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IN THE UNITED STATES BANKRUPTCY COURT

In re: )

FOR THE DISTRICT OF DELA WARE

Chapter 11

PACIFIC ENERGY RESOURCES LTD., et al., i )

Debtors. )
)

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


Related Docket No. 12

Deadline for Objections: April 1,2009 at 4:00 p.m. prevailng Eastern time Hearing Date: April 8, 2009 at 11 :00 a.m. prevailng Eastern time

CERTIFICATION OF NO OBJECTION RE: DEBTORS' MOTION FOR AN ORDER UNDER SECTION 366 OF THE BANKRUPTCY CODE (A) PROHIBITING UTILITY PROVIDERS FROM
AL TERING, REFUSING OR DISCONTINUING SERVICE, (B) DEEMING UTILITIES ADEQUA TEL Y ASSURED OF FUTURE PERFORMANCE, AND (C) ESTABLISHING PROCEDURES FOR DETERMINING ADEQUATE ASSURANCE OF PAYMENT
The undersigned hereby certifies that, as of the date hereof, she has received no

answer, objection or other responsive pleading to Debtors' Motionfor Order under Section 366
of the Bankruptcy Code (A) Prohibiting Utilty Providers

from Altering, Refusing or

Discontinuing Service, (B) Deeming Utilities Adequately Assured of Future Performance, and

(C) Establishing Procedures for Determining Adequate Assurance of Payment (Docket No. 12)

(the "Motion") filed on March 9,2009. The undersigned further certifies that she has reviewed
the Court's docket in this case and no answer, objection or other responsive pleading to the
Motion appears thereon. Pursuant to the Notice of

the Motion, objections to the Motion were to

be fied and served no later than April 1, 2009.


the Debtors' federal tax identification number, are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska
i The Debtors in these cases, along with the last four digits of each of

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 address for all of the Debtors is I I I W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.

Accordingly, the Debtors request that the Order attached to the Motion be entered
at the Court's earliest convenience.

Dated: April 7, 2009

PACHULSKI STANG ZIEHL & JONES LLP

Lau a Davis ones (D . 2436)


Ira . Kharasch (CA B r No.1 9084)

ScottaE.McFarland( EBar 0.4184,CABarNo.165391)


Robert M. Saunders ( Ba o. 226172)
James E. O'Neil (DE Bar No. 4042)

Kathleen P. Makowski (DE Bar No. 3648)


919 North Market Street, 17th Floor

P.O. Box 8705 Wilmington, DE 19899-8705


Telephone: 302/652-4100

Facsimile: 310/652-4400
Email: liones~pszilaw.com

ikharasch~pszi law .com smcfarland~pszi law.com rsaunders~pszi law. com

ioneil~pszilaw.com kmakowski~pszilaw.com
(Proposed) Counsel for Debtor and Debtor in Possession Pacific Energy Resources Ltd.

68773-001\DOCS_DE: 146587.1

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