IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: PACIFIC ENERGY RESOURCES LTD., et al.

Debtors.
Objection Deadline: July 21, 2010 at 4:00 p.m. (prevailing Eastern time) Hearing: July 28, 2010 at 3:00 p.m. (prevailing Eastern time)

Chapter 11 Case No. 09-10785 (KJC) (Jointly Administered)

DEBTORS FOURTH MOTION FOR AN ORDER PURSUANT TO 11 U.S.C. 1121(d) EXTENDING THE TIME PERIODS DURING WHICH THE DEBTORS HAVE THE EXCLUSIVE RIGHT TO FILE A PLAN AND SOLICIT ACCEPTANCES THEREOF
The above-captioned debtors and debtors in possession (the "Debtors") hereby move (the "Motion") the Court for the entry of an order, pursuant to section 1121(d) of title 11 of the United States Code (the "Bankruptcy Code"), (a) extending by sixty-nine (69) days, to September 9, 2010, the period under section 1121(b) of the Bankruptcy Code during which the Debtors have the exclusive right to file a chapter 11 plan (the "Exclusive Filing Period") and (b) if the Debtors file a plan before the expiration of the Exclusive Filing Period, extending by sixtynine (69) days, to November 9, 2010, the period under section 112 1 (c)(3) of the Bankruptcy Code during which the Debtors may solicit acceptances of a chapter 11 plan without any other party having the right to file a plan (the "Exclusive Solicitation Period," together with the Exclusive Filing Period, the "Exclusive Periods"). This request is the fourth by the Debtors for

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 I.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of the Debtors is 111 W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.

DOCSSF:72869.

an extension of the Exclusive Periods. In support of the Motion, the Debtors respectfully state as follows: Preliminary Statement This is the Debtors last request to extend the Exclusive Periods. The Debtors are barred from obtaining any further extensions beyond those requested hereby pursuant to section 1121(d)(2) of the Bankruptcy Code. The Debtors have made substantial progress in this case to date in terms of liquidating assets and maximizing available returns to all constituents. The Debtors have drafted a proposed form of liquidating chapter 11 plan (the "Plan"), but at the request of the Official Committee of Unsecured Creditors (the "Committee"), the Debtors have not yet filed the Plan in order allow the Debtors and the Committee to reach agreement on the terms thereof. The Debtors request an extension of the Exclusive Periods by sixty-nine (69) days in order to finalize the terms of the Plan. Jurisdiction and Venue 2. The Court has jurisdiction over this Motion under 28 U.S.C. 1334. This

matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2)(A), (L), and (0). 3. Venue of the Debtors chapter 11 cases and this Motion in this District is

proper pursuant to 28 U.S.C. 1408 and 1409. 4. requested herein. Background 5. On March 9, 2009 (the "Petition Date"), the Debtors commenced their Section 1121(d) of the Bankruptcy Code provides the basis for the relief

chapter 11 cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy Code.

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The Debtors have continued in the possession of their property and have continued to operate and manage their businesses as debtors and debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 6. No trustee or examiner has been appointed in the chapter 11 cases. The

Office of the United States Trustee appointed an Official Committee of Unsecured Creditors on March 19, 2009. 7. The Debtors are a group of independent energy companies that were

engaged in the acquisition, development and exploitation of oil and gas properties in the western United States. As of the Petition Date, the Debtors oil and gas assets were located offshore near California (the "Beta Assets") and principally offshore in Alaska (the "Alaska Assets"). The Debtors acquired these oil and gas assets in transactions occurring in the fourth quarter of 2006 and during 2007, and their secured debt was related to these acquisitions. The Debtors revenue was largely dependent on the market price for the underlying crude oil produced, in addition to the level of production. Their revenue for 2008 was approximately $226.2 million. 8. These chapter 11 cases are large and complex and have presented

numerous and significant business and legal challenges related to the operation of oil and gas properties, the negotiation of debtor in possession financing, the eventual abandonment of certain of the Alaska Assets, the sale of certain of the Alaska Assets to a third party, the sale of the Beta Assets to the lenders, litigation with parties claiming a variety of interests in the Alaska Assets or the Beta Assets, and other matters related to the winding down of an oil and gas business. These matters, including the analysis and resolution of approximately 580 claims filed against the Debtors, several of which are substantial administrative and other priority claims, have required

DOCSSF:72869. 1

substantial attention from the Debtors employees, management, and professionals from the beginning of these chapter 11 cases. 9. The Debtors are now at the point of proposing a liquidating chapter 11

plan for these estates. The Debtors have drafted the Plan and provided it to the Committee for comment. Because the Committee requested additional time in order to review the Plan and to reach agreement on the terms thereof, the Debtors have delayed filing the Plan and this has necessitated the need to request one last extension of the Exclusive Periods by sixty-nine (69) days. 10. This is the Debtors Fourth motion to extend the Exclusivity Periods in

these cases. The current Exclusive Filing Period will expire on July 2, 2010, and the current Exclusive Solicitation Period will expire on September 1, 2010. In light of the complexity of these chapter 11 cases, the progress made to date, and the status of negotiations regarding the terms of the Plan with the Committee, the Debtors require additional time in which to file a plan and obtain its acceptance. Relief Requested II. By this Motion, the Debtors seek to extend the Exclusive Filing Period for

sixty-nine (69) days, from July 2, 2010, through and including September 9, 2010, and to extend the Exclusive Solicitation Period for sixty-nine (69) days from September 1, 2010, through and including November 9, 2010. Basis for Relief 12. Section 112 1(d)(1) of the Bankruptcy Code grants the Court authority to

extend the Exclusive Periods "for cause" after notice and a hearing. 11 U.S.C. 1 121(d)(1).

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Although the term "cause" is not defined by the Bankruptcy Code, the legislative history indicates that it is to be viewed flexibly "in order to allow the debtor to reach an agreement." H.R. Rep. No. 95, 95 1h Cong., 1st Sess. 232 (1997). See also In re McLean Indus., Inc., 87 B.R. 830, 833 (Bankr. S.D. N.Y. 1987) (quoting H.R. Rep. No. 595, 95th Cong., 2d Sess. 231 (1978),

reprinted in 1978, U.S.C.C.A.N. 5963, 6190); In re Public Serv. Co. off. H, 88 B.R. 521, 534
(Bankr. D. N.H. 1988) ("[T]he legislative intent. . . [is] to promote maximum flexibility") 13. To facilitate this legislative intent, a debtor should be given a reasonable

opportunity to negotiate an acceptable plan with creditors and to prepare adequate financial and nonfinancial information concerning the ramifications of any proposed plan for disclosure to creditors. See, e.g., In re McLean Indus., Inc., 87 B.R. at 833-34; In re Texaco Inc., 76 B.R. 322, 327 (Bankr. S.D. N.Y. 1987). The decision to extend a debtors exclusive periods to file a plan and solicit acceptances thereto is committed to the sound discretion of the bankruptcy court, based upon the facts and circumstances of each particular case.

See, e.g., First Am. Bank off.

v. Southwest Gloves and Safety Equip., Inc., 64 B.R. 963, 965 (D. Del. 1986).
14. Courts have relied on a variety of factors when determining whether cause

exists for an extension of a debtors exclusive periods to file a plan and solicit acceptances thereto, each of which may provide sufficient grounds for extending those periods. These factors include (a) the size and complexity of the cases, (b) the necessity of sufficient time to negotiate and prepare adequate information, (c) the existence of good faith progress toward reorganization, (d) whether the debtor is paying its debts as they come due, (e) whether the debtor has demonstrated reasonable prospects for filing a viable plan, (f) whether the debtor has made progress in negotiating with creditors, (g) the length of time the case has been pending,

DOCS5F:72869.I

(h) whether the debtor is seeking the extension to pressure creditors, and (i) whether unresolved contingencies exist. See, e.g., In re Dow Corning Corp., 208 B.R. 661, 664-65 (Bankr. E.D Mich. 1997); In re Express One Intl, Inc., 194 B.R. 98, 100 (Bankr. E.D. Tex 1996); In re

Grand Traverse Dev. Co. Ltd. P ship, 147 B.R. 418, 420 (Bankr. W.D. Mich. 1992); In re Texaco, Inc., 76 B.R. at 327. However, the identified criteria are only factors, not all of which
are necessarily relevant in every case.

See In the Matter of Federated Department Stores and

Allied Stores Corporation, 1990 Bankr. Lexis 711, *6 (Bankr. S.D. Ohio 1990). Moreover, no
one factor is dispositive, and the Court is not restricted to counting factors. B.R. at 669. 15. Cause clearly exists in these chapter 11 cases for extending the Exclusive

Dow Corning, 208

Periods as requested in this Motion. 16. First, it bears mention that this will be the Debtors final extension of the

Exclusive Periods. Section 112 1 (d)(2) of the Bankruptcy Code provides that the Exclusive Filing Period may not be extended beyond a date that is 18 months after the order for relief, and the Exclusive Solicitation Period may not be extended beyond a date that is 20 months after the order for relief. 11 U.S.C. 112 1 (d)(2)(A)-(B). The extension of the Exclusive Periods requested hereby is to the latest date permitted under section 112 1 (d)(2) of the Bankruptcy Code. 17. Second, these cases are undoubtedly large and complex and have required

significant time to resolve. Since the commencement of these cases, the Debtors have, among other things, (a) negotiated the terms of the postpetition financing and obtained a final order approving same; (b) negotiated the terms of the employment of various of their professionals who were instrumental in the marketing and sale of the assets; (c) prepared and filed their

DOCS5F:72869.1

Schedules and Statements of Financial Affairs; (d) obtained a general bar date of June 23, 2009 for prepetition claims and an administrative bar date of March 15, 2010; (e) marketed substantially all of their operating assets; (f) obtained orders setting sales procedures; (g) conducted auctions of the Alaska Assets and the Beta Assets; (h) negotiated purchase and sale agreements with potential buyers of the Alaska Assets and of the Beta Assets; (i) rejected office leases, various employment agreements and other contracts and leases; (j) substantially reduced the number of their employees; (k) determined which of the Debtors properties are burdensome to the estates and must be abandoned, if not sold, and proceeded to obtain orders authorizing the abandonment of certain of the Alaska Assets as well as stock of Cook Inlet Pipeline Company; (1) finalized the sale of certain of the Alaska Assets; (m) negotiated the terms of the sale of the Beta Assets to the Debtors secured lenders (including the release of certain claims by the lenders and the funding of a wind-down budget by the lenders); (n) reviewed and reconciled over five hundred claims that were filed against these estates, filed objections to many of the claims and obtained orders on most of those objections; (o) obtained orders deeming approximately 415 claims satisfied by previous payments; (p) filed objections to and litigated multi-million dollar administrative claims; and (r) actively pursued and satisfied the other pressing obligations of these chapter 11 estates. 18. Third, the Debtors have drafted the Plan and are prepared to get it on file

as soon as negotiations with the Committee are complete. The Debtors have cultivated a relationship of cooperation with the Committee to date and have worked successfully with the Committee to resolve various issues that have arisen in these chapter 11 cases. The Debtors

D0055F:72869.1

anticipate that negotiation of the terms of the Plan, likewise, will be fruitful and lead towards a smooth and efficient confirmation process. 19. Finally, the Debtors have a wind-down budget in place which provides

sufficient funds for the Debtors to pay their undisputed postpetition obligations and the Debtors have been paying such obligations as they come due. 20. Accordingly, by this Motion, the Debtors seek to extend their Exclusive

Filing Periods by an additional sixty-nine (69) days, which will result in the Debtors having the full eighteen months to propose a plan that is contemplated by the Bankruptcy Code. 21. The extensions of the Exclusive Periods sought herein will not harm or

prejudice the Debtors creditors or other parties in interest in these chapter 11 cases and will, in the Debtors opinion, further the intent of section 1121 of the Bankruptcy Code, which is to afford the Debtors a meaningful and reasonable opportunity to negotiate with their creditors and to propose and confirm a consensual plan. These chapter 11 cases do not bear characteristics that would justify the denial of an extension of the exclusive periods.

See, e.g., In re Gagel &

Gagel, 24 B.R. 674 (Bankr. S.D. Ohio 1982) (denying extension of exclusivity period because
extension would be fruitless); Dow Corning, 208 B.R. at 670 (stating that an extension of the exclusive period should be denied if debtor appeared to be attempting to delay the administration of the bankruptcy case). The Debtors are not seeking the extensions to delay administration of their cases or to pressure creditors to accept unsatisfactory plans. On the contrary, this request is intended to facilitate an orderly, efficient, and cost-effective plan process for the benefit of all creditors.

DOCSSF:72869.I

22.

Moreover, the Debtors submit that the requested extensions are

reasonable. The fact that the Debtors have liquidated substantially all of their assets does not preclude their ability to request an extension of exclusivity. Courts in this District have, on numerous occasions, granted extensions of exclusivity in liquidating chapter 11 cases.

See, e.g.

In re Western Nonwovens, Inc. et at., Case No. 08-1 1435(PJW) (Bankr. D. Del. Fe. 26, 2009)
(granting second 90 day extension of exclusivity);

In re S-Tran Holdings, Inc., et at., Case No.

05-1 1391(KJC) (Bankr. D. Del. Mar. 24, 2009) (granting further 90 day extension nearly four years after commencement); In re Tiro Acquisition, LLC, Case No. 04-12938 (PJW) (Bankr. D. Del. Nov. 3, 2005) (granting fourth motion to extend exclusivity period and extending exclusivity period for an additional 90 days); In re SENBAcquisition Corp., Case No. 03-11524 (PJW) (Bankr. D. Del. Aug. 25, 2004) (granting fifth motion to extend exclusivity period and extending exclusivity period for an additional 124 days);

In re Orion Refining Corp., Case No.

03-11483 (MFW) (Bankr. D. Del. Sept. 12, 2004) (granting Fourth motion to extend exclusivity and extending exclusivity period for an additional 60 days). 23. Accordingly, the Debtors submit that the extension of the Exclusive

Periods requested herein should be granted as being in the best interests of the Debtors estates and creditors. Notice 24. Notice of this Motion has been given to (a) the Office of the United States

Trustee; (b) counsel for the Committee; and (c) those persons who have requested notice pursuant to Rule 2002 of the Federal Rules of Bankruptcy Procedure. The Debtors submit that, in light of the nature of the relief requested, no other or further notice need be given.

DOCSSF:72869. I

No Prior Request
25.

No prior request for the relief sought in this Motion has been made to this

or any other court, except for prior extensions of the Exclusive Periods. WHEREFORE, the Debtors respectfully request that the Court enter an order (i) granting an extension of the Debtors Exclusive Filing Period for sixty-nine (69) days through and including September 9, 2010, (ii) granting an extension of the Debtors Exclusive Solicitation Period for sixty-nine (69) days through and including November 9, 2010, and (iii) granting such other relief as may be fair and equitable. Dated: July 1, 2010 PACHULSKI STANG ZIEHL & JONES LLP

f, d -X~
Ira.,Kharasch (CA Bar No. 109084) JaiW E. ONeill (DE Bar No. 4042) Maxim B. Litvak (CA Bar No. 215852) Scotta E. McFarland (DE Bar No. 4184, CA Bar No. 165391) 919 North Market Street, 17 th Floor P.O. Box 8705 Wilmington, DE 19899-8705 Telephone: 302/652-4100 Facsimile: 310/652-4400 Email: ikharasch@pszjlaw.com mlitvak @ pszjlaw.com joneill@pszjlaw.com smcfarland@pszjlaw.com

Counsel for Debtors and Debtors in Possession

DOCSSF:72869. I

10

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: PACIFIC ENERGY RESOURCES LTD., el al. Debtors.
Objection Deadline: July 21, 2010 at 4:00 p.m. (prevailing Eastern time) Hearing: July 28, 2010 at 3:00 p.m. (prevailing Eastern time)

Chapter 11 Case No. 09-10785 (KJC) (Jointly Administered)

NOTICE OF DEBTORS FOURTH MOTION FOR AN ORDER PURSUANT TO 11 U.S.C. 1121(d) EXTENDING THE TIME PERIODS DURING WHICH THE DEBTORS HAVE THE EXCLUSIVE RIGHT TO FILE A PLAN AND SOLICIT ACCEPTANCES THEREOF
TO: (a) the Office of the United States Trustee; (b) counsel to the Debtors postpetition lenders; (c) counsel to the Official Committee of Unsecured Creditors; and (d) those persons who have requested notice pursuant to Rule 2002 of the Federal Rules of Bankruptcy Procedure. On July 1, 2010, the debtors and debtors in possession in the above-captioned cases (collectively, the "Debtors") filed the attached Debtors Fourth Motion for an Order Pursuant to 11 U.S.C. 1121(d) Extending the Time Periods During Which the Debtors Have the Exclusive Right to File a Plan and Solicit Acceptances Thereof (the "Motion"). By the Motion, the Debtors seek a sixty-nine (69) day extension, through September 9, 2010, of the exclusive period within which only the Debtors may file a plan of reorganization and, if the Debtors file a plan before the expiration of that period, a sixty-nine (69) day extension, through

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 I.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of the Debtors is 111 W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.

DOCS SF72869.!

November 9, 2010, of the period in which the Debtors may solicit acceptances for that plan without any other party having the right to file a plan. ANY RESPONSE OR OBJECTION TO THE MOTION MUST BE IN WRITING AND BE FILED WITH THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE, 824 NORTH MARKET STREET, WILMINGTON, DELAWARE 19801 (THE "BANKRUPTCY COURT") NOT LATER THAN JULY 21, 2010, AT 4:00 P.M. PREVAILING EASTERN TIME. Objections or other responses to the Application, if any, must also be served so that they are received not later than July 21, 2010 at 4:00 p.m. prevailing Eastern time, by: (1) Pachulski Stang Ziehl & Jones LLP, 919 North Market Street, 17th Floor, Wilmington, DE 19899-8705, Attn: James ONeill, Esq.; Fax: 302-652-4400, e-mail:oneill(dpszjlaw.com and

(2) Pachulski Stang Ziehi & Jones LLP, 10100 Santa Monica Blvd., I I 1h Floor, Los Angeles, CA 90067-4100; Attn: Ira D. Kharasch, Esq; Fax: 310-201-0760, e-mail: ikharasch(pszjlaw.com (b) the Office of the United States Trustee, J. Caleb Boggs Federal Building, 844 N. King Street, Suite 2207, Lock Box 35, Wilmington, Delaware 19801; and (c) counsel for the Official Committee of Unsecured Creditors (the "Committee"), (1) Steptoe & Johnson LLP, 2121 Avenue of the Stars, 28th Floor, Los Angeles, CA 90067; Attn: Katherine C. Piper, Esq., Fax: (310) 734-3173, e-mail: kpiper@steptoe.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: can gnanj()pepperlaw.com . IF OBJECTIONS OR RESPONSES ARE TIMELY FILED AND SERVED IN ACCORDANCE WITH THIS NOTICE, A HEARING ON THE MOTION WILL BE HELD

DOCSSF:72869.I

BEFORE THE HONORABLE KEVIN J. CAREY AT THE UNITED STATES BANKRUPTCY COURT, 824 MARKET STREET, FIFTH FLOOR, COURTROOM #5, WILMINGTON, DELAWARE 19801 ON JULY 28, 2010 AT 3:00 P.M. PREVAILING EASTERN TIME. IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF REQUESTED IN THE MOTION WITHOUT FURTHER NOTICE OR HEARING. Dated: July 1, 2010 PACHULSKJ STANG ZIEHL & JONES LLP

wmwm4
I ra (harasch (CA Bar No. 109084) Jar#ejE. ONeill (DE Bar No. 4042) Ma6m B. Litvak (CA Bar No. 215852) Scotta E. McFarland (DE Bar No. 4184, CA Bar No. 165391) 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE 19899-8705 Telephone: 302/652-4100 Facsimile: 310/652-4400 Email: ikharaschpszjlaw.com mlitvak@pszjlaw.com joneill@pszjlaw.com smcfarland@pszjlaw.com

t/

Counsel for Debtors and Debtors in Possession

DOCSSF:72869.1

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: PACIFIC ENERGY RESOURCES LTD., et al. Debtors. Related Docket No. ORDER GRANTING DEBTORS FOURTH MOTION FOR AN ORDER PURSUANT TO 11 U.S.C. 1121(D) EXTENDING THE TIME PERIODS DURING WHICH THE DEBTORS HAVE THE EXCLUSIVE RIGHT TO FILE A PLAN AND SOLICIT ACCEPTANCES THEREOF Upon the motion (the "Motion
,)2

Chapter 11 Case No. 09-10785 (KJC) (Jointly Administered)

of the above-captioned debtors and debtors in

possession (collectively, the "Debtors") for entry of an order pursuant to section 1121(d) of the Bankruptcy Code extending the Exclusive Periods in which to file a chapter 11 plan and to solicit acceptances thereof; and it appearing that this Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334; and it appearing that this proceeding is a core proceeding pursuant to 28 U.S.C. 157(b)(2); and it appearing that venue of this proceeding and the Motion is proper in this district pursuant to 28 U.S.C. 1408 and 1409; and due and proper notice of the Motion having been given; and after due deliberation and it appearing that sufficient cause exists for granting the requested relief; and that the relief requested under the Motion is in the best interests of the Debtors estates and creditors; it is hereby ORDERED that the Motion is granted in its entirety; and it is further
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 I.D. # not available); Carneros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of the Debtors is 111 W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.
2

Capitalized terms not defined herein shall have the meaning ascribed to them in the Motion.

DOCSSF:72869. I

ORDERED that the Debtors Exclusive Filing Period is extended through and including September 9, 2010; and it is further ORDERED that the Debtors Exclusive Solicitation Period is extended through and including November 9, 2010; and it is further ORDERED that the Court shall retain jurisdiction to hear and determine all matters arising from or relating to this Order. Dated: 2010

Honorable Kevin J. Carey Chief United States Bankruptcy Judge

DOCSSF:72869. I

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: PACIFIC ENERGY RESOURCES LTD., et al., Debtors.
)

Chapter 11

Case No. 09-10785 (KJC) (Jointly Administered)

AFFIDAVIT OF SERVICE STATE OF DELAWARE COUNTY OF NEW CASTLE

)

) ss:
)

Kathleen Forte Finlayson, being duly sworn according to law, deposes and says that she is employed by the law firm of Pachuiski Stang Ziehi & Jones LLP, attorneys for the Debtors in the above-captioned action, and that on the 1St day of July 2010 she caused a copy of the

following document(s) to be served upon the parties on the attached service lists in the manner indicated: Notice and Fourth Motion for Order Extending Exclusive Periods

atlyieen Forte Finlayson Sworn to me

tiLLS (

LdV4t
youNG

ij~ 20
L.

No1arvub Commission Exp.:

DOCSDE: 149366.1

PU STATE OF DELQ11 0n ex

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 I.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of the Debtors is III W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.

Pacific Energy Resources Ltd. 2002 Service List Case No. 09-10785 Document No. 145745 19 - Hand Delivery 50 - First Class Mail 02 - FOREIGN First Class Mail

Hand Delivery (United States Attorney) Ellen W. Slights, Esq. United States Attorneys Office District of Delaware 1007 N. Orange Street, Suite 700 Wilmington, DE 19801 Hand Delivery (Counsel for Silver Point Finance) Ian S. Fredericks, Esquire Skadden Arps, Slate, Meagher & Flom LLP One Rodney Square P.O. Box 636 Wilmington, DE 19899 Hand Delivery (Counsel for J. Aron & Company) Don A. Beskrone, Esquire Amanda M. Winfree, Esquire Ashby & Geddes, P.A. 500 Delaware Avenue, 8 Floor Wilmington, DE 19899 Hand Delivery (Counsel for Union Oil Company of California, a California Corporation) Norman M. Monhait, Esquire Rosenthal, Monhait & Goddess, PA Citizens Bank Center, Suite 1401 919 Market Street, P.O. Box 1070 Wilmington, DE 19899 Hand Delivery (Counsel for Westchester Fire Insurance Company and Noble Energy Inc.) Tobey M. Daluz, Esquire Joshua E. Zugerman, Esquire Ballard Spahr Andrews & Ingersoll, LLP 919 N. Market Street, 12th Floor Wilmington, DE 19801

(Counsel for Debtors) Laura Davis Jones, Esquire James E. ONeill, 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, Esquire Scotta E. McFarland, Esquire Pachulski Stang Ziehl & Jones LLP 10100 Santa Monica Blvd., 11th Floor Los Angeles, CA 90067 Hand Delivery (United States Trustee) Joseph McMahon, Esquire Office of the United States Trustee J. Caleb Boggs Federal Building 844 North King Street, Suite 2207 Lockbox 35 Wilmington, DE 19801 Hand Delivery (Copy Service) Parcels, Inc. Vito I. DiMaio 230 N. Market Street Wilmington, DE 19801

Hand Delivery (Counsel for Oxy Long Beach Inc.) David L. Finger, Esquire Finder, Slanina Liebesman, LLC One Commerce Center 1201 N. Orange St., 7th Floor Wilmington, DE 19801 Hand Delivery (Official Committee of Unsecured Creditors) David B. Stratton, Esquire James C. Carignan, Esquire Pepper Hamilton LLP Hercules Plaza, Suite 1500 13 13 Market Street Wilmington, DE 19899 Hand Delivery (Counsel for Marathon Oil Company) Kevin J. Mangan, Esquire Womble Carlyle Sandridge & Rice, PLLC 222 Delaware Avenue, Suite 1501 Wilmington, DE 19801 Hand Delivery (Counsel for Cook Inlet Region, Inc.) Eric Lopez Schnabel, Esquire Dorsey & Whitney (Delaware) LLP 300 Delaware Avenue, Ste 1010 Wilmington, DE 19801 Hand Delivery (Counsel for Area Energy LLC) Norman L. Pernick, Esquire Karen M. McKinley, Esquire Cole, Schotz, Meisel, Forman & Leonard, P.A. 500 Delaware Avenue, Suite 1410 Wilmington, DE 19801

Hand Delivery (Counsel for Ammadon Limited and Catherwood Limited) Mark E. Felger, Esquire Cozen OConnor 1201 N. Market Street, Suite 1400 Wilmington, DE 19801 Hand Delivery (Counsel for Forest Oil Corporation) Robert J. Dehney, Esquire Curtis S. Miller, Esquire Morris Nichols Arsht & Tunnell LLP 1201 N. Market Street Wilmington, DE 19899 Hand Delivery (Counsel for Stellar Energy LLC) Brian E. Farnan, Esquire Phillips, Goldman & Spence, P.A. 1200 North Broom Street Wilmington, DE 19806 Hand Delivery (Counsel for Ramshorn Investments, Inc.) Jonathan L. Parshall, Esquire Murphy & Landon 10 11 Centre Road, Suite 210 Wilmington, DE 19805 Hand Delivery (Counsel for Longfellow Energy LP) Teresa K.D. Currier, Esquire Saul Ewing LLP 222 Delaware Avenue, Suite 1200 Wilmington, DE 19899 Hand Delivery (Counsel for Rise Energy Partners, LP) Christopher A. Ward, Esquire Justin K. Edelson, Esquire Polsinelli Shughart, PC 222 Delaware Avenue, Suite 1101 Wilmington, DE 19801

Hand Delivery (Counsel to Cook Inlet Pipe Line Company) Stephen M. Miller, Esquire Brett D. Fallon, Esquire Douglas N. Candeub, Esquire Morris James LLP 500 Delaware Avenue, Suite 1500 Wilmington, DE 19899 First Class Mail (United States Attorney General) Eric H. Holder, Jr. Office of the Attorney General U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, DC 20530-0002 First Class Mail Secretary of State Division of Corporations Franchise Tax P.O. Box 7040 Dover, DE 19903 First Class Mail Secretary of Treasury P.O. Box 7040 Dover, DE 19903 First Class Mail Secretary of Treasury 15th & Pennsylvania Avenue, N.W. Washington, DC 20220 First Class Mail Attn: Insolvency District Director Internal Revenue Service 31 Hopkins Plaza, Room 1150 Baltimore, MD 21201 First Class Mail Internal Revenue Service P.O. Box 21126 Philadelphia, PA 19114-0326

First Class Mail Attn: Insolvency Internal Revenue Service 1352 Marrows Road, 2 Floor Newark, DE 19711-5445 First Class Mail Mark Schonfeld, Esq. Regional Director Securities & Exchange Commission New York Regional Office 3 World Financial Center, Suite 400 New York, NY 10281-1022 First Class Mail Michael A. Berman, Esq. Securities & Exchange Commission Office of General Counsel-Bankruptcy 100 F Street, N. E. Washington, DC 20549 First Class Mail Matthew Berry, Esquire Office of General Counsel Federal Communications Commission 445 12 Street, S.W. Washington, DC 20554 First Class Mail POLLARD WIREL[NE P.O. Box 1360 Kenai, AK 99611 First Class Mail Chevron Oil Company Attn: Steven Lastraps 3800 Centerpoint Drive, Suite 100 Anchorage, AK 99503 First Class Mail California Franchise Tax Board Bankruptcy, BE MSA 345 P.O. Box 2952 Sacramento, CA 95812-2952

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