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)

Related Docket No. 1480

CERTIFICATION OF NO OBJECTION REGARDING [REDACTED] SUPPLEMENTAL APPLICATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS PURSUANT TO FED. R. BANKR. 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 [Redacted] Supplemental Application of the Official Committee of Unsecured Creditors Pursuant to Fed. R. Bankr. 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 Aovidance Actions, nunc pro tunc to February 1, 2010 (Docket No. 1480; the Application). The Notice filed with respect to the Application 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 Application and that no answer, objection or any responsive pleading with respect to the Application has been filed with the Court.

#12473500 v1

It is hereby respectfully requested that the Court enter the proposed order filed with the Application, a copy of which is attached hereto as Exhibit A, at the Courts earliest convenience.

Dated: April 19, 2010 Wilmington, Delaware

PEPPER HAMILTON LLP

/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

#12473500 v1

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.

#12473500 v1

EXHIBIT A

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) Related Docket No.

ORDER EXPANDING SCOPE OF EMPLOYMENT AND RETENTION OF PEPPER HAMILTON LLP AS COUNSEL TO INCLUDE PROSECUTION OF AVOIDANCE ACTIONS, NUNC PRO TUNC TO FEBRUARY 1, 2010 UPON THE SUPPLEMENTAL APPLICATION of the Official Committee of Unsecured Creditors (the Official Committee) of the above captioned debtors and debtors-in-possession (the Debtors) pursuant to Fed. R. Bankr. P. 2014(a) for an Order under sections 328(a) and 1103(a) of Title 11 of the United States Code (the Bankruptcy Code) expanding the scope of the employment and retention of Pepper Hamilton LLP (Pepper Hamilton) as counsel to include prosecution of Avoidance Actions nunc pro tunc to February 1, 2010 (the Supplemental Application)1; and upon the affidavit of David B. Stratton, a member of Pepper, in support of the Supplemental Application; and upon the Original Affidavit (D.I. 190) and the First Supplemental Affidavit (D.I. 469) in support of Pepper Hamiltons original retention application; and this Court possessing jurisdiction to consider the Supplemental Application; and venue being proper; and upon finding that the employment of Pepper Hamilton to prosecute, negotiate, settle and litigate the Avoidance Actions effective as of February 1, 2010 is necessary and is in the best interests of the Official Committee, the Debtors and their
1

Capitalized terms not otherwise defined herein shall have the respective meanings ascribed to such terms in the Supplemental Application.

#12261946 v1

estates; and notice of the Supplemental Application having been proper; and the relief requested in the Supplemental Application being warranted, IT IS HEREBY ORDERED THAT: 1. 2. The Supplemental Application is GRANTED. In accordance with Bankruptcy Code sections 328(a) and 1103(a),

the scope of Pepper Hamiltons representation of the Official Committee is hereby expanded to include the representation of the Official Committee in connection with the Avoidance Actions, including prosecuting, negotiating, settling and / or litigating the Avoidance Actions. 3. Pepper Hamilton shall be compensated in accordance with the

Application, the procedures set forth in Bankruptcy Code sections 330 and 331, such of the Bankruptcy Rules as may be applicable from time to time, and such procedures as may be fixed by the Court. 4. With respect to compensation for the services Pepper Hamilton

renders and reimbursement for the expenses Pepper Hamilton incurs in representing the Official Committee in connection with the Avoidance Actions, only, the fee schedule as set forth in the Supplemental Application shall govern such compensation and reimbursement. 5. Nothing herein shall prejudice, impair or otherwise alter the scope

of Pepper Hamiltons representation of the Official Committee in these proceedings except to the extent specifically set forth herein. 6. In the event that a Chapter 11 Plan is confirmed in these

proceedings, and such Plan provides for the commencement and/or continuation of any

#12261946 v1

Avoidance Actions by some entity other than the Official Committee, Pepper Hamilton shall be authorized to represent such other entity in prosecuting, negotiating, settling and/or litigating the Avoidance Actions without further notice. 7. This Court shall retain jurisdiction over all matters pertaining to

this Order and the Application.

Dated: ____________________, 2010 Wilmington, DE

________________________________________________ THE HONORABLE KEVIN J. CAREY UNITED STATES BANKRUPTCY JUDGE

#12261946 v1