Claims and Litigation Rights for Sale

Sale of all of Seller’s right, title and interest, if any, in and to the claims, causes of action, interests and rights of Seller as plead by Seller in its pleadings and documents filed of record on the docket for Adversary Proceeding No. 20-05046 (the “Claim”) and styled “Jon Christian Amberson and Amberson Natural Resources LLC, et. al., Plaintiffs v. James Argyle McAllen et. al., Defendants”, and which is presently on appeal to the United States District Court for the Western District of Texas in Cause No. 20-cv- 01193 (the “Litigation”), and all rights, benefits and standing of the Seller relating to the Claim and the Litigation, including: (i) the Seller’s rights to confirm or vacate any arbitration awards with any McAllen Party (as defined in the Litigation”), and (ii) all of Seller’s claims or rights to affirmative recovery of money or property against any McAllen Party, including but not limited to injunctive relief, claims derivative of the seller, declaratory relief, contract claims, tort claims, recovery of costs and attorney fees, and (iii) all of Seller’s rights, claims, counterclaims, offsets, recoupments, or any other pecuniary interest in any dispute between the Debtor and any McAllen Party as plead in the Litigation, and (iv) the membership interest of the Debtor’s estate in Cannon Grove Investments, LLC (“CGI”), including the ninety per cent (90%) membership interest which the Debtor assigned to James Argyle McAllen on November 9, 2020 and any rights inherent in such CGI membership interest, and (v) all of the Debtor estate’s rights under the “limited liability agreement” governing CGI (collectively, the “Transferred Rights”).