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TWELFTH APPLICATION OF SCHULL Y, ROBERTS, SLATTERY & MAO PLC FOR COMPENSATION FOR SERVICES RENDERED AN REIMUREMENT OF EXPENSES AS SPECIA OIL & GAS AN TRASACTIONAL COUNSEL TO THE DEBTORS AN DEBTORS-IN-POSSESSION FOR TH PERIOD FROM FEBRUARY 1.2010 THROUGH FEBRUARY 28. 2010
Name of Applicant:
Authorized to Provide
Professional Servces to:
March 8, 2009
Februar t, 2010 though Februai 28,2010
reimburement is sought:
Amount of Compensation sought as
actual, reasonable and necessar:
Amount of
$10,620.00
i The Debtors in these cases, along with the las four digits of each of
are: Pacific Energy Resoures Ltd. (3442); Petroc Acquisition Corp. (6249); Pacific Energy Alaska Holdings,
LLC (ta J.D. # not avaiable); Cameros Acquisition Corp. (5866); Pacifc Energy Alaska Opratig LLC (7021);
address for all of
San Pedo Bay Pipeline Compay (1234); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing the Debtors is 111 W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.
02 i .2879a2795.februai .attcluents.docx
ATTACHMNTB
TO FEE APPLICATION
Name of Professional Person
Name of the Applicant,
Number of
Hourly
Biling Rate
Years in that
Tota Biled
Hours
Tota
Compensation
(including changes)
Anthony C. Marno
0.60
$270.00
servces
Heran E. Garer
$385.00
servces
Lyn G. Wolf
$300.00
32.60
$9,780.00
servces
Katheen L. Doody
Edward L.
Boudreaux, II
Associate 2002, Member of Louisiana Bar since 2002; oil & gas and transactional selVces Associate 2007, Member of Louisian Bar since 2005; oil & gas litigation Associate 2009, Member of Louisiana Bar since 2009; oil
and gas and tranctional
$250.00
$225.00
200.00
servces
Joan G. Seelman Diane M. Casle
Chantelle C.
Paregal
Paralegal Paralegal
$270.00
Boudreaux
02 i .2879a.2795.februar .atthments.docx
VERIFICATION
STAlE OF
LOUISIANA
PARSH OF ORlAN
Anthony C Mao, after being duly sworn according to law, deposes and says:
I am a shareholder of the applicant law fir Schuly, Robert, Slattery & Mao ("the ''Fir'').
ar tre and correct to the best of my knowledge, inomition and belief. l\reover, I have
rewed Del Ban.l.2016-2 and the Adtrtie Orr entered on or about Apri
15, 200,
and submit that the Application substantialy complies with such Rule and Order.
..ANO C MANO
;7 r ~7 ~-l
F(lc~inijlc: 504585-n90
STATEMENT
Page: 1
04/09/2010 6476-2795M
19
Forbearance Agreements
HOURS
02/01/2010
CCB
LGW
LGW
(BL) Retrieve newly filed pleadings from Pacer and evaluate new issues (.20); (AD)Discussion of SRSM fee application with Ms. McFarland and follow-up with Ms. Piper at Steptoe firm; emails to Ms. Piper and Ms. McFarland to discuss activity description; (AD)Discussion of finalization of CIE issues with Alaska DNR Ms. Woolf and follow up with Mr. Arlington regarding Donkel filings;
0.20
0.90
30.00
270.00
90.00
0.30
02/02/2010
CCB
LGW
(BL) Retrieve newly filed pleadings from Pacer and evaluate new issues; memorandum to Mr. Marino(.50);
(AD)Emails from Mr. Tywoniuk regarding Alaska propert
0.50
75.00
retained and/or abandoned of interest to Chevron; review motions and exhibits as well as emails to determine extent of
properties;
LGW
0.90 0.30
270.00
90.00
(AD)Discussion of finalization of CIE issues with Alaska DNR Ms. Woolf and follow up with Mr. Arlington regarding Donkel filings;
02/03/2010
LGW
(AD)Continued work on retained properties/abandoned Group 2 propertes list and descriptions for Mr. Tywoniuk - Chevron related properties; discuss with Mr. Arlington and forward on to Debtor;
0.90
270.00
02104/2010 LGW
(CP)Address issues from fee auditor - 2nd interim application; draft memorandum and undertake revisions; discussions with Ms. Parnell at Smith firm;
0.90
270.00
02/05/2010
CCB
(BL) Retrieve newly filed pleadings from Pacer and evaluate new issues; memorandum to Mr. Marino; conference regarding
Page: 2
04/09/2010
STATEMENT NO: 19
Forbearance Agreements
same;
LGW
(AD)Work on revisions to closing documents and assignments per Ms. Woolf at Alaska DNR; discussion of filing notice of correction on certain descriptions; preliminary drafting of same;
HOURS 1.00
150.00
0.90
270.00
02/06/2010
LGW
(AD)Continued work on clean up issues with Alaska DNR and BLM; follow-up with verification of title matters using DNR website to confirm information; draft response;
0.90
270.00
02/08/2010
LGW
(AD)Emaiis and call from Alaska DNR, Ms. Woolf, to discuss status of PERL MLQ ORRis not reconveyed to PERL; discussion of legal issues surrounding such ORRIs since the underlying leases were abandoned; discussion of mechanism to reunite ORRis with subject leases to insure continuity of title; follow-up with call to Goldman attorneys at Bingham to discuss their client's thoughts on same; (AD)Continued work on legal issues involved with the MLQ/Goldman ORRis; discussion with Alaska Attorney General's offce and continued discussion with Bingham attorneys to determine timing for reconveyance of the interests; must be before PERL is discharged in bankruptcy; (AD)Telephone calls and emails from Mr. Arlington regarding finalizing the BLM Alaska assignment to CIE; discussion of how to accomplish since Mr. Hall is not returning Mr. Arlington's calls; continued discussion of whether BLM records reflect initial transfer into PEAO; further discussion of Chevron issues left hanging in adversary actions as well as Spurr Platform abandonment matters to be heard at next Omnibus
0.90
270.00
LGW
0.90
270.00
LGW
hearing;
0.90
270.00
02/09/2010
LGW LGW
(CP)Continue addressing fee auditor questions and draft responses accordingly; (CP)Check expense account reports to check that amounts
bils are correct per fee auditor request; follow-up with email;
0.90 0.40
270.00
120.00
02/10/2010
LGW
(AD)Emaii and call from Allen Eddy at Alaska DNR regarding correction pages to Alaska assignments; draft correction pages and send to regulator; follow-up with master
04/09/2010 6476-2795M
19
Forbearance Agreements
HOURS
conveyance exhibit issues and questions; follow-up with Mr. Arlington as well;
0.70
210.00
02/11/2010
LGW
LGW
LGW
(BL)Receive documents and proposed dismissal of PERL from Unocal v. PERL suit per Mr. Jungreis; review dismissal and email with questions; receive emails from Mr. Tywoniuk and Mr. Amber regarding dismissal with or without prejudice as to claims of Forest Oil and PERL and Mr. Jungreis' follow-up explanation; discuss with Mr. Marino and respond; (AD)Email to Allen Eddy at Alaska DNR regarding ADL 38314 and 18790 Alaska assignments; draft additional correction pages and send; continue to review memorandum sent by DNR to assure compliance; send out responses and questions as needed; (AD) Receive requests from Mr. Lyng regarding billngs for closing matters and clean up; review emails, projects and billings and response with preliminary numbers;
0.90
270.00
0.90 0.60
270.00
180.00
02/12/2010
LGW
(AD)Separate out billng expenses that relate to Alaska properties so that Mr. Lyng can determine amount of Goldman hold-back and finalize accounting of same; review backup from Mr. Marino and Ms. Seelman to double-check allocations of
costs;
LGW LGW
(CP)Prepare December bil for bankruptcy court; (BL)Receive and review final dismissal of Unocallitigation; prepare file for closing and send request for instructions on how to handle document retention for this litigation in light of company bankruptcy; follow-up with Mr. Marino;
0.90 3.00
270.00 900.00
0.90
270.00
02/15/2010
LGW
(AD)Continued work on clean up issues with Alaska regulators; discussion and research on abandonment issues with DNR; follow-up with client;
0.90
270.00
02/17/2010
LGW
(CP)Emails from Ms. McFarland requesting electronic backup for third interim fee application; file research to gather necessary documentation and draft memorandum to explain certain items related to closing the Alaska acquisition; (CP)Review statement conversions from pdf to word and
0.80
240.00
LGW
Page: 4
04/09/2010 6476-2795M 19
Forbearance Agreements
HOURS
supplement where necessary for fee auditor; send to auditor in email;
0.90
270.00
02/18/2010
CCB
CCB
ACM ACM LGW
Retrieve newly filed pleadings from Pacer and evaluate new issues (.90); Retrieve fee application dates for current fee application submission (.30); (AD) Conference with Ms. Wolf regarding filings and state
0.90
135.00
45.00
90.00 90.00
lands;
(AD) Follow-up with MMS attorney Phylls Leslie; (CP)Prepare third quarterly interim fee application; file research to gather necessary documentation draft and finalized application;
900.00
02/19/2010
LGW
bil of sale and Master Conveyance; review and comment per quest;
LGW
0.90
270.00
LGW
(AD)Continued work on Alaska bil of sale and master conveyance; review comments from Mr. Sullvan and follow up with Ms. Parker for guidance; review Alaska recordations and add recordation information to drafts; (AD)Work on language changes to accmmodate purchaser; follow-up with emails and calls to discuss and attempt to finalize;
0.90 0.30
270.00
90.00
02/22/2010
CCB
ACM
LGW
(BL) Retrieve newly filed pleadings from Pacer and evaluate new issues; memorandum and meeting on same (.90); (BL) Conference with Mr. Dreuil regarding appeal at IBLA for Supplemental bonding; (AD) Discussion with Mr. Arlington regarding emails from Donkel regarding recordation; discuss with Mr. Tywoniuk and follow-up;
135.00
90.00
270.00
02/23/2010
LGW
(BL) Receive email from Mr. Saunders at Pachulski requesting research and other information regarding indemnification and contribution provisions in numerous Union and Marathon Spurr documents; begin preliminary research and drafting of
response;
0.90
270.00
04/09/2010 6476-2795M
19
Forbearance Agreements
HOURS
LGW
LGW
(BL) Continued legal research and drafting of response to requests of bankruptcy counsel on Union and Marathon issues; extensive review of correspondence from due diligence materials to demonstrate that issues were never resolved by the seller and buyer; include in memorandum; (BL) Review new filings from Union relative to the adversary actions; attempt to determine which version of historical documents they are basing argument on; correspondence on same to Mr. Saunders;
0.90
270.00
LGW
(CP) Receive emails from fee auditor Ms. Parnell and respond;
lease assignment in Alaska and
0.90 0.30
270.00 90.00
02/24/2010
LGW
(AD)Receive emails on federal
0040
120.00
02/26/2010
LGW LGW
(AD) Follow-up with MMS and BLM on filings; (BL) Email from Mr. Saunders increasing scope of indemnification and contribution review and research to include
0.90
270.00
0.90 0.90
LGW
(BL) Continue internet and file research to determine applicabilty of such Alaska provisions and follow-up with additional questions for litigation staff at Pachulski;
TOTAL FEES:
RECAPITULATION
37.00
HOUR~ 0.60 32.60 3.80
tlQ.lJRL Y RATE
TOTAL
Chantelle C. Boudeaux
Page: 6
STATEMENT NO: 19
Forbearance Agreements
PREVIOUS BALANCE
$357,254.29
12,843.93
BALANCE DUE:
$370,098.22
PLEASE INDICATE FILE NUMBER, STATEMENT NUMBER AND STATEMENT DATE ON ALL REMITTANCES
In re: ) Chapter 11
)
Debtors. )
) (Jointly Administered)
) Objections Deadline: April 29, 2010 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 filed its Monthly Application for Compensation and Reimbursement of
Expenses of Schully, Roberts, Slattery & Marino PLC as Special Oil and Gas and
Transactional Counsel to Debtor and Debtors in Possession, for the Period from February 1,
2010 through February 28, 2010, seeking compensation for services in the amount of
$10,620.00 and reimbursement of costs incurred in the amount of $2,223.93 (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
be fied with the Clerk of the United States Bankuptcy Court for the District of Delaware, 824
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 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
Market Street, Wilmington, Delaware 19801, and received by no later than 4:00 p.m. (Eastern
(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:
ioneill(0pszilaw.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(0pszilaw.com (c) the Office ofthe United States Trustee, J. Caleb Boggs
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(0steptoe.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(pepperlaw.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
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
Dated: April ll, 2010 PACHULSKI STANG ZIEHL & JONES LLP
165391)
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(qpszilaw.com
ioneil(0pszilaw.com
kmakowski(0pszi law. com
In re: )
STATE OF DELAWARE )
) ss:
) )
Debtors. )
AFFIDAVIT OF SERVICE
Debtors in the above-captioned action, and that on the 9th day of April 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 Fee Application of Schully, Roberts, Slattery & Marino PLC as Special Oil and Gas and Transactional Counsel for the Debtors for the
Period February 1-28,2010
DEBR L. YOU
NOTARY PUBUC
STATE OF DELAWAR
(
1 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 (702 I); San Pedro Bay Pipel ine Company (i 234); Cameros
Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of
the Debtors is 11 I W.
Hand Delivery (Counsel to Official 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
Interoffce 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
Wilmington, DE 19801
Hand Delivery (Copy Service)
Parcels, Inc.
Unsecured Creditors)
Filiberto Agusti, Esquire Steven Reed, Esquire Joshua Taylor, Esquire Steptoe & Johnson LLP 1330 Connecticut Avenue NW Washington, DC 20036
Unsecured Creditors)
Robbin Itkin, Esquire Katherine Piper, Esquire Kelly Frazier, Esquire Steptoe & Johnson LLP
2121 Avenue of