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CERTIFICATION OF NO OBJECTION REGARDING MOTION OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS FILE UNDER SEAL THE UNREDACTED VERSION OF THE SUPPLEMENTAL APPLICATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS PURSUANT TO FED. R. BANK. P. 2014(A) FOR ORDER UNDER SECTIONS 328(A) AND 1103(A) OF THE BANKRUPTCY CODE EXPANDING THE SCOPE OF EMPLOYMENT AND RETENTION OF PEPPER HAMILTON LLP AS COUNSEL TO INCLUDE PROSECUTION OF AVOIDANCE ACTIONS, NUNC PRO TUNC TO FEBRUARY 1, 2010 On April 5, 2010, the Official Committee of Unsecured Creditors (the Committee) of the above captioned debtors and debtors-in-possession filed their Motion of Official Committee of Unsecured Creditors to File under Seal the Unredacted Version of the Supplemental Application of the Official Committee of Unsecured Creditors Pursuant to Fed. R. Bankr. P. 2014(a) of the Bankruptcy Code Expanding the Scope of Employment and Retention of Pepper Hamilton LLP as Counsel to Include Prosecution of Avoidance Actions, nunc pro tunc to February 1, 2010 (Docket No. 1479; the Motion). The Notice filed with respect to the Motion provided an objection deadline of 4:00 p.m. (Prevailing Eastern Time) on April 14, 2010. The undersigned hereby certifies that he has received no answer, objection or any responsive pleading with respect to the Motion and that no answer, objection or any responsive pleading with respect to the Motion has been filed with the Court.
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It is hereby respectfully requested that the Court enter the proposed order filed with the Motion, a copy of which is attached hereto as Exhibit A, at the Courts earliest convenience.
/s/ James C. Carignan David B. Stratton, Esq. (DE No. 960) James C. Carignan, Esq. (DE No. 4230) Hercules Plaza, Suite 5100 1313 N. Market Street P.O. Box 1709 Wilmington, Delaware 19899-1709 Tel: (302) 777-6500 Fax: (302) 421-8390 and Francis J. Lawall, Esq. 3000 Two Logan Square Eighteenth & Arch Streets Philadelphia, PA 19103-2799 Tel: (215) 981-4000 Fax: (215) 981-4750 and Filiberto Agusti, Esq. (DC Bar No. 270058) (admitted pro hac vice) Joshua R. Taylor, Esq. (VA Bar No. 45919) (admitted pro hac vice) STEPTOE & JOHNSON LLP 1330 Connecticut Avenue NW Washington, DC 20036 Tel: (202) 429-3000 Fax: (202) 506-3902 and
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Robbin L. Itkin, Esq. (CA Bar No. 117105) (admitted pro hac vice) Katherine C. Piper, Esq. (CA Bar No. 222828) (admitted pro hac vice) STEPTOE & JOHNSON LLP 2121 Avenue of the Stars, Suite 2800 Los Angeles CA 90067 Tel: (310) 734-3200 Fax: (310) 734-3300 Counsel for the Official Committee of Unsecured Creditors of Pacific Energy Resources Ltd., et al.
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EXHIBIT A
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2.
Supplemental Application under seal, to remain under seal in accordance with the conditions set forth in the Motion to Seal. 3. The unredacted version of the Supplemental Application shall remain
under seal and shall not be disclosed to any entity other than the Committee and the Debtors, without further Order of this Court. Dated: ____________________, 2010 Wilmington, DE
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