4865-2381-1794v.1 023074.00001

Davor Rukavina

State Bar No. 24030781

Thomas D. Berghman

State Bar No. 24082683

Julian Vasek

State Bar No. 24070790

MUNSCH HARDT KOPF & HARR, P.C.

500 N. Akard St., Suite 4000

Dallas, TX 75201

Telephone: 214.855.7500

Facsimile: 214.855.7584

PROPOSED ATTORNEYS FOR THE DEBTOR

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE:

PEGASO ENERGY SERVICES, LLC

 Debtor.

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Case No. 24-42429-mxm11

DEBTOR’S EMERGENCY MOTION TO ESTABLISH COMPLEX 

CASE SERVICE LIST AND NOTICE PROCEDURES

Emergency relief has been requested. Relief is requested not 

later than July 22, 2024. 

If you object to the relief requested or you believe that 

emergency consideration is not warranted, you must appear at 

the hearing if one is set, or file a written response prior to the 

date that relief is requested in the preceding paragraph. 

Otherwise, the Court may treat the pleading as unopposed and 

grant the relief requested.

A virtual hearing will be conducted on this matter on July 22, 

2024 at 9:30 a.m. (CT) in Room 128, U.S. Courthouse, 501 W. 

Tenth Street, Fort Worth, Texas 76102. You may participate in 

the hearing by an audio and video connection.

Audio communication will be by use of the Court’s dial-in 

facility. You may access the facility at 1.650.479.3207. Video 

communication will be by the use of the Cisco WebEx platform. 

Connect via the Cisco WebEx application or click the link on 

Judge Mullin’s home page. The meeting code is 2310-650-8783. 

Click the settings icon in the upper right corner and enter your 

name under the personal information setting.

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Hearing appearances must be made electronically in advance of 

electronic hearings. To make your appearance, click the 

“Electronic Appearance” link on Judge Mullin’s home page. 

Select the case name, complete the required fields and click 

“Submit” to complete your appearance.

Pegaso Energy Services, LLC, as debtor-in-possession in the above-referenced chapter 11 

cases (the “Debtor”) hereby files this Debtor’ Emergency Motion to Establish Complex Case 

Service List and Notice Procedures (the “Motion”). In support of the Motion, the Debtor 

respectfully states as follows:

Jurisdiction and Venue

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

Court”) has jurisdiction over the subject matter of this Motion pursuant to 28 U.S.C. § 1334. The 

District Court’s jurisdiction has been referred to this Court pursuant to 28 U.S.C. § 157 and the 

District Court’s Miscellaneous Order No. 33, Order of Reference of Bankruptcy Cases and 

Proceedings Nunc Pro Tunc dated August 3, 1984. This is a core matter pursuant to 28 U.S.C. 

§ 157(b), which may be heard and finally determined by this Court. Venue is proper pursuant to 

28 U.S.C. §§ 1408 and 1409. 

Background 

2. On July 15, 2024 (the “Petition Date”), the Debtor filed a voluntary petition for 

relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”) commencing 

the above captioned case (the “Chapter 11 Case”). The Debtor continues to manage and operate 

its business as a debtor-in-possession pursuant to Bankruptcy Code §§ 1107 and 1108. 

3. An official committee of unsecured creditors has yet to be appointed in this Chapter 

11 Case. Further, no trustee or examiner has been requested or appointed in this Chapter 11 Case. 

4. A detailed description of the Debtor and its business, and the facts and 

circumstances supporting the Motion and the Debtor’s Chapter 11 Case, are set forth in greater 

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detail in the Declaration of Cole Stout in Support of the Debtor’s Chapter 11 Petition and First 

Day Motions (the “First Day Declaration”), which is incorporated by reference in this Motion. 

Relief Requested

5. The Debtor requests the entry of an order, substantially in the form attached as 

Exhibit A, (the “Proposed Order”) (a) establishing a complex case service list, and (b) setting 

notice procedures with respect thereto.

6. The Debtor anticipates there will be more than 200 notice parties in this Chapter 11 

Case. The costs associated with photocopying and mailing routine pleadings to all potential 

creditors going forward would be substantial and exceedingly burdensome, especially because it 

is not necessary to apprise all creditors and parties-in-interest of routine matters that do not affect 

their rights. Accordingly, the Debtor believes it is appropriate for the Court to limit notice in this 

Chapter 11 Case such that the Debtor and all other parties-in-interest do not incur needlessly large, 

recurring expenses in serving routine pleadings. 

7. By and through this Motion, the Debtor requests the entry of an order limiting 

notice and establishing certain notice procedures described herein (the “Procedures”). Given the 

large number of parties-in-interest in this Chapter 11 Case, the Debtor (and other parties) are 

currently required to expend a substantial amount of resources in copying costs, postage charges, 

and other handling expenses. Continuing to provide notice of all pleadings, motions, applications, 

notices, briefs, objections, responses, affidavits, declarations, or other writings filed in this Chapter 

11 Case (each a “Filing”, collectively, the “Filings”) to each creditor and party-in-interest will be 

unnecessarily burdensome and costly to the estates.

8. The Debtor therefore proposes to establish an official Complex Service List (the 

“Complex Service List”) that would include the following parties: the Debtor, the Debtor’ counsel, 

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counsel for the proposed DIP lender, members of any unsecured creditors’ committee and counsel 

for the unsecured creditors’ committee, the 20 largest unsecured creditors, the U.S. Trustee, the 

United States Attorney, the Internal Revenue Service, all secured creditors, and any party that 

requests notice pursuant to Bankruptcy Rule 2002.

9. The Debtor further proposes that notice of any Filing, other than an event or 

deadline that must be served on all creditors pursuant to Bankruptcy Rule 2002, be served only on 

(a) the parties on the Complex Service List, (b) any party who has filed a notice of appearance and 

request for service of pleadings but has not yet been added to the Complex Service List, and (c) 

any party whose interests the specific Filing affects.

10. The Debtor further proposes to file the initial Complex Service List within seven 

(7) days after entry of an order by the Court granting this Motion, and the Debtor will update the 

Complex Service List and file a copy thereof every fourteen (14) days for the two months and 

every thirty (30) days thereafter during the pendency of this Chapter 11 Case. In the event there 

are no changes to the Complex Service List within a thirty (30) day period, no update will be 

required.

11. As required by the Bankruptcy Rules, the matters for which notice would not be 

limited include the following: (a) notice of the meeting of creditors pursuant to section 341 of the 

Bankruptcy Code; (b) notice of the time fixed for filing proofs of claim pursuant to Bankruptcy 

Rule 3003(c); (c) notice of the time fixed for filing objections to and the hearing on approval of a 

disclosure statement; (d) notice of the time fixed for accepting or rejecting or filing objections to 

and the hearing on the confirmation of a plan of reorganization; (e) notice of any hearing on 

dismissal or conversion of the Chapter 11 Case; (f) notice of a hearing on any entity’s request for 

compensation or reimbursement of expenses exceeding $1,000; (g) a proposed use, sale, or lease 

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of property of the estate other than in the ordinary course of business; (h) the hearing on approval 

of a compromise or settlement of a controversy other than approval of an agreement pursuant to 

Rule 4001(d), unless the court for cause shown directs that notice not be sent; and (i) notice of any 

matter with respect to which a different form of notice is ordered to be given by this Court. 

12. Furthermore, to the extent that any Filing particularly or discretely affects any 

party’s rights, the Debtor would be required to provide proper notice as otherwise required by due 

process and all applicable rules and procedures. 

Basis for Relief Requested

13. Section 105(a) of the Bankruptcy Code, in conjunction with Bankruptcy Rule 9007 

and certain subsections of Bankruptcy Rule 2002, permit the Court to establish notice standards as 

to most pleadings which are likely to be filed in a bankruptcy case. See FED. R. BANKR. P. 

2002(a)(2) and (a)(3) (recognizing court’s ability to modify notice requirements); FED. R. BANKR.

P. 2002(m) (providing authority to determine notice requirements as to Bankruptcy Rule 2002 

matters); FED. R. BANKR. P. 9007 (providing overall authority to regulate notices). 

14. The establishment of the requested procedures, including limiting notice of certain 

matters to those parties included on the Complex Service List, will not alter or modify in any way 

the right of a party whose interests are directly affected by a particular matter to receive all 

pleadings and other court documents filed in connection with that matter. However, limiting the 

service of Filings as proposed herein will avoid unnecessary expense to the Debtor and other 

parties-in-interest by ensuring that only those parties with a direct interest in a particular matter 

will be served. Approval of this Motion and the proposed Complex Service List will therefore 

reduce administrative costs, allow for the conservation of resources, and preserve the Debtor’s 

assets for the benefit of the estates and creditors thereof.

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15. Based on the foregoing, the Debtor submits that the requested procedures are both 

reasonable and appropriate. Moreover, to the extent that any party wishes to be included on the 

Complex Service List and obtain notice of each Filing, that party need only file a notice of 

appearance with the Court, the burden for which is minimal. 

Notice

16. Notice of this Motion will be provided to the proposed Complex Service List. 

Based on the urgency of the circumstances surrounding this Motion and the nature of the relief 

requested herein, the Debtor respectfully submits that no further notice is required. 

Conclusion

WHEREFORE, based on the foregoing, the Debtor respectfully request that the Court (i) 

grant the Motion, and (ii) grant such other and further relief as is just and proper. 

RESPECTFULLY SUBMITTED this 18th day of July, 2024. 

/s/ Julian P. Vasek 

Davor Rukavina 

State Bar No. 24030781 

Thomas D. Berghman

State Bar No. 24082683 

Julian Vasek

State Bar No. 24070790 

MUNSCH HARDT KOPF & HARR, P.C.

500 N. Akard St., Suite 4000 

Dallas, TX 75201 

Telephone: 214.855.7500 

Facsimile: 214.855.7584 

PROPOSED ATTORNEYS FOR THE 

DEBTOR

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CERTIFICATE OF SERVICE

 I hereby certify that separate certificate of service will be filed with respect to all first-day 

motions. 

/s/ Julian P. Vasek 

Julian P. Vasek

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4865-2381-1794v.1 023074.00001

EXHIBIT A

PROPOSED ORDER

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4865-2381-1794v.1 023074.00001

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE:

PEGASO ENERGY SERVICES, LLC

 Debtor.

§

§ 

§ 

§ 

§ 

 Case No. 24-42429-mxm11

ORDER GRANTING DEBTORS’ EMERGENCY MOTION TO ESTABLISH 

COMPLEX CASE SERVICE LIST AND NOTICE PROCEDURES

Upon the Debtor’ Emergency Motion to Establish Complex Case Service List and Notice 

Procedures (the “Motion”)1 of Pegaso Energy Services, LLC (the “Debtor”); and the Court having 

jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. §§ 157 

and 1334, and the Order of Reference of Bankruptcy Cases and Proceedings Nunc Pro Tunc (N.D. 

Tex. Aug. 3, 1984); and consideration of the Motion and the requested relief being a core 

proceeding pursuant to 28 U.S.C. § 157(b); and it appearing that venue is proper before this Court 

pursuant to 28 U.S.C. §§ 1408 and 1409; and due and proper notice of the Motion having been 

provided, and it appearing that no other or further notice need be provided; and the Court having 

 

1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion.

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reviewed the Motion; and the Court having held a hearing on the Motion (the “Hearing”); and all 

objections, if any, to the Motion have been withdrawn, resolved, or overruled; and the Court having 

determined that the legal and factual bases set forth in the Motion establish just cause for the relief 

granted herein; and upon all of the proceedings had before the Court, the record at the Hearing, 

and after due deliberation and sufficient cause appearing therefor, 

IT IS HEREBY ORDERED THAT:

1. The Motion is GRANTED as set forth herein. 

2. The Debtor shall establish an official Complex Service List (the “Complex Service 

List”) for this Chapter 11 Case that will include only the following parties: the Debtor, the Debtor’ 

counsel, counsel for the proposed DIP lender, members of any unsecured creditors’ committee and 

counsel for the unsecured creditors’ committee, the 20 largest unsecured creditors, the U.S. 

Trustee, the United States Attorney, the Internal Revenue Service, all secured creditors, and any 

party that requests notice pursuant to Bankruptcy Rule 2002. 

3. Notice of any Filing in the Bankruptcy Case, other than those events or deadlines 

listed below that must be served on all creditors pursuant to Bankruptcy Rule 2002, be served only 

on (a) the parties on the Complex Service List, (b) any party who has filed a notice of appearance 

and request for service of pleadings in the Chapter 11 Case but has not yet been added to the 

Complex Service List, and (c) any party whose interests the specific Filing affects.

4. The Debtor must file the initial Complex Service List within seven (7) days after 

entry of this Order, and the Debtor must update the Complex Service List and file a copy of the 

updated Complex Service List every fourteen (14) days for the first two months and every thirty 

(30) days thereafter during the pendency of the Bankruptcy Case. In the event there are no changes 

to the Complex Service List within a thirty (30) day period, no update will be required. 

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5. The matters for which notice would not be limited include the following: (a) notice 

of the meeting of creditors pursuant to section 341 of the Bankruptcy Code; (b) notice of the time 

fixed for filing proofs of claim pursuant to Bankruptcy Rule 3003(c); (c) notice of the time fixed 

for filing objections to and the hearing on approval of a disclosure statement; (d) notice of the time 

fixed for accepting or rejecting or filing objections to and the hearing on the confirmation of a plan 

of reorganization; (e) notice of any hearing on dismissal or conversion of the Chapter 11 Case; (f) 

notice of a hearing on any entity’s request for compensation or reimbursement of expenses 

exceeding $1,000; (g) a proposed use, sale, or lease of property of the estate other than in the 

ordinary course of business; (h) the hearing on approval of a compromise or settlement of a 

controversy other than approval of an agreement pursuant to Rule 4001(d), unless the court for 

cause shown directs that notice not be sent; and (i) notice of any matter with respect to which a 

different form of notice is ordered to be given by this Court. 

# # # END OF ORDER # # #

Submitted by:

Julian P. Vasek

State Bar No. 24070790

MUNSCH HARDT KOPF & HARR, P.C.

500 N. Akard St., Ste. 3800

Dallas, TX 75201

Telephone: 214.855.7500

Facsimile: 214.855.7584

Email: jvasek@munsch.com 

PROPOSED ATTORNEYS FOR DEBTORS

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