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Full title: Motion to Pay Federal Royalty Claims (21 Day Objection Language) filed by Stephen W. Sather for Trustee Ronald E Ingalls (Attachments: # 1 Proposed Order)(Sather, Stephen)

Document posted on Aug 19, 2021 in the bankruptcy, 7 pages and 0 tables.

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF TEXAS MIDLAND DIVISION IN RE: § § Case No. 19-70106-tmd Remnant Oil Company, LLC and § Case No. 19-70107-tmd Remnant Oil Operating, LLC § Chapter 7 § § (Jointly administered under § Case No. 19-70106) MOTION OF RONALD INGALLS, Comes now Ronald Ingalls, Chapter 7 Trustee of the bankruptcy estates of Remnant Oil Company, LLC and Remnant Oil Operating, LLC (the “Trustee”) in this chapter 7 case, filing his Motion of Ronald Ingalls, Chapter 7 Trustee to Pay Federal Royalty Claims, and in support thereof would respectfully show the Court as follows: 1. WHEREFORE, Ronald Ingalls, Chapter 7 Trustee of the bankruptcy estates of Remnant Oil Company, LLC and Remnant Oil Operating, LLC, respectfully requests that the Court grant this Motion and authorize him to make payment to the Office of Natural Resources Revenue in the amount of $89,818.98 and for such other and further relief to which he may be entitled at law or in equity.Bens Oilfield Services Motley Service, LLC 4411 98thy Street, Suite 400 Catherine Claire Couzzart Irrevocable Trust US Dept. of the Interior, BLM Oil and Gas Dept c/o

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF TEXAS MIDLAND DIVISION IN RE: § § Case No. 19-70106-tmd Remnant Oil Company, LLC and § Case No. 19-70107-tmd Remnant Oil Operating, LLC § Chapter 7 § § (Jointly administered under § Case No. 19-70106) MOTION OF RONALD INGALLS, CHAPTER 7 TRUSTEE TO PAY FEDERAL ROYALTY CLAIMS If you object to the relief requested, you must respond in writing, specifically answering each paragraph of this pleading. Unless otherwise directed by the court, you must file your response with the clerk of the bankruptcy court within 21 days from the date you were served with this pleading. You must serve a copy of your response on the person who sent you the notice; otherwise, the court may treat the pleading as unopposed and grant the relief requested. TO THE HONORABLE TONY M. DAVIS, UNITED STATES BANKRUPTCY JUDGE: Comes now Ronald Ingalls, Chapter 7 Trustee of the bankruptcy estates of Remnant Oil Company, LLC and Remnant Oil Operating, LLC (the “Trustee”) in this chapter 7 case, filing his Motion of Ronald Ingalls, Chapter 7 Trustee to Pay Federal Royalty Claims, and in support thereof would respectfully show the Court as follows: 1. These cases were filed under Chapter 11 on July 16, 2019. 2. The Court entered an order for joint administration on July 22, 2019. 3. On April 14, 2020, the cases were converted to Chapter 7. Ronald Ingalls has been appointed as interim Chapter 7 trustee. 4. The bankruptcy estate owned various oil and gas interests in Texas and New Mexico.

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5. The oil and gas properties were sold subsequent to the conversion of the case to Chapter 7. 6. During the Chapter 11 phase of the case, the Debtors incurred royalty obligations to the Office of Natural Resources Revenue. Payment of such amounts is required to keep the leases in good standing. 7. The Trustee’s consultants, Martindale Consultants, have reached agreement with the ONRR as to the amounts owed. As shown on the attached Exhibit A, the Estates are liable in the amount of $89,818.98. 8. Although the royalties were incurred during the Chapter 11 phase of the case, the Trustee believes that he is obligated to pay such royalties for the following reasons: a. The order selling the oil and gas leases was not free and clear of the royalty obligations. If the Trustee does not pay these obligations, the purchaser will have an indemnity claim against the estate. b. The Estate has received benefits from operating the leases, including both oil revenues and proceeds from sale of the wells. Together these benefits total $430,104.30. Payment of the royalties is a necessary cost to receive these proceeds which shall benefit the estate. WHEREFORE, Ronald Ingalls, Chapter 7 Trustee of the bankruptcy estates of Remnant Oil Company, LLC and Remnant Oil Operating, LLC, respectfully requests that the Court grant this Motion and authorize him to make payment to the Office of Natural Resources Revenue in the amount of $89,818.98 and for such other and further relief to which he may be entitled at law or in equity.

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Respectfully Submitted, BARRON & NEWBURGER, P.C. 7320 N. MoPac Expwy., Suite 400 Austin, Texas 78731 (512) 649-3243 (512) 476-9253 Facsimile By: /s/ Stephen W. Sather Stephen W. Sather (SBN. 17657520) ATTORNEY FOR TRUSTEE CERTIFICATE OF SERVICE I certify that on the 20th day of August, 2021, a true and correct copy of the above and foregoing was served by first class mail, postage prepaid, to the parties listed on the attached Master Service List and/or electronically by the Court’s ECF system to all parties registered to receive such service. _____/s/Stephen W. Sather

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Table 1 on page 4. Back to List of Tables
None Amount
None $ 2,434.88
PS111901 $ 2,542.45
PS121901 $ 3,413.38
PS012001 $ 2,481.62
PS022001 $ 2,323.43
PS032001 $ 1,244.33
PS042001 $ 669.93
Pecos Slope
None $ 15,110.02
None
RM102019 $ 11,895.91
RM112019 $ 18,882.08
RM122019 $ 14,110.63
RM012020 $ 10,919.98
RM022020 $ 10,765.80
RM032020 $ 5,312.85
RM042020 $ 2,821.71
RM052020 $ 0.00
RM062020 $ 0.00
RM072020 $ 0.00
None
None $ 74,708.96
None
None $ 89,818.98

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FIRST MASTER SERVICE LIST (June 5, 2020) United States Trustee: Professionals for Debtor (cont’d): James Rose, Bernard R. Given, II Deborah Bynum Loeb & Loeb, LLP Office of the U.S. Trustee 10100 Santa Monica Blvd, Suite 2200 903 San Jacinto Blvd., Room 230 Los Angeles, CA 90067 Austin, TX 78701 bgiven@loeb.com James.Rose@usdoj.gov deborah.a.bynum@usdoj.gov Bethany D. Simmons Loeb & Loeb, LLP Chapter 7 Trustee: 345 Park Avenue New York, NY 10154 Ronald E. Ingalls bsimmons@loeb.com PO Box 2867 Fredericksburg, TX 78624-1927 ron@ingallstrustee.com Secured Creditors: Debtor: 3-2-1 Partners, Ltd. Remnant Oil Company, LLC Thomas Howells 6 Desta Dr #5100 9706 Ruskin Circle Midland, TX 79705 Sandy, UT 84092-3569 Professionals for Trustee: Art’s Hot Oil Service, LLC Arturo R. Carrasco Principal Barbara M. Barron PO Box 188 Stephen W. Sather Lovington, NM 88260-0188 Barron & Newburger, P.C. 7320 N. Mopac Expressway Baker Hughes Oilfield Operations, LLC Greystone II, Suite 400 Will Marsh Chief Legal Officer Austin, TX 78731 PO Box 301057 bbarron@bn-lawyers.com Dallas, TX 75303-1057 ssather@bn-lawyers.com Baker Petrolite John Mosley 12645 W. Airport Blvd 3834 Spicewood Springs Road, Suite 202 Sugar Land, TX 77478-6120 Austin, TX 78759 Ben’s Oilfield Services, LLC Professionals for Debtor: Attn: Jennifer Grassham Daniel B. Besikof 2701 N. Acoma Loeb & Loeb, LLP Hobbs, NM 88240-1801 345 Park Avenue New York, NY 10154 dbesikof@loeb.com

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Secured Creditors (cont’d): Ben’s Oilfield Services, LLC c/o Traci D. Siebenlist Ben’s Oilfield Svc Llc Crenshaw Dupree & Milam LLP PO Box 2364 PO Box 64479 Hobbs, NM 88241-2364 Lubbock, TX 79464-4479 Bens Oilfield Services Motley Service, LLC 4411 98thy Street, Suite 400 Aka KLX Energy Services LLC Lubbock, TX 79424-5062 Kozyak Tropin Trockmorton 2525 Ponce De Leon, 9th Floor First Capital Bank Texas Miami, FL 33134 310 W. Wall Street, Suite 100 Midland, TX 79701-5129 New Mexico Taxation and Revenue Dept. First Capital Bank of Texas, N.A. 1100 South St. Francis Drive c/o John Massouh Santa Fe, NM 67505-4147 Sprouse Shrader Smith PLLC PO Box 15008 New Mexico Tax and Revenue Dept Amarillo, TX 79105-5008 Legal Services Bureau 1100 South St. Francis Drive Mesa Well Servicing, LP Santa Fe, NM 87505-4147 PO Box 1620 Hobbs, NM 88241-1620 New Mexico Tax and Revenue Dept. PO Box 630 Mesa Well Servicing, LP Santa Fe, NM 87504-0630 c/o Dore Rothberg McKay, P.C. 17171 Park Row, Suite 160 New Mexico Taxation and Revenue Dept. Houston, TX 77084-4927 PO Box 2308 Santa FE, NM 87504-2308 Midland County c/o Laura J. Monroe New Mexico Taxation and Revenue Dept Perdue, Brandon, Fielder, Collins & Mott PO Box 25127 PO Box 817 Santa FE, NM 87504-5127 Lubbock, TX 79408-0817 New Mexico Taxation and Revenue Dept Midland CAD Bankruptcy Section c/o Tara LeDay PO Box 8575 PO Box 1269 Albuquerque, NM 87198-8575 Round Rock, TX 78680-1269 NM Oil Conservation Division Motley Service, LLC c/o Adrienne Sandoval 2150 S. Dixie Blvd 1220 S. St. Francis Drive Odessa, TX 79766-2167 Santa Fe, NM 67505

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Secured Creditors (cont’d): Rick’s Well Service Mark Schuck Beverly Schmidt Couzzart 700 Louisiana St, Suite 4800 Irrevocable Trust Houston, TX 77002 Amarillo National Bank TTEE PO Box 1 Tessco Energy Svc., Inc. Amarillo, TX 79105-0001 PO Box 1999 Midland, TX 79702-1999 Catherine Claire Couzzart Irrevocable Trust US Dept. of the Interior, BLM Oil and Gas Dept c/o Mitchell Zeff Amarillo National Bank TTEE 1100 L. Street, NW – Room 7530 PO Box 1 Washington DC 20007 Amarillo, TX 79105-0001 Mitchell.Zeff2@usdoj.gov Margaret Francis Grace Couzzart Wildcat Oil Tools Storage Irrevocable Trust 706 N. Colorado Oil and Gas Dept Midland, TX 79701-3437 Amarillo National Bank TTEE PO Box 1 William E. Walker Living Trust Amarillo, TX 79105-0001 4849 W. Lone Mountain Road, Apt 101 Las Vegas, NV 89130

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