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(00390561).Docx Case 19-12269-CSS Doc 303 Filed 12/17/19 Page 1 of 4 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE _______________________________________ In Re: ) Chapter 11 ) MTE HOLDING LLC, et al.,1 ) Case No. 19-12269 (KBO) ) Debtors. ) (Jointly Administered) _______________________________________) Re: D.I. 212 VERIFIED STATEMENT OF MULTIPLE REPRESENTATION OF CERTAIN PARTIES-IN-INTEREST PURSUANT TO BANKRUPTCY RULE 2019 Pursuant to Bankruptcy Rule 2019 and in connection with the chapter 11 cases (the “Chapter 11 Cases”) commenced by the above-captioned debtors (the “Debtors”), McWhorter Cobb & Johnson, LLP (“MCJ”), counsel for DuraChem Production Services, LLC, ACE Tubular Services, LLC, Paladin Completion Services, LLC, Stone Oilfield Service, Inc., Stone Rentals II, LLC, Clearwater Resources, LLC, Evans Petroleum Consultants and Services, Snyper Energy Services, Inc. and Callie Stevens (collectively, “Service Provider Group”), files this Verified Statement of Multiple Representation of Certain Parties-in-Interest (“Statement”), as follows: 1. Pursuant to Rule 2019(b) and (c), below is a listing of the names, addresses, nature, amount and basis for all disclosable economic interests held in relation to the Debtors by the Service Provider Group represented by MCJ in the Chapter 11 Cases.2 Lien Claimant Well Name Lien Amount DuraChem Affirmed 6 3HM, 5H & 7H $483,059.55 DuraChem California Chrome 27 2H, 10H, & $296,845.85 12H DuraChem Copperhead 23 4H $309,835.15 DuraChem Imperial Eagle 24 1H, 2HM, 5H & $635,750.00 6H DuraChem War Admiral 24 1H, 3HM, 4H & 5H $597,162.57 Total DuraChem Secured $2,322,653.12 Claim Total DuraChem Unsecured $1,112,705.19 Claim 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are: MTE Holdings LLC (7894); MTE Partners LLC (1158); Olam Energy Resources I LLC (0770); MDC Energy LLC (9140); MDC Texas Operator LLC (1087) Ward I, LLC (6817); and MDC Reeves Energy LLC (3644). The Debtors’ address is 280 East 96th Street, Suite 210, Indianapolis, Indiana 46240. 2 MCJ does not hold any disclosable economic interests in relation to the Debtors. Case 19-12269-CSS Doc 303 Filed 12/17/19 Page 2 of 4 ACE Tubular Alysheba 18 1H & 2H $26,076.75 ACE Tubular Just Call Me Ken 2H $86,422.13 ACE Tubular Omaha 11 5H & 6H $60,901.92 ACE Tubular Whirlaway 24 1H $52,079.96 Total ACE Tubular Secured $225,489.76 Claim Total ACE Tubular 0 Unsecured Claim Paladin Completion Services A Classic Dash 18 3H $20,947.60 Paladin Completion Services Alysheba 18 1H & 2H $44,794.70 Paladin Completion Services Coppers Dream 23 1H $35,076.15 Paladin Completion Services Count Fleet 11 1H, 4H, 5H & 6H $191,269.74 Paladin Completion Services Delightful Dasher 114H $24,774.41 Paladin Completion Services Gavyns Run 23 1H $58,880.88 Paladin Completion Services Imperial Eagle 24 3HM, 4H & 5H $125,772.27 Paladin Completion Services Just Call Me Ken 2H $36,230.27 Paladin Completion Services Omaha 11 5H & 6H $109,845.61 Paladin Completion Services Rocket Wrangler 11 2H, 3H & 4H $79,846.57 Paladin Completion Services Whirlaway 24 1H $25,537.72 Total Paladin Secured Claim $752,975.92 Total Paladin Unsecured 0 Claim Stone Oilfield California Chrome 27 2H, 7H, 8HM, $9,971.58 9H & 12H Stone Oilfield Copperhead 23 2H & 4H $3,981.66 Stone Oilfield Count Fleet 11 1H & 4H $6,210.31 Stone Oilfield Imperial Eagle 24 1H, 3HM, 4H, 5H $108,900.08 & 6H Stone Oilfield Omaha 11 1H $21,381.40 Stone Oilfield Sir Barton 24 1H $3,598.24 Stone Oilfield War Admiral 24 1H & 3HM $36,014.56 Stone Oilfield Whirlaway 24 1H, 2H, 3H $56,917.06 Stone Oilfield Yucca 4H $986.70 Total Stone Oilfield Secured $243,979.93 Claim Total Stone Oilfield 0 Unsecured Claim Stone Rentals II, LLC Omaha 11 1H $4,080.02 Stone Rentals II, LLC Imperial Eagle 24 1H,2HM, 3HM, $98,559.07 {00390561.DOCX - ver} 2 Case 19-12269-CSS Doc 303 Filed 12/17/19 Page 3 of 4 5H & 6H Stone Rentals II, LLC War Admiral 24 1H & 3HM $8,585.00 Stone Rentals II, LLC Count Fleet 11 1H $2,167.50 Stone Rentals II, LLC Yucca 4H $1,976.25 Stone Rentals II, LLC California Chrome 27 9H $5,843.75 Stone Rentals II, LLC Whirlaway 24 2H $14,821.88 Stone Rentals II, LLC Sir Barton 24 1H $1,466.25 Total Stone Rentals II $137,499.72 Secured Claim Total Stone Rentals II 0 Unsecured Claim Total Clearwater Resources $2,520,106.01 Unsecured Claim Total Evans Petroleum $16,173.19 Unsecured Claim Total Snyper Energy $277,086.00 Unsecured Claim Total Callie Stevens Claim TBD 2. Unless otherwise noted, the amounts listed above are exclusive of pre-petition and post-petition interest and attorneys’ fees. In addition to the Service Provider Groups’ claims listed above are subject to further amendment and/or supplementation. 3. Disclosure regarding multiple party representation. Each creditor has received full disclosure of MCJ’s representation of multiple creditors and has been informed of the possible implications of multi-creditor representation. Each creditor has consented to multi-creditor representation by MCJ in the Chapter 11 Cases. 4. Reservation of Rights. MCJ and the Service Provider Group reserve the right to amend and/or supplement this Statement, including as set forth in Rule 2019(d). {00390561.DOCX - ver} 3 Case 19-12269-CSS Doc 303 Filed 12/17/19 Page 4 of 4 Dated: December 17, 2019 Respectfully submitted, /s/ Scott J. Leonhardt Scott J. Leonhardt (DE 4885) THE ROSNER LAW GROUP LLC 824 Market Street, Suite 810 Wilmington, Delaware 19801 (302) 777-1111 [email protected] and Todd J. Johnston McWHORTER, COBB & JOHNSON, L.L.P. P.O. Box 2547 Lubbock, Texas 79408 806-762-0214 - Telephone 806-762-8014 - Facsimile Attorneys for Service Provider Group {00390561.DOCX - ver} 4 .
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