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Tubular Synergy Group, LP (“TSG”) and OCTG Connections, LLC (“OCTG”), as debtors 

and debtors in possession (collectively, the “Debtors”) in the above-captioned chapter 11 cases 

(the “Chapter 11 Cases”) hereby file Debtors’ Emergency Motion for Entry of an Order (I) 

Directing Joint Administration of Chapter 11 Cases and (II) Granting Related Relief (this 

“Motion”). In support of this Motion, the Debtors respectfully represent as follows: 

Holland N. O’Neil (TX 14864700)

Stephen A. Jones (TX 24101270)

FOLEY & LARDNER LLP

2021 McKinney Avenue, Suite 1600

Dallas, TX 75201

Telephone: (214) 999-3000

Facsimile: (214) 999-4667

honeil@foley.com

sajones@foley.com

PROPOSED COUNSEL TO DEBTORS

AND DEBTORS IN POSSESSION

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

In re: 

Tubular Synergy Group, LP, 

Debtor. 

Tax I.D. No. 26-1743375 

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§ 

§ 

§ 

§

Chapter 11 

Case No.: 24-80056-11 

(Joint Administration Requested) 

In re: 

OCTG Connections, LLC, 

Debtor. 

Tax I.D. No. 82-2682025 

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§ 

§ 

§ 

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§ 

§ 

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§

Chapter 11 

Case No.: 24-80057-11 

(Joint Administration Requested) 

(Emergency Consideration Requested) 

DEBTORS’ EMERGENCY MOTION FOR ENTRY OF AN ORDER

(I) DIRECTING JOINT ADMINISTRATION OF CHAPTER 11 CASES

AND (II) GRANTING RELATED RELIEF

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I.

JURISDICTION AND VENUE

1. The United States Bankruptcy Court for the Northern District of Texas (the 

“Court”) has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This matter is a core 

proceeding within the meaning of 28 U.S.C. § 157(b). The Debtors confirm their consent, pursuant 

to Rule 7008 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), to the 

entry of a final order by the Court. 

2. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

3. The bases for the relief requested herein are section 105(a) of title 11 of the United 

States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), Bankruptcy Rule 1015(b), Rule 

1015-1(a) of the Local Bankruptcy Rules of the United States Bankruptcy Court for the Northern 

District of Texas (the “Local Rules”), and the Procedures for Complex Cases in the Northern 

District of Texas.

II.

BACKGROUND

4. On July 9, 2024 (the “Petition Date”), the Debtors filed voluntary petitions for 

relief under chapter 11 of Title 11 of the United States Code (the “Bankruptcy Code”). The 

Debtors remain in possession of their property and are managing their businesses as debtors-inpossession pursuant to Sections 1107(a) and 1108 of the Bankruptcy Code. The court has not 

appointed a trustee, and no official committee has been established.

5. Information on the Debtors, their businesses, and a summary of the relief requested 

in this Motion can be found in the Declaration of W. Byron Dunn, Sr. in Support of First Day 

Motions (the “First Day Declaration”), filed concurrently herewith and incorporated herein by 

reference.

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III.

RELIEF REQUESTED

6. By this Motion, pursuant to section 105(a) of the Bankruptcy Code and Bankruptcy 

Rule 1015, the Debtors seek entry of an order, substantially in the form attached hereto as Exhibit 

A (the “Proposed Order”), directing the joint administration and consolidation of the Chapter 11 

Cases for procedural purposes only. The Debtors also request that the Court administer the Chapter 

11 Cases under the case number assigned to TSG and that the Clerk of the Court maintain one file 

and one docket—under TSG—for the Chapter 11 Cases. 

7. The Debtors further request that the caption of the Chapter 11 Cases be modified 

as follows to reflect their joint administration:

1 The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s federal identification number,

are Tubular Synergy Group, LP (3375) and OCTG Connections, LLC (2025). The Debtors’ address is 8117 Preston 

Road, Suite 600, Dallas, TX 75225.

8. In addition, the Debtors request the Court to direct that a separate docket entry be 

made on the docket of the chapter 11 case for OCTG, substantially as follows: 

An order has been entered in accordance with Rule 1015(b) of the 

Federal Rules of Bankruptcy Procedure and Rule 1015-1(a) of the 

Local Bankruptcy Rules of the United States Bankruptcy Court for 

the Northern District of Texas directing joint administration of the 

chapter 11 cases of Tubular Synergy Group, LP, Case No. 24-

80056-11 and OCTG Connections, LLC, Case No. 24-80057-11. All 

further pleadings and other papers shall be filed in and all 

further docket entries shall be made in Case No. 24-80056-11.

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

In re: 

Tubular Synergy Group, LP, et al.,

1

Debtors. 

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§ 

§ 

§ 

§ 

§ 

Chapter 11 

Case No.: 24-80056-11 

(Jointly Administered)

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IV.

BASIS FOR RELIEF 

9. Bankruptcy Rule 1015(b) provides, in pertinent part, that “[i]f . . . two or more 

petitions are pending in the same court by or against . . . a debtor and an affiliate, the court may 

order a joint administration of the estates.” Fed. R. Bankr. P. 1015. The Debtors in these Chapter 

11 Cases are “affiliates,” as that term is defined in section 101(2) of the Bankruptcy Code. 

Accordingly, the Bankruptcy Code and Bankruptcy Rules authorize the Court to grant the relief 

requested herein.

10. Further, Local Rule 1015-1 provides additional authority for the Court to order joint 

administration of these Chapter 11 Cases:

When a case is filed for or against a debtor related to a debtor with a case 

pending in the Bankruptcy Court, a party in interest may file a motion for 

joint administration in each case. Motions for joint administration will be 

assigned for determination to the bankruptcy judge presiding over the first 

related case filed in this district, regardless of the division in which the case 

is filed.

N.D. Tex. Bankr. L.R. 1015-1(a).

11. Joint administration is generally non-controversial, and courts in this district 

routinely order joint administration in cases with multiple related debtors. See, e.g., In re Ebix,

Inc., No. 23-80004 (SWE) (Bankr. N.D. Tex. Dec. 19, 2023) [Docket No. 50]; In re Impel

Pharmaceuticals, Inc., No. 23-80016 (SGJ) (Bankr. N.D. Tex. Dec. 21, 2023) [Docket No. 53]; 

In re Tuesday Morning, No. 23-90001 (ELM) (Bankr. N.D. Tex. Feb. 16, 2023) [Docket No. 107]

(authorizing joint administration); In re Sunland Medical Foundation, No. 23-80000 (MVL)

(Bankr. N.D. Tex. Aug. 31, 2023) [Docket No. 37] (same); In re Northwest Senior Housing

Corporation, No. 22-30659 (MVL) (Bankr. N.D. Tex. April 19, 2022) [Docket No. 88] (same); In

re Studio Movie Grill Holdings, LLC, No. 20-32633 (SGJ) (Bankr. N.D. Tex. Oct. 27, 2020)

[Docket No. 48] (same); In re Tuesday Morning, No. 20-31476 (HDH) (Bankr. N.D. Tex. May 28,

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2020) [Docket No. 66] (same); In re Diamondback Industries, Inc., No. 20-41504 (ELM) (Bankr.

N.D. Tex. April 28, 2020) [Docket No. 41] (same); In re PHI, Inc., No. 1930923 (HDH) (Bankr. 

N.D. Tex. Mar 19, 2019) [Docket No. 57] (same). 

12. Given the integrated nature of the Debtors’ operations, joint administration of these 

Chapter 11 Cases will provide significant administrative convenience without harming the 

substantive rights of any party in interest. Many of the motions, hearings, and orders in these 

Chapter 11 Cases will affect each Debtor entity. The entry of an order directing joint administration 

of these Chapter 11 Cases will reduce fees and costs by avoiding duplicative filings and objections.

Joint administration also will allow the United States Trustee for the Northern District of Texas 

and all parties in interest to monitor these Chapter 11 Cases with greater ease and efficiency.

13. Moreover, joint administration will not adversely affect the Debtors’ respective 

constituencies because this Motion seeks only administrative, not substantive, consolidation of the 

Debtors’ estates. Parties in interest will not be harmed by the relief requested; instead, parties in 

interest will benefit from the cost reductions associated with the joint administration of these 

Chapter 11 Cases. Accordingly, the Debtors submit that the joint administration of these Chapter 

11 Cases is in the best interests of their estates, their creditors, and all other parties in interest.

V.

NOTICE

14. No trustee, examiner, or statutory creditors’ committee has been appointed in these 

Chapter 11 Cases. This Motion has been provided to (i) the Office of the United States Trustee for 

the Northern District of Texas; (ii) the Debtors’ secured lender and counsel to the Debtors’ secured 

lender; (iii) the agent for the Debtors’ secured lender and counsel to the agent for the Debtors’ 

secured lender; (iv) the holders of the 30 largest unsecured claims against the Debtors (on a 

consolidated basis); (v) the Internal Revenue Service; and (vi) all parties in interest who have 

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formally appeared and requested notice. The Debtors respectfully submit that no further notice of 

this Motion is required. 

15. The pleadings in these Chapter 11 Cases and supporting papers are available on the

Debtors’ website at https://cases.stretto.com/TSG or on the Bankruptcy Court’s website at 

https://ecf.txnb.uscourts.gov/. You can request any pleading you need from (i) the proposed 

noticing agent at: Stretto, 410 Exchange, Suite 100, Irvine, CA 92602, 888-838-7307 (toll-free), 

(TeamTSG@stretto.com) or (ii) proposed counsel for the Debtors at: Foley & Lardner LLP, c/o 

Stephen A. Jones, 2021 McKinney Avenue, Suite 1600, Dallas, Texas 75201 

(sajones@foley.com).

WHEREFORE, the Debtors respectfully request that the Court enter an order, substantially 

in the form attached hereto as Exhibit A, granting the relief requested herein and such other relief 

as the Court deems appropriate under the circumstances.

DATED: July 9, 2024 Respectfully submitted by: 

/s/ Holland N. O’Neil

Holland N. O’Neil (TX 14864700) 

Stephen A. Jones (TX 24101270) 

FOLEY & LARDNER LLP

2021 McKinney Avenue, Suite 1600 

Dallas, TX 75201 

Telephone: (214) 999-3000 

Facsimile: (214) 999-4667 

honeil@foley.com 

sajones@foley.com 

PROPOSED COUNSEL TO DEBTORS

AND DEBTORS IN POSSESSION

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CERTIFICATE OF SERVICE

I hereby certify that, on July 9, 2024, a true and correct copy of the foregoing document 

was served electronically by the Court’s PACER system. 

/s/ Stephen A. Jones 

 Stephen A. Jones 

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