Case Document 1215 Filed in TXSB on 07/31/17 Page 1 of 6

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1 Case Document 1215 Filed in TXSB on 07/31/17 Page 1 of 6 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION IN RE VA:\TGVARD LLC, et al,1 NATURAL RESOURCES, Debtor's CHAD LOGSDON and.julie LOGSDON, Individually and as Next Friends of COLE LOGSDON, a Minor Child, ZACH LOGSDON and ALEX LOGSDON, Movants, VS..JUAN FRANCISCO LONGORIA, EAGLE ROCK ENERGY, LP, EAGLE ROCK ENERGY G&P LLC; REGENCY FIELD SERVICES, LLC; and VANGUARD VANGUARD NATURAL RESOURCES, LLC Defendants. CASE NO (Chapter 11 (Jointly Administered AGREED \HTION OF CHAD LOGSDON AND JULIE LOGSDON, INDIVIDUALLY AND AS NEXT FRIENDS OF COLE LOGSDON, A MINOR CHILD, ZACH LOGSDON AND ALEX LOGSDON FOR ENTRY OF STIPULATION AND AGREED ORDER GRANTING RELIEF FROM THE AUTOMATIC STAY This is a Motion for Relief from the Automatic Stay. If it is granted, the Movant may act outside of the bankruptcy process. If you do not want the stay lifted, immediately contact the moving part' to settle. If you cannot settle, you must file a response and send a copy to the moving part' at least 7 days before the hearing. If you cannot settle, you must attend the hearing. Evidence may be offered at the hearing and the Court may rule. Represented parties should act through their attorney. I The Debtors in these chapter II cases. along with the last four digits of each Debtor's federal tax identification number. as applicable. are: Vanguard :'\atural Resources, LLC (I 161: Eagle Rock Acquisition Partnership. L.P. (6706: Eagle Rock Acquisition Partnership II. L.P. (0903: Eagle Rock Energy Acquisition Co., Inc. (4564: Eagle Rock Energy Acquisition Co. II. Inc. (3:164: t:agle Rock L'pstrcarn Development Company, Inc. (0113: Eagle Rock L'pstrcam Development Company II. Inc. (7453; Encore Clear fork Pipeline I.I.C (2032; Escambia Asset Co.. LLC (3869; Escambia Operating Co. LI.C (20(O: Vanguard :'\atural Cas, LLC (1004; Vanguard Operating, LLC (9331: \':,\R Finance corp. (1494: V:,\R Holdings. I.I.C (6371: The location of the Debtors' service address is: 5847 San Felipe. Suite Houston. Texas

2 Case Document 1215 Filed in TXSB on 07/31/17 Page 2 of 6 TO THE HO:\'ORABLE MARVI]\ ISGLR, C~ITED STATES BA:\,KRUPTCY.ILDGE: Comes Now. CIIAD I.OGSD01'\ and JULIE LOGSDON. Individually and as Next Friends of COLE LOGSDON, a Minor Child. ZACH LOGSDON and ALEX LOGSDON. Movants herein. with this Agreed Motion for Relief from Automatic Stay against Vanguard Natural Resources. LI.e. Ilk/a Eagle Rock Energy Partners, LP. Debtors. (the "Debtors" pursuant to II U.s.c. ~362( d. and in support thereof would respectfully show unto the Court as follows: Jurisdiction and Venue I. This Court has jurisdiction over this matter pursuant to 28 U.S.C. ~1334. Venue is proper in this District pursuant to 28 L.S.C. ~~1408 and This is a core proceeding pursuant to 28 U.s.e. ~ 157(b(2(G. This matter is being brought pursuant to 11 U.s.c. ~~105 and 362(d. Underlying Facts 2. On April , the Movants filed their Second Amended Original Petition and Request for Disclosure in Chad Logsdon and Julie Logsdon, Individually and as Next Friends 0/ Cole Logsdon, a Minor Child. Zach Logsdon. and Alex Logsdon v. Juan Francisco Longoria, Eagle Rock Energy, LP, Eagle Rock Energy G&P, LLC, Regency Field Services. IJ(', and Vanguard Xatural Resources, LLC: In the 69 th District Court, Moore County. Texas: (the "State Court Litigation". 3. On March the Debtors tiled their First Amended Answer to the Movant's Original Petition. According to the Docket Sheet for the 69 th Judicial District Court. no other Answers have been filed by the Debtors.

3 Case Document 1215 Filed in TXSB on 07/31/17 Page 3 of 6 4. On February the Debtors. and other related entities. filed voluntary petitions for relief under Chapter 11 of Title 11 of the United States Code. 5. On February the Court entered an order directing joint administration of related chapter 11 cases thereby jointly administering all of thc cases under Vanguard Natural Resources. LLC. Case No at Docket No On February , the Debtors filed a Notice of Bankruptcy and Suggestion of Automatic Stay in the State Court Litigation. thereby staying the continuation of that litigation. The State Court Litigation 7. PlaintiffJulie Logsdon was driving a 2012 Ford Explorer and was traveling north on FM 119. Defendant Longoria was driving a 2010 Ford F250 pickup truck and was traveling south on FM 119. At the intersection of FM 119 and FM 721 Defendant Longoria. making a left-hand turn onto FM 72 L drive his vehicle into the lane Plaintiff Julie Longoria was traveling on and violently struck the front of Plaintiffs vehicle. S. Defendant Longoria worked for Eagle Rock Energy Partners at the time the causes of action in the State Court Litigation arose. 9. Eagle Rock Energy Partners has an insurance policy with Liberty Mutual Fire Insurance Company for S 1.000_000 and surplus coverage with Lexington Insurance Company for , for total insurance coverage of $26,000,000. Copies of the Certificates of Insurance for the relevant period are attached hereto as Exhibit -A". 1O. Clearly there is sufficient third party insurance coverage to satisfy any judgment obtained by Logsdon.

4 Case Document 1215 Filed in TXSB on 07/31/17 Page 4 of 6 Cause Exists for Terminating the Automatic Stav 11. Cause exists for terminating the automatic stay pursuant to Section 362(d( 1 of the Bankruptcy Code to allow Logsdon to liquidate all claims in the State Court Litigation with recovery limited to insurance proceeds only. What constitutes "cause" for lifting the stay pursuant to Section 362(d( 1 is not defined in the Bankruptcy code. but must be determined on a case by case analysis based upon an examination of the totality of the., C1rcumstanccs. ~ 12. "Courts are generally In agreement that an insurance policy itself will be considered property of the estate." "The more important question the Court must determine is whether the proceeds from liability insurance policies are also considered property of the estate." "Under the typical liability policy, the debtor will not have a cognizable interest in the proceeds of the policy. Those proceeds would normally be payable only for the benefit of those harmed by the debtor under the terms of the insurance contract:' 13. In the instant proceeding. the insurance policies arc provided by non-debtors and any recovery under those policies will have no impact on the Debtors' Estate. Therefore cause exists under 11 U.S.C. ~362(d( 1 to lift the automatic stay. \VHEREFOH.E, PREMISES CONSIDERED, Movants Chad Logsdon and Julie Logsdon, Individually and a Next Friends of Cole Logsdon. a Minor. Zach Logsdon and Alex Logsdon. pray that this Court lift the automatic stay pursuant to 11 e.s.c. ~362(d as to all parties to permit the Movants to liquidate and collect on their claims in the State Court Litigation with collection of any damages awarded limited to insurance proceeds only. and for such other and further relief. at law and in equity. as this Court deems just. C See. (' g. III n: li"id"ii/./ssijc 1../'. 5~ F.3d 1~7 (6 'h Cir. 19(5; Claughton v slixson, 33 F.3d 4 (4 '11 Cir. 19(4; and III re TucsIJII FS/iI/l'S. lnc. 91 ~ F.2d 1162 (<Ih('ir. 19<0

5 Case Document 1215 Filed in TXSB on 07/31/17 Page 5 of 6 Respectfully submitted, (Y\...-\ CJI CLLA.fj fyu / YZJ ( ~ s~ L-h s: PETERSON FARRIS BYRD & PARKER A Professional Corporation P. O. Box 9620 Amarillo, TX ( ( (facsimile Michael L Byrd: SB# min I'll 1/ h\ rdljrm.c(_li_ll Chris D. Parker: S B# cpdrk\.t~ull -Ll\\ firm.corn R~~I~::4kKSO]\ Laura W. Slay State Bar No I~I:tY..!Lrllljd:l_\_\_._c~111 Nathan M. Rymer State Bar No Ilr: 11lcI"_IIJmj Cla \\_.C(2_IlJ 2801 Post Oak Blvd.. Suite 250 Ilouston. Texas Telephone: ( Facsimile: ( ATTORNEYS FOR MOVANTS & ECHOLS ~s, (ooi-v~ /ho~jrv-j" LW l' Chris L. Dickerson (admitted pro hac vice Todd M. Schwartz (admitted pro hac "ice PAUL I IASTI:"-JGS LLP 71 South Wacker Drive. Suite 4500 Chicago. Illinois Telephone: ( Facsimile: ( and-

6 Case Document 1215 Filed in TXSB on 07/31/17 Page 6 of 6 James T. Grogan (Tex. Bar No Danny Newman (Tex. Bar No PAUL HASTINGS LLP 600 Travis Street, 58th Floor Houston, Texas Telephone: ( Facsimile: ( and- G. Alexander Bongartz (admitted pro hac rice PACL liastings LLP 200 Park A venue NCVi York. New York Telephone: ( Facsimile: ( DEBTORS' COUNSEL CERTIFICATE OF SERVICE I hereby certi fy that on this 31 st day of July a true and correct copy of the above and foregoing document was placed in the U. S. Mail, postage prepaid. to the following: ria hohc (/'clhg/all' CO 1/1 I'i(/ I:'I/I([i/: inerwin'd.cthvluw.com Mr. Robert L. Craig. Jr. Ms. Marcy ~1. Erwin CRAIG TERRilL tut.t: & GRAYTlIAM, IJP First Bank Centre 9816 Slide Road. Suite 201 Lubbock. Texas Chris D. Parker/Laura W. Slay

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13 Case Document Filed in TXSB on 07/31/17 Page 1 of 7 IN TI IL':UNITED STi\TES Bi\NKRLJPTCY COURT FOR TI IE SOCTI IER\J DISTRICT OF TEXAS I[OCSTON DIVISION "~ In re: S Chapter 11 S V ANCilJARD NATURAL RI:SOURCES, S CASE NO LLC et al.. 1 S S (Jointly Administered Debtors ~ S S AGREED ORDER GRANTING MOTION OF CHAD LOGSDON, ET AL., FOR RELIEF FROM THE STAY On this clay. the Court considered the Agreed Motion for Relief from Stay of Chad Logsdon. ct al, (the "Motion" tiled by Chad Logsdon and Julie Logsdon. individually and as next friend of Cole Logsdon, a minor child. Zach Logsdon. and Alex Logsdon CMovants", creditors and parties in interest in the above-styled and numbered bankruptcy case. with respect to the lawsuit styled. Chad Logsdon. et al, \'. Juan Francisco Longoria: Eagle Rock Energy. LP: Eagle Rock Energy G&P. LLC Regency Filed Services. IJC. and Vanguarc! Natural Resources, IJC Cause Number in the 69th District Court of \;100re County. Texas (the LawsuiC. which alleges personal injury claims as a result of an automobile accident which allegedly occurred on May 22,2014. against Debtors Eagle Rock Energy L.P. and Vanguard Natural Resources, LLC (collectively. the "Debtor Defendants". among others. The Debtors in these chapter I I cases. along with the last four digits of each Debtor's federal tax identification number, are Vanguard Natural Resources. Ll.C (1161: Eagle Rock Acquisition Partnership, L.P. (6706: Eagle Rock Acquisition Partnership II. L.P. (0903: Eagle Rock Energy Acquisition Co.. Inc. (4564: Eagle Rock Energy Acquisition Co. 11, Inc. (3364: Eagle Rock Upstream Development Company, Inc. (0113: Eagle Rock Upstream Development Company II. Inc. (7453: Encore Clear Fork Pipeline I.I.C (2032: Escarnbia Asset Co. LLC (3869: Escambia Operating Co. LLC (2000: Vanguard Natural Gas, LLC (1004: Vanguard Operating, Ll.C (9331: VNR Finance Corp. (1494; and VNR Holdings. LLC (6371 (collectively, the "I2~btors". The location of the Debtors' service address is: 5847 San Felipe. Suite 3000, Houston, Texas Page I

14 Case Document Filed in TXSB on 07/31/17 Page 2 of 7 WI IERFAS. it appearing that due notice of said Motion having been properly given. the Court having considered the Motion and the agreement of Debtors is of the opinion that it is in the best interests of all parties and should be approved. \VlIERFAS. the Debtor Defendants' have an insurance policy with Liberty Mutual Fire Insurance Company for S I and surplus coverage with Lexington Insurance Company for $ for total insurance coverage of S (the "Insurers". Debtor Defendants' insurance has prox idcd coverage and has retained Robert L. Craig..lr. of Craig, Terrill. liail & Grantham. I JJl to represent the Debtor Defendants in the Lawsuit. \VHERFAS. commencing on February (the "Petition Date", VNR and the other Debtors commenced chapter 11 cases (the "Chapter 11 Cases" by tiling voluntary petitions for reliefunder chapter 1 I of title 11 of the United States Code (the "Bankruptcv Code". The Chapter 11 Cases have been consolidated for procedural purposes only and arc jointly administered pursuant to Bankruptcy Rule 10 15(a. The Debtors continue to operate their businesses and manage their properties as debtors in possession pursuant to sections 1107(a and 1108 of the Bankruptcy Code. WIIFREAS. since the Petition Date. the Lawsuit has been stayed by operation of the automatic stay arising under section 362 of the Bankruptcy Code. WIIFREAS. Movants intend to proceed with the Lawsuit only insofar as the Insurers provide defense and/or coverage. and to execute. levy. and collect upon any judgment rendered as may be obtained in the Lawsuit from the Insurers only, and not against any of the Debtors. Movant acknow ledges that Vanguard has not made any representations or warranties as to the likelihood or possibility of recovery against the Insurers. Page ~

15 Case Document Filed in TXSB on 07/31/17 Page 3 of 7 WIIEREAS. the Debtors consent to a limited modification of the automatic stay on the terms and conditions set forth in this Agreed Order for the exclusive purpose of allowing Movants to proceed solely against the proceeds of any insurance policies held by or on behalfof the Debtors (the "Permitted Policies". and solely to the extent provided in this Agreed Order. TI IEREFORL it is hereby ORDERED that 1. The above recitals are incorporated by reference into this Agreed Order with the same force and effect as if fully set forth hereinafter. 2. The automatic stay is modi tied \\ ith respect to the l.a«suit for the cxc lusivc purpose of permitting Movants to proceed against the Debtor Defendants in the Lawsuit as a nominal defendant only. at no cost to the Debtors. their estates. or their successors. so the Movants may establish liability. if any. against the Debtor Defendants for the sole purpose of recovering from proceeds of the Permitted Policies. 3. Movants agree and acknowledge that: (a any recoveries arising the Lawsuit or related claims (whether by mediation. arbitration, or otherwise. if any. with respect to the Debtors. their estates. or their successors are limited solely to proceeds from the Permitted Policies. and not from the Debtors. their estates. or their successors; (b Movants waive any and all claims arising from or related to the Lawsuit that could otherwise be asserted against the Debtors. their estates, or their successors. except to the extent necessary to preserve Debtors' insurance carriers' obligation to provide defense and/or indemnity; (c Movants waive any recoveries arising from the Lawsuit to the extent such recoveries may trigger indemnification or reimbursement rights owed to a co-defendant from one or more of the Debtors. their estates. or their successors. except to the extent necessary to preserve Debtors' insurance carriers' obligation to provide defense and/or indemnity; and (d as against the Debtors, Movants must prosecute the Lawsuit (and enforce any Page 3

16 Case Document Filed in TXSB on 07/31/17 Page 4 of 7 judgment obtained on account of the Lawsuit. if any, solely with respect to proceeds available from the Permitted Policies. 4. Movants must tile this Agreed Order in the court in which the Lawsuit is pending within ten (10 business days after the approval by the Bankruptcy Court and the entry of this Agreed Order on the Bankruptcy Court docket. 5. The Debtors arc not waiving and are not deemed to have waived any available rights. counterclaims. or defenses, including at law. equity, or otherwise with respect to the Lawsuit. 6. Neither this Agreed Order nor any negotiations and writings in connection with this Agreed Order will in any way be construed as or deemed to be evidence of or an admission on behalf of any Party regarding any claim or right that such party may have against the other Party. 7. Each of the Parties to this Agreed Order represents and warrants it is duly authorized to enter into and be bound by this Agreed Order. r Remainder (~fp({ke intent tonally left blank.t Page 4

17 Case Document Filed in TXSB on 07/31/17 Page 5 of 7 The Bankruptcy Court retains exclusive jurisdiction to resolve any dispute arising from or related to the interpretation or enforcement of this Agreed Order. SICi],;ED this day of,2017. The Honorable Marvin Isgur Lnitcd States Bankruptcy Judge Page 5

18 Case Document Filed in TXSB on 07/31/17 Page 6 of 7 AGREED AS TO FORM AND ENTRY REQCESTED: Ct-vn S p~ / YJO I':_{/~ c;;,\.~ '. l-w.s Chris D. Parker PETERSO:\!-':\RRIS BYRD & PARKI~R. P.e. Chase Tower 600 S. Tyler. Ste Amari 110. Texas Telephone: ( Fax: ( ~~ Laura W. Slay ~ State Bar No, I"L1Y!Z rmjch\\,cllll Nathan M. Rymer State Bar No r III '-co rfrmj l'l ~I\\,L'l im RY\lER. MOORE. JACKSO:\ & ECIIOLS. p,e Post Oak Blvd.. Suite 250 I Iouston, Texas Telephone: ( Facsimile: ( ATTORNEYS FOR MOY ANTS vtvtls (2n~r-' I tjj ~'s~ : uns Chris L. Dickerson (admitted pro hac vice Todd \;1. Schwartz (admitted pro hac vice; PALl. I L\STE\(iS I.LP 71 South Wacker Drive. Suite 4500 Chicago. Illinois Telephone: ( Facsimile: ( and- James T. Grogan (Texas Bar No, 24(27354 Danny Newman (Tex. Bar ;\lo. 24(92896 PAUL IIASTINGS LI.P 600 Travis Street. 58th Floor I Iouston. Texas Telephone: ( Facsimile: ( Page 6

19 Case Document Filed in TXSB on 07/31/17 Page 7 of 7 - and- G. Alexander Bongartz (admitted pro hac vicei PACL JlASTI\:GS LLP 100 Park A venue Ncv«York. Ncv, York Telephone: ( Facsimile: ( DEBTORS' COCNSEL Page 7