In re: )
)
)
Debtors. )
)
Pursuant to sections 330 and 331 of Title 11 of the United States Code (the "Bankptcy
Code"), Rule 2016 of the Federal Rules of Banptcy Procedure (collectively, the "Banptcy
Rules"), and the Court's "Administrative Order Under 11 US.c. 105(a) and 331 Establishing
Procedures for Interim Compensation and Expense Reimbursement of Professionals and Committee
Members," entered on or about April 15, 2009 (the "Administrative Order"), Schully, Roberts,
Slattery & Marino PLC (or the "Firm"), Special Oil & Gas and Transactional Counsel to the Debtors
and Debtors in Possession ("Debtor"), hereby submits its Fifth Verified Monthly Application (the
"Application") for Compensation and for Reimbursement of Expenses for the Period from
September 1, 2009 through September 30, 2009 (the "Interim Fee Period") in the amount of
$101,985.00 and actual and necessary expenses in the amount of $30.89 for a total allowance of
payment of $81,588.00 (80% of the allowed fees) and reimbursement of $30.89 (100% of the
2 The Debtors in these cases, along with the last four digits of each of
are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska Holdings,
LLC (tax I.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); San Pedro Bay Pipeline Company (1234); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing the Debtors is I I I W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802. address for all of
allowed expenses) for a total payment of $81,618.89. In support of this Application, the Firm
respectfully represents as follows:
March 8, 2009, by this Court's "Order Granting Debtor's Application to Retain Schully, Roberts,
Slattery & Marino PLC as Special Oil & Gas and Transactional Counsel Nunc Pro Tunc
Pursuant to Section 327(e) of the Bankruptcy Code and Bankptcy Rule 2014" entered on or
about April 15, 2009 (the "Retention Order"). The Retention Order authorized the Firm to be
compensated on an hourly basis and to be reimbursed for actual and necessary out-of-pocket
expenses.
Interim Fee Period showing the amount of$101,985.00 due for fees.
3. The services rendered by the Firm during the Interim Fee Period are grouped into
a single category related to the Firm's role as Special Oil & Gas and Transactional Counsel for
the Debtor.
4. During the Interim Period, the Firm, among other things: (1) communicated with
regulators II response to notices related to reporting requirements, royalty assessments, lease
abandonment/sales, and pending litigation; (2) assisted Debtor in the preparation of motions and
memoranda relating to oil and gas and transactional legal issues, prepared and reviewed lease
and property assessments for entities who are managing Debtors' assets, in the review of deeds
and assignments to Debtor for assets acquired by Debtor, in the review of plans of on-going
operation of
gas assets and related property; (3) assisted Debtor in responding to claims made by Debtor's co-
lessees for moneys due under various oil & gas agreements; (4) responded to direct creditor
inquiries regarding conduct of Debtor's ongoing business, including properties previously held
or serviced by Debtors; (5) worked extensively on possible abandonment and/or sale scenarios,
and (6) expended significant time drafting multiple purchase and sale agreements and
abandonment motions and exhibits.
5. The Firm spent a total of 272.56 hours and incurred fees in the amount of
$101,985.00 in providing these oil and gas and transactional services to the Debtors.
6. A more detailed identification of the actual services provided is set forth on the
attached Exhibit A. Exhibit A identifies the attorneys and paraprofessionals who rendered
services relating to each category, along with the number of hours for each individual and the
total compensation sought for each category.
the categories set forth below. SRSM attempted to place the services provided in the
category that best relates to such services. However, because certain services may relate to one
or more categories, services pertaining to one category may in fact be included in another
category. These services performed, by categories, are generally described below, with a more
detailed identification of the actual services provided set forth on the attached Exhibit A.
Exhibit A identifies the attorneys and paraprofessionals who rendered services relating to each
category, along with the number of
hours for each individual and the total compensation sought for
each category.
02 i 28 i Oa 2795 septemberfees.doc
A. Asset Disposition
8. During the Interim Period, the Firm, among other things: (1) performed continued
work regarding the location of assets, (2) the continued preservation of assets for the Debtor's
estate or for disposition; (3) the qualification of potential purchasers; (4) interfacing with
regulatory entities and (5) corresponded extensively regarding asset disposition issues. The Firm
(1) participated in negotiations with prospective purchasers; (2) drafted numerous purchase and
sale agreements and letters of commitment; (3) participated in conference calls with the Debtor
and prospective purchasers to discuss transitions, cure amounts, and regulatory matters; (5)
interfaced with regulators and creditors' counsel to access the scope of issues that transfer of
ongoing operations present; (6) worked extensively with co-lessees in attempts to guarantee
access to facilities for any new purchaser; and (7) dealt with contending interests under proposed
abandonment scenarios.
Fees: $63,590.00
B. Bankruptcy Litie:ation
9. During the Interim Period, the Firm, among other things: (1) performed work
Hours: 174.76
regarding the secured creditor matters; (2) attended to notice issues; (3) performed work regarding
lessor and co-lessee claims, threatened litigation, and ongoing adversary actions; (4) performed
work regarding Notices and Hearings; (5) performed research; (6) attended to pending
litigation coordination issues; (7) attended to scheduling issues; (8) performed work regarding
unpaid royalties and obligations to partners; (9) drafted several extensive memoranda relative to oil
and gas litigation and valuation issues; (10) performed work regarding overriding royalty issues
and how such interests are handled in bankruptcy; (11) drafted additional memoranda
regarding regulatory, bonding and escrow issues; (12) reviewed and analyzed documents
02 i 28 i Oa 2795 septemberfees.doc
dealing with property rights of the Debtor; (13) prepared bankruptcy counsel to address
issues at hearings; (14) performed work regarding lender/creditor production payments and legal
remedies thereunder; (15) performed work regarding objections; and (16) corresponded and
conferred regarding bankptcy litigation matters.
10. During the Interim Period, the Firm, among other things: (1) maintained a
memorandum of Critical Dates; (2) maintained document control; and (3) reviewed
correspondence and pleading and forwarded them to appropriate parties.
Fees: $32,985.00
c. Business Operations
11. During the Interim Period, the Firm, among other things, (1) responded to
Hours: 82.7
inquiries regarding the continued operations of the oil and gas business of the Debtor relative to
its Alaska and California holdings; (2) interfaced with and represented the Debtor before
regulatory agencies including, but not limited to the United State Department of Interior
Minerals Management Service, The United States Bureau of Land Management, the State of
Alaska Department of Natural Resources, the Alaska Oil and Gas Conservation Commission,
and the United state Environmental Protection Agency; (3) assisted the Debtor and bankruptcy
counsel in its dealings with ongoing escrow and bonding obligations; (4) worked to facilitate the
location of potential partners or purchasers; (5) performed extensive document production and
technical assistance to individuals employed to assist in the day-to-day operations of the Debtor;
(6) assisted bankruptcy counsel in understanding the operations of the Debtor as well as the
details of the acquisition of the oil and gas properties and the obligations of the Debtor
thereunder; (7) worked with Debtor to inform partners in business ventures and to finalize a
proposal to Chevron; (8) worked to assure that title issues and recordation matters were
02 i 28 i Oa 2795 septemberfees.doc
understood by bankptcy counsel; (9) worked to resolved pending matters before regulatory
agencies; (10) continued correspondence and communication regarding royalty relief; (11)
continued negotiations with Union regarding access to production facilities as well as matters in
controversy relative to pipelines and right-of-ways as well as Lessors and regulators; (12)
complied with operational and transactional document requests from Creditor Committees;(13)
participated in numerous conference calls to facilitate matters for Creditors Committees; and (14)
worked with Lazard Freres and Zolfo Cooper to facilitate possible sale of operations or the
eventuality of abandonment.
Fees: $2,365.00
Hours: 4.8
inquiries from claimants; (2) attended to bar date issues; (3) performed work regarding the Aera,
SWEPI and Noble claims; (4) performed work regarding claims analysis; (5) assisted
bankruptcy counsel in drafting objections to claims; (6) reviewed and analyzed claims and
related documents; (7) performed work regarding exhibits to claim objections; (8) performed
work regarding various abandonment motions and claims of entities to oppose; (9) attended to
discovery issues; (10) performed work regarding royalty claims; (11) performed work regarding
claims in the Chevron and Marathon litigation matters; (12) attended to issues regarding latefiled claims; (13) performed work regarding a stipulation involving Chevron claims; (14)
performed extensive research on a number of claims issues presented by bankuptcy counsel; (15)
attended to issues regarding priority claims; (16) prepared memoranda for a hearings regarding
royalty matters; (17) performed work regarding claim objection responses; (18) performed work
regarding potential regulatory claims matters; (19) attended to issues regarding lessor claims;
02 i 28 i Oa 2795 septemberfees.doc
(20) attended to potential abandonment issues; (21) performed work regarding orders; and (22)
Fees: $2,932.50
E. Compensation of Professionals
Hours: 10.0
13. This category includes work related to the fee applications of the Firm as well as
compensation to related professionals. During the Interim Period, the Firm, among other
things: (1) performed work regarding the Firm's September 2009 monthly and supplemental fee
applications; (2) drafted the Firm's September 2009 monthly fee applications; (3) monitored the
status and timing of fee matters; and (4) reworked all prior monthly biling for auditors.
in the amount of $30.89. Pursuant to Local Rule 2016-2, the Firm represents that its rate for
duplication is $.10 per page.
Valuation of Services
15. Attorneys and paraprofessionals of the Firm have expended a total of 3.00 hours
16. The amount of time spent by each of these persons providing services to the
Debtors for the Fee Period is fully set forth in the detail attached hereto as Exhibit A. These
are the Firm's standard hourly rates of compensation for work of this character. The
reasonable value of the services rendered by the Firm for the Interim Fee Period as Special
Oil & Gas and Transactional Counsel for the Debtor is $101,985.00.
17. The Firm believes that the time entries included in Exhibit A attached hereto are
is fair and reasonable given (a) the complexity of this case, (b) the time expended, (c) the
nature and extent of the services rendered, (d) the value of such services, and (e) the costs of
comparable services other than in a case under this title.
19. This Application covers the Interim Fee Period from September 1, 2009
WHEREFORE, the Firm respectfully requests that, for the from September 1, 2009
through September 30, 2009 period, an interim allowance be made to the Firm for
compensation in the amount of $101,985.00 and actual and necessary expenses in the amount
of $30.89 for a total allowance of $81 ,588.00 (80% of the allowed fees) and reimbursement of
$30.89 (100% of
02 i 28 i Oa 2795 septemberfees.doc
EXHIBIT A
Proiect Cateiiories .
Total Hours
174.76 82.7 10.00 .30 4.8
Total Fees
63,590.00 32,985.00 2,932.50 112.50 2,365.00
EXPENSE SUMMARY
Total Expenses
Reproduction
$15.25 $15.94
$15.25 $15.94
Date
Filed
Period Covered
B/09/09 - 03/31/09
)4/01/09 - 04/30/09
)5/01/07 - 05/31/09 )6/01/09 - 06/31/09
07/01/09 - 07/3 1/09
Requested
Fees
Requested Expenses
Approved
Fees
Approved
Expenses
$88,261.3
$95,177.00
$2 i 9,508.50
$1,201.0
$ i ,207.23
$661 .23
08/01/09 - 08/31/09
$149,092.50
$247.50
VERIFICATION
STAlE OF LOUISIANA
PARSH OF ORLAN
Anthony C Mao, afer being duly sworn accordig to law, deposes and says:
I am a sharholder of the applicant law fir SchuIy, Robert, Slattery & Mao ("the "Fir").
a) I am thoroug fam wi the work performd on beha of the
Debtors by
ar tre and correct to the best of my knowledge, inormtion and belief. Moreover, I have
rewe Del Ban.LR2016-2 and the Adtrtie Orer entered on or abut Apri
15, 200,
and submit that the Application substantialy complies with such Rule and Order.
~~
SWORN AN SUBSCRBED before me
Th :l day
AmO ~ NO
of () , 2009.
In re: ) Chapter 11
)
Debtors. )
) (Jointly Administered)
) Objections Deadline: December 21, 2009 at 4:00 p.m.
Schully, Roberts, Slattery & Marino PLC ("SRSM"), special oil and gas and
transactional counsel to the debtors and debtors in possession in the above-captioned case (the
"Debtors"), has fied its Monthly Application for Compensation and Reimbursement of
Expenses of Schully, Roberts, Slattery & Marino P LC as Special Oil and Gas and
Transactional Counsel to Debtor and Debtors in Possession, for the Period
from September 1,
2009 through September 30, 2009, seeking compensation for services in the amount of
$10 1,985.00 and reimbursement of costs incurred in the amount of $30.89 (the "Application").
PLEASE TAK FURTHER NOTICE that objections, if any, to the Application must
be made in accordance with the Administrative Order Under 11 US.C. 105(a) and 331
the Debtors' federal tax identification number, are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska Holdings,
LLC (tax I.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); San Pedro Bay Pipeline Company (1234); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing
that they are received not later than December 21,2009 at 4:00 p.m. prevailng Eastern time,
by: (a) the Debtors, (1) Pacific Energy Resources, 111 W. Ocean Boulevard, Suite 1240, Long
Beach, CA 90802, Attn: Gerry Tywoniuk, Senior VP & CFO and(2) Zolfo Cooper, 1166 Sixth
Avenue, 24th Floor, New York, NY 10036, Attn: Scott W. Winn, Senior Managing Director;
(b) counsel to the Debtors, (1) Pachulski Stang Ziehl & Jones LLP, 919 North Market Street, 1 ih
Floor, Wilmington, DE 19899-8705, Attn: James E. O'Neil, Esq.; Fax: 302-652-4400, e-mail:
ioneil(fpszjlaw.com and (2) Pachulski Stang Ziehl & Jones LLP, 10100 Santa Monica Blvd.,
11th Floor, Los Angeles, CA 90067-4100; Attn: Ira D. Kharasch, Esq; Fax: 310-201-0760,
e-mail: ikharash(fpszilaw.com (c) the Office of
Federal Building, 844 N. King Street, Suite 2207, Lock Box 35, Wilmington, Delaware 19801,
Attn: Joseph McMahon, Esq. and (d) counsel for the Official Committee of
Unsecured Creditors
Angeles, CA 90067; Attn: Katherine C. Piper, Esq., Fax: (310) 734-3173, e-mail:
kpiper(fsteptoe.com and (2) Pepper Hamilton LLP, Hercules Plaza, Ste 5100, 1313 N. Market
Street, Wilmington, DE 19801; Attn: James C. Carignan, Esq., Fax: (302) 421-8390, e-mail:
icarignan(fpepoerlaw.com (the "Notice Parties")
convenience of the Bankruptcy Court. Only those objections made in writing and timely fied
and received in accordance with the Administrative Order and the procedures described herein
address for all of the Debtors is I I I W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.
no objection to the Application is timely filed, served and received by the Objection Deadline, the
Applicant may be paid an amount equal to the lesser of (1) 80 percent of the fees and 100 percent
of expenses requested in the Application or (ii) 80 percent of the fees and 100 percent of the
expenses not subject to an objection without the need for further order of
((
Kathleen P. Makowski (DE Bar No. 3648) 919 North Market Street, 1 ih Floor P.O. Box 8705 Wilmington, DE 19899-8705
Telephone: 302/652-4100
Facsimile: 310/652-4400
Email: ikharasch(fpszilaw.com
ioneil(fpszi law.com
kmakowski(fpszi law .com
EXHIBIT A
42 125-00
I \DOCS_DE:6375.
STATEMENT
Page: 1
Pacifc Energy Resources, Ltd. 111 W. Ocean Blvd. Suite 1240 Long Beach CA 90802
10/2712009 6476-2795M 14
Forbearance Agreements
HOURS
09/01/2009
LGW
(AD)Review of emails regarding proposed state of Alaska PSA - extensive review of same and numerous emalls with Morrson
firm;
0.90 0.90
337.50 337.50
LGW
LGW
LGW LGW LGW
(AD)Continued review and discussion of NAE PSA to address issues of proposed purchase price reductions and contract rights issues; (AD)Response to bankruptcy counsel comments regarding various Beta Trust agreements; (AD)Review and comment on Group /I funding issues discussion of Chevron issues and email; (AD)Extensive emalls with Mr. Arlington regarding abandonment issues follow-up wit conference cali on exhibits; (AD)Review communications from Ms. Parker regarding Group 2 abandonment and need for termination letter for the Ocar Group 2 PSA; Closing deadline for Group 1 was extended from
9/4 to 9/9;
0.90
0.90 0.90
337.50
337.50 337.50
0.90
337.50
337.50 337.50 337.50
337.50
LGW
LGW LGW
(AD)Discussion of abandonment issues -follow-up with Mr. Tywoniuk and Mr. Arlington; discussion with Mr. Hall; (AD)Telephone call from ERG regarding lender buyout and discuss provisions; suggest revisions; (AD)Continued work on assumption of BETA leases and trust agreements wih Mr. Saunders; numerous emalls and
0.90
0.90 0.90 0.90 0.60 0.90 0.70
research;
LGW
LGW LGW
(AD)Continued work on BETA assumption motion with Mr. Saunders; emaHs to MMS and CSLC to discuss continuance; discussion of proper notice partes; (AD)Review of Group i closing checklist frm Rutan firm and discussion of how best to facilitte closing; (AD)Review emalls from Gerr Tywoniuk regarding division of
discussion with Mr. Marino and Ms. Castle of same; (AD)Discussion with Mr. Arington about West Foreland cure amount issues and follow-up with Ms. Shahan; (AD)Receive draft exhibits from Rutan for new PSAs and work
Page: 2
STATEMENT NO: 14
Forbearance Agreements
HOURS 0.90
Assets;
09/0212009
LGW
(AD)Continued work on revisions to PSAs; review deletions to contract and propert lists; consult with Mr. Marino and Mr. Arlington; (AD)Review various emails regarding PSA's and strategies; (AD)Conference with Ms. Wolf rearding Alaska Assets; (AD)Review and respond to varius emails from Mr. Saunders regarding Assumption of Beta Leases Trust Agreement; (AD)Conference with Ms. Wolf regarding PSA for Alaska
(AD)Follow-up materials from Mr. Cervi;
LGW
LGW
LGW
(AD)Continued work on MMS/BLM royalty issues; email from Ms. Barder regarding objecions of BlM/MMS, Salamatof and CIRI; (AD)Continued discussion with Mr. Saunders rearding MMS BETA issues and PERl's response to objections for DE hearing; extensive emails and telephone calls - AERA, SWEPI, Noble; (AD)Exensive work on schedules and exhibits for Alaska PSAs as revised; follow-up with Ms. Parker, Mr. Tywoniuk and Mr. Arington; (AD)Review extensive executory contract matters and exhibits; line; send comments with suggested comments and revise red language and questions for purchasers;
0.90
337.50
0.90
337.50 337.50
337.50 337.50 337.50
337.50 337.50 262.50
0.90
0.90
0.90
LGW
LGW LGW
(AD)Continued discussion and work on MMS/DOJ issues; suggest alternate approaches to Pachulski attomeys; research for Bl attomeys and clarify;
(AD)Emaiis and discussion of Alaska offce lease and locte
LGW
bankruptcy counsel;
LGW
(CO)Continued discussion and comment in regarding claims from MMS and DOJ; discussion with Mr. Saunders and Mr. Marino; attempt to determine best approach for 9/24 DE
Page: 3
STATEMENT NO: 14
Forbearance Agreements
HOURS 0.90
337.50
337.50
150.00
(BL)Review TBUfTBF abandonment order; discuss dismissal of Alaska court cases; (AD)Review offer letter for Three Mile Creek from Aurora; discussion with Mr. Tywoniuk rearding same; follow-up with
Mr. Arlington;
LGW
LGW
(AD)Continued work on cure amounts and discussion with bidders regarding assumption of same; questions rearding throughputs and refer to Mr. Arlington; (AD)Review letter from NAE regarding return of good faith
337.50
337.50 337.50 150.00
165.00
(BL)Review research requests from bankruptcy counsel regarding whether MMS lease is subject to Bankruptcy Code Section 365; locate matenals and send to Mr. Saunders;
LGW ACM
ACM
0.40 0.30
0.60 0.40
220.00 165.00
330.00 220.00
09/03/2009
HEG
0.90
0.90
382.50 337.50
337.50 337.50
337.50
(AD)Prepare for and partcipate in telephone call with Lenders' counsel regarding MMS and Beta Leases per Mr. Saunders; (AD)Continued discussion and further work with Lenders counsel on MMS issues and attempt to clanfy predecessor
secunty issues;
LGW
0.90
0.90 0.90 0.90
LGW
(AD)Response to NAE purchase questions and concerns regarding access for Group i; discussion of equipment Issues; (AD)Continue discussion of form of reconveyance of ORRis
(AD)Extensive emails with lenders and Mr. Saunders rearding vanous issues regarding BETA; follow-up with conference call
337.50
Page: 4
STATEMENT NO: 14
Forbearance Agreements
lGW
bidders; discuss with Mr. Gamer; (AD)Continued revisions to PSAs, exhibits and schedules
HOURS 0.90
337.50
0.90
337.50
lGW
lGW
(Bl)Continued work on CrE PSA; discussion with Jr. Wilcox regarding overrdes and Copper River leases; discussion of Anschutz agreement and determine whether to include in Exhibit A;. (AD)Continued work and discussion of issues related to Group
0.90
337.50
of potential conflicts and need for confidentiality; discussion with Mr. Marino regarding need for Mr. Katic independent
counsel;
0.90
337.50
lGW
lGW
(AD)lntemal communications to objections and claims of owners/lessors of Whale Building and where client stands on lease; discuss involvement of FOC on lease issues and how best to handle; (AD)Continued work to address questions of new lenders for potential purchasers; discussion of title and propert issues with ERG and Goldking; furnish pertnent documents as
0.90
337.50
requested;
LGW
337.50 225.00
LGW
(AD)Discuss DNR's objections to sale of Group i and bonding requirements/ cash requirements for Redoubt; question whether any potential purchaser can meet financial hurdle; (AD)Participate in extensive conference call on abandonment issues and ramifications for abandonment of assets if
(Bl) Participate in weekly internal call; (AD)Follow-up with Ms. Wolf on Alaska Group I assets; (AD)Conferences with Ms. Wolf rearding preparation of assignments (Cook Inlet); (AD)Preliminary draft of recnveyance of overrding royalty
interests;
(AO)Conference with Ms. Wolf relating to recnveyance; (AD)Revision of conveyance of overrding royalty interests; (AD)Print and revise draft assignments and edit; (AD)Organlze same for Ms. Wolfs addition of pertinent
Page: 5
STATEMENT NO: 14
Forbearance Agreements
HOURS
information; Make necessary revisions and check against
database;
09/04/2009
SAH
0.60
135.00
EJD
LGW
LGW
(AD)Create labels for the closing folders for the assignments; print same and affx to folders; (BL)Telephone call to Ms. Walsh regarding extension of time to file joint report; respond to Ms. Leslie's e-mail regarding status report; (AD)Continued work on closing items - request and receive contact and counsel information for various bidders; contact counsel and verify information; explain that closing with be very quick; (AD)Continued work to identify what entit wil hold tite and operate for each potential purchaser; determine whether entiies are qualified with DNR and able to meet bonding requirement; review Information for Webb Exploration and
Production LC;
0.75
0.30
150.00
67.50
0.90
337.50
0.90 0.90
337.50
LGW
LGW
(AD)Additional work on PSAs for Group i purchasers; and concerns regarding draft language to insure Group i contracts and cures are accurate for each buyer; (AD)Partcipate in conference call with Goldking attorneys and man discussion with NPT and Goldking regarding title land matters and bonding issues; discussion of DNR issues and financial obligations; forward prior tite opinions and similar information as requested;
337.50
0.90 0.90
337.50
337.50
LGW
LGW
due and which contracts NPT wil accpt responsibilty for cure
LGW
on; (BL)Discuss MMS/BLM findings regarding royalty issues for West Foreland wells with potential purchasers questioning cure amount; discussion of whether court would escrow amount required to close until final determination of royalties owed can be determine; (AD)Attempt to discuss issues related to Escopeta farmout and what issues Potential buyer might face given Escopeta previous attempt to void farmout; consider additional revisions
0.90
337.50
0.90
337.50
LGW
Page: 6
STATEMENT NO: 14
Forbearance Agreements
LGW
of disclaimer for PSA; (AD)Continued work on cure amounts for PSAs; discussion with
Mr. Tywoniuk regarding throughputs and CIRI and Salamatof
HOURS 0.50
225.00
337.50
337.50
issues;
LGW
0.90 0.90
(AD)Receive requests for various CIRI and Salamatof documents and legal analysis of obligations thereunder; draft
and send;
LGW LGW
(AD)Work to finish up NAE final PSA; finalize exhibits and send to Ms. Parker; (AD)Participate in extensive conference call on PSA issues and work to conform CIE and NPT PSAs accordingly;
0.90 0.90 0.90 0.30 0.40 0.30 0.80 0.75 0.90 0.90
(AD)Continued work on Lender Recnveyances and send to Hunter White and other lender counsel for comments; (AD)Conference with Ms. Wolf regarding Beta Leases; (AD)Review and respond to emails from Mr. Saunders; (AD)Follow-up on offer by ERG;
(Ailarious conferences with Ms. Wolf regarding preparation
SAH
DMC DMC DMC DMC
of closing documents (Cook Inlet); (AD)Collate assignments and make changes per DNR database; finalize; (AD)Prepare assignment checklist; (AD)Continue with preparation of closing checklist; (AD)Make necessry revisions to closing checklist against
database and PSA;
0.90
0.90
202.50
neeed;
202.50
09/05/2009
HEG
LGW LGW
(AD)Review of assignments prepared by lenders and preparation of redline comments; (AD)Continued work on NAE PSA; numerous emails from Mr. Gross regarding Exhibit A and respond; (AD)Continued work on CIE PSA; numerous emails from Mr.
Hall and Mr. Wilcox rearding Exhibit A; bonding matters and
1.00
425.00
337.50
LGW
LGW
other financial responsibilty issues and respond; (AD)Continued work on NPT PSA; numerous emails and revisions of Exhibit A;
Page: 7
STATEMENT NO: 14
Forbearance Agreements
HOURS
09/06/2009
LGW
(AD)Receive requests for information regarding BLM lease from Mr. Tywoniuk and discussion of CIRI objecions; draft memorandum regarding royalty issues and history of wells for Mr. Tywonluk; (AD)Continued work on BLM lease memorandum for Mr. Tywoniuk and attch CIRI and BLM objecions; send to Mr. Tywoniuk; (CO)Receive email from Mr. Perkins regarding unpaid bil and proof of claim; request documentation and respond; send to Ms. McFarland; (AD)Review emails from Mr. Tywoniuk regarding revisions to closing checklist; discuss timing of closing and anticipated
337.50 337.50
LGW
LGW
225.00
LGW
0.90
337.50
09/07/2009
LGW
(AD)Emails and calls with lender's counsel to discuss proposed recnveyance documents and draft new language to conform to industr usage; send for comment; (AD)Continued response and limited research for Mr. Litvak and bankruptcy counsel regarding issues presented by CrRI and BLM agreements regarding royalty interests in WF wells; (AD)Continued work on ancilary closing documents in light of changes over weekend to various PSAs and included items in schedules; re-work Bil of Sale to reflect propert to be
0.90
0.90
337.50
LGW
337.50
LGW
0.90
337.50
LGW
(AD)Continue review of relevant title docments for TBPF interest and discussions with client regarding diffculties presented if Group i assets lose access to facilities. Follow-up with Mr. Marino and Mr. Saunders; (AD)Emails and discussion of ORRI amounts owed to Alaska
0.90
337.50
0.90
0.90 0.90
LGW
Forbearance Agreements
STATEMENT NO: 14
HOURS
LGW
(AD)Continued work on closing documents; proceed with
drafting three sets since debtor wil not know who wins auction until bankruptcy court decides. (NPT);
LGW
(AD)Begin re-working of propert exhibit for Motion to
0.90
0.90
337.50
337.50
wil be rejected or financing may not materialize; (AD)Exended conference call wit co-ounsel regarding need
for available support staff and notaries for closing; discussion of how parties can get frm DE to CA in time to close deal; discussion of whether some paper can be executed prior to closing and held in escrow; (AD)lntemal discussion on closing issues and returns of
LGW
ACM
337.50
262.50 275.00
09/08/2009
SAH
0.90 0.50
180.00
212.50
0.90 0.90
337.50 337.50
LGW
LGW
current; telephone call frm Mr. Gross to question throughputs; (AD)Recive requests for reserve report and forward to
prospecive purchasers attempt to answer title questions for
337.50
112.50
purchaserllender;
LGW LGW
(AD)Preliminary drafting of NAE assignments for closing; review propert descriptions and compare with DNR website; (AD)Continued preliminary drafting of NAE assignments for closing; review propert descriptions and compare with DNR
337.50 337.50
website;
LGW (AD)Preliminary drafting of NAE assignments for closing; review propert descriptions and compare with DNR website;
337.50
Page: 9
10/27/2009 6476-2795M
14
Forbearance Agreements
HOURS
LGW
for service; (AD)Review request frm Alaska DNR regarding cure amounts and other issues and respond to Ms. Woolf; discussion of what properties DNR would need to have if Group I is abandoned;
0.96
360.00
0.90
337.50
LGW
Review email frm Mr. Katic regarding where financial responsibilty lies for Alaska abandonment liabilty - parent
(A D)
0.90
337.50
whether debtor wil renew, who can sign, etc.; discussion with
LGW LGW bankruptcy counsel and Mr. Arlington regarding estimates for abandoning injection wells; (AD)Review CIE submitals to Seller; comment on same; (AD)Receive email from Mr. Arlington and Mr. Jeric regarding BLM royalty issues; discuss whether PERL has all
responsibilty for royalties of whether there is residual liabilty
0.90 0.70
337.50 262.50
LGW
with FOC; review transaction documents to determine; (AD)Receive emaH from Mr. Litvak requesting furter scrutiny of contract rejection list and cure amounts for assumed contracts; review, comment and redline;
0.90
0.90
337.50
337.50
LGW
three candidates;
ACM ACM
ACM
0.90
337.50 330.00
assignments;
(AD)Conference with Ms. Wolf regarding status of assignments for Alaska assets; (AD)Review materials with Ms. Castle for finalizing
0.60
0.50 0.60 0.50 0.50 0.50 0.40 0.30
275.00
330.00 275.00 275.00 275.00
(AD)Review and respond to various emails with Mr. Saunders regarding consent by MMS to extend deadline to assume
leases;
ACM ACM ACM ACM
ACM
(AD)Telephone conference with Ms. Shanan at MMS; (AD) Follow-up email for wrien consent and extension;
220.00
165.00
leases;
Page: 10
STATEMENT NO: 14
Forbearance Agreements
ACM ACM
DMC
HOURS 0.50
275.00
220.00
0.40
0.90
0.90 0.90 0.90 0.60
202.50
180.00 180.00 180.00 120.00
SAH
(AD)Continue preparation of 59 assignments for Cook Inlet Energy as Assignee; (AD)Continue with preparation of assignments - Cook Inlet Energy; (AD)Continue with preparation of assignments - Cook Inlet Energy; AD)Continue with preparation of assignments - Cook Inlet Energy; AD)Continue with preparation of assignments - Cook Inlet Energy; (AD)Make revisions to Cook Inlet Energy assignments per Ms.
Wolf;
202.50 202.50
DMC
45.00
09/09/2009
LGW
(AD)Continued work on redline of draft Alaska PSA - per Mr. Tywonluk's comments; work on Exhibit A propert descriptions, new facilities agreement and exclude escrows from list of
LGW LGW
contract cure amounts; (AD)Recive email from Mr. Kharasch advising that State of
Alaska wil not be bidding; follow-up with Mr. Tywoniuk; (AD)Receive email from Mr. Kharasch regarding what happens to ORRis if leases are abandoned. Discussion that ORRis are
ancilary rights and are passive; follow-up with Mr. Marino;
337.50
150.00
337.50
337.50
LGW
LGW
0.90
337.50
Page: 11
STATEMENT NO: 14
Forbearance Agrements
HOURS
LGW
0.90 0.30
337.50
112.50
0.90
0.90 0.90 0.90
337.50
337.50
337.50
LGW
LGW
337.50
LGW
0.90 0.90
337.50
337.50
337.50 220.00 165.00 440.00
385.00
385.00 67.50 202.50
318.75
questions;
DMC DMC
HEG
(ADVanous conferences with Ms. Wolf rearding assignments; (AD)Draft assignment logs; (AD)Preparation with Ms. Wolf of changes to the purchase and sale agreement and to the assignment and bil of sale;
09/10/2009
HEG
(AD)Review of draft of proposed assignment and bill of sale;
Page: 12
STATEMENT NO: 14
Forbarance Agreements
HOURS
conference with Ms. Wolf relating to proposed assignment and
LGW
0.75
318.75
handle;
LGW
(AD)Receive NAE commitment letter; review and discuss inadequacy of Pyramid response; follow-up; discuss with bankruptcy counsel and Lazard; offer to assist If required; line of Exhibit A (AD)Receive additional inquiry regarding red from Chevron and discuss changes and whether buyer pays for services to be rendered; telephone calls and emails to Mr. Arlington; (AD)Review emails and questions from Ms. Parker regarding
0.90
0.90
337.50 337.50
LGW
0.90
337.50
LGW
0.90
337.50 262.50
262.50
0.70 0.70
bankruptcy counsel;
(AD)Receive email from Mr. Tywoniuk regarding issues for buyers re insurance and deposits in order to close if sale goes through and follow-up; review bonding agreements to see how DNR handles transitons and if there are emergency
provisions;
LGW
0.90
337.50
0.60
225.00
LGW
0.80
0.90 0.90
300.00 337.50
LGW
(Bl)Review email frm Mr. Tywoniuk that NAE ICIE sales are
LGW
Parker;
LGW
(BL)Continued revisions and draftng of abandonment related
337.50
Page: 13
STATEMENT NO: 14
Forbarance Agreements
HOURS
documents per counsel and debtor; coordinate with Mr. Litvak;
0.90
337.50
LGW
(BL)Discussion of reconveyance of ORRIs in light of abandonment and in light of Holdback of exploratory properties; check with lenders' counsel for update on their thinking; (BL)Telephone conference with Mr. Litvak to insure that court and creditors are noticed and that amended notice does not need to be filed; (AD)Emails to Ms. Wolf regarding authorized parties to sign for PERL at MMS & DNR; (AD)Follow-up with Mr. Tywoniuk; (AD)Telephone conference with Ms. Willams at MMS;
0.90
0.90 0.30 0.30 0.30
337.50
337.50
165.00 165.00 165.00
09/11/2009
LGW LGW
(AD)Continued work on Group I Abandonment Order and exhibits; finalized changes in light of Chevron demands; (AD)Continued work on exhibits to add Middle Lake lease with abandonment issues; finalize and send to bankruptcy and business counsel for hearing; review emails to address issues
0.90
337.50
with contracts that wil need to be rejected that are related to abandoned leases;
LGW
(AD)Receive emails form lenders' counsel regarding reconveyances and status of sales and/or abandonment; advise that most properties are going to be abandoned but
0.90
337.50
some wil be held out for later sale; reconveyance wil becme necessary and inquire as to produre;
LGW
0.90
0.90
337.50 337.50
337.50 225.00 112.50
LGW
LGW
DMC
(AD)Review email frm Mark Cervi rearding information about CIPL funding agreement and forward same; provide short history of CIPL funding matters and liabilities; (AD)Review Revised Abandonment Order from Mr. Litak incorporating CIRI and Donkellanguage; comment and return after discussion with Mr. Marino; (AD)Review of additional material from CIE;
(AD)Various conferences with Ms. Wolf rearding preparation
0.90 0.60
0.50
1.00 1.00 1.00 1.00
225.00 225.00
225.00 225.00
Page: 14
STATEMENT NO: 14
Forbearance Agreements
HOURS
LGW
LGW
(AD)Review updated lease list from Alaska DNR; confirm that Debtors' abandonment exhibit is consistent with same; question some entries and confirm with DNR; (AD)Review Abandonment Order from Court; answer emails from bankruptcy counsel rearding MMS and BLM issues and cease work on Alaska;
0.90
270.00 270.00
0.90
09/13/2009
LGW
(AD)Continued work with DNR on abandoned propert lists that are not yet posted on OMNI website; continued work on
LGW
0.90 0.90
337.50
337.50
09/14/2009
LGW
(AD)Work on additional abandonment issues for bankruptcy counsel; furter discussion of timing in light of when Alaska offce wil close; discussion with Mr. Arlington regarding same;
LGW LGW
0.90 0.20
337.50 75.00
working and
0.90
LGW
draft language sent to Mr. Kharasch; follow-up with email to Ms. Shahan; (AD)Review offer letter from Aurora for Three Mile Creek; discuss with Mr. Tywoniuk and determine that properties wil
337.50 337.50
0.90
0.60
(BL)Review MMS email regarding continuance and address Ms. Shahan's concems; (BL)Review email from Mr. Litak requesting particular scrutiny of contracts to be rejected; begin preliminary review as
225.00 337.50
requested;
LGW
0.90
LGW
LGW
(BL)Additional email from Mr. Litvak requesting that SRSM create and handle exhibit to rejection motion; discuss with Mr. Saunders as to form and how contents are to be arranged; also discuss notice issues; (BL)Review of Donkel Limited Objecion to Alaska abandonment; discussion with bankruptcy counsel regarding merits of same; query whether theses ORRIS wil eventually be paid; (BL)Review of updated numbers for MMS proof of claim for WF wells and royalties; advise bankruptcy counsel regarding our objections to same; discuss settlement if possible;
0.90
337.50
0.90
0.90
337.50 337.50
Page: 15
Forbearance Agreements
STATEMENT NO: 14
HOURS
ACM
ACM
consent;
ACM ACM
(AD)Conference with Ms. Wolf regarding status of propose sale of Alaska assets to Cook Inlet; (AD)Review various emails from Mr. Saunders regarding MMS
220.00
DMC
DMC
DMC
DMC
(AD)Review emails regarding MMS issues; (AD)Follow-up with Ms. Wolf regarding Ms. Shanon at MMS and discussions of California State Lands; (BL)Review new pleading obtained frm PACER and prepare attomey summaries for Mr. Marino; (BL)Continue preparation of summaries of newly filed claims as found on PACER website and discuss with Ms. Wolf, (AD)Continue with preparation of memoranda regarding BK sales procedures and revise schedule accordingly; (AD)Continue with preparation of assignments - Cook Inlet
220.00 165.00
275.00
0.50
0.90
0.90
0.90 0.30
Energy;
09/15/2009
LGW
(BL)Emails from Ms. Shahan questioning MMS extension wording; call, discuss and propose new language to take care of concems; discuss with Mr. Saunders to see if he agrees to
changes;
LGW
(BL)Continued work on MMS extension draft and clarify proposed language; receive new language from Mr. Saunders and discuss prior to sending on numerous emails; (BL)Receive signed MMS extension; forward to Saunders and receive request to get similar from CA State Lands Commission; contact Ms. Young's offce and speak to paralegal about request and need for quick response; send
0.90 0.90
337.50
337.50
LGW
0.90
337.50
0.90
337.50
LGW
LGW
permit process for Breitbum, potential purchaser; review files to see if such pennit was obtained at closing or whether it was obtained by predecessor in title; discuss with Mr. Marino and respond accordingly; (BL)Receive email from Mr. Saunders requesting reconcilation of contract lists for sale motion and abandonment motion; preliminary review of same; (BL)Continued work on reconcilation of contract lists for sale
0.90 0.90
337.50
337.50
Page: 16
STATEMENT NO: 14
Forbearance Agreements
LGW
motion and abandonment motion; follow-up with Mr. Arlington; (BL)Receive service list for bankruptcy court and update as
HOURS 0.90
337.50
LGW
emails and follow-up; determine whether some contrcts are room for newer information; stil in force; check data (AD)Review exhibit of exploratory propertes for proposed sale;
337.50
ORRIs wil be sold; if so, have creditors approved such sale; (AD)Conference with Ms. Wolf regarding Alaska assets; (AD)Review and respond to emails from Mr. Saunders, Ms Shahan wntten consent of MMS; (AD)Emails to Mr. Tywoniuk; (BL)Review additional pleadings obtained from PACER and prepare attorney summanes for Mr. Manno and Ms. Wolf; (BL)Continue preparation of summanes of newly filed claims and discuss with Ms. Wolf; (BL)Continue with preparation of memoranda regarding BK claims and revise schedule accordingly;
337.50 220.00
220.00 165.00
0.90
0.90 0.90
202.50 202.50
202.50
09/16/2009
LGW
LGW
(BL)lnquiries from Mr. Saunders regarding WY propertes and contracts to be abandoned; request copies of contracts and other agreements relative to these propertes and discuss with Mr. Cervi regarding outcome of well driled in WY; (BL)Review WY propert documents and contracts to be abandoned; determine whether contracts that Debtor took interest subject to nee to be rejected; internet search for addresses of possible necessary notice parties;
0.90
337.50
337.50
337.50
LGW
LGW
(BL)Furter communication with CLSL regarding extension; make changes to document and resend; recive executed pdf; forward to bankruptcy counsel; (BL)Furter communication with City of Long Beach regarding
extension; make changes to document and resend; receive executed pdf; forward to bankruptcy counsel; (BL)Review Third Rejection Motion draft - contract from Saunders and bein comments; discuss contracts with Mr. Arlington and Long Beach offce to see whether rejection might be premature; discuss with Mr. Tywoniuk; numerous emails; (BL)Continue work on Third Rejection Motion; (BL)Emails from bankruptcy counsel requesting information regarding why some leases were rejected and others with similar names were not; explained liabilties associated with
337.50
LGW
LGW LGW
0.90 0.90
337.50 337.50
SCHULLY, ROBERTS,
Page: 17
NO: 14
Forbearance Agreements
HOURS
specific properties; pointed out that non abandoned leases are exploratory and therefore perhaps marketable to potential purchaser with no attendant liabilty to debtor;
0.90
337.50
LGW
(BL)Revise exhibits per Mr. Litak - exclude all 011 and Gas leases; question existence of other real propert leases;
LGW
discuss diffrence between oil and gas leases and landlord tenant issues; (BL)Additonal inquiries frm DNR regarding abandoned
properties; respond and refer to Mr. Arlington and Mr. Hall; discussion of whether there might be a buyer in the wings; referred to Mr. Tywoniuk; (BL)Follow-up telephone cali from DOJ attomeys to determine whether any progress has been made toward determination of proper royalty amount for WF wells; forwarded emails and agreed to conference cali to discuss; explained that amount as it stands wil probably lead to abandonment becuse new owner would have to pay cure; discussion of settement power of agency; (AD)Emails to Ms. Wolf; (AD) Follow-up emails to Mr. Tywoniuk; (OP) Telephone conference wit Ms. Willams at MMS regarding update qualification; (OP)Conference with Ms. Wolf; (CO)Emails to Mr.Cervi regarding Osprey propert;
0.90
337.50
0.90
337.50
LGW
09/17/2009
ACM ACM ACM ACM ACM DMC
(OP)Emails to Mr. Tywoniuk regarding MMS signing authority; (OP)Telephone conference with Ms. Willams at MMS; (OP)Conference with Ms. Wolf on status of documents; (CO)Emails to Mr. Tywoniuk regarding MMS Beta issues; (CO)Conference with Ms. Wolf;
(BL)Review new documents received frm counsel and
LGW
LGW
prepare attomey summaries for Mr. Marino and Ms. Wolf; (BK)Continued discussion of CIPL liabilit and need to abandon funding agreement; sent short memorandum on same to requesting partes; (BK)Emails and discussion of need to change signing authority
0.90
LGW
research process by which to amend incumbency documents In Alaska; follow-up with Mr. Tywonluk to see who is empowered to sign for debtor as of now; (BK)Extensive work on service list for Third Rejection Motion
0.90
337.50
Page: 18
STATEMENT NO: 14
Forbearance Agreements
HOURS
LGW
determine whether there are new parties not previously noticed and inquire how to handle; (AD)Discussion with Alaska offce regarding seismic information and licenSing in light of abandonment; anticipate that Digital will request return of its data; further discussion of Escopeta issue and Sabre Prospect; (BK)Participate in internal call to discuss Chapter 11 work and asset sale; receive assignments from Mr. Tywoniuk and begin to work on bankruptcy motions regarding BETA; (BK)Numerous revisions and tweaks to exhibits for Mr.
0.90
337.50
0.90 0.90
0.80
337.50
LGW
337.50 300.00
337.50
LGW
LGW
Saunders;
(BK)Receive AERA limited objection and review; determine how wil impact sale of BETA assets and discuss how to handle in adversary action; (AD)Discussion with Mr. Marino regarding how to handle incumbency issues for MMS - Pacific region; update on discussions with Ms. Willams and Mr. Mlng; continued man regarding possible acquisition of discussion with ERG land Beta leases and follow-up; (AD)Discussion with DNR bankruptcy attorney regarding need
0.90
LGW
0.90 0.60
0.60
337.50 225.00
LGW
LGW
LGW
DMC
DMC
(CO)Receive additional information regarding renewal of EPA escrow and contact debtor to determine course of action; (AD)Conference with Mr. Marino to discuss Beta due dilgence requests - pipeline permits and Aera title issues; (BL)Continue preparation of summaries of newly filed claims and discuss with Ms. Wolf; (BL) Revise schedules to conform to new information from BK
225.00
337.50 202.50
counsel;
JGS
09/18/2009
ACM ACM ACM
202.50 82.50
Issues;
(OP)Review Insolvency Certificate for PERL; (AD)Telephone conference with Ms. Wolf on status of
prospective buyers;
220.00 165.00
ACM
JGS
LGW
(OP)Follow-up with Mr. Tywoniuk and Ms. Willams; (OP)Researched and found forms to update qualification card for San Pedro Bay and Perl with the MMS; (BL)Review Certification of Counsel extending deadline for
220.00 275.00
247.50
Page: 19
Forbearance Agreements
STATEMENT NO: 14
LGW LGW
BET A; copy all counsel and send appropriate thank you notes; (AD)Discussion of retums of deposits; review extensive email chain to determine chronology; (AD)Discussion of potential purchasers for Beta and response to continued due diligence requests for creditors; discussion of
HOURS 0.90
337.50
0.90
337.50 337.50
0.90
0.90
0.90
337.50
LGW
LGW
LGW
0.90 0.70
09/19/2009
LGW
(AD)Review of exhibits for retained assets from Mr. Arlington;
0.90
337.50
0.90
337.50
LGW
0.90
337.50
LGW
0.90
337.50
LGW
Page: 20
10127/2009
STATEMENT NO: 14
Forbearance Agreements
HOURS 0.90
337.50 337.50
LGW
0.90
LGW
0.90
0.70
337.50
LGW
Objections - BETA;
262.50
09/22/2009
LGW
(BL)Review of email from Mr. Arlington regarding Copper River dry hole; discussion of whether to abandon such leases and farmout agreement; revise exhibits accordingly; (BL)Work on new Incumbency certificates for debtor; preliminary drafting; (BL)Review Inquiry from DNR regarding reconveyances of lender ORRis and timing thereof; discussion with Mr. Tywoniuk and Mr. Marino and determine that only wil request reconveyance for exploratory propert when and if sold;
0.90
337.50 337.50
LGW
0.90
LGW
0.90
337.50
LGW
0.70 0.90
262.50 337.50
09/23/2009
ACM
(OP)Various emails to Mr. Tywoniuk and Ms. Willams at MMS concerning incumbency certficates and resolutions;
165.00
ACM ACM
ACM
275.00
275.00
385.00
337.50
LGW
documents;
LGW
(BL)Email form Debtor regarding cancellng insurance
0.90
Page: 21
STATEMENT NO: 14
Forbearance Agreements
HOURS
also informing that the EPA LOC will not be renewed; research
LGW LGW
LGW
LGW
tech deposit issues with Mr. Tywoniuk; partcipate in internal cali to discuss; review attorney notes and emails to establish tim'ing of discussions; tech deposit issues call and comment; (BL)Partcipate in Poly (BL)Continued work on Polytech related matters to see when regulators were contacted; gather documents to support; (BL)Review Order permitting extension of time; send to MMS, DOJ, CSLC and City of Long Beach; follow-up with Ms. Shahan regarding royalty issues as well; (AD)Receive request from Mr. Tywoniuk to review Mr. Arlington's exhibits for exploration properties; discussion of
(BL)Discuss Poly
337.50 337.50
09/24/2009
DMC
ACM ACM ACM LGW
(BL)Review new documents received from co-ounsel and prepare attorney summaries for Mr. Marino and Ms. Wolf; (BL)Update and status report with Ms. Wolf;
questions posed by bankruptcy counsel - common fund doctrine and deposit with registry of court of attomey fees for
Medema counsel;
LGW
0.90 0.90
0.90 0.90
(BL)Continued work on legal issues posed by bankruptcy counsel above including rights of lender defendants; (BL)Review proposed settlement agreements per bankruptcy counsel and suggest that Alaska counsel be copied; (BL)Partcipate in weekly call;
available;
LGW LGW
tech team; (BL)Discussion with Mr. Arlington regarding records and offce closing; determine whether to send original FOC documents to Long Beach or retain; discussion with Mr. Marino;
(BL)Prepare for conference call with Poly
Page: 22
STATEMENT NO: 14
Forbearance Agreements
HOURS
DMC
(BL)Continue preparation of summaries of newly filed claims and discuss with Ms. Wolf;
0.90
202.50
09/25/2009
LGW
(BL)Review MMS meeting notes from Mr. Jeric; discuss with Mr. Arlington and begin draftng response for propose conference call; (AD)Continued work on exploration propertes sale issues, PSA and exhibits;
337.50
LGW
LGW LGW
09/28/2009
LGW
(BL)Receive numerous questions from ERG land man
regarding lender interests in Alaska; explain that there are no lender production payments in Alaska and therefore could not be abandoned; lengthy discussion of proposed sale and how to work with lender and how to faciltate qualification in Pacific Region;
0.90 0.90
337.50
LGW
337.50 337.50
LGW LGW
requested;
0.90
determine that PERL cannot dispose of such documents or destroy; request guidance on these and other documents; (AD)Receive word to rework of exhibits and schedules and update PSA;
0.90
337.50
337.50
165.00
0.90
0.30 0.40 0.90 0.90
09/29/2009
ACM ACM
LGW
(BL)Conference with Ms. Wolf;. (BL)Review and respond to various emails regarding pending action in bankruptcy court; (BL)Review bullet point letter from BlM/MMS/DOJ conference cali and begin preliminary drafting of position statement per MMS request;
220.00
337.50
337.50
lGW
Page: 23
STATEMENT NO: 14
Forbearance Agreements
HOURS
0.90 0.90
337.50 337.50
337.50
0.90
0.90 0.90
documents;
(AO)Continued work on contrcts/documents for dataroom; (AO)Work on revisions of drafts of PSA with Ms. Parkerseismic and other exhibits; discussion of items with Mr. Arlington; (AD)Work on contract selection and lists for Mr. Cosgrove per Mr. Marino; (AD)Review delay rentals exhibit and comment; follow up with
Mr. Arlington;
337.50 337.50
337.50 337.50 337.50
337.50
lGW
lGW
lGW
(AD)Follow-up on ERG questions for Mr. leFleur with MMS and debtor; review AERA, SWEPI conveyances to determine extent of obligations;
09/30/2009
ACM ACM
(AD)Conference with Ms. WOLf;
lGW
(AD) Review of Exploration propert list; (Bl)Review Digitel's Objection to Third Rejection Motion; discuss of what nees to done and whether data must be returned; review licensing agreement and determine that return Is proper course; review emails from Mr. Arlington and Mr. Tywoniuk and send email to Mr. Saunders on issue;
220.00 165.00
0.90
337.50
337.50 337.50 337.50
LGW
0.90 0.90
lGW
lGW
lGW
0.90
lGW
Tywoniuk and trustee; follow-up reading of agreement and review of statute; (AO)Continued extensive file review for exploratory properties exhibits and review to confirm that there are no ancilary
0.90
337.50
STATEMENT NO: 14
Forbearance Agreements
documents required;
lGW (AD)Continued work and analysis of documents for exhibits; lGW (Bl)File review and short memorandum to Mr. Saunders
regarding EPA issues; negotiation of trust and letter of credit; explain that Belmar Engineering has determined that Trust is
337.50 337.50
0.90
TOTAL FEES:
RECAPITULATION
0.90 272.56
HOURLY RATE $200.00 225.00 550.00 275.00 374.33 225.00 425.00
TIMEKEEPER Susan A. Hymel Diane M. Castle Anthony C. Marino Joan Guidry Seelman Lynn G. Wolf
Emile J. Dreuil, III
15.25 15.64
30.89
$479,306.32
102,015.89
10/14/2009
10/14/2009
Payment Received on Statement No.12, Wire Transfer of October 14, 2009 Payment Recived on Statement No.12, Wire Transfer of October
-661.63
14,2009
TOTAL PAYMENTS
-175,336.80 -175,998.43
STATEMENT NO: 14
Forbearance Agreements
BALANCE DUE:
$405,323.78
PLEASE INDICATE FILE NUMBER, STATEMENT NUMBER AND STATEMENT DATE ON ALL REMITTANCES
DATE OESCRIP1ON
INV #
9095502
AMOUNT DEDN
3,205.07
CHECK
NET AMOUNT
3,205.07
CHEC DATI
CONTL NUM
09/30/09
24703
TOTALS
Gross:
3,205.07
Oed:
0.00 Net:
3,205.07
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-.
24703
~ lX 1+8Q2U WV.delm
Check Request
Date:
Payable to:
Cypress
3205.07
Telecommunications
See Below
Amount:
Description/Purpose:
File Number:
Requesting Attorney
AEH
Time/Date Needed:
Approved by:
Regular Bilino
Comments: 5660: 1614.75; 5660.2: 807.00; 5670: 37.23; 1300.3: 483.73; 5660.4: 270.00; 4190: -7.64
~
()cclcuedoc
~ c 4D
Page 01
Act #:
Invo #:
Invce Dale: Pavment Cue:
280oo00030801802 9055 5
SEPTEMBER 01, 200
cypress COwrlCAONS'.
OCTOBER 01,200
D1rllnuiri To:
(888)528-1788
Thank you for choosing Cypress Communications. Inc. For questions about your invoice. please contact our Customer Care Department ~ 888-528-1788 or e-mail us at invoicehelp~cypresscom.net. Please send name & address changes via email toinvoicehelp~cypresscom.net.
Returned Check Charge is $25.00 Please write the invoice number on your check. Make checks payable to: Cypress Communications. Inc.
_~ - .e_
..
REMITTANCE STATEMENT
Pag 03
.. .. .. 4D. .. ..
4D .. .. .. ...... ..
. cypress COMMNlCONS"
SCHULL Y ROBERTS SLATTERY & MARINO 1100 POYDRAS ST. SUITE 1800 NEW ORLEANS, LA 70163
Account ,,:
Invice ,,:
Invice Date:
28003-801802
9095502 5 SEPTEMBER 01, 20
OCTOBER 01, 2009
Diret inuiris To:
Payment Du
(88)5281788
Regulated serce provid by Cyes Comunlcatins Operating Company, U.c
lJi~
19.38
--------ig:3a yf
0114722243 08/06/09
515.0
175.10
CONFERENCE TOTAL ~
-------i7:ia vi
4
01148424 08/21/09
134.0
45.56
---------~--- /
CONfERENCE TOTAl
45.56
01148 08/22/09
5046153021 26.0 2259270503 24.0 504B611481 23.0 5048879151 20.0 CONFERENCE MINUTES 93.0
CONFERENCE TOTAL
31.62
------------- ,
31.62
011470943 08/05/09
1.02
------------- ./
1.02
01147055 00/0/09
.."
Page 2 018
( Eq ProfelSfonal vJ.5 i
Ty Date TIme
Use
Device Name
Deription
DurUon
05:02:27
Items
Cost sl
ClientIatter Totals:
183 / $459.00
CllentIalter Totls:
CllentIattr: 3100.274. COLLECTION ON OPEN ACCOUNT
00:0548 0005:48
27/
27
288 86
$6.75 V
$675
0011:27
00:02:28 00:10:14
2
26
19
Copy Sep. 08. 200 20:32:46 30 - BOUDREAUX, EDWARD Caon Copy Sep. 09, 2009 13:43:21 30 - BOUDREAUX, EDWARD Can Copy Sep. 09. 20 13:58:0 30 - BOUDREAUX, EDWARD Cann
Copy Sep. 09, 20 18:26:04 30 - BOUDREAUX, eDWARD Cannon
0010:32
0026: 12
0003:14
00:15:13
00:01 :41
25
13 14 5
Copy Sep. 09, 20018:38:36 30 - BODREAUX, eDWARD Caon Coy Sep. 09, 200 18:55:05 30 - BOUDREAUX, EDWARD Cano
Coy Sep. 09,200 21 :53:32 30 - BOUDREAux EDWARD Xero Cop Sep. 14,200917:19:37 30- BOUDREAUX, EDWARD Canon
Copy Sep. 15,2015:29:14 30 - BOUDREAUX, EDWARD Xerox Coy Sep. 16, 20 17:01 :39 30 - BOUDREUX, EDWARD Xerox
68 54 2 5
102
31
$72.00 V $21.50 V $0.50 V $6.50 V $4.75 V $6.25 V $3.25 V $3.50 V $1.25 V $17.00 V $13.50 V
SO.50 V
0015:59
03:22:22
86
12 /
12
$217.25
00:00:49 00:00:49
$3.00 V $3.00
Cop Sep. 16. 20 16:31 :21 7 - JARROTT. COEN Caon ClientJtter Totls:
CllentIater 5740.2021. NIEV MORTGAGE
00:01 :48
0001 :48
2 2
SO.50 V
$0
Co Sep. 28, 2015:10:59 29- BROWN. JOANIE Xerox Co Sep. 29, 20011:54:50 33 - DOY, KATHLEN Xerox Copy Sep. 29, 2011:58:03 33- DOY. KATHLEEN Xerox
Clientlattr Totals:
00:13:49
00:01 :48
35 47
00:10:33 00:26:10
11/
3
Cllenatter: 6476.25. FORBEARACE AGREEMEN Copy Sap. 04, 200 11 :001 8 . HYMEl SUSAN Canon
Copy Sap. 09. 20011:537 021 - WOLF, LYNN Xerox Coy Se. 14, 20 10:14:37 12 - CAST, DIANE Xerox
0001 :08
SO.75 V
00:25:34
Cllentatt Totals:
0012:10 00:3852
:1
12
0001 :56
00:15:28 00:17:24
122 /
In re: )
STATE OF DELAWARE )
) ss:
Debtors. )
AFFIDAVIT OF SERVICE
copy of
the following document(s) to be served upon the parties on the attached service lists in
Notice and Fee Application of Schully, Roberts, Slattery & Marino PLC as Special Oil and Gas and Transactional Counsel for the Debtors for the
Period September 1-30,2009
November 2009
Q ;;r;____ir~~ ()1~
Notar.y Public
DOC$_DE: I 4743
i The Debtors in these cases, along with the last four digits of each of the Debtors' federal tax
identification number, are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska Holdings, LLC (tax J.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); San Pedro Bay Pipeline Company (1234); Cameros
Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of
Hand Delivery (Counsel to Offcial Committee of Unsecured Creditors) David B. Stratton, Esquire James C. Carignan, Esquire Pepper Hamilton LLP
Hercules Plaza, Suite 1500
01 - Interoffice Pouch
(Counsel for Debtors) Laura Davis Jones, Esquire James E. O'Neil, Esquire Kathleen P. Makowski, Esquire Pachulski Stang Ziehl & Jones LLP 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE 19899-8705
Interoffice Pouch to Los Angeles (Counsel for Debtors) Robert M. Saunders, Esquire Ira D. Kharasch,Bsquire Scotta E. McFarland, Esquire Pachulski Stang Ziehl & Jones LLP
10100 Santa Monica Blvd., 11 th Floor
York, NY 10026
yYilmington, DE 19801
; . "
n -,"('"
: :, ,
\ T l'
.'l" .
'.;.)..
':..C'
-',;-i,
')~"\
Unsecured
Creditors) Francis J. Lawall, Esquire Pepper Hamilton LLP 3000 Two Logan Square Eighteenth & Arch Streets Philadelphia, P A 19103
Filiberto Agusti, Esquire Steven Reed, Esquire Joshua Taylor, Esquire Steptoe & Johnson LLP 1330 Connecticut Avenue NW Washington, DC 20036
Unsecured Creditors)
Kelly Frazier, Esquire Steptoe & Johnson LLP 2121 Avenue ofthe Stars, 28th Floor Los Angeles, CA 90067
68773-00 I \DOCS _DE: i 47432, I