Case 20-32021 Document 908 Filed in TXSB on 01/06/21 Page 1 of 3
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Case 20-32021 Document 908 Filed in TXSB on 01/06/21 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ) In re: ) Chapter 11 ) 1 WHITING PETROLEUM CORPORATION, et al., ) Case No. 20-32021 (DRJ) ) ) (Jointly Administered) Reorganized Debtors. ) ) Re: Docket Nos. 886, 887, 888, 889, 890, 892 OMNIBUS CERTIFICATE OF NO OBJECTION Pursuant to the Procedures for Complex Chapter 11 Cases in the Southern District of Texas (the “Complex Case Procedures”), the undersigned counsel for the above-captioned reorganized debtors (collectively, the “Reorganized Debtors”) certifies as follows: 1. On December 1, 2020, the Reorganized Debtors filed the following objections (collectively, the “Omnibus Objections”): The Reorganized Debtors’ Eighth Omnibus Objection to Certain Proofs of Claim (Satisfied Claims) [Docket No. 886]; The Reorganized Debtors’ Ninth Omnibus Objection to Certain Proofs of Claim (Satisfied Claims) [Docket No. 887]; The Reorganized Debtors’ Tenth Omnibus Objection to Certain Proofs of Claim (Satisfied Claims) [Docket No. 888]; The Reorganized Debtors’ Eleventh Omnibus Objection to Certain Proofs of Claim (Satisfied Claims) [Docket No. 889]; The Reorganized Debtors’ Twelfth Omnibus Objection to Certain Proofs of Claim (Duplicate Bondholder Claims) [Docket No. 890]; and 1 The Reorganized Debtors in these chapter 11 cases, along with the last four digits of each debtor’s federal tax identification number, are: Whiting Canadian Holding Company Unlimited Liability Corporation (3662); Whiting Petroleum Corporation (8515); Whiting US Holding Company (2900); Whiting Oil and Gas Corporation (8829); and Whiting Resources Corporation (1218). The location of the debtors’ service address is: 1700 Lincoln Street, Suite 4700, Denver, Colorado 80203. Case 20-32021 Document 908 Filed in TXSB on 01/06/21 Page 2 of 3 The Reorganized Debtors’ Fourteenth Omnibus Objection to Certain Proofs of Claim (Duplicate Bondholder Claims) [Docket No. 892]. 2. The deadline for parties to respond to the relief requested in the Omnibus Objections was January 4, 2021 (the “Response Deadline”). No responses to the Omnibus Objections were filed on the docket before the Response Deadline. Counsel for the Reorganized Debtors did not receive any informal responses to the Omnibus Objections. 3. The Reorganized Debtors respectfully request that the Court enter the attached proposed orders at the earliest convenience of the Court. Houston, Texas January 6, 2021 /s/ Vienna F. Anaya Matthew D. Cavenaugh (Bar No. 24062656) Jennifer F. Wertz (Bar No. 24072822) Vienna F. Anaya (Bar No. 24091225) JACKSON WALKER LLP 1401 McKinney Street, Suite 1900 Houston, Texas 77010 Telephone: (713) 752-4200 Facsimile: (713) 752-4221 Email: [email protected] Email: [email protected] Email: [email protected] Co-Counsel to the Reorganized Debtors 2 Case 20-32021 Document 908 Filed in TXSB on 01/06/21 Page 3 of 3 Certificate of Service I certify that on January 6, 2021, I caused a copy of the foregoing document to be served by the Electronic Case Filing System for the United States Bankruptcy Court for the Southern District of Texas. /s/ Vienna F. Anaya Vienna F. Anaya 3 Case 20-32021 Document 908-1 Filed in TXSB on 01/06/21 Page 1 of 15 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION ) In re: ) Chapter 11 ) WHITING PETROLEUM CORPORATION, ) Case No. 20-32021 (DRJ) et al.,1 ) ) (Jointly Administered) Reorganized Debtors. ) Re: Docket No. __ ) ORDER SUSTAINING REORGANIZED DEBTORS’ EIGHTH OMNIBUS OBJECTION TO CERTAIN PROOFS OF CLAIM (SATISFIED CLAIMS) Upon the objection (the “Objection”)2 of the above-captioned Reorganized Debtors for entry of an order (this “Order”) sustaining the Reorganized Debtors’ Eighth Omnibus Objection to certain Satisfied Claims, all as more fully set forth in the Objection; and this Court having jurisdiction over this matter pursuant to 28 U.S.C. § 1334; and this Court having found that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having found that it may enter a final order consistent with Article III of the United States Constitution; and this Court having found that venue of this proceeding and this Objection in this district is permissible pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the relief requested in the Objection is in the best interests of the Debtors’ estates, their creditors, and other parties in interest; and this Court having found that the Reorganized Debtors’ notice of the Objection and opportunity for a hearing on the Objection were appropriate under the circumstances and no other notice need be 1 The debtors in these chapter 11 cases, along with the last four digits of each debtor’s federal tax identification number, are: Whiting Canadian Holding Company Unlimited Liability Corporation (3662); Whiting Petroleum Corporation (8515); Whiting US Holding Company (2900); Whiting Oil and Gas Corporation (8829); and Whiting Resources Corporation (1218). The location of the debtors’ service address is: 1700 Lincoln Street, Suite 4700, Denver, Colorado 80203. 2 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Objection. 26930977v.4 Case 20-32021 Document 908-1 Filed in TXSB on 01/06/21 Page 2 of 15 provided; and this Court having reviewed the Objection and having heard the statements in support of the relief requested therein at a hearing before this Court (the “Hearing”); and this Court having determined that the legal and factual bases set forth in the Objection and at the Hearing establish just cause for the relief granted herein; and upon all of the proceedings had before this Court; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT: 1. The Objection is sustained as set forth herein. 2. Each Satisfied Claim identified on Exhibit A attached to this Order is disallowed and expunged in its entirety. 3. The Reorganized Debtors’ claims, noticing, and solicitation agent, Stretto, is authorized and directed to update the claims register maintained in these chapter 11 cases to reflect the relief granted in the Order. 4. To the extent a response is filed regarding any Satisfied Claim, each such Satisfied Claim, and the Objection as it pertains to such Satisfied Claim, will constitute a separate contested matter as contemplated by Bankruptcy Rule 9014. This Order will be deemed a separate order with respect to each Satisfied Claim. 5. Notwithstanding the relief granted in this Order and any actions taken pursuant to such relief, nothing in this Order shall be deemed: (a) an admission as to the validity of any prepetition claim against a Debtor entity; (b) a waiver of the Reorganized Debtors’ right to dispute any prepetition claim on any grounds; (c) a promise or requirement to pay any prepetition claim;(d) an implication or admission that any particular claim is of a type specified or defined in this Objection or any order granting the relief requested by this Objection; (e) a request or authorization to assume any prepetition agreement, contract, or lease pursuant to § 365 of the 2 26930977v.4 Case 20-32021 Document 908-1 Filed in TXSB on 01/06/21 Page 3 of 15 Bankruptcy Code; or (f) a waiver of the Reorganized Debtors’ rights under the Bankruptcy Code or any other applicable law. 6. Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this Order are immediately effective and enforceable upon its entry. 7. The Reorganized Debtors are authorized to take all actions necessary to effectuate the relief granted in this Order in accordance with the Objection. 8. This Court retains exclusive jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order. Dated: __________, 2020 Houston, Texas DAVID R. JONES UNITED STATES BANKRUPTCY JUDGE 3 26930977v.4 Case 20-32021 Document 908-1 Filed in TXSB on 01/06/21 Page 4 of 15 Exhibit A Satisfied Claims 26930977v.4 Case 20-32021 Document 908-1 Filed in TXSB on 01/06/21 Page 5 of 15 Whiting Petroleum Corporation 20-32021 (DRJ) Satisfied Claims Exhibit A DATE NAME FILED DEBTOR CLAIM # CLAIM AMOUNT REASON FOR DISALLOWANCE 1 3 FORKS SERVICES 5/6/2020 Whiting Oil and Gas S00190 $ 79,816.00 Claim satisfied via first day motion/order and subsequent PO BOX 2594 Corporation payment of Invoices by ACH900 dated 5/7/2020 and ACH3763 WILLISTON, ND 58802 dated 7/16/2020. 2 4D CONSULTING SERVICES INC 5/6/2020 Whiting Oil and Gas S00602 $ 7,920.00 Claim satisfied via first day motion/order and subsequent 2 WHITETAIL DR Corporation payment by ACH901 dated 5/7/20. COLUMBUS, MT 59019 3 4D CONSULTING SERVICES INC. 4/11/2020 Whiting Oil and Gas 42 $ 53,810.00 Claim satisfied via first day motion/order and subsequent NATHAN DAVIS Corporation payment of Invoice #1109, 1110, 1111 and 1112 by ACH160 212 MOONSTONE LANE dated 4/15/20, ACH901 dated 5/7/20 and ACH3763 dated BILLINGS, MT 59106 7/23/20. 4 4D CONSULTING SERVICES INC. 4/13/2020 Whiting Oil and Gas 46 $ 53,810.00 Claim satisfied via first day motion/order and subsequent NATHAN DAVIS Corporation payment of Invoice #1109, 1110, 1111 and 1112 by ACH160 212 MOONSTONE LANE dated 4/15/20, ACH901 dated 5/7/20 and ACH3763 dated BILLINGS, MT 59106 7/23/20. 5 ADLER TANK RENTALS 5/6/2020 Whiting Oil and Gas S00094 $ 8,427.51 Claim satisfied via first day motion/order and subsequent PO BOX 45081 Corporation payment of Invoice #242951, 4468138, 4471816 by check #1019 SAN FRANCISCO, CA 94145-0081 dated 05/07/2020. 6 AEGIS CHEMICAL SOLUTIONS 5/6/2020 Whiting Oil and Gas S00103 $ 13,739.88 Claim satisfied via first day motion/order and subsequent PO BOX 679380 Corporation payment by ACH903 dated 5/07/20 and ACH1512 dated DALLAS, TX 75267-9380 5/21/20.