Answer: JAB ENERGY SOLUTIONS II LLC vs. OFFSHORE SPECIALTY FABRICATORS INC

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                                CAUSE NO.      2016 48155

 JAB ENERGY SOLUTIONS II, LLC and                                          IN THE DISTRICT COURT
 ALLISON OFFSHORE SERVICES II, LLC

 VS.
                                                                         OF HARRIS COUNTY, TEXAS
 OFFSHORE          SPECIALTY FABRICATORS, INC.
 and
 FAIRWAYS OFFSHORE              EXPLORATION, INC.                             151 JUDICIAL DISTRICT


               JAB ENERGY SOLUTIONS II, LLC’S VERIFIED ANSWER TO
             OFFSHORE SPECIALTY FABRICATORS, LLC.’S COUNTERCLAIMS

           NOW    COMES JAB Energy Solutions, LLC (“JAB”) files this Verified Answer to Offshore

Specialty Fabricators,       ’s (“OSF”) Counterclaims, and states as follows:


                                         GENERAL DENIAL

           Pursuant to Rule 92 of the    EXAS   ULES   OF   IVIL   ROCEDURE     JAB generally denies each

and every, all and singular, the allegation contained in OSF’s Counterclaim and demand strict proof

thereof.



                                        VERIFIED DENIALS

                  JAB denies by verification attached hereto the account sworn to by OSF because not

every item of the account it just or true.

                  JAB disputes the entire account attached to OSF’s counterclaim because Fairways

Offshore Exploration, Inc. (“FOE”) owes JAB such amount and JAB is entitled to an offset for any

amounts owed to OSF pursuant to agreement with OSF and FOE.

                  JAB denies the account on which OSF         sues because OSF has not credited JAB

account with all lawful offsets or other credits.

                  JAB denies the account on which OSF sues because OSF is liable to JAB because OSF

breached its contract with JAB.
JAB denies the account on which OSF claims because OSF charges for goods and

servicesthat are not in accordance with the parties’ agreement and are unreasonable.


                                    AFFIRMATIVE DEFENSES

                JAB denies that OSF’s allegations that all conditions precedent have been performed

of have occurred.

                Defendants’ claims are barred in whole or in part by unclean hands

                Defendants’ claims are barred in wholeor in part by prior material breach

                Defendants’ claims are barred in whole or in part by accord and satisfaction

                Defendants’ claims are barred in whole or in part by novation

                Defendants’ claims are barred in whole or in part by modification

                JAB is not liable to OSF for the amount claimed because JAB is entitled to setoff or

an offset

                                                PRAYER


        WHEREFORE,        PREMISES CONSIDERED,
                                            JAB                prays that OSF take nothing and for

such other relief to which JAB is entitled.


                                         Respectfully submitted,

                                          NOW    PENCE   REEN       LLP




                                         By
                                                Ross Spence
                                                State Bar No. 18918400
                                                Email: ross@snowspencelaw.com
                                                Carolyn Carollo
                                                State Bar No. 24083437
                                                Email: carolyncarollo@snowspencelaw.com
                                                2929 Allen Parkway, Suite 28
                                                Houston, TX        77019
Telephone: (713) 335 4800
                                                         Telecopier: (713) 335 4848
                                               Attorneys for JAB Energy Solutions, LLC

                                            CERTIFICATE OF SERVICE

          I certify that on the ™ day of October 2016, I used the Court’s electronic case filing system
to file Plaintiffs’ Verified Answer to Offshore Specialty Fabricators,     *s Counterclaims and serve
this document on counsel as follows:



C. Larry Carbo, TIT
Julie R. Offerman
  HAMBERLAIN           RDLICKA,         HITE       ILLIAMS          UGHTRY
1200 Smith, Suite 1400
Houston, TX 77002
Via Email: larry.carbo@chamberlainlaw.com
Via Email: julie.offerman@chamberlainlaw.com
Attorneys for Fairways Offshore Exploration, Inc.

Chris M. Knudsen
 ERPE,    ONES       NDREWS         ALLENDER             ELL PLLC
America Tower
2929 Allen Parkway, Suite 1600
Houston, TX 77019
Via Email:cknudsen@serpejones.com
Attorney for Offshore Specialty Fabricators, LLC

                                                                        /s/ Carolyn Carollo
                                                                        Carolyn Carollo


  Client JABE0002OSF, Fairways   Pleadings Answer to OSF Counterclaim.docx
CAUSE NO,      2016-48155

 JAB ENERGY SOLUTIONS II, LLC and                                                         IN THE DISTRICT COURT
 ALLISON OFFSHORE SERVICES II, LLC

 VS.
                                                                                       OF HARRIS COUNTY,            TEXAS
 OFFSHORE SPECIALTY FABRICATORS,                                  INC.
 and
 FAIRWAYS OFFSHORE EXPLORATION,                                   INC.         §            151* JUDICIAL DISTRICT



                                                  AFFIDAVIT OF BRENT BOUDREAUX

STATE OF TEXAS                                      §
COUNTY OF HARRIS                                    §
                 BEFORE            MB,   the undersigned authority, personally came and appeared Brent Boudreaux,
and after first being duly sworn did state that:

       1         Jam currently the President of JAB Energy Solutions II, LLC (“JAB”)

       2.        J have read JAB’s answer to Offshore Specialty Fabricators, LLC’s Counterclaims,                  and the

                 facts stated in the Verified Denials portion are within my personal knowledge and are true and

                 cottect.




                 Further, Afftant sayeth not.




                                                        Cactobe
        SUBSCRIBED                       and SWO.             -EFORE     ME,       the undersigned   authority,   by Brent
Boudreaux, on this th                       day of                        2016,




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