Case 11-13028

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Filed 06/12/13 Entered 06/12/13 16:40:20 Page 1 of 2

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA

IN RE: VIRGIN OFFSHORE USA, INC., DEBTOR

CASE NO. 11-13028 CHAPTER 11 CHIEF JUDGE ELIZABETH W. MAGNER

SUPPLEMENT TO THE FIRST AMENDED CHAPTER 11 PLAN OF REORGANIZATION DATED MARCH 28, 2013 SUBMITTED BY GERALD H. SCHIFF, CHAPTER 11 TRUSTEE FOR THE ESTATE OF VIRGIN OFFSHORE, USA, INC.

Gerald H. Schiff, chapter 11 trustee for the Virgin Offshore U.S.A., Inc. bankruptcy estate (the Trustee), hereby submits this supplement (Plan Supplement) to the FIRST AMENDED CHAPTER 11 PLAN OF REORGANIZATION DATED MARCH 28, 2013 SUBMITTED BY GERALD H. SCHIFF, CHAPTER 11 TRUSTEE FOR THE ESTATE OF VIRGIN OFFSHORE, USA, INC. (the Plan).1 1. Form of Offshore Equity Trust Agreement

Attached hereto as Exhibit A is a form of the proposed Offshore Equity Trust Agreement contemplated in Article VI(B) of the Plan. The form is subject to execution by the proposed Equity Trustee, and further amendment and modification as necessary. 2. RLI Stipulation

Attached hereto as Exhibit B is the Term Sheet Stipulation (Stipulation) executed by and between the Trustee, on behalf of the state, the Virgin Oil Plan Trust and RLI Insurance Company. As set forth in Section (1)(a) of the Stipulation, the Trustee agreed to incorporate the term of the Stipulation into the proposed Plan as further clarification of the treatment of the RLI
1

(R. at 402.)

Case 11-13028

Doc 430

Filed 06/12/13 Entered 06/12/13 16:40:20 Page 2 of 2

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Insurance Class 2 Claim and to reduce to writing the meaning of Paragraph 8 of the Decommissioning Term Sheet. Respectfully submitted by: GORDON, ARATA, MCCOLLAM, DUPLANTIS & EAGAN, LLC By: /s/ Patrick M. Shelby Patrick Rick M. Shelby (La. Bar. No. 31963) James D. Rhorer (La. Bar No. 34052) Place St. Charles 201 St. Charles Avenue, 40th Floor New Orleans, LA 70170-4000 Telephone: (504) 582-1111 Email: pshelby@gordonarata.com And Louis M. Phillips (La. Bar No. 10505) One American Place 301 Main Street, Suite 1600 Baton Rouge, LA 70801-1916 Telephone: (225) 381-9643 Facsimile: (336) 336-9763 Email: lphillips@gordonarata.com And Armistead M. Long (La. Bar No. 33949) 400 East Kaliste Saloom Road, Suite 4200 Lafayette, LA 70508 Phone: (337) 237-0132 Email: along@gordonarata.com Attorneys for Gerald H. Schiff, Chapter 11 Trustee