Case rfn Doc 19 Filed 07/15/16 Entered 07/15/16 14:42:41 Page 1 of 5

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1 Case rfn Doc 19 Filed 07/15/16 Entered 07/15/16 14:42:41 Page 1 of 5 Sam M. Stricklin TBN Laura M. Fontaine TBN TBN GRUBER ELROD JOHANSEN HAIL & SHANK LLP 1445 Ross Avenue, Suite 2500 Dallas, Texas (t) ; (f) sstricklin@ghetrial.com lfontaine@ghetrial.com mstull@ghetrial.com SPECIAL COUNSEL FOR PLAINTIFFS AND REORGANIZED DEBTORS IN THE UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION In re: CHAPTER 11 ENERGY & EXPLORATION PARTNERS, INC., et al., Debtors. 1 CASE NO (RFN) (Jointly Administered) ENERGY & EXPLORATION PARTNERS, INC., ENERGY & EXPLORATION PARTNERS, LLC, ENERGY & EXPLORATION PARTNERS OPERATING GP, LLC, AND ENERGY & EXPLORATION PARTNERS OPERATING, LP Plaintiffs, vs. ARCHROCK PARTNERS OPERATING, L.L.C.; FESCO, LTD.; HALLIBURTON ENERGY SERVICES, INC., AND KEY ENERGY SERVICES, LLC Adversary Proceeding No (RFN) 1 The Debtors/Reorganized Debtors in the chapter 11 cases are: Energy & Exploration Partners, Inc. (9466); Energy & Exploration Partners, LLC (8621); Energy & Exploration Partners Operating GP, LLC (4266); and Energy & Exploration Partners Operating, LP (4049). UNOPPOSED MOTION TO CONSOLIDATE Page 1

2 Case rfn Doc 19 Filed 07/15/16 Entered 07/15/16 14:42:41 Page 2 of 5 Defendants. UNOPPOSED MOTION TO CONSOLIDATE ADVERSARY PROCEEDINGS Debtors/Reorganized Debtors/Plaintiffs Energy & Exploration Partners, Inc., Energy & Exploration Partners, LLC, Energy & Exploration Partners Operating GP, LLC, and Energy & Exploration Partners Operating, LP (collectively, the Debtors or Plaintiffs ) hereby file this Motion to Consolidate Adversary Proceeding No , Energy & Exploration Partners, Inc., Energy & Exploration Partners, LLC, Energy & Exploration Partners Operating GP, LLC, and Energy & Exploration Partners Operating, LP v. Acid & Cementing Service, Inc., et al., and Adversary Proceeding No , Energy & Exploration Partners, Inc., Energy & Exploration Partners, LLC, Energy & Exploration Partners Operating GP, LLC, and Energy & Exploration Partners Operating, LP v. Archrock Partners Operating, L.L.C., et al., also pending before this Court, and hereby state as follows: BASIS FOR CONSOLIDATION These cases involve common questions of law and fact, making consolidation for all purposes appropriate under Federal Rule of Civil Procedure 42(a). Specifically, both of these cases are related, as they involve the same Debtors/Plaintiffs and similar Defendants, purported mineral lienholders who have asserted mineral liens against the assets of the Debtors/Plaintiffs. Likewise, Debtors/Plaintiffs in both cases seek a judgment of this Court declaring which of the Defendants, if any, holds a Senior Statutory Lien or a Junior Statutory Lien (as defined in the Debtors Third Amended Joint Plan of Reorganization with Technical and Confirmation Modifications [Dkt. No. 733] (the Plan )), confirmed on April 26, 2016, as well as the value of said liens against the Debtors properties. UNOPPOSED MOTION TO CONSOLIDATE Page 2

3 Case rfn Doc 19 Filed 07/15/16 Entered 07/15/16 14:42:41 Page 3 of 5 Moreover, the same laws in each case apply to these legal issues: Rule 7001(2) of the Federal Rules of Bankruptcy Procedure, sections 362(d), 506(a), and 541(a) of title 11 of the United States Code, and the Declaratory Judgment Act (28 U.S.C. 2201). Because both proceedings involve similar parties, the same legal issues, and virtually the same facts, the Court and the parties would benefit from consolidation. Accordingly, the parties in both cases have conferred and each of the Defendants in both proceedings that have appeared and/or answered have stated they have no opposition to the requested consolidation. Consolidation of these cases for all purposes will best serve the aims of Federal Rule of Civil Procedure 1 for the just, speedy, and inexpensive determination of every action. PRAYER Wherefore, the Debtors/Plaintiffs respectfully request that the Court consolidate Adversary Proceeding No and Adversary Proceeding No into a single case with a uniform case number. Debtors/Plaintiffs further request any other relief, at law or in equity, to which they may be justly entitled. July 15, 2016 Respectfully submitted, GRUBER ELROD JOHANSEN HAIL SHANK LLP By: /s/ Sam Stricklin (State Bar No ) Laura M. Fontaine (State Bar No ) John Machir Stull (State Bar No ) 1445 Ross Avenue, Suite 2500 Dallas, TX Telephone: Facsimile: sstricklin@getrial.com lfontaine@getrial.com mstull@getrial.com UNOPPOSED MOTION TO CONSOLIDATE Page 3

4 Case rfn Doc 19 Filed 07/15/16 Entered 07/15/16 14:42:41 Page 4 of 5 SPECIAL COUNSEL TO THE PLAINTIFFS AND REORGANIZED DEBTORS BRACEWELL LLP By: /s/ Brian C. Mitchell Brian C. Mitchell Brian C. Mitchell (State Bar No ) 1445 Ross Avenue, Suite 3800 Dallas, Texas Telephone: (214) Telecopier: (214) Brian.Mitchell@bracewelllaw.com William (Trey) Wood III (State Bar No ) 711 Louisiana, Suite 2300 Houston, Texas Telephone: (713) Facsimile: (713) Trey.Wood@bracewelllaw.com Jennifer Feldsher (admitted pro hac vice) 1251 Avenue of the Americas New York, New York Telephone: (212) Facsimile: (212) Jennifer.Feldsher@bracewelllaw.com ATTORNEYS FOR PLAINTIFFS, DEBTORS and REORGANIZED DEBTORS UNOPPOSED MOTION TO CONSOLIDATE Page 4

5 Case rfn Doc 19 Filed 07/15/16 Entered 07/15/16 14:42:41 Page 5 of 5 CERTIFICATE OF CONFERENCE I hereby certify that a conference was conducted on June 20, 2016, between counsel for the Debtors/Plaintiffs in both adversary proceedings (Brian Mitchell and Machir Stull), and counsel for each of the Defendants that have filed an answer in either of the adversary proceedings in question, and that counsel for Defendants indicated that they were unopposed to the relief sought in this Motion. Accordingly, this motion is unopposed. /s/ CERTIFICATE OF SERVICE I certify that a true and correct copy of the nearly identical pleading file in the related adversary case was served on June 22, 2016, on all parties receiving service via the Court s electronic case filing system in both adversary proceedings. For the avoidance of doubt, I also certify that a true and correct copy of this pleading was served on all parties via the Court s electronic case filing system in this adversary proceeding on July 15, /s/ UNOPPOSED MOTION TO CONSOLIDATE Page 5