Case 20-50815-CSS Doc 48 Filed 10/01/20 Page 1 of 82 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 MTE HOLDINGS LLC, et al., Case No. 19-12269 (CSS) Debtors. (Jointly Administered) BAKER HUGHES OILFIELD OPERATIONS, LLC, et al., Plaintiffs, v. Adv. Proc. No. 20-50815 (CSS) ALAMO PRESSURE PUMPING, LLC, et al., Defendants. RODAN TRANSPORT (U.S.A), LTD. D/B/A AVEDA TRANSPORTATION AND ENERGY SERVICES’ ANSWER TO PLAINTIFFS’ ORIGINAL COMPLAINT FOR DECLARATORY JUDGMENT REGARDING VALIDITY OF COMPETING M&M LIENS Rodan Transport (U.S.A), Ltd. d/b/a Aveda Transportation and Energy Services (“Aveda” or “Defendant”), by and through its undersigned counsel, hereby answers the Original Complaint for Declaratory Judgment Regarding Validity of Competing M&M Liens [Adv. D.I. 1] (the “Complaint”), filed by Baker Hughes Oilfield Operations, LLC, GE Oil & Gas Pressure Control, LP, Nabors Drilling Technologies USA, Inc., Schlumberger Technology Corporation and Smith International, Inc. (collectively “Plaintiffs”) in the above-referenced Adversary Proceeding, as follows: DMS 18110636.1 Case 20-50815-CSS Doc 48 Filed 10/01/20 Page 2 of 82 I. PARTIES Plaintiffs 1. Baker Hughes is a California limited liability company with its offices and principal place of business in Houston, Harris County, Texas. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 1 of the Complaint and therefore the allegations are denied. 2. GEO&G is a Texas limited partnership with its office and principal place of business in Houston, Harris County, Texas. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 2 of the Complaint and therefore the allegations are denied. 3. Nabors is a Texas corporation with its offices and principal place of business in Houston, Harris County, Texas. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 3 of the Complaint and therefore the allegations are denied. 4. Schlumberger is a Texas corporation with its offices and principal place of business in Houston, Harris County, Texas. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 4 of the Complaint and therefore the allegations are denied. 5. Smith is a Delaware corporation with its offices and principal place of business in Houston, Harris County, Texas. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 5 of the Complaint and therefore the allegations are denied. 2 Case 20-50815-CSS Doc 48 Filed 10/01/20 Page 3 of 82 Defendants 6. Alamo Pressure Pumping, LLC is a Texas limited-liability company and may be served with process through, its registered agent, Jeff Hansen, 1101 Little School Road, Arlington, TX 76017. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 6 of the Complaint and therefore the allegations are denied. 7. Applied US Energy, Inc. is an Ohio corporation and may be served with process through its registered agent, Cogency Global Inc., 1601 Elm Street, Suite 4360, Dallas, TX 75201. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 7 of the Complaint and therefore the allegations are denied. 8. Eastham Drilling, Inc. d/b/a Big E Drilling Co. is a Texas corporation and may be served with process through its registered agent, Lyle Eastham, 4710 Bellaire Blvd., Ste 350, Bellaire, TX 77401. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 8 of the Complaint and therefore the allegations are denied. 9. Briley Trucking, Ltd. is a Texas limited partnership and may be served with process through its registered agent, J. Chan Price, 2301 W. Francis, Midland, TX 79701. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 9 of the Complaint and therefore the allegations are denied. 10. BT Midstream, LLC is a Texas limited liability company and may be served with process through its registered agent, Gregory P. Berry, 4841 Hill Street, Abilene, TX 79602. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 10 of the Complaint and therefore the allegations are denied. 3 Case 20-50815-CSS Doc 48 Filed 10/01/20 Page 4 of 82 11. Buckeye, Inc. is a Texas corporation and may be served with process through its registered agent, Chan Price, 2301 W. Francis, Midland, TX 79701. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 11 of the Complaint and therefore the allegations are denied. 12. CSP-Permian, LLC is a Delaware limited liability company and may be served with process through its registered agent, CT Corporation System, 1999 Bryan St., Ste 900, Dallas, TX 75201-3136. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 12 of the Complaint and therefore the allegations are denied. 13. DuraChem Production Services, LLC is a Texas limited liability company and may be served with process through its registered agent, Tim Allen, 2495 N. Hwy 385, Andrews, TX 79714. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 13 of the Complaint and therefore the allegations are denied. 14. Fluid Delivery Solutions, LLC is a Texas limited liability company and may be served with-process through its registered agent, Cody Compton, 6795 Corporation Parkway, Suite 200, Fort Worth, TX 76126. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 14 of the Complaint and therefore the allegations are denied. 15. FTS International Services, LLC is a Texas limited liability company-and may be served with process through its registered agent, Capitol Corporate Services, Inc., 206 E. 9th Street, Suite 1300, Austin, TX 78701 -4411. 4 Case 20-50815-CSS Doc 48 Filed 10/01/20 Page 5 of 82 ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 15 of the Complaint and therefore the allegations are denied. 16. Hadco Services, Inc. is a Louisiana corporation and may be served with process through its registered agent, Hugh A. Brashier, 2508 E CR 120, Midland, TX 79706. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 16 of the Complaint and therefore the allegations are denied. 17. Halliburton Energy Services, Inc. is a Delaware corporation and may be served with process through its registered agent Capitol Corporate Services, Inc., 206 E. 9th Street, Suite 1300, Austin, TX 78701-4411. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 17 of the Complaint and therefore the allegations are denied. 18. Integrity Bio-Chemicals, LLC is a Delaware limited liability company and may be served with process through its registered agent, Capitol Corporate Services, Inc., 206 E. 9th Street, Suite 1300, Austin, TX 78701-4411. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 18 of the Complaint and therefore the allegations are denied. 19. JW Powerline, LLC is a Texas limited liability company and may be served with process through its registered-agent Registered Agent Solutions, Inc., 1701 Directors Blvd., Suite 300, Austin, TX 78744-0000. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 19 of the Complaint and therefore the allegations are denied. 20. L.F. Manufacturing, Inc. is a Texas corporation and may be served with process through its registered agent, Dan Edling, 5528 E. Hwy 290, Giddings, TX 78942. 5 Case 20-50815-CSS Doc 48 Filed 10/01/20 Page 6 of 82 ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 20 of the Complaint and therefore the allegations are denied. 21. McClinton Energy Group, L.L.C. is a Texas limited liability company and may be served with process through its registered agent, Tony D. McClinton, 12620 Hwy 191, Midland, TX 79707. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 21 of the Complaint and therefore the allegations are denied. 22. Meyer Energy Services, LLC is a Texas limited liability company and may be served with process through its registered agent, Jonathan Meyer, 200 Scenic Valley, Kerrville, TX 78028. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 22 of the Complaint and therefore the allegations are denied. 23. Motley Asset Management, LLC is a Texas limited liability company and may be served with process through its registered agent, Marco Davis, 8 Old Lampasas, Odessa, TX 79765. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 23 of the Complaint and therefore the allegations are denied. 24. National Oilwell DHT, L.P. is a Delaware-limited partnership and may be served with process through its registered agent, C T Corporation System, 1999 Bryan St., Ste. 900, Dallas, TX 75201-3136. ANSWER: Aveda is without sufficient knowledge or information to form a belief regarding the allegations in Paragraph 24 of the Complaint and therefore the allegations are denied. 6 Case 20-50815-CSS Doc 48 Filed 10/01/20 Page 7 of 82 25.