Case Document 913 Filed in TXSB on 06/19/18 Page 1 of 3 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

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1 Case Document 913 Filed in TXSB on 06/19/18 Page 1 of 3 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: Chapter 11 Cobalt International Energy, Inc., et al., 1 Case No (MI) Reorganized Debtors. (Jointly Administered) NOTICE OF FILING OF REVISED PROPOSED ORDER GRANTING THE PLAN ADMINISTRATOR S EXPEDITED MOTION FOR APPROVAL OF (I) OMNIBUS CLAIMS OBJECTION PROCEDURES AND (II) THE FORM OF NOTICE TO CLAIMANTS OF SUCH OBJECTIONS PURSUANT TO SECTIONS 105(a) AND 502 OF THE BANKRUTCY CODE, RULES 3007 AND 9007 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE, AND RULE OF THE BANKRUPTCY LOCAL RULES PLEASE TAKE NOTICE that on May 25, 2018, Nader Tavakoli, solely in his capacity as the Lead Member and Chairman of the Plan Administrator Committee of Cobalt International Energy, Inc., et al. (the Plan Administrator ) appointed under the Fourth Amended Joint Chapter 11 Plan of Cobalt International Energy, Inc. and Its Debtor Affiliates, confirmed on April 5, 2018, filed Plan Administrator s Expedited Motion for Approval of (I) Omnibus Claims Objection Procedures and (II) the Form of Notice to Claimants of such Objections Pursuant to Sections 105(a) and 502 of the Bankruptcy Code, Rules 3007 and 9007 of the Federal Rules of Bankruptcy Procedure, and Rule of the Bankruptcy Local Rules [Docket No. 871] (the Motion ). PLEASE TAKE FURTHER NOTICE that the Plan Administrator hereby files a revised proposed Order Granting Plan Administrator s Expedited Motion for Approval of (I) Omnibus Claims Objection Procedures and (II) the Form of Notice to Claimants of such Objections Pursuant to Sections 105(a) and 502 of the Bankruptcy Code, Rules 3007 and 9007 of the Federal Rules of Bankruptcy Procedure, and Rule of the Bankruptcy Local Rules (the Revised Proposed Order ), attached hereto as Exhibit A, which incorporates informal comments received by the Plan Administrator from the United States of America. PLEASE TAKE FURTHER NOTICE that attached hereto as Exhibit B is a redline of the Revised Proposed Order reflecting changes from the proposed form of order attached to the Motion. 1 The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt International Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas

2 Case Document 913 Filed in TXSB on 06/19/18 Page 2 of 3 PLEASE TAKE FURTHER NOTICE that the deadline to object to the Motion expired on June 18, 2018, and no formal or informal objections (other than informal comments received from the United States of America, which have been incorporated in the Revised Proposed Order) were received. Accordingly, the Motion is unopposed, and the Plan Administrator respectfully requests that the Court enter the Revised Proposed Order. PLEASE TAKE FURTHER NOTICE that the Plan Administrator will appear on June 29, 2018 at 9:00 a.m. (prevailing Central Time) or as soon thereafter as counsel may be heard before the Honorable Marvin Isgur or any other judge who may be sitting in his place and stead, in Courtroom 404 in the United States Courthouse, 515 Rusk, Houston, Texas 77002, to present the Motion to the Court and request entry of the Revised Proposed Order, unless the Court enters the Revised Proposed Order prior to the scheduled hearing. PLEASE TAKE FURTHER NOTICE that copies of the Motion, the Revised Proposed Order, and all other documents filed in these chapter 11 cases are available free of charge by visiting the case website maintained by the Debtors notice and claim agent, Kurtzman Carson Consultants LLC, available at or by calling (866) (toll free) or (310) (international). You may also obtain copies of any pleadings by visiting the Court s website at in accordance with the procedures and fees set forth therein. Dated: June 19, GREENBERG TRAURIG, LLP By: /s/ David R. Eastlake Shari L. Heyen Texas State Bar No HeyenS@gtlaw.com David R. Eastlake Texas State Bar No EastlakeD@gtlaw.com 1000 Louisiana Street, Suite 1700 Houston, Texas Telephone: Facsimile: Counsel for Nader Tavakoli, solely in his capacity as the Lead Member and Chairman of the Plan Administrator Committee of Cobalt International Energy, Inc. et al. 2

3 Case Document 913 Filed in TXSB on 06/19/18 Page 3 of 3 Certificate of Service I certify that on June 19, 2018, 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/ David R. Eastlake David R. Eastlake 3

4 Case Document Filed in TXSB on 06/19/18 Page 1 of 20 Exhibit A Revised Proposed Order

5 Case Document Filed in TXSB on 06/19/18 Page 2 of 20 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: Chapter 11 COBALT INTERNATIONAL ENERGY, INC., Case No (MI) et al., 1 Reorganized Debtors. (Jointly Administered) ORDER GRANTING PLAN ADMINISTRATOR S EXPEDITED MOTION FOR APPROVAL OF (I) OMNIBUS CLAIMS OBJECTION PROCEDURES AND (II) THE FORM OF NOTICE TO CLAIMANTS OF SUCH OBJECTIONS Upon the Plan Administrator s Expedited Motion for Approval of (I) Omnibus Claims Objection Procedures and (II) the Form of Notice to Claimants of Such Objections (the Motion ); 2 and upon consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157 and 1334; and venue being proper before this Court pursuant to 28 U.S.C and 1409; and due and proper notice of the Motion having been provided; and it appearing that no other or further notice need be provided; and the Court having determined that there exists just cause for the relief granted herein; and upon the record of the hearing before the Court, and any responses to the Motion having been withdrawn, resolved, or overruled on the merits; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED that: 1. The Motion is granted as set forth herein. 1 The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt International Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas Capitalized but undefined terms herein shall have the same meaning as ascribed to them in the Motion.

6 Case Document Filed in TXSB on 06/19/18 Page 3 of Notwithstanding anything to the contrary in the Bankruptcy Code and Bankruptcy Rules, and pursuant to Bankruptcy Rule 3007(c) and Bankruptcy Local Rule , the Plan Administrator may file Omnibus Objections that include objections to claims on any basis provided for in the Objection Grounds. 3. The Plan Administrator shall file and prosecute any Omnibus Objections in accordance with the Objection Procedures attached hereto as Exhibit 1, which are hereby approved, and the other procedural safeguards set forth in Bankruptcy Rule 3007(e) and Bankruptcy Local Rule The form of Objection Notice attached hereto as Exhibit 2 is hereby approved. 5. The provisions below shall apply to any Omnibus Objection that includes a claim of the United States of America or a claim of any agency of the United States of America (collectively, the United States ), notwithstanding anything to the contrary contained in this Order or the attached form of Objection Notice: (a) (b) (c) (d) (e) The deadline for the United States to respond to any Omnibus Objection will be thirty (30) days after the filing of the Omnibus Objection; There is no requirement that a response by the United States to an Omnibus Objection be actually received by the Plan Administrator or his counsel; instead it must be served on the Plan Administrator or his counsel pursuant to the Federal Rules of Bankruptcy Procedure; The Court will not hear any Omnibus Objection that includes a claim of the United States before the thirty-fourth (34th) day after such Omnibus Objection is filed, and the Plan Administrator shall not seek to schedule any hearing on any such Omnibus Objection before the thirty-fourth (34th) day after it is filed; Pursuant to BLR (d), the initial hearing on any Omnibus Objection that includes a claim of the United States will be non-evidentiary and used as a scheduling conference; If either the Plan Administrator or the United States believes that discovery is necessary in connection with an Omnibus Objection to a 2

7 Case Document Filed in TXSB on 06/19/18 Page 4 of 20 claim of the United States, either party may seek it pursuant to the Federal Rules of Bankruptcy Procedure and subject to any scheduling order that the Court may enter; (f) (g) The United States is not required to attach any documentation or other evidence to a response to an Omnibus Objection; and To the extent any of the procedures set forth in this Order or the attached form of Objection Notice concerning the form and timing of any response to an Omnibus Objection by the United States conflict with any Bankruptcy Local Rule or to any Federal Rule of Bankruptcy Procedure, the Bankruptcy Local Rules and Federal Rules of Bankruptcy Procedure shall govern. 6. Nothing in this Order shall affect the Plan Administrator s authority to pay claims to the extent authorized by a separate order of the Court. 7. Nothing in this Order shall obligate the Plan Administrator to settle or pursue a settlement of any particular claim. Settlements of claims may be negotiated and compromised by the Plan Administrator in his sole discretion (subject to applicable law). 8. Notwithstanding the relief granted in this Order and any actions taken pursuant to such relief, nothing in this Order, the Motion, or the Objection Procedures shall be deemed: (a) an admission as to the validity of any prepetition claim against a Debtor entity; (b) a waiver of any right of the Plan Administrator to dispute any claim on any grounds; (c) a promise or requirement to pay any claim; (d) an implication or admission that any particular claim is of a type specified or defined in this Motion or any order granting the relief requested by this Motion; (e) a request or authorization to assume any prepetition agreement, contract, or lease pursuant to section 365 of the Bankruptcy Code; or (f) a waiver of any right of the Plan Administrator under the Bankruptcy Code or any other applicable law. 3

8 Case Document Filed in TXSB on 06/19/18 Page 5 of Notice of the Motion as provided therein shall be deemed good and sufficient notice of such Motion and the requirements of Bankruptcy Rule 6004(a) and the Bankruptcy Local Rules are satisfied by such notice. 10. Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this Order shall be immediately effective and enforceable upon its entry. 11. The Plan Administrator is authorized to take all actions necessary to effectuate the relief granted in this Order in accordance with the Motion. 12. This Court retains exclusive jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order. Signed:, 2018 HONORABLE MARVIN ISGUR UNITED STATES BANKRUPTCY JUDGE 4

9 Case Document Filed in TXSB on 06/19/18 Page 6 of 20 EXHIBIT 1 Objection Procedures

10 Case Document Filed in TXSB on 06/19/18 Page 7 of 20 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: Chapter 11 COBALT INTERNATIONAL ENERGY, INC., Case No (MI) et al., 1 Reorganized Debtors. (Jointly Administered) PROCEDURES FOR FILING OMNIBUS CLAIMS OBJECTIONS 1. Grounds for Omnibus Objections. In addition to those grounds expressly set forth in Bankruptcy Rule 3007(d), Nader Tavakoli, solely in his capacity as the Lead Member and Chairman of the Plan Administrator Committee of Cobalt International Energy, Inc. et al. (the Plan Administrator ) appointed under the Fourth Amended Joint Chapter 11 Plan of Cobalt International Energy, Inc. and Its Debtor Affiliates, confirmed on April 5, 2018 (the Plan ), 2 may file omnibus objections (each, an Omnibus Objection ) to Claims on the following grounds, in part or in whole: a. A Claim is a duplicate of another Claim in that it asserts a single claim against a single debtor or it asserts a claim for the same debt against another debtor (the Duplicate Claim ); b. A Claim has been amended or superseded (the Amended Claim ); c. A Claim has been filed after the Bar Date or the Governmental Bar Date as applicable (the Late Filed Claim ); d. A Claim is based on an equity interest (the Equity Interest Claim ); 1 The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt International Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas Capitalized but undefined terms used herein shall have the meanings given to such terms in the Plan.

11 Case Document Filed in TXSB on 06/19/18 Page 8 of 20 e. The Debtor(s) is unable to determine the validity of the claim because the claim was presented in a form that does not comply with applicable rules (the Unsupported Claim ); f. A Claim was incorrectly classified (the Misclassified Claim ); g. A Claim has been satisfied or released during the case in accordance with the Bankruptcy Code, applicable Bankruptcy Rules, or a Court Order (the Satisfied Claim ); h. A Claim was filed in the wrong case (the Wrongly Filed Claim ); i. A Claim is for a dollar amount which does not match the Debtors books and records and should be reduced (the Claim to be Adjusted ); j. A Claim was paid prepetition, or a Claim for which the Debtors books and records show no outstanding liability to the Claimant (the No Liability Claim ); k. A Claim that is disallowed pursuant to section 502 of the Bankruptcy Code (the Section 502 Disallowed Claim ); l. A Claim should be re-classified into Class 7 because the Claim arises out of the purchase or sale of a security of the debtor or affiliate pursuant to section 510(b) of the Bankruptcy Code (the Section 510(b) Claim ); and m. A Claim fails to specify a Debtor against whom the claim is asserted (the No Debtor Claim ). 2. Form of Omnibus Objection. Each Omnibus Objection shall conform to the following requirements: a. Each Omnibus Objection shall be numbered sequentially and, to the extent possible, state the category which forms the primary basis for the objection in its title; b. An exhibit listing Claims to which the Omnibus Objection relates shall be attached to the Omnibus Objection; c. Each exhibit shall contain only those Claims to which there is one common basis for objection; d. A Claim for which there are two or more bases for objection (e.g., a claim that is objectionable as both an Untimely Claim and an Unsupported Claim) shall be referenced on each applicable exhibit attached to each applicable Omnibus Objection; and 2

12 Case Document Filed in TXSB on 06/19/18 Page 9 of 20 e. Each exhibit shall have the Claims listed alphabetically. 3. Number of Claims in Omnibus Objections. Each Omnibus Objection may include more than 100 claims. 4. Supporting Documentation. To the extent appropriate, Omnibus Objections may include an affidavit or declaration that provides a factual basis for the Plan Administrator s objection to the claims, including from someone with personal knowledge of the Debtors books and records and the manner in which they are maintained that states that the affiant or the declarant has reviewed the claims included therein and applicable supporting information and documentation provided therewith, made reasonable efforts to research the claim on the Debtors books and records, and determined that the books and records do not reflect the debt or the amount of debt that is alleged in the claim. 5. Claims Exhibits. An exhibit listing the claims that are subject to the particular Omnibus Objection will be attached thereto. Each exhibit will include only the claims to which there is a common basis for the objection. Claims for which there is more than one basis for the objection will be referenced on each exhibit applicable thereto. The exhibits will include, without limitation, the following information alphabetized by claimant: a. the claims that are the subject of the Omnibus Objection and, if applicable, the proof of claim number related thereto from the claims register; b. the asserted amount of the claim; c. the grounds for the objection; d. a cross-reference to the section of the Omnibus Objection discussing such claim; and e. other information, as applicable, including: (i) the proposed classification of claims the Plan Administrator seeks to reclassify; (ii) the reduced claim amounts of claims the Plan Administrator seeks to reduce; or (iii) the surviving claims of claimants affected by the Omnibus Objection. 3

13 Case Document Filed in TXSB on 06/19/18 Page 10 of Objection Notice. Each Omnibus Objection will be accompanied by a customized objection notice, substantially in the form annexed to the Order as Exhibit 2 (the Objection Notice ), tailored, as appropriate, to address a particular creditor, claim, or objection, which will: a. describe the basic nature of the objection; b. inform creditors that their rights may be affected by the objection; c. describe the procedures for filing a written response (each, a Response ) d. to the objection, including all relevant dates and deadlines related thereto; e. identify the hearing date, if applicable, and related information; and f. describe how copies of proofs of claim, the Omnibus Objection, and other pleadings filed in the Chapter 11 Cases may be obtained. 7. Notice and Service. Each Omnibus Objection will be filed with the Court and served electronically using the Court s electronic filing system. In addition, each Omnibus Objection shall be served by United States First Class Mail, postage prepaid, on all claimants holding claims that are the subject of the Omnibus Objection. 8. Omnibus Claims Objection Hearings. Each Omnibus Objection shall be set for hearing no less than 30 days after service of the Omnibus Objection (each, a Hearing ), unless otherwise ordered by the Court. In the Plan Administrator s sole discretion, and after notice to the affected claimant, the Plan Administrator may (without further order of the Court) adjourn the Hearing on the Omnibus Objection to a subsequent hearing date by filing a notice or statement on the record. For claims subject to an Omnibus Objection and with respect to which either no Response is filed in accordance with the proposed response procedures and no appearance is made at the Hearing or a Response is filed in accordance with the proposed response procedures but such Response is resolved prior to the Hearing, the Plan Administrator 4

14 Case Document Filed in TXSB on 06/19/18 Page 11 of 20 may request at the Hearing that the Court enter an order granting the Omnibus Objection with respect to such claim and without further notice to the claimant or any other party. Contested claims for which a Response is filed in accordance with the proposed response procedures but such Response is not resolved prior to the Hearing and an appearance is made at the Hearing may be heard at the Hearing or adjourned to a subsequent hearing date in the sole discretion. If a subsequent hearing is determined to be necessary, the Plan Administrator shall file with the Court and serve on the affected claimants a notice of the hearing (the date of which shall be determined in consultation with the affected claimant(s)) or announce such adjournment on the record. 9. Contested Matter. Each claim subject to an Omnibus Objection and the Response thereto shall constitute a separate contested matter as contemplated by Bankruptcy Rule 9014, and any order entered by the Court will be deemed a separate order with respect to such claim. The Plan Administrator may, in his discretion and in accordance with other orders of this Court, and the provisions of the Bankruptcy Code and Bankruptcy Rules, settle the priority, amount, and validity of such contested claims without any further notice to or action, order, or approval of the Court. Responses to Omnibus Objections 10. Parties Required to File a Response. Any party who disagrees with an objection is required to file a Response in accordance with the procedures set forth herein and to appear at the Hearing. If a claimant whose claim is subject to an Omnibus Objection does not file and serve a Response in compliance with the procedures below or fails to appear at the Hearing, the Court may grant the objection with respect to such claim without further notice to the claimant. 11. Response Contents. Each Response must contain the following (at a minimum): 5

15 Case Document Filed in TXSB on 06/19/18 Page 12 of 20 a. The case number and the title of the Omnibus Objection to which the Response relates; b. The name of the Claimant and a description of the basis for the amount of the Claim; c. A concise statement setting forth the reasons why the Claim should not be disallowed for the reasons set forth in the Omnibus Objection, including, but not limited to, the specific factual and legal bases upon which the Claimant will rely in opposing the Omnibus Objection; d. A copy of other documentation or other evidence of the Claim, to the extent not included with the Proof of Claim, upon which the Claimant will rely in opposing the Omnibus Objection at the hearing on such Omnibus Objection; and e. The name(s), address(es), telephone number and facsimile number of the person(s) (who may be the Claimant and/or the Claimant s legal representative) to whom counsel for the Plan Administrator should serve any reply to the Response, and who possess the authority to reconcile, settle, or otherwise resolve the Omnibus Objection on the Claimant s behalf. 12. Filing and Service of the Response. A Response will be deemed timely only if it is filed with the Court and served electronically using the Court s electronic filing system and actually received by 4:00 p.m. (prevailing Central Time) on the day that is twenty-one (21) calendar days from the date of service of the Omnibus Objection (the Response Deadline ), unless as otherwise ordered by the Court, by the following parties (the Notice Parties ): Counsel for Plan Administrator: Shari L. Heyen David R. Eastlake Greenberg Traurig, LLP 1000 Louisiana Street, Suite 1700 Houston, Texas HeyenS@gtlaw.com EastlakeD@gtlaw.com Counsel for the U.S. Trustee: Hector Duran U.S. Trustee 515 Rusk Ste 3516 Houston, TX Hector.Duran.Jr@usdoj.gov 13. Discovery. If the Plan Administrator determines that discovery is necessary in advance of a hearing on an Omnibus Objection, the Plan Administrator will serve notice on the 6

16 Case Document Filed in TXSB on 06/19/18 Page 13 of 20 affected claimant and its counsel of record that the scheduled hearing will be treated as a status conference during which the parties will request that the Court issue a scheduling order to facilitate dismissal or resolution of the litigation. Such notice may be incorporated into the initial agenda letter for the hearing, or may be provided by separate notice. 14. Failure to Respond. A Response that is not filed and served in accordance with the procedures set forth herein may not be considered by the Court at the Hearing. Absent reaching an agreement with the Plan Administrator resolving the objection to a claim (as described in the Objection Notice), failure to timely file and serve a Response as set forth herein or to appear at the Hearing may result in the Court granting the Omnibus Objection without further notice or hearing. Upon entry of an order sustaining an Omnibus Objection, affected creditors will be served with such order. 15. Reply to a Response. The Plan Administrator shall be permitted to file a reply to any Response no later than two days before the hearing with respect to the relevant Omnibus Objection. Miscellaneous 16. Additional Information. Copies of these procedures, the Motion, the Order, or any other pleadings (the Pleadings ) filed in these Chapter 11 Cases are available at no cost at the claims administrator s website: You may also obtain copies of any of the Pleadings filed in these Chapter 11 Cases for a fee at the Court s website at A login identification and password to the Court s Public Access to Court Electronic Records ( PACER ) are required to access this information and can be obtained through the PACER Service Center at 7

17 Case Document Filed in TXSB on 06/19/18 Page 14 of Reservation of Rights. NOTHING IN ANY OMNIBUS OBJECTION OR OBJECTION NOTICE IS INTENDED OR SHALL BE DEEMED TO CONSTITUTE (A) AN ADMISSION AS TO THE VALIDITY OF ANY PREPETITION CLAIMAGAINST A DEBTOR ENTITY; (B) A WAIVER OF ANY RIGHT OF THE PLAN ADMINISTRATOR 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 MOTION OR ANY ORDER GRANTING THE RELIEF REQUESTED BY THIS MOTION; (E) A REQUEST OR AUTHORIZATION TO ASSUME ANY PREPETITION AGREEMENT, CONTRACT, OR LEASE PURSUANT TO SECTION 365 OF THE BANKRUPTCY CODE; OR (F) A WAIVER OF ANY RIGHT OF THE PLAN ADMINSTRATOR OR UNDER THE BANKRUPTCY CODE OR ANY OTHER APPLICABLE LAW. Dated: May 25, GREENBERG TRAURIG, LLP By: /s/ David R. Eastlake Shari L. Heyen Texas State Bar No HeyenS@gtlaw.com David R. Eastlake Texas State Bar No EastlakeD@gtlaw.com 1000 Louisiana Street, Suite 1700 Houston, Texas Telephone: Facsimile: Counsel for Nader Tavakoli, solely in his capacity as the Lead Member and Chairman of the Plan Administrator Committee of Cobalt International Energy, Inc. et al. 8

18 Case Document Filed in TXSB on 06/19/18 Page 15 of 20 EXHIBIT 2 Form of Objection Notice

19 Case Document Filed in TXSB on 06/19/18 Page 16 of 20 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: Chapter 11 COBALT INTERNATIONAL ENERGY, et al., 6 Case No (MI) Reorganized Debtors. (Jointly Administered) NOTICE OF PLAN ADMINISTRATOR S OMNIBUS CLAIMS OBJECTION THIS IS AN OBJECTION TO YOUR CLAIM. THE OBJECTING PARTY IS ASKING THE COURT TO DISALLOW THE CLAIM THAT YOU FILED IN THIS BANKRUPTCY CASE. YOU SHOULD IMMEDIATELY CONTACT THE OBJECTING PARTY TO RESOLVE THE DISPUTE. IF YOU DO NOT REACH AN AGREEMENT, YOU MUST FILE A RESPONSE TO THIS OBJECTION AND SEND A COPY OF YOUR RESPONSE TO THE OBJECTING PARTY WITHIN 21 DAYS AFTER THE OBJECTION WAS SERVED ON YOU. YOUR RESPONSE MUST STATE WHY THE OBJECTION IS NOT VALID. IF YOU DO NOT FILE A RESPONSE WITHIN 21 DAYS AFTER THE OBJECTION WAS SERVED ON YOU, YOUR CLAIM MAY BE DISALLOWED WITHOUT A HEARING. A HEARING HAS BEEN SET ON THIS MATTER ON [DATE] AT [TIME] IN COURTROOM 404, 515 RUSK, HOUSTON, TEXAS Important Information Regarding the Objection Grounds for the Objection. By the Objection, the Plan Administrator is seeking to [disallow/expunge/reclassify/reduce/ subordinate] your claim(s) listed in the table below on the grounds that your claim(s) [is/are] [ ]. The claim(s) subject to the Objection may also be found on the schedules attached to the Objection, a copy of which has been provided with this notice. Objection Procedures. On [ ], 2018, the United States Bankruptcy Court for the Southern District of Texas (the Court ) entered an order [Docket No. ] approving procedures for filing and resolving objections to claims asserted against the Debtors in these Chapter 11 Cases (the Objection Procedures ). A copy of the Objection Procedures is included with this 6 The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt International Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas

20 Case Document Filed in TXSB on 06/19/18 Page 17 of 20 notice. Please review the Objection Procedures to ensure your response to the Objection, if any, is timely and correctly filed and served. Resolving the Objection Parties Required to File a Response. If you disagree with the Objection filed with respect to your claim, you must file a response (each, a Response ) with the Court in accordance with the procedures described below and appear at the Hearing (as defined herein). Response Contents. Each Response must contain the following (at a minimum): a. The case number and the title of the Omnibus Objection to which the Response relates; b. The name of the Claimant and a description of the basis for the amount of the Claim; c. A concise statement setting forth the reasons why the Claim should not be disallowed for the reasons set forth in the Omnibus Objection, including, but not limited to, the specific factual and legal bases upon which the Claimant will rely in opposing the Omnibus Objection; d. A copy of other documentation or other evidence of the Claim, to the extent not included with the Proof of Claim, upon which the Claimant will rely in opposing the Omnibus Objection at the hearing on such Omnibus Objection; and e. The name(s), address(es), telephone number and facsimile number of the person(s) (who may be the Claimant and/or the Claimant s legal representative) to whom counsel for the Plan Administrator should serve any reply to the Response, and who possess the authority to reconcile, settle, or otherwise resolve the Omnibus Objection on the Claimant s behalf. Notice and Service. Your Response must be filed with the Court and served so as to be actually received by 4:00 p.m. (prevailing Central Time) on [_], 2018 (the Response Deadline ) by the following parties (the Notice Parties ): Counsel for Plan Administrator: Shari L. Heyen David R. Eastlake Greenberg Traurig, LLP 1000 Louisiana Street, Suite 1700 Houston, Texas HeyenS@gtlaw.com EastlakeD@gtlaw.com 3 Counsel for the U.S. Trustee: Hector Duran U.S. Trustee 515 Rusk Ste 3516 Houston, TX Hector.Duran.Jr@usdoj.gov

21 Case Document Filed in TXSB on 06/19/18 Page 18 of 20 Failure to Respond. A Response that is not filed and served in accordance with the procedures set forth herein may not be considered by the Court at the Hearing. Absent an agreement with the Plan Administrator resolving the Objection to a claim, failure to timely file and serve a Response as set forth herein and appear at the Hearing may result in the Court granting the Objection without further notice or hearing. Upon entry of an order, affected creditors will be served with a notice of entry, and a copy, of the order. Hearing on the Objection Date, Time, and Location. A hearing (the Hearing ) on the Objection will be held on [_], at [_] prevailing Central Time, before the Honorable Marvin Isgur, United States Bankruptcy Judge, in Courtroom 404, 515 Rusk, Houston, Texas The Hearing may be adjourned to a subsequent date in these Chapter 11 Cases in the Plan Administrator s sole discretion. You must attend the Hearing if you disagree with the Objection and have filed a Response. Contested claims for which (a) a Response is filed in accordance with the proposed response procedures but such Response is not resolved prior to the Hearing and (b) an appearance is made at the Hearing may be heard at the Hearing or adjourned to a subsequent hearing in the Plan Administrator s sole discretion. If a subsequent hearing is determined to be necessary, the Plan Administrator shall file with the Court and serve on the affected claimants a notice of the hearing (the date of which shall be determined in consultation with the affected claimant(s)). Discovery. If the Plan Administrator determines that discovery is necessary in advance of a hearing on an Objection, the Plan Administrator will serve notice on the affected claimant and its counsel of record that the scheduled hearing will be treated as a status conference during which the parties will request that the Court issue a scheduling order to facilitate dismissal or resolution of the litigation. Any such notice may be incorporated into the initial agenda letter for the hearing or may be provided by separate notice. Additional Information Questions or Information. Copies of these procedures, the Motion, the Order, or any other pleadings (the Pleadings ) filed in these Chapter 11 Cases are available at no cost at the claims administrator s website: You may also obtain copies of any of the Pleadings filed in these Chapter 11 Cases for a fee at the Court s website at A login identification and password to the Court s Public Access to Court Electronic Records ( PACER ) are required to access this information and can be obtained through the PACER Service Center at Please do not contact the Court to discuss the merits of any claim or any Objection filed with respect thereto. Reservation of Rights NOTHING IN ANY OMNIBUS OBJECTION OR OBJECTION NOTICE IS INTENDED OR SHALL BE DEEMED TO CONSTITUTE (A) AN ADMISSION AS TO THE VALIDITY OF ANY PREPETITION CLAIM AGAINST A DEBTOR ENTITY; (B) A 4

22 Case Document Filed in TXSB on 06/19/18 Page 19 of 20 WAIVER OF ANY RIGHT OF THE PLAN ADMINSTRATOR 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 MOTION OR ANY ORDER GRANTING THE RELIEF REQUESTED BY THIS MOTION; (E) A REQUEST OR AUTHORIZATION TO ASSUME ANY PREPETITION AGREEMENT, CONTRACT, OR LEASE PURSUANT TO SECTION 365 OF THE BANKRUPTCY CODE; OR (F) A WAIVER OF ANY RIGHT OF THE PLAN ADMINSTRATOR UNDER THE BANKRUPTCY CODE OR ANY OTHER APPLICABLE LAW. Dated:, GREENBERG TRAURIG, LLP By: Shari L. Heyen Texas State Bar No HeyenS@gtlaw.com David R. Eastlake Texas State Bar No EastlakeD@gtlaw.com 1000 Louisiana Street, Suite 1700 Houston, Texas Telephone: Facsimile: Counsel for Nader Tavakoli, solely in his capacity as the Lead Member and Chairman of the Plan Administrator Committee of Cobalt International Energy, Inc. et al. 5

23 Case Document Filed in TXSB on 06/19/18 Page 20 of 20 Date Filed Court Claim No. KCC Claim No. Debtor Asserted Claim Amount 7 Basis for Objection Proposed Treatment Surviving Claim No. 7 Asserted claim amounts listed as $0.00 reflect that the claim amount asserted is unliquidated. 6

24 Case Document Filed in TXSB on 06/19/18 Page 1 of 22 Exhibit B Redline of Proposed Order

25 Case Document Filed in TXSB on 06/19/18 Page 2 of 22 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: Chapter 11 COBALT INTERNATIONAL ENERGY, INC., Case No (MI) et al., 1 COBALT INTERNATIONAL ENERGY, INC., Case No (MI) et al., 1 Reorganized Debtors. (Jointly Administered) ORDER GRANTING PLAN ADMINISTRATOR S EXPEDITED MOTION FOR APPROVAL OF (I) OMNIBUS CLAIMS OBJECTION PROCEDURES AND (II) THE FORM OF NOTICE TO CLAIMANTS OF SUCH OBJECTIONS Upon the Plan Administrator s Expedited Motion for Approval of (I) Omnibus Claims Objection Procedures and (II) the Form of Notice to Claimants of Such Objections (the Motion ); 2 and upon consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. 157 and 1334; and venue being proper before this Court pursuant to 28 U.S.C and 1409; and due and proper notice of the Motion having been provided; and it appearing that no other or further notice need be provided; and the Court having determined that there exists just cause for the relief granted herein; and upon the record of the hearing before the Court, and any responses to the Motion having been withdrawn, resolved, or 1 The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt Internatio nal Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt Internatio nal Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas Capitalized but undefined terms herein shall have the same meaning as ascribed to them in the Motion.

26 Case Document Filed in TXSB on 06/19/18 Page 3 of 22 overruled on the merits; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED that: The Motion is granted as set forth herein. Notwithstanding anything to the contrary in the Bankruptcy Code and Bankruptcy Rules, and pursuant to Bankruptcy Rule 3007(c) and Bankruptcy Local Rule , the Plan Administrator may file Omnibus Objections that include objections to claims on any basis provided for in the Objection Grounds. 3. The Plan Administrator shall file and prosecute any Omnibus Objections in accordance with the Objection Procedures attached hereto as Exhibit 1, which are hereby approved, and the other procedural safeguards set forth in Bankruptcy Rule 3007(e) and Bankruptcy Local Rule The form of Objection Notice attached hereto as Exhibit 2 is hereby approved. The provisions below shall apply to any Omnibus Objection that includes a claim of the United States of America or a claim of any agency of the United States of America (collectively, the United States ), notwithstanding anything to the contrary contained in this Order or the attached form of Objection Notice: (a) (b) (c) The deadline for the United States to respond to any Omnibus Objection will be thirty (30) days after the filing of the Omnibus Objection; There is no requirement that a response by the United States to an Omnibus Objection be actually received by the Plan Administrator or his counsel; instead it must be served on the Plan Administrator or his counsel pursuant to the Federal Rules of Bankruptcy Procedure; The Court will not hear any Omnibus Objection that includes a claim of the United States before the thirty-fourth (34th) day after such Omnibus Objection is filed, and the Plan Administrator shall not seek to schedule any hearing on any such Omnibus Objection before the thirty-fourth (34th) day after it is filed; HOU v1 2

27 Case Document Filed in TXSB on 06/19/18 Page 4 of 22 (d) (e) (f) (g) 6. Pursuant to BLR (d), the initial hearing on any Omnibus Objection that includes a claim of the United States will be non-evidentiary and used as a scheduling conference; If either the Plan Administrator or the United States believes that discovery is necessary in connection with an Omnibus Objection to a claim of the United States, either party may seek it pursuant to the Federal Rules of Bankruptcy Procedure and subject to any scheduling order that the Court may enter; The United States is not required to attach any documentation or other evidence to a response to an Omnibus Objection; and To the extent any of the procedures set forth in this Order or the attached form of Objection Notice concerning the form and timing of any response to an Omnibus Objection by the United States conflict with any Bankruptcy Local Rule or to any Federal Rule of Bankruptcy Procedure, the Bankruptcy Local Rules and Federal Rules of Bankruptcy Procedure shall govern. 5. Nothing in this Order shall affect the Plan Administrator s authority to pay claims to the extent authorized by a separate order of the Court Nothing in this Order shall obligate the Plan Administrator to settle or pursue a settlement of any particular claim. Settlements of claims may be negotiated and compromised by the Plan Administrator in his sole discretion (subject to applicable law) Notwithstanding the relief granted in this Order and any actions taken pursuant to such relief, nothing in this Order, the Motion, or the Objection Procedures shall be deemed: (a) an admission as to the validity of any prepetition claim against a Debtor entity; (b) a waiver of any right of the Plan Administrator to dispute any claim on any grounds; (c) a promise or requirement to pay any claim; (d) an implication or admission that any particular claim is of a type specified or defined in this Motion or any order granting the relief requested by this Motion; (e) a request or authorization to assume any prepetition agreement, contract, or lease pursuant to HOU v1 3

28 Case Document Filed in TXSB on 06/19/18 Page 5 of 22 section 365 of the Bankruptcy Code; or (f) a waiver of any right of the Plan Administrator under the Bankruptcy Code or any other applicable law Notice of the Motion as provided therein shall be deemed good and sufficient notice of such Motion and the requirements of Bankruptcy Rule 6004(a) and the Bankruptcy Local Rules are satisfied by such notice Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this Order shall be immediately effective and enforceable upon its entry The Plan Administrator is authorized to take all actions necessary to effectuate the relief granted in this Order in accordance with the Motion This Court retains exclusive jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order. Signed:, 2018 HONORABLE MARVIN ISGUR UNITED STATES BANKRUPTCY JUDGE HOU v1 4

29 Case Document Filed in TXSB on 06/19/18 Page 6 of 22 EXHIBIT 1 Objection Procedures HOU v1

30 Case Document Filed in TXSB on 06/19/18 Page 7 of 22 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: Chapter 11 COBALT INTERNATIONAL ENERGY, INC., Case No (MI) et al., 1 COBALT INTERNATIONAL ENERGY, INC., Case No (MI) et al., 1 Reorganized Debtors. (Jointly Administered) PROCEDURES FOR FILING OMNIBUS CLAIMS OBJECTIONS 1. Grounds for Omnibus Objections. In addition to those grounds expressly set forth in Bankruptcy Rule 3007(d), Nader Tavakoli, solely in his capacity as the Lead Member and Chairman of the Plan Administrator Committee of Cobalt International Energy, Inc. et al. (the Plan Administrator ) appointed under the Fourth Amended Joint Chapter 11 Plan of Cobalt International Energy, Inc. and Its Debtor Affiliates, confirmed on April 5, 2018 (the Plan ), 2 may file omnibus objections (each, an Omnibus Objection ) to Claims on the following grounds, in part or in whole: a. b. A Claim is a duplicate of another Claim in that it asserts a single claim against a single debtor or it asserts a claim for the same debt against another debtor (the Duplicate Claim ); A Claim has been amended or superseded (the Amended Claim ); 1 The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt Internatio nal Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas The Reorganized Debtors in the Chapter 11 Cases, along with the last four digits of each Reorganized Debtor s federal tax identification number, are: Cobalt International Energy, Inc. (1169); Cobalt Internatio nal Energy GP, LLC (7374); Cobalt International Energy, L.P. (2411); Cobalt GOM LLC (7188); Cobalt GOM # 1 LLC (7262); and Cobalt GOM # 2 LLC (7316). The Reorganized Debtors service address is: 920 Memorial City Way, Suite 100, Houston, Texas Capitalized but undefined terms used herein shall have the meanings given to such terms in the Plan. HOU v1

31 Case Document Filed in TXSB on 06/19/18 Page 8 of 22 c. d. e. f. g. h. i. j. k. l. m. A Claim has been filed after the Bar Date or the Governmental Bar Date as applicable (the Late Filed Claim ); A Claim is based on an equity interest (the Equity Interest Claim ); The Debtor(s) is unable to determine the validity of the claim because the claim was presented in a form that does not comply with applicable rules (the Unsupported Claim ); A Claim was incorrectly classified (the Misclassified Claim ); A Claim has been satisfied or released during the case in accordance with the Bankruptcy Code, applicable Bankruptcy Rules, or a Court Order (the Satisfied Claim ); A Claim was filed in the wrong case (the Wrongly Filed Claim ); A Claim is for a dollar amount which does not match the Debtors books and records and should be reduced (the Claim to be Adjusted ); A Claim was paid prepetition, or a Claim for which the Debtors books and records show no outstanding liability to the Claimant (the No Liability Claim ); A Claim that is disallowed pursuant to section 502 of the Bankruptcy Code (the Section 502 Disallowed Claim ); A Claim should be re-classified into Class 7 because the Claim arises out of the purchase or sale of a security of the debtor or affiliate pursuant to section 510(b) of the Bankruptcy Code (the Section 510(b) Claim ); and A Claim fails to specify a Debtor against whom the claim is asserted (the No Debtor Claim ). 2. Form of Omnibus Objection. Each Omnibus Objection shall conform to the following requirements: a. b. c. Each Omnibus Objection shall be numbered sequentially and, to the extent possible, state the category which forms the primary basis for the objection in its title; An exhibit listing Claims to which the Omnibus Objection relates shall be attached to the Omnibus Objection; Each exhibit shall contain only those Claims to which there is one common basis for objection; HOU v1 2

32 Case Document Filed in TXSB on 06/19/18 Page 9 of 22 d. e. A Claim for which there are two or more bases for objection (e.g., a claim that is objectionable as both an Untimely Claim and an Unsupported Claim) shall be referenced on each applicable exhibit attached to each applicable Omnibus Objection; and Each exhibit shall have the Claims listed alphabetically. 3. Number of Claims in Omnibus Objections. Each Omnibus Objection may include more than 100 claims. 4. Supporting Documentation. To the extent appropriate, Omnibus Objections may include an affidavit or declaration that provides a factual basis for the Plan Administrator s objection to the claims, including from someone with personal knowledge of the Debtors books and records and the manner in which they are maintained that states that the affiant or the declarant has reviewed the claims included therein and applicable supporting information and documentation provided therewith, made reasonable efforts to research the claim on the Debtors books and records, and determined that the books and records do not reflect the debt or the amount of debt that is alleged in the claim. 5. Claims Exhibits. An exhibit listing the claims that are subject to the particular Omnibus Objection will be attached thereto. Each exhibit will include only the claims to which there is a common basis for the objection. Claims for which there is more than one basis for the objection will be referenced on each exhibit applicable thereto. The exhibits will include, without limitation, the following information alphabetized by claimant: a. b. c. d. the claims that are the subject of the Omnibus Objection and, if applicable, the proof of claim number related thereto from the claims register; the asserted amount of the claim; the grounds for the objection; a cross-reference to the section of the Omnibus Objection discussing such claim; and HOU v1 3

33 Case Document Filed in TXSB on 06/19/18 Page 10 of e. other information, as applicable, including: (i) the proposed classification of claims the Plan Administrator seeks to reclassify; (ii) the reduced claim amounts of claims the Plan Administrator seeks to reduce; or (iii) the surviving claims of claimants affected by the Omnibus Objection. Objection Notice. Each Omnibus Objection will be accompanied by a customized objection notice, substantially in the form annexed to the Order as Exhibit 2 (the Objection Notice ), tailored, as appropriate, to address a particular creditor, claim, or objection, which will: a. b. c. d. e. f. describe the basic nature of the objection; inform creditors that their rights may be affected by the objection; describe the procedures for filing a written response (each, a Response ) to the objection, including all relevant dates and deadlines related thereto; identify the hearing date, if applicable, and related information; and describe how copies of proofs of claim, the Omnibus Objection, and other pleadings filed in the Chapter 11 Cases may be obtained. 7. Notice and Service. Each Omnibus Objection will be filed with the Court and served electronically using the Court s electronic filing system. In addition, each Omnibus Objection shall be served by United States First Class Mail, postage prepaid, on all claimants holding claims that are the subject of the Omnibus Objection. 8. Omnibus Claims Objection Hearings. Each Omnibus Objection shall be set for hearing no less than 30 days after service of the Omnibus Objection (each, a Hearing ), unless otherwise ordered by the Court. In the Plan Administrator s sole discretion, and after notice to the affected claimant, the Plan Administrator may (without further order of the Court) adjourn the Hearing on the Omnibus Objection to a subsequent hearing date by filing a notice or statement on the record. For claims subject to an Omnibus Objection and with respect to which either no Response is filed in accordance with the proposed response procedures and no HOU v1 4