Claim for Sale

Sale of claims which includes:

1. Seller is seeking declaratory relief that it holds a perfected ien in a drilling rig that Seller had transported and is the subject of the lawsuit. Seller is seeking to foreclose the lien in order to recover terminal charges and dead freight fees it accrued as an expense of transporting the rig (the “Rig Lien Claim”).
2. Lien Claim to drill pipe that is subject to the dispute in Cause No. 2016-16913, ASSURED RISK TRANSFER, LLC, et al vs. HOLLEY, GARY, et al., to which Seller is an intervening Plaintiff. Seller is claiming a $350,000 lien against the drill pipe in connection with storage charges incurred by Seller for the drill pipe since 2015 (the “Pipe Lien Claim”).
3. Moreover, because of the Seller’s bankruptcy filing, certain causes of action asserted by both ART and OEJP in the Litigation became property of the Bankruptcy Estate and, as such, are subject to the exclusive control of the Trustee. Specifically, these claims include the Texas common law fraudulent transfer claims asserted pre-petition in the Litigation against the Seller (and expressly exclude any other potential fraudulent transfer claims that are not already asserted in the Litigation) (the “Fraudulent Transfer Claims”).