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In re:
) Chapter 11
)
Related to Docket Nos. 998,999,1000
Requested Deadline for Objections: October 27, 2009 at 4:00 p.m. Eastern time Requested Hearing Date: November 3,2009 at 10:00 a.m. Eastern time
hereby move this Court (the "Motion to Shorten") for an Order shortening the notice period for
the hearing on Debtors' Motion/or an Order (a) Vacating This Court's Abandonment Order in
Part/or Certain Alaska Assets and (b) Authorizing the Debtors to Sell Such Assets to Cook Inlet
Energy, LLC (the "Reconsideration and Sale Motion") (Docket No. 998).2
On October 14,2009, the Debtors fied (1) the Reconsideration and Sale Motion, (2) the
Notice 0/ Date and Time o/Sale Hearing Re Debtors' Motion/or an Order (a) Vacating This
Court's Abandonment Order in Part/or Certain Alaska Assets and (b) Authorizing the Debtors
i The Debtors in these cases, along with the last four digits of each Debtor's federal tax identification number, are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska Holdings LLC (tax 1.0. # 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 address for all of
the Debtors is III W. Ocean Boulevard, Suite 1240, Long Beach, CA.
2 Unless otherwise defined herein, all capitalized terms shall have the meanings ascribed to them in the
68773-002\DOCS _ LA:209308.2
to Sell Such Assets to Cook Inlet Energy, LLC (the "Sale Hearing Notice") (Docket No. 999), and
(3) the Notice to Counterparties to Executory Contracts and Unexpired Leases that May Be
Assumed and Assigned (the "Cure Notice") (Docket No.;! 000). The Reconsideration and Sale
Motion, the Sale Hearing Notice and the Cure Notice are. hereinafter collectively referred to as
the "Sale Pleadings". The'Reconsideration and Sale Motion seeks an order of the Bankuptcy
Court (1) vacating its Order Granting Alternative Motiotl of the Debtors for an Order
Authorizing Abandonment of
Trading Bay) and Rejection of Executory Contracts Relating Thereto entered on September 11,
2009 (the "Abandonment Order") (Docket No. 876) as it relates to certain of
(defined below) and (2) approval of (a) the sale by the Debtors to Cook Inlet Pipeline, LLC (the
"Buyer") of certain of
generiiy ofPEAO's interests in leased oil and gas production and exploration assets located in
Alaska (and related assets) that were formerly operated by PERL or presently operated by
Aurora Gas, LLC (an entity that is unrelated to the Debtors), other than other certain oil and gas leases and related assets located in the Redoubt Unit as well as other Excluded Items (as defined
in the Purchase and Sale Agreement, which is attached to the Reconsideration and Sale Motion
as Exhibit A), and (b) the assumption by the Debtors and assignment to the Buyer of certain
, ,
. .
Debtors' served the Sale Hearing Notice by overnight mail on all creditors of
on October 14,2009, served the Sale Pleadings on counsel for Union Oil of California by email
on October 14,2009, and, of course, all paries that have
received electronic notice ofthe Sale Pleading when they'were filed. However, the Debtors
missed the overnight delivery deadline on October 14,2009, for service of
the Reconsideration
68773-002\DOCS _ LA:209308 ,2
and Sale Motion and the Cure Notice on the required paries, and, therefore, those pleadings
were served on the required parties by overnight delivery on October 15,2009.
The next scheduled omnibus hearing date in these chapter 11 cases is November 3,2009.
The Sale Pleadings, because the Debtors expected to meet the service deadline for that hearing
date, scheduled November 3, 2009, as the hearing date for the Reconsideration and Sale Motion
and October 27,2009, the regular deadline for objections to motions being heard on that hearing
date, as the objection deadline.
Debtors respectfully submit that service by overnight delivery as set forth above is
suffcient notice of a November 3, 2009 hearing on the Reconsideration and Sale Motion and to
provide parties in interest an opportunity to review and, if
Reconsideration and Sale Motion because the Notice of Sale Hearing was served in a timely
manner on all creditors, parties who have requested such notice received timely notice of
the
hearing and objection deadline through Pacer, and the Reconsideration and Sale Motion, served
,
by overnight delivery on October 15,2009, wil be delivered on October 16, 2009, giving parties
a full eighteen (18) days notice of the hearing and ten (10) days to file any responses or
objections. Accordingly, under the circumstances, the Debtors submit that shortening the time
for notice on the Reconsideration and Sale Motion in accordance with the foregoing and
approving the scheduling of
the hearing for November 3, 2009, wil not prejudice the rights of
68773-002\DOCS _LA:209308 ,2
WHEREFORE, the Debtors respectfully request.the entry of an Order approving (1) the
shortening of the notice period as set forth above, (2) the scheduling of
Reconsideration and Sale Motion on November 3,2009 at 10:00 a.m., and (3) the October 27,
2009, deadline for fiing responses or objections to the Reconsideration and Sale Motion
Dated: October 16,2009
mlitvak~pszj law.com
rsaunders~pszj law .com
smcfarland~pszyjlaw.com
Counsel for Debtors and Debtors in Possession
:\;
68773-002\DOCS _ LA:209308.2
In re:
PACIFIC ENERGY RESOURCES L TD, et aI., i
) Chapter 11
)
) Case No. 09-10785 (KJC)
) (Jointly Administered)
Debtor.
)
Related to Docket No.
ORDER GRANTING DEBTORS' MOTION TO SHORTEN THE NOTICE PERIOD FOR HEARING ON DEBTORS' MOTION FOR AN ORDER (A) V ACA TING THIS COURT'S ABANDONMENT ORDER IN PART FOR CERTAIN ALASKA ASSETS AND (B) AUTHORIZING THE DEBTORS TO SELL SUCH ASSETS TO COOK INLET ENERGY. LLC
Upon consideration of Debtors' Motion to Shorten the Notice Periodfor Hearing
on Debtors' Motionfor an Order (a) Vacating This Court's Abandonment Order in Partfor
Certain Alaska Assets and (b) Authorizing the Debtors to Sell Such Assets to Cook Inlet Energy,
ORDERED that the hearing on Debtors' Motionfor an Order (a) Vacating This
Court's Abandonment Order in Part for Certain Alaska Assets and (b) Authorizing the Debtors
to Sell Such Assets to Cook Inlet Energy, LLC (the "Reconsideration and Sale Motion") is
i The Debtors in these cases, along with the last four digits of each Debtor's 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 address for all of
the Debtors is 1 I 1 W. Ocean Boulevard, Suite 1240, Long Beach, CA.
2 Unless otherwise defined herein, all capitalized terms shall have the meanings ascribed to them in the
Reconsideration and Sale Motion.
68773-002\DOCS _ LA :209308.2
scheduled for November 3, 2009 at 10:00 a.m. prevailng Eastern Time; and it is further
ORDERED that the deadline to object olrespond to the Reconsideration and Sale
Motion is set for October 27,2009 at 4:00 p.m. prevailng Eastern Time; and it is further
ORDERED that counsel for the Debtors shall, within one business day of entry of
this Order, serve a copy of
68773-002\DOCS _ LA:209308.2
In re: )
STATE OF DELAWARE )
) ss:
)
)
Debtors. )
AFFIDAVIT OF SERVICE
Pachulski Stang Ziehl & Jones LLP, attorneys for the Debtors in
the above-captioned action, and that on the 16th day of October, 2009 she caused a copy of the
following document(s) to be served upon the parties on the attached service lists in the manner
indicated:
Debtors' Motion to Shorten Notice Period for Hearing on Debtors' Motion for Order (A) Vacating Court's Abandonment Order in Part for Certain Alaska Assets and (B) Authorizing Debtors to Sell such Assets to Cook Inlet Energy, LLC
DEBR L YOU
NOTARY PUBIC STATE OF DELAWAR
Mr _miili ti Jt 11, 2011
i The Debtors in these cases, along with the last four digits of each ofthe 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 address for all of the Debtors is III W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.
14 - Hand Delivery
43 - First Class Mail 02 - FOREIGN First Class Mail
Hand Delivery (United States Attorney) Ellen W. Slights, Esq. United States Attorney's 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 Ars, Slate, Meagher & Flom LLP
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
Interoffce Pouch to Los Angeles
Counsel for Debtors) Robert M. Saunders, Esquire Ira D. Kharasch, Esquire Scotia E. McFarland, Esquire Pachulski Stang Ziehl & Jones LLP
10100 Santa Monica Blvd., 11 th Floor
Hand Delivery (Counsel for J. Aron & Company) Don A. Beskrone, Esquire Amanda M. Winfree, Esquire Ashby & Geddes, P.A.
500 Delaware Avenue, 8th Floor
Wilmington, DE 19899
Hand Delivery (Counsel for Union Oil Company of California, a California Corporation) Norman M. Monhait, Esquire Rosenthal, Monhait & Goddess, P A
Citizens Ban Center, Suite 1401
Wilmington, DE 19801
Hand Delivery (Copy Service)
Parcels, Inc.
Hand Delivery (Counsel for Oxy Long Beach Inc.) David L. Finger, Esquire
Finder, Slanina Liebesman, LLC
Hand Delivery
Wilmington, DE 19801
Hand Delivery
Unsecured Creditors) David B. Stratton, Esquire James C. Carignan, Esquire Pepper Hamilton LLP
(Official Committee of
Morris Nichols Arsht & Tunell LLP 1201 N. Market Street Wilmington, DE 19899
Hand Delivery (Counsel for Marathon Oil Company) Kevin 1. 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
1105 North Market Street, Suite 16th Floor
Wilmington, DE 19801
District Director Internal Revenue Service 31 Hopkins Plaza, Room 1150 Baltimore, MD 21201
California Franchise Tax Board Bankuptcy, BE MSA 345 P.O. Box 2952 Sacramento, CA 95812-2952
Bakersfield, CA 93311-1164
SWEPI LP
Washington, DC 20554
E. Kathleen Shahan, Esquire U.S. Deparment of Justice 1100 L Street, NW Washington, D.C. 20005
Bankptcy Coordinator
MMS I Denver Federal Center POBox 25165 Mail Stop 370B2 Denver, CO 80225
Philadelphia, P A 19103
John J. Harris, Esquire Rachel M. Feiertag, Esquire Meyers, Nave, Riback, Silver & Wilson 333 South Grand Avenue, Suite 1670 Los Angeles, CA 90071
Baltimore, MD 21209
Greenwich, CT 06830
Creditors) Francis J. Lawall, Esquire Pepper Hamilton LLP 3000 Two Logan Square Eighteenth & Arch Streets Philadelphia, P A 19103
Martin A. Mooney, Esquire Deily, Mooney & Glastetter, LLP 8 Thurlow Terrace Albany, NY 12203
Unsecured
(Counsel for Aera Energy LLC) Steven E. Rich, Esquire Mayer Brown LLP
350 South Grand Avenue, 25th Floor
Joshua Taylor, Esquire Steptoe & Johnson LLP 1330 Connecticut Avenue NW Washington, DC 20036
Anchorage, AK 99501
(Counsel for Union Oil Company of California) Richard L. Epling, Esquire David A. Crichlow, Esquire Roger Elder, Esquire Pilsbury Winthrop Shaw Pittman LLP 1540 Broadway New York, NY 10036
Region
755 Parfet Street, Suite 151
Lakewood, CO 80215
the Americas