Case Document 985 Filed in TXSB on 06/23/17 Page 1 of 5

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1 Case Document 985 Filed in TXSB on 06/23/17 Page 1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION IN RE: VANGUARD NATURAL RESOURCES, LLC et al., 1 Debtor. CASE NO (MI) CHAPTER 11 AMENDED NOTICE OF DEPOSITION UNDER RULE 30(b)(6) OF THE FEDERAL RULES OF CIVIL PROCEDURE [Confirmation Issues] TO: Vanguard Natural Resources, LLC, and its direct and indirect affiliates as debtors and debtors-in-possession c/o James T. Grogan Paul Hastings LLP 600 Travis Street, Fifty-Eighth Floor Houston, TX jamesgrogan@paulhastings.com (713) PLEASE TAKE NOTICE that, pursuant to Federal Rules of Civil Procedure 26 and 30 (made applicable to this matter by Federal Rules of Bankruptcy Procedure 7026, 7030, and 9014), the Ad Hoc Committee of Equity Holders (collectively, the Equity Committee ), compromising certain unaffiliated holders of Vanguard Natural Resources, LLC s ( VNR ) preferred and common units, will take the oral deposition of a Federal Rule of Civil Procedure 30(b)(6) witness or witnesses of the Debtors (as defined in footnote 1, below), by the person designated as most knowledgeable to testify on their behalf with respect to the topics identified in Exhibit B attached hereto. 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: Vanguard Natural Resources, LLC (1161); Eagle Rock Acquisition Partnership, L.P. (6706); Eagle Rock Acquisition Partnership II, L.P. (0903); Eagle Rock Acquisition Co., Inc. (4564); Eagle Rock Energy Acquisition Co. II, Inc. (3364); Eagle Rock Upstream Development Company, Inc. (0113); Eagle Rock Upstream Development Company II, Inc. (7453); Encore Clear Fork Pipeline LLC (2032); Escambia Asset Co. LLC (3869); Escambia Operating Co. LLC (2000); Vanguard Natural Gas, LLC (1004); Vanguard Operating, LLC (9331); VNR Finance Corp. (1494); and VNR Holdings, LLC (6371). The location of the Debtors service address is: 5847 San Felipe, Suite 3000, Houston, Texas PAGE 1

2 Case Document 985 Filed in TXSB on 06/23/17 Page 2 of 5 The deposition will commence at 9:30 a.m. on June 28, 2017, or such other time and date to which the Equity Committee and the Debtors agree, at the offices of Paul Hastings LLP, 600 Travis Street, Fifty-Eighth Floor, Houston, TX 77002, and continue from day to day until completed. The examination may be recorded by video. Dated: June 23, 2017 Houston, Texas Respectfully submitted, GARDERE WYNNE SEWELL LLP /s/ Alexander C. Chae Alexander C. Chae (TX Bar No ) (direct dial) (direct fax) achae@gardere.com Sharon M. Beausoleil (TX Bar No ) (direct dial) (direct fax) sbeausoleil@gardere.com 1000 Louisiana, Suite 2000 Houston, Texas and Holland N. O Neil (TX ) (direct dial) (direct fax) honeil@gardere.com 2021 McKinney Avenue, Suite 1600 Dallas, TX 7520 ATTORNEYS FOR AD HOC EQUITY COMMITTEE PAGE 2

3 Case Document 985 Filed in TXSB on 06/23/17 Page 3 of 5 CERTIFICATE OF SERVICE I do hereby certify that on June 23, 2017 a true and correct copy of the foregoing pleading was served via CM/ECF to all parties authorized to receive electronic notice in these cases. /s/ Sean Wilson Sean Wilson PAGE 3

4 Case Document 985 Filed in TXSB on 06/23/17 Page 4 of 5 EXHIBIT A: DEFINITIONS The following defined terms form an integral part of the Equity Committee s Notice of Deposition and apply to each of the Deposition Topics set forth in Exhibit B: 1. The term Debtors shall mean Vanguard Natural Resources, LLC and its direct and indirect affiliates, collectively and individually, that are parties to the above-captioned bankruptcy proceeding. 2. The term Disclosure Statement shall mean the Debtors Disclosure Statement Relating to the Second Amended Plan of Reorganization of Vanguard Natural Resources, LLC, et al., Pursuant to Chapter 11 of the Bankruptcy Code [Dkt. No. 892] as may be subsequently amended or supplemented from time to time. 3. The term Plan shall mean the Debtors Second Amended Joint Plan of Reorganization of Vanguard Natural Resources, LLC, et al., Pursuant to Chapter 11 of the Bankruptcy Code [Dkt. No. 843] as may be subsequently amended or supplemented from time to time. PAGE 4

5 Case Document 985 Filed in TXSB on 06/23/17 Page 5 of 5 EXHIBIT B: RULE 30(b)(6) DEPOSITION TOPICS 1. All issues relating to the confirmation of the Debtors Plan and Disclosure Statement, and any related documents. 2. The valuation of the Debtors, their assets and liabilities, and components thereof. 3. The business plan of the Debtors for 2017 to The financial projections of the Debtors, including without limitation: production estimates, plans for existing and new wells, operating expenses, capital expenditures, and liquidity. 5. The management incentive program proposed under the Plan. 6. The third party releases, exculpations, and injunctions contained in the Plan. 7. Expressions of interest by any parties, including third parties, in any of the Debtors assets. 8. Evercore retention and compensation. 9. Communications related to potential asset sales or dispositions of the Debtors assets after the Effective Date of the proposed Plan. PAGE 5