IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
In re:
SANCHEZ ENERGY CORPORATION, et al.,1 Debtors. ) ) ) ) ) ) ) Chapter 11
Case No. 19-34508 (MI) (Jointly Administered)
NOTICE OF FILING OF EXHIBIT E OF THE PLAN SUPPLEMENT FOR THE JOINT CHAPTER 11 PLAN OF REORGANIZATION OF SANCHEZ ENERGY CORPORATION AND ITS DEBTOR AFFILIATES
PLEASE TAKE NOTICE that as contemplated by the Joint Chapter 11 Plan of
Reorganization of Sanchez Energy Corporation and Its Debtor Affiliates (as may be amended or modified from time to time and including all exhibits and supplements thereto, the “Plan”), the above-captioned Debtors filed Plan Supplement2 Exhibit D—the Schedule of Retained Causes
of Action on April 24, 2020 [Docket No. 1148].
PLEASE TAKE FURTHER NOTICE that on April 29, 2020, the Debtors filed (i) Plan
Supplement Exhibit B—the Schedule of Rejected Executory Contracts and Unexpired Leases and Exhibit C—the Schedule of Assumed Executory Contracts and Unexpired Leases [Docket No. 1188], and (ii) Plan Supplement Exhibit A—the Schedule of New Organizational
Documents [Docket No. 1194], as may be further modified, amended, or supplemented from time
to time to the extent permitted by the Confirmation Order, Plan and the Plan Supplement.
PLEASE TAKE FURTHER NOTICE that the Debtors hereby file Plan Supplement Exhibit E—Members of the Reorganized SN Board and Officers.
PLEASE TAKE FURTHER NOTICE that the Debtors reserve all rights, with the
consent of any applicable counterparties to the extent required under the Plan to alter, amend, modify or supplement the Plan Supplement and any of the documents contained therein in accordance with the terms of the Plan; provided that, if any document in this Plan Supplement is altered, amended, modified or supplemented in any material respect prior to the Combined Hearing, the Debtors will file a redline of such document with the Court.
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification
PLEASE TAKE FURTHER NOTICE that the documents contained in the Plan
Supplement are integral to, and are considered part of, the Plan. If the Plan is approved, the documents contained in the Plan Supplement will be approved by the Court pursuant to the order confirming the Plan.
PLEASE TAKE FURTHER NOTICE that the Debtors will seek confirmation of the
Plan at the Combined Hearing set for April 30, 2020 at 9:00 a.m., prevailing Central Time before United States Bankruptcy Judge Marvin Isgur, Courtroom No. 404, 515 Rusk Avenue, Houston, TX 77002.
PLEASE TAKE FURTHER NOTICE that copies of all documents filed in this Chapter
Houston, Texas Dated: April 29, 2020 /s/ Matthew D. Cavenaugh
JACKSON WALKER L.L.P. AKIN GUMP STRAUSS HAUER & FELD LLP
Matthew D. Cavenaugh (TX Bar No. 24062656) Marty L. Brimmage, Jr. (TX Bar No. 00793386) Elizabeth Freeman (TX Bar No. 24009222)
1401 McKinney Street, Suite 1900 Houston, Texas 77010
Telephone: (713) 752-4284 Facsimile: (713) 308-4184 [email protected] Counsel for the Debtors and Debtors in Possession
Lacy M. Lawrence (TX Bar No. 24055913) 2300 N. Field Street, Suite 1800
Dallas, Texas 75201 Telephone: (214) 969-2800 Facsimile: (214) 969-4343 [email protected] [email protected] - and -
Ira S. Dizengoff (pro hac vice) Lisa Beckerman (pro hac vice) Jason P. Rubin (pro hac vice) One Bryant Park
New York, New York 10036 Telephone: (212) 872-1000 Facsimile: (212) 872-1002 [email protected] [email protected] [email protected] - and -
Certificate of Service
I certify that on April 29, 2020, 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.
EXHIBIT E
Pursuant to Article IV.J. of the Plan and section 1129(a)(5) of the Bankruptcy Code, the Secured Ad Hoc Group proposes the following directors and officers to serve on behalf of Reorganized SN:
Position Name
Reorganized SN Board Members
Nate Van Duzer Wilson Handler
Independent Member To Be Selected
Reorganized SN Officers
Cameron W. George, Interim CEO, Executive Vice President and Chief Financial Officer Gregory B. Kopel, Executive Vice President, General Counsel and Secretary
Nate Van Duzer
Nate Van Duzer, Fidelity Investments.
Wilson Handler
Wilson Handler, Apollo Global Management.
Cameron W. George
Cameron George is currently the Executive Vice President and Chief Financial Officer of SN, and serves in the same capacity for (i) SN’s consolidated direct and indirect Debtor and non-Debtor subsidiaries (other than as discussed below) and (ii) SOG. In addition, since March 2017, Mr. George has served as Chief Financial Officer and Treasurer and as a member of the board of directors of UnSub GP, the general partner of SN UnSub, both of which are non-Debtor unrestricted subsidiaries of SN.
Gregory B. Kopel
