December 30, 2024

David Lesar
Chief Executive Officer
Superior Energy Services, Inc.
1001 Louisiana Street, Suite 2900
Houston, TX 7702

       Re: Superior Energy Services, Inc.
           Schedule 13E-3 filed December 17, 2024
           File No. 005-43588
Dear David Lesar:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

        Please respond to these comments by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comments
apply to your
facts and circumstances, please tell us why in your response.

       After reviewing your response to these comments, we may have additional
comments.

Schedule 13E-3 filed December 17, 2024
General

1.     We note that Mr. Flores and Mr. Foster serve as directors and
GoldenTree, which is
       affiliated with them, beneficially owns approximately 51.4% of the Class
A Common
       Stock. Please advise why Mr. Flores, Mr. Foster and GoldenTree have not
been
       identified as filing persons in the Schedule 13E-3. Provide the same
analysis with
       respect to Mr. Citarrella and Monarch. Please note that each new filing
person must
       individually comply with the filing, dissemination and disclosure
requirements of
       Schedule 13E-3. In this regard, the reasons for the Transaction and the
alternatives
       considered by these affiliates may be different than those of the
Company, and this
       fact should be reflected in the disclosure. In addition, please be sure
that any new
       filers sign the Schedule 13E-3.
2.     We note that the Fairness Opinion states that it    is furnished for the
use of the Board
           and may not be used for any other purpose without [Houlihan Lokey
s] prior
       written consent.    Please disclose, if true, that Houlihan Lokey has
consented to use of
 December 30, 2024
Page 2

       its materials in the filing.
3.     We note that Houlihan Lokey provided a preliminary financial analysis to
the Board
       on December 6, 2024. Provide the disclosure required by Item 1015(b)(6)
of
       Regulation M-A with respect to that presentation.
4.     Please quantify the fee paid or to be paid to Houlihan Lokey. See Item 9
of Schedule
       13E-3 and corresponding Item 1015(b)(4) of Regulation M-A.
Fairness of the Transaction, page 16

5.     Revise to considerably expand this section so that it includes the
results and
       illustrative ranges for each point of analysis conducted by the
financial advisor, along
       with the results yielded by each. See Item 9 of Schedule 13E-3 and Item
1015 of
       Regulation M-A.
6.     Please include all projections prepared by management and provided to
Houlihan
       Lokey for purposes of the fairness opinion, including any forecasts
pertaining to the
       discounted cash flow analysis. Your expanded discussion should also
discuss the
       underlying assumptions and limitations on any projections provided.
7.     The factors listed in Instruction 2 to Item 1014 of Regulation M-A and
paragraphs (c),
       (d) and (e) of Item 1014 are generally relevant to each filing person
s fairness
       determination and should be discussed in reasonable detail. See
paragraph (b) of Item
       1014 of Regulation M-A and Questions 20 and 21 of Exchange Act Release
No. 34-
       17719 (April 13, 1981). Please revise this section to include the
factors described in
       clauses (iii), (iv), and (v) of Instruction 2 to Item 1014 or explain
why such factors
       were not deemed material or relevant to the fairness determination of
the Board.
8.     We note your disclosure that the Board has determined    that effecting
the Transaction
       by means of the Stock Splits is procedurally and substantively fair to
all stockholders
       of the Company, including the unaffiliated stockholders who will only
receive cash
       consideration in the Stock Splits and unaffiliated stockholders who will
continue as
       owners of the Company.    The disclosure required by Item 1014(a) of
Regulation M-A
       should separately address the fairness of the Transaction to
unaffiliated
       securityholders as a distinct group. Please revise accordingly.
9.     Please address how any filing person relying on the Fairness Opinion was
able to
       reach the fairness determination as to all unaffiliated securityholders
given that the
       Fairness Opinion addressed fairness with respect to the Cashed-Out
Stockholders,
       rather than all securityholders unaffiliated with the Company. See
Exchange Act Rule
       13e-3(a)(4), Item 8 of Schedule 13E-3, and Item 1014(a) of Regulation
M-A.
Executive Officers, page 31

10.    Many of the biographies disclosed in this section do not provide all of
the information
       required by Item 1003(c)(2) of Regulation M-A for the past five years.
Please revise
       accordingly.
        We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.
 December 30, 2024
Page 3

      Please direct any questions to Blake Grady at 202-551-8573.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Mergers &
Acquisitions