Case Document 265 Filed in TXSB on 01/15/21 Page 1 of 14

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

- ---In re

SUPERIOR ENERGY SERVICES, INC., et al., Debtors.1 - ---x : : : : : x Chapter 11 Case No. 20-35812 (DRJ) (Jointly Administered)

DECLARATION OF JAMES LEE OF

KURTZMAN CARSON CONSULTANTS LLC REGARDING SOLICITATION OF VOTES AND TABULATION OF BALLOTS CAST ON FIRST AMENDED JOINT PREPACKAGED PLAN OF REORGANIZATION FOR SUPERIOR ENERGY SERVICES, INC. AND ITS AFFILIATE DEBTORS UNDER CHAPTER 11 OF THE BANKRUPTCY CODE

I, James Lee, declare under the penalty of perjury:

1. I am a Vice President, Public Securities Services, employed by Kurtzman Carson Consultants LLC (“KCC”), the administrative agent retained by the above-captioned debtors and debtors-in-possession (collectively, the “Debtors”) to assist with the solicitation and voting process in the above-captioned chapter 11 cases (the “Chapter 11 Cases”), pursuant to the Order Authorizing

Employment and Retention of Kurtzman Carson Consultants LLC as Claims, Noticing, and Solicitation Agent Effective as of the Petition Date [Docket No. 77]. My business address is 1290

Avenue of the Americas, 9th Floor, New York, NY 10104. I am over the age of 18 and not a party to

this action.

1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: Superior Energy Services, Inc. (9388), SESI, L.L.C. (4124), Superior Energy Services-North America Services, Inc. (5131), Complete Energy Services, Inc. (9295), Warrior Energy Services Corporation (9424), SPN Well Services, Inc. (2682), Pumpco Energy Services, Inc. (7310), 1105 Peters Road, L.L.C. (4198), Connection Technology, L.L.C. (4128), CSI Technologies, LLC (6936), H.B. Rentals, L.C. (7291), International Snubbing Services, L.L.C. (4134), Stabil Drill Specialties, L.L.C. (4138), Superior Energy Services, L.L.C. (4196), Superior Inspection Services, L.L.C. (4991), Wild Well Control, Inc. (3477), and Workstrings International, L.L.C. (0390). The Debtors’ address is 1001 Louisiana Street, Suite 2900, Houston, Texas 77002.

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2. Varouj Bakhshian, Director at KCC, assisted in the solicitation and tabulation of Class 6 General Unsecured Claims Against Parent and Notice of Non-Voting and Opt-Out Forms described herein.

3. On December 8, 2020, the Court entered the Order (I) Conditionally Approving

Disclosure Statement, (II) Scheduling Combined Hearing on (A) Adequacy of Disclosure Statement and (B) Confirmation of Plan, (III) Establishing Deadline to Object to Disclosure Statement and Plan and Form of Notice Thereof, (IV) Approving Solicitation Procedures and Forms of Ballots and Notices of Non-Voting Status, (V) Conditionally Waiving Requirement of Filing Schedules and Statements and of Convening Section 341 Meeting of Creditors, with Respect to Certain Creditors, and (IV) Granting Related Relief [Docket No. 98] (the “Disclosure Statement Interim Order”) establishing, among

other things, certain solicitation and voting tabulation procedures (the “Solicitation Procedures”) 4. KCC worked with the Debtors and their advisors to solicit votes to accept or reject the

Joint Prepackaged Plan of Reorganization for Superior Energy Services, Inc. and its Affiliate Debtors under Chapter 11 of the Bankruptcy Code [Docket No. 11], dated December 7, 2020 (as amended,

supplemented, or modified from time to time, the “Plan”) and to tabulate the ballots of creditors voting to accept or reject the Plan in accordance with the Solicitation Procedures. Except as otherwise noted, I could and would testify to the following based upon my personal knowledge. I am authorized to submit this Declaration on behalf of KCC.

5. Pursuant to the Plan, holders of (a) Prepetition Notes Claims Against Parent in Class 5, (b) General Unsecured Claims Against Parent in Class 6, and (c) Prepetition Notes Claims Against Affiliate Debtors in Class 7 (together, the “Voting Classes”) were entitled to vote on the Plan. The Debtors established December 3, 2020 as the record date for determining which Holders of Claims in the Voting Classes were entitled to vote to accept or reject the Plan (the “Voting Record Date”). No other classes were entitled to vote on the Plan.

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Service and Transmittal of Solicitation Packages and Tabulation Process

6. The Solicitation Procedures adhered to by KCC for the solicitation and tabulation of votes are outlined in the Disclosure Statement for Joint Prepackaged Plan of Reorganization for

Superior Energy Services, Inc. and its Affiliate Debtors under Chapter 11 of the Bankruptcy Code

[Docket No. 12] (the “Disclosure Statement”) and the ballots distributed to parties entitled to vote on the Plan, and were summarized in the Disclosure Statement Interim Order.

I. Prepetition Solicitation

7. KCC relied on security position reports provided by The Depository Trust Company (“DTC”) as of the Voting Record Date to identify the bank and brokerage firms (the “Nominees”) that held Class 5 and Class 7 Claims on behalf of underlying beneficial owners who were entitled to vote to accept or reject the Plan. Pursuant to the Solicitation Procedures, only holders in Class 5 and 7 who were Eligible Holders2 as of the Voting Record Date were entitled to vote to accept or reject the

Prepetition Noteholder Ballots.

8. On December 5, 2020, KCC commenced service of the Solicitation Packages upon Nominees for subsequent distribution to Eligible Holders of Class 5 Prepetition Notes Claims Against Parent and Class 7 Prepetition Notes Claims Against Affiliates. A Certificate of Service evidencing the service of the foregoing was filed with the Court on December 7, 2020 [Docket No. 42].

II. Postpetition Solicitation

9. On December 10, 2020, KCC served the Solicitation Packages upon the Nominees, or Nominees’ agents, for subsequent forwarding to the underlying beneficial owners of Non-Eligible Holders3 of Class 5 Prepetition Notes Claims Against Parent, Class 7 Prepetition Notes Claims Against

2 “Eligible Holders” are beneficial holders of Prepetition Notes Claims Against Parent that are also “accredited investors”, as such term is defined in Rule 501 of Regulation D of the Securities Act.

3 “Non-Eligible Holders” are beneficial holders of Prepetition Notes Claims Against Parent that are not “accredited investors”, as such term is defined in Rule 501 of Regulation D of the Securities Act.

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Affiliates; and Class 6 General Unsecured Claims Against Parent. Additionally, on December 10, 2020, KCC posted links to the electronic versions of the Notice Of (I) Commencement Of Chapter 11

Bankruptcy Cases, (II) Combined Hearing On Disclosure Statement, Confirmation Of Joint Prepackaged Chapter 11 Plan, And Related Matters, And (III) Objection Deadlines, And Summary Of Debtors’ Joint Prepackaged Chapter 11 Plan (the, “Combined Notice”), Disclosure Statement

Interim Order, Plan, and Disclosure Statement on the face of the public access website at www.kccllc.net/superior.

10. On December 11, 2020, KCC served the Solicitation Packages on the Non-Voting Classes in accordance with the Disclosure Statement Interim Order and Solicitation Procedures. KCC also relied on a registered shareholder list provided by the Debtors’ stock transfer agent as of the Voting Record Date in connection with the distribution and tabulation of the non-voting Class 10 Old Parent Interest Non-Voting Notice and Opt-Out Form. A Certificate of Service evidencing the service of the foregoing, as well as the service identified in paragraph 8 hereof, was filed with the Court on December 16, 2020 [Docket No. 164].

11. Additionally, between December 30, 2020 and January 8, 2021, KCC served the Solicitation Packages on Class 6 General Unsecured Claims Against Parent creditors who filed a proof of claim against the parent, Superior Energy Services, Inc. Certificates of Service evidencing the service of the foregoing were filed with the Court on January 4, 2021 [Docket No. 200], January 7, 2021 [Docket No. 205] and January 11, 2021 [Docket No. 224].

III. Tabulation Process

12. In accordance with the Solicitation Procedures, KCC reviewed, determined the validity of, and tabulated the ballots submitted to vote on the Plan. Each ballot submitted to KCC was processed in accordance KCC’s standard tabulation procedures and in compliance with the Solicitation Procedures. To be included in the tabulation results as valid, a ballot must have been (a) properly

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completed pursuant to the Solicitation Procedures, (b) executed by the relevant holder entitled to vote on the Plan (or such holder’s authorized representative), (c) returned to KCC via electronic submission or another approved method of delivery set forth in the Solicitation Procedures, and (d) received by KCC by 5:00 p.m. (prevailing Central Time) on January 8, 2021 (the “Voting Deadline”).

13. All valid ballots cast by holders entitled to vote in the Voting Classes and received by KCC on or before the Voting Deadline were tabulated pursuant to the Solicitation Procedures.

14. The final tabulation of votes cast by timely and properly completed ballots received by KCC is attached hereto as Exhibit A.

15. A report of all Ballots excluded from the final tabulation prepared by KCC, and the reasons for exclusion of such Ballots, is attached hereto as Exhibit B.

16. KCC conducted a hypothetical tabulation to include any defective Class 5, Class 6, and Class 7 Ballots that were excluded from the final tabulation in Exhibit A, where such defective Ballot either cast a vote to reject the Plan or did not indicate a vote to accept or reject the Plan. This hypothetical tabulation is attached hereto as Exhibit C. The hypothetical tabulation counted each of these defective Ballots as valid and each as a vote to reject the Plan. For the avoidance of doubt, the hypothetical results in Exhibit C do not include any defective Ballots that (a) accepted the Plan, (b) were superseded by otherwise valid Ballots, and/or (c) did not include a voting amount.

17. KCC conducted a hypothetical tabulation to combine Class 5 and Class 6 into a single class. This hypothetical tabulation is attached hereto as Exhibit D. More than two-thirds in the amount of Allowed Claims (as defined in the Plan) and 50% in the number of Holders (as defined in the Plan) in Classes 5 and 6, on a combined basis, voted to accept the Plan. This result stands even if, for voting purposes, Claims in Class 6 were set at their asserted contingent and unliquidated amounts, as opposed to the customary $1.00 for such Claims.

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To the best of my knowledge, information and belief, I declare under penalty of perjury that the foregoing information concerning the distribution, submission and tabulation of Ballots in connection with the Plan is true and correct.

Dated: January 15, 2021 /s/ James Lee

James Lee

Vice President, Public Securities Services Kurtzman Carson Consultants LLC

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Exhibit A Tabulation Summary Class Name Class Description Members Voted Members Accepted Members Rejected % Members Accepted % Members Rejected Total Amount

Voted Amount Accepted Amount Rejected

% Amount Accepted

% Amount Rejected

5 Prepetition Notes Claims Against Parent 559 555 4 99.28% 0.72% $1,218,504,380.00 $1,218,426,380.00 $78,000.00 99.99% 0.01%

6 General Unsecured Claims Against Parent 25 15 10 60.00% 40.00% $92,759.59 $72,875.59 (1) $19,884.00 78.56% 21.44%

7 Prepetition Notes Claims Against Affiliates 559 555 4 99.28% 0.72% $1,218,504,380.00 $1,218,426,380.00 $78,000.00 99.99% 0.01%

(1) Baker and McKenzie LLP submitted two ballots in the amounts of $9,649,552.15 and $11,756.05. These ballots were counted as $1.00 each for voting purposes.

Superior Energy Services, Inc., et al. Case No.: 20-35812

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Exhibit B Unacceptable Ballots

Date Filed Ballot

No. Creditor Name

Tabulated Vote Amount Accept or Reject? Vote Voting Amount Provided by Creditor Opt-Out

Election Debtor Name Reason Unacceptable

01/07/2021 109 ROUL, KELLAND AND STONE $1.00 Abstained Unacceptable Undetermined YES Superior Energy Services, Inc. Creditor did not vote to either accept or reject. 01/07/2021 111 SHELL OFFSHORE INC. $1.00 Abstained Unacceptable No Response YES Superior Energy Services, Inc. Creditor did not vote to either accept or reject. 01/08/2021 126 ADRIAN ALGERIBIYA, ET AL. $1.00 Reject Unacceptable Undetermined YES Superior Energy Services, Inc. Creditor not entitled to vote in Class 6. Claim is filed as a PRIORITY claim. 01/07/2021 107 AGFINITY INC $27,479.02 Accept Unacceptable No Response NO Complete Energy Services, Inc. Creditor not entitled to vote in Class 6. Claim is not against the Parent.

Superior Energy Services, Inc., et al. Case No.: 20-35812

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Exhibit C

Hypotherical Voting Class Summary with Class 6 Unacceptable Ballots Assumed as Rejecting

Class Name Class Description Members Voted Members Accepted Members Rejected % Members Accepted % Members Rejected Total Amount Voted Amount Accepted Amount Rejected % Amount Accepted % Amount Rejected 6 General Unsecured Claims Against Parent 25 15 10 60.00% 40.00% $92,759.59 $72,875.59 $19,884.00 78.56% 21.44%

Class Name Class Description Members Voted Members Accepted Members Rejected (Including Unacceptable) % Members Accepted % Members Rejected Total Amount Voted Amount Accepted Amount Rejected % Amount Accepted % Amount Rejected 6 General Unsecured Claims Against Parent 28 15 13 53.57% 46.43% $92,762.59 $72,875.59 $19,887.00 78.56% 21.44%

ORIGINAL VOTE SUMMARY OF CLASS 6

HYPOTHETICAL VOTE SUMMARY OF CLASS 6 THAT INCLUDES DEFECTIVE BALLOTS VOTING TO REJECT

Superior Energy Services, Inc., et al. Case No.: 20-35812

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Exhibit D

Hypothetical Parent Classes 5 and 6 Combined Voting Summary

Class Name Class Description Members Voted Members Accepted Members Rejected % Members Accepted % Members Rejected Total Amount

Voted Amount Accepted Amount Rejected

% Amount Accepted

% Amount Rejected

5 Prepetition Notes Claims Against Parent 559 555 4 99.28% 0.72% $1,218,504,380.00 $1,218,426,380.00 $78,000.00 99.99% 0.01%

6 General Unsecured Claims Against Parent 25 15 10 60.00% 40.00% $228,900,674.59 $72,875.59 $228,827,799.00 (1) 0.03% 99.97%

5/6 All Claims Against Parent Combined 584 570 14 97.60% 2.40% $1,447,405,054.59 $1,218,499,255.59 $228,905,799.00 84.19% 15.81%

(1) Assumes all valid Class 6 rejecting ballots are counted in the full amounts asserted by creditors.

Superior Energy Services, Inc., et al. Case No.: 20-35812

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