other Employment. Because of the time commitment involved in the Chapter 11 Cases and deadlines imposed upon Okin Adams, Okin Adams’ ability to take on other substantial engagements was limited to some degree. 41. Customary Fees. Okin Adams’ standard rates are consistent with fees charged by Okin Adams’ peers in similar cases. Okin Adams sets its fees consistent with available market data for similarly sized and situated firms given the years of experience of each attorney. Further, Okin Adams employs associates and legal assistants on this case in lieu of a single attorney, resulting in a blended rate of $498. Okin Adams’ blended rate compares favorably with hourly rates charged by local practitioners. Okin Adams further submits that the hourly rates of its professionals are not unusual given the time expended in representing the Debtors in these Chapter 11 Cases. 42. Whether the Fees are Fixed or Contingent. The fees requested in this Application were calculated at normal hourly rates charged by Okin Adams and are in line with those charged for similar work in this jurisdiction. 43. Time Limitations and Other Factors. The Debtors’ Chapter 11 Cases have been negotiated outside of the courtroom, but at times have required expedited action in certain instances throughout the Application Period. Okin Adams performed its services on an expedited or emergency basis when needed and was successful in meeting the various deadlines imposed by the Bankruptcy Code and the Court. 13

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44. Undesirability of the Case. This factor has no applicability in the Chapter 11 Cases. 45. Results Obtained. Okin Adams worked diligently with the Debtors to get the Plan confirmed and Confirmation Order entered by the Court within the strict milestones set forth in the cash collateral orders. Extensive effort was also required to get the Plan-related sale transactions closed and achieve consummation of the Plan. Notwithstanding the impediments imposed by certain parties in interest, Applicant’s efforts have enabled the Debtors to resolve outstanding case administration issues, achieve a global resolution with numerous parties, and progress toward the expeditious conclusion of these Chapter 11 Cases. 46. Nature, Length and Professional Relationship with Client. Okin Adams had no previous relationship with the Debtors prior to the preparation and filing of the Chapter 11 Cases. Okin Adams has previously represented debtors, trustees and committees of unsecured creditors in chapter 11 and chapter 7 matters. 47. Fees Awarded in Similar Cases. As more fully described above, Okin Adams submits that its services to the Debtors fully warrants the final approval of all fees and payment of the outstanding fees requested herein under the twelve factors identified by the Fifth Circuit and as are awarded in similar complex cases in the Southern District of Texas pursuant to the Complex Case Procedures and U.S. Trustee Guidelines. 48. In sum, Okin Adams respectfully submits that all professional services rendered on behalf of the Debtors in these Chapter 11 Cases for which allowance is requested were necessary and appropriate given the complexity of these Chapter 11 Cases, the time expended by Applicant, the nature and extent of Applicant’s services provided, the value of Applicant’s services, and the cost of comparable services outside of bankruptcy, all of which are relevant factors set forth in 14

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section 330 of the Bankruptcy Code. Accordingly, Okin Adams respectfully submits that approval of the compensation sought herein is warranted and should be approved. V. STATEMENT PURSUANT TO U.S. TRUSTEE GUIDELINES 49. In accordance with the U.S. Trustee Guidelines, Okin Adams respectfully states as follows:
Table 1 on page 17. Back to List of Tables
Question Response
Did Okin Adams agree to any variations from,
or alternatives to, its standard or customary
billing rates, fees or terms for services
pertaining to this engagement that were
provided during the Application Period?
No.
If the fees sought in this Application as
compared to the fees budgeted for the time
period covered by this Application are higher
by 10% or more, did you discuss the reasons
for variation with the client?
N/A.
Have any of the professionals included in this
Application varied their hourly rate based on
the geographic location of the Chapter 11
Cases?
No.
Does the Application include time or fees
relating to review, revising, or reducing time
records or preparing, reviewing or revising
invoices?
No.
Does this Application include time or fees for
reviewing time records to redact any privileged
or other confidential information?
No.
If the Application includes any rate increases
since retention, did the Debtors review and
approve those rate increases in advance? Did
the Debtors agree when retaining Okin Adams
to accept all future rate increases?
N/A.
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VI. NOTICE 50. Notice of this Application has been provided to all necessary parties in interest in accordance with the Bankruptcy Rules, Bankruptcy Local Rules, Complex Case Procedures, and the Court’s Order Granting Complex Chapter 11 Bankruptcy Case Treatment [ECF # 20]. Okin Adams respectfully submits that such notice is sufficient, and no further notice is required. VII. PAYMENT REQUEST 51. Okin Adams requests that this Court allow these fees and approve compensation by the estates on a final basis in the amount of $771,812.00 for professional fees, $30,857.64 for reimbursable expenses, and $10,000.00 in Application costs for preparing and prosecuting this Application, for a total of $812,669.64 in fees and expenses incurred from the Petition Date through the Effective Date of June 30, 2021. By this Application, Okin Adams respectfully requests that the Court: (i) authorize and direct Okin Adams to draw down $130,039.00 of the remaining Retainer; and (ii) authorize and direct the Liquidating Trustee and Post-Effective Date Debtors, as applicable, to pay all remaining fees and expenses incurred during the Application Period in accordance with the provisions of the Plan less the remaining Retainer and the amounts actually paid to Okin Adams by the Debtors in accordance with the Interim Compensation Order. VIII. CONCLUSION Based on the foregoing, Okin Adams LLP requests that this Court allow and authorize on a final basis the legal fees and reimbursable expenses incurred for the entire Application Period and grant it any other legal or equitable relief to which it may be entitled. 16

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Respectfully submitted on the 26th day of August, 2021. OKIN ADAMS LLP By: /s/ Matthew S. Okin Matthew S. Okin Texas Bar No. 00784695 Email: mokin@okinadams.com David L. Curry, Jr. Texas Bar No. 24065107 Email: dcurry@okinadams.com Ryan A. O’Connor Texas Bar No. 24098190 Email: roconnor@okinadams.com 1113 Vine St., Suite 240 Houston, Texas 77002 Tel: 713.228.4100 Fax: 888.865.2118 ATTORNEYS FOR THE DEBTORS 17

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