IN THE UNITED STATES BANKUPTCY COURT

fu~ )

FOR THE DISTRICT OF DELAWARE

Chapter 11

) PACIFIC ENERGY RESOURCES LTD., et al., 2 ) )

Debtors. )
)

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

Objection Deadline: April 14,2010 at 4:00 p.m. EDT 21, 2010 at 3:00 p.m. EDT Hearing Date: April

DEBTORS' FOURTH OMNIBUS OBJECTION (NON-SUBSTANTIVE) TO CERTAIN (A) CLAIMS THAT HAVE BEEN AMENDED AND SUPERSEDED; (8) CLAIMS THAT WERE LATE FILED; AND (C) STOCKHOLDER CLAIMS
The above-captioned debtors and debtors in possession (the "Debtors") hereby fie the
Debtors' Fourth Omnibus Objection (Non-Substantive) to Certain (a) Claims That Have Been Amended and Superseded; (b) Claims That Were Filed Late; and (c) Stockholder Claims (the

"Fourh Omnibus Objection"). Pursuant to the Fom1h Omnibus Objection, the Debtors seek to:
(i) disallow the three (3) claims set forth on Exhibit A hereto that have been amended and

superseded by subsequently fied claims (the "Amended Claims"); (ii) disallow the two (2)
claims set forth on Exhibit B hereto that were fied after the applicable bar date for filing the

claims (the "Late Claims"); and (ii) disallow the two (2) claims set forth on Exhibit C hereto

that are claims fied by shareholders that are based upon the ownership of stock of Pacifc
Energy Resources Ltd. (the "Stockholder Claims"). The facts and circumstances supporting the

Z The Debtors in these cases, along with the last four digits of each of

the Debtors' federal tax identification number, are: Pacifc 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); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailng address for all of the Debtors is 111 W.
Ocean Boulevard, Suite 1240, Long Beach, CA 90802.
68773-002\DCS_LA:2172I 7.3

Fourth Omnibus Objection are set fort below, in the Exhibits hereto, in the Declaration of
Jennifer Kuritz in Support of

the Debtors' Fourth Omnibus Objection (Non-Substantive) to

Certain (a) Claims That Have Been Amended and Superseded; (b) Claims That Were Filed

Late,' and (c) Stockholder Claims (the "Kuritz Declaration"), the Declaration of

Nova George in

Support of

the Debtors J Fourth Omnibus Objection (Non-Substantive) to Certain (a) Claims

That Have Been Amended and Superseded; (b) Claims That Were Filed Late; and (c)
Stockholder Claims, and the Declaration of Scott a McFarland in Support of

the Debtors' Fourth

Omnibus Objection (Non-Substantive) to Certain (a) Claims That Have Been Amended and

Superseded; (b) Claims That Were Filed Late; and (c) Stockholder Claims (the "McFarland
Declaration"). In support of

the Fourth Omnibus Objection, the Debtors state as follows:

Jurisdiction
1. This Cour has jurisdiction over this Fourh Omnbus Objection pursuant

to 28 U.S.C. 157 and 1334. This matter is a core proceeding pursuant to 28 D.S.C.

l57(b)(2). Venue is proper pursuant to 28 D.S.C. 1408 and 1409.

2. The statutory bases for the relief

requested herein are sections 502(b),

1106(a) and 1 107(a) of

title 11 of

the United States Code (the "Banptcy Code"), Rules 3003

Banptcy Procedure (the "Banptcy Rules") and DeL.

and 3007 of

the Federal Rules of

Ban. L.R. 3007-1.

Baclround
3. On March 9, 2009 (the "Petition Date"), the Debtors commenced these
cases by filing voluntar petitions for relief under chapter 11 the Banptcy Code.

68773-002\DOCS_LA:217217.3

I.

4. The Debtors have continued in possession of

their property and have

continued to operate and manage their business as debtors in possession pursuant to sections
1107(a) and 1108 of

the Banptcy Code. No request has been made for the appointment ofa

trstee or an examiner in these cases.

5. The Offce ofthe United States Trustee appointed an Offcial Committee

of

Unsecured Creditors (the "Committee") on March 19,2009.

6. On May 5, 2009, the Court entered the Order (A) Fixing the Procedures

and Deadlines to File Proofs of

Claim, (B) Approving the Form and Manner of

Notice of

Bar

Dates, and (C) Granting Related Relief (Docket No. 277) ("Bar Date Order"). The Bar Date
Order established, among other bar dates, the bar dates of (i) June 23, 2009 for claims arising
prior to the Petition Date, which includes administrative expenses against the Debtors' estates
arsing under Banptcy Code 503(b)(9), and (ii) thirt (30) days after the entr of

the order

approving the rej ection of a contract or lease for the filing of rejection damage claims. It furter
provided that claims filed after the applicable bar date would be forever bared.

7. On May 9,2009, the Debtors' claims and noticing agent served (i) a
"Notice of Bar Date for Filng Proofs of

Claim" that was approved by the Court in the Bar Date

Order, and (ii) a proof of claim form on all paries listed on the Debtors' creditor matrix.
(Affdavit of

Service, fied May 14,2009 at Docket No. 308.)

The Objection and ReQuest for Relief

8. By this Motion, the Debtors seek to disallow the Amended Claims, the

Late Filed Claims and the Stockholder Claims listed on Exhibits A-C attached.

68773-0D2\DOCS_LA:217217.3

Basis for Relief

9. Section 502 of

the Banuptcy Code, and other applicable non-banptcy

law set forth below, provide the bases for the relief sought in this Fourt Omnibus Objection. Section 502(b) states in relevant par that:
(T)he cour, after notice and a hearing, shall determine the amount the United States as of the date of the fiing of the petition, and shall allow such claim in such amount,
of (a) claim in lawfl curency of

except to the extent that -

(1) such claim is unenforceable against the debtor or

the debtor, under any agreement or applicable law for a reason other than because such claim is contingent or unmatued
propert of

11 V.S.C. 502(b).
10. For the reasons set forth below, each ofthe Amended Claims, Late Filed

Claims and Stockholder Claims are unenforceable against the Debtors under applicable law and
should therefore be disallowed.
A. The Amended Claims
11. The Debtors object to the three (3) claims set forth on Exhibit A under the
colum entitled "Amended Claim to Be Disallowed" upon the grounds that each of

these initial

claims has been amended and superseded by a subsequently filed proof of claim. In order to
prevent a double recovery by the claimants asserting such initial and amended claims, the
Debtors request that each of

the initial claims set forth on Exhibit A (under the colum entitled
the Cour grants this relief, the claim of

"Amended Claims to Be Disallowed") be disallowed. If

68773-002\DOCS_LA:2 17217.3

each of the holders listed in Exhibit A under the colum entitled "Remaining Claim Number"
wil be the suriving claim.3

B. The Late Filed Claims

12. Each of the two (2) claims listed on Exhibit B attched hereto was fied

after the applicable bar date.

13. Quinn Power Systems was served at P.O. Box 905229, Charlotte, North

Carolina 28290-5229 with the approved Notice of Bar Dates for Filng Proofs of Claim (the "Bar
Date Notice") and a proof of claim form on May 9,2009, as required by the Bar Date Order.
Such notice is evidenced by the Affidavit of Service of

the Bar Date Notice signed by the

Debtors noticing and claims agent ("Omni Management") and filed on May l4, 2009 at Docket

Number 308 (the "Bar Date Notice Affdavit of Service"). Omni Management has advised the

Debtors that it did not receive any retu mail that was sent to Quinn Power Systems at the above
stated address.

14. The Bar Date Notice clearly established June 23, 2009 as the last day by
which all prepetition claims against the Debtor, with certain stated exceptions, had to be fied. It

further stated that any claim not fied by the bar date would be forever bared. Quinn Power

. Systems filed Claim No. 444 on August 17,2009, almost two months after the bar date. Claim

No. 444 was fied late and should be disallowed.

15. On April

27, 2007, Pacific Energy Resources Ltd. ("PERL") entered into a

thirt-nine month lease of a 2007 Mercedes-B ML 500 (the "Car Lease"). The Car Lease was

3 The Debtors reserve their right to object to any of Number" of

the claims listed in the colum.n entitled "Remaining Claim Exhibit A on any other grounds. Is such an objection is raised, the claimants wil receive separate notice of such.

68713-002\DOCS_LA:217217.3 5

financed through Mercedes-Benz FinanciaL. The Debtors, soon after the filing of

these chapter

1 i cases, determined that the Mercedes was no longer needed because the employee who used

the car was terminated prepetition and on March 19,2009, advised Downtown L.A. Motors, the
dealer, that PERL was returning the car and PERL did so. On April

30, 2009, the Debtors fied a

the rejection of

motion (the "Rejection Motion") seeking this Cour's approval of

the Car Lease

(Docket No. 259) effective as of

March 19,2009.
Service, on May 9,

16. As is established by the Bar Date Notice Affdavit of

2009, Mercedes-Benz Financial, P.O. Box 9001921, Louisvile, Kentucky 40290-l92

i (the only

address the Debtors had for Mercedes-Benz and the one used for payments on the car lease) was served with the Bar Date Notice that specifically states that all rejection damage claims are to be
fied within thirt (30) days after the entr of the order approving the rejection of

the contract or

lease and that any claim fied after the applicable bar date will be forever bared. Omni
Management has advised the Debtors that it did not receive any retued mail for Mercedes-Benz
sent to the above address.
17. On June 2,2009, the Cour entered an order (the "Rejection Order")

granting the Rejection Motion and on June 16,2009, counsel for DSFS USA LLC, successor in
interest to Daimler Chrsler Financial Services Americas LLC ("DCFS"), record owner of

the

leased car, was served a copy of

the Rejection Order by emaiI. A copy of

that email is attached to

the McFarland Declaration as Exhibit i.

18. On Januar 15,2010, almost seven (7) months after receiving service of

the Rejection Order, Mercedez-Benz Credit Corporation (an entity unown to the Debtors) filed

68773-002\DOCS_LA:217217.3

Claim No. 494 for damages for the rejection of

the Car Lease. Claim No. 494 is a late fied

claim and should be disallowed as provided in the Bar Date Order and the Bar Date Notice.
C. The Stockholder Claims
19. For the reasons set forth in detail below, each of

the two (2) Stockholder

Claims are unenforceable against the Debtors under applicable law and should therefore be

disallowed
20. The Debtors object to the Stockholder Claims set forth on Exhibit C upon

the grounds that each of these claims were fied by shareholders and are based solely upon the

ownership of stock in Pacific Energy Resources Ltd. ("PERL"). The ownership of stock, and
resulting possible loss on an equity investment, does not, in and of itself, give nse to a claim
against PERL or any of

the Debtors. In re Inslico Technologies, Inc., 480 F. 3d 212, 218 (3rd Cir.

2007) ("Equity investent bnngs not a right to payment, but a share of ownership in the debtor's
assets-a share that is subject to all of

the debtor's payment obligations.") Accordingly, the

Debtors respectfully request that each of the Stockholder Claims set forth on Exhbit C be
disallowed and expunged.
Reservation of Riehts
21. To the extent this Fourh Omnibus Objection is not granted as to any claim

listed on Exhibits A-C, the Debtors hereby reserve the right to object in the future to any of

the

claims on any additional ground, and to amend, modifY and/or supplement the Fourh Omnibus
Objection as may be necessary. In addition, the fiing of

the Fourh Omnibus Objection is not

intended to limit the Debtors' abilty to fie futue objections to any claims that have been or may

68773-002\DOCS_LA:2 17217.3

subsequently be fied in these cases, or that may be listed on the Debtors' Schedules, on the
grounds set forth herein or any other appropriate grounds.
22. Further, notwthstanding anything contained in this Four Omnibus

Objection or the attached Exhibits A-D nothing herein shall be constred as a waiver of any

rights that the Debtors or the estates may have (a) to bring avoidance actions under the applicable
sections of

the Banptcy Code, including, but not limited to, i 1 D.S.C. 547, against the

holders of claims subject to this Four Omnibus Objection, or (b) to exercise their right of setoff

against the holders of such claims relating to such avoidance actions.

Statement of ComDliance with Del. Bania. L.R. 3007-1

23. In compliance with DeL. Ban. L.R. 3007-l(e)(i)(E), the Debtors and their

counsel submit that the Fourh Omnibus Objection complies with DeL. Ban. L.R. 3007-1.

Reauest for EDt" of Final Judl!ent

24. The Debtors request that the Cour, pursuant to Rule 54(b) of

the Federal

Rules of Civil Procedure, made applicable in a contested matter by Banptcy Rules 7054 and
9014, direct entry of a final judgment with respect to the Fourh Omnibus Objection as to which.
relief

is entered by any Order on the Fourh Omnbus Objection.

Notice
25. The Debtors have served the Fourth Omnibus Objection on: (i) counsel to

the Committee; (ii) the U.S. Trustee; (ii) all paries who have requested notice pursuant to DeL.

Ban. L.R. 2002-l; and (iv) the claimants set forth on Exhibits A. B, and C whose claims are
the subject of this Fourh Omnibus Objection. The Debtors submit that notice of

the Fourth

68773-O2\DOCS _LA:2 i 7217.3

Omnibus Objection is suffcient under Banptcy Rule 3007, and the Local Banruptcy Rules,
and that no further or other notice is necessar.

WHEREFORE, for the reasons set fort above, the Debtors request the entry of
an order (i) disallowing the three (3) Amended Claims set fort in the column titled "Amended Claim to Be Disallowed" on Exhibit A; (ii) disallowing the two (2) Late Filed Claims set fort
on Exhibit B; (ii) disallowing the two Stockholder Claims set forth on Exhibit C.

Dated: March 22, 2010

PACHULSKI STANG ZIEHL & JONES LLP

Ira D. Kharasch (CA Bar No. 109084) Maxim B. Litvak (CA BarNo. 215852) James E. O'Neil (Bar No. 4042) Scotta E. McFarland (Bar No. 4184) 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE 19899-8705
Telephone: 302/652-4 i 00

~,J)1~;
joneill~pszyjiaw.com
smcfarland~pszj law .com

Facsimile: 310/652-4400
Email: ikharasch~pszjiaw.com mlitvak(fpszyj law .com

Counsel for Debtors and Debtors in Possession

68773..02\DOCS_LA:217217.3

EXHBIT SUMMARY SHEET

Exhibit A Exhibit B Amended and Superseded Claims

Late Filed Claims

Stockholder Claims

Exhibit C -

6871J-02\DOCS_LA:217217.3

IN THE UNITED STATES BANKRUPTCY COURT

In re: )

FOR TH DISTRICT OF DELA WARE

Chapter 11

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

Debtors. ))
)

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

Objection Deadline: April 14,2010 at 4:00 p.m. EDT Hearing Date: AprilZl, Z010 at 3:00 p.m. EDT

NOTICE OF DEBTORS' FOURTH OMNIBUS OBJECTION (NON-SUBSTANTIV) TO CERTAIN (A) CLAIMS THAT HAVE BEEN AMENDED AND SUPERSEDED; () CLAIMS THAT WERE LATE FILED: AND (C) STOCKHOLDER CLAIMS
The above-captioned debtors and debtors in possession (the "Debtors") object
(the "Fourth Omnibus Objection") pursuant to sections 105(a) and 502(b) of

title 11, United

States Code, Rules 3001 and 3007 of

the Federal Rules of

Banptcy Procedure and DeL. Bank.

L. R. 3007-1 to certain (a) claims that have been amended and superseded, (b) claims that were
fied after the applicable bar date for filing such claims, and (c) clais fied by shareholders that
are based upon the ownership of stock of

Pacific Energy Resources Ltd.

Objections and other responses to the relief

requested in the Fourth Omnbus

Objection, if any, must he in wrting and be filed with the Banptcy Court no later than 4:00
p.m. Eastern Time on April

14, 2010.

Any objections or other responses to the Fourh Omnibus Objection, if

any, must

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); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailng address for all of the Debtors is III W.
Ocean Boulevard, Suite 1240, Long Beach, CA 90802.
68773-002\DOCS_LA:2172 i 7.3

also be served, so that they are received not later than April

14, 2010 at 4:00 p.m. Eastern

Time, upon: (i) the Debtors' counsel, (A) Pachulski Stang Ziehl & Jones LLP, 10100 Santa

Monica Blvd., lIth Floor, Los Angeles, California 90067-4100, Attn: Scotta E. McFarland
(ernail: smcfarland~pszjlaw.com) and (B) Pachulski Stag Ziehl & Jones LLP, 919 N. Market

St., 17th Floor, Wilmington, Delaware 19801, Attn: James A. O'Neil (email:
joneil~pszjlaw.com); and (ii) counsel to the Offcial Committee of

Unsecured Creditors (the

"Committee"): Steptoe & Johnson, 1330 Connecticut Ave., N.W., Washington, DC 20036, Att:
Fil Agusti (email: fagusti(gsteptoe.com); Pacific Energy Resources Ltd., 111 West

Ocean

Boulevard, Suite 1240, Long Beach, California 90802, Attn: Jennifer Kuritz (email:
jkuritz~pacenergy .com).

A HEARING ON THE FOURTH OMNIBUS OBJECTION (THE

"CLAIMS HEARING") WILL BE HELD BEFORE THE HONORABLE KEVI J.

CAREY, CHIEF UNITED STATES BANKUPTCY JUDGE, 824 MARKT STREET,

5TH FLOOR, COURTROOM 5, WILMINGTON, DELA WARE 19801, ON APRIL 21,
2010 AT 3:00 P.M., EDT. The Claims Hearing may be continued from time to time upon
wrtten notice to you or oral anouncement in Cour.
If

you fie a response to the Fourh Omnbus Objection, you should be prepared

to argue that response at the Claims Hearing. You need not appear at the Claims Hearng if you
do not oppose the relief requested in the Fourth Umnibus Objection.

IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE,

THE COURT MAY GRANT THE RELIEF DEMANDED BY THE FOURTH OMNIBUS

OBJECTION WITHOUT FUTHER NOTICE OR HEARING.

68773-002\DOCS_LA:21727.3 2

Each claimant who has fied a claim subject to the Four Omnibus Objection is
receiving a copy of

the Fourh Omnbus Objection. Each claimant should read the Fourh

Omnbus Objection, which describes the grounds for the objection to each claim set fort therein,
and should review the exhibits attached thereto, which lists all claims subject to the Fourh
Omnibus Objection.

Any response filed with the Cour must contain at a minimum the following:
a. a caption setting forth the name of the Cour, the names of the Debtors, the

case number and the title of

this Fourt Omnibus Objection;

b. the name of the claimant and description of the basis for the amount of the

claim;
c. a concise statement setting forth the reasons why the claim should not be

disallowed for the reasons set forth in the Fourh Omnibus Objection, including, but not limited to, the specific factual and legal basis upon which the claimant will rely in opposing the Fourh
Omnibus Objection;
d. all documentation or other evidence of the claim, to the extent not

included with the proof of claim previously filed with the Banptcy Cour, upon which the

claimant will rely in opposing the Fourth Omnibus Objection at the Claims Hearing; and
e. the name, address, and telephone number of

the person (who may be the

claimant or the claimant's legal representative) possessing ultimate authonty to reconcile, settle
or otherwse resolve the claim on behalf of the claimant.

Questions about the Fourt Omnibus Objection or requests for additional

information about the proposed disposition of claims should be directed to counsel for the
68773-002\DOCS_LA:217

17.3 3

Debtors at the address or telephone number set fort below.

The Debtors reserve the right to object in the future to any of

the proofs of claim

that are the subject of this Fourth Omnibus Objection on any furher or additional grounds.
Separate notice will be made and a separate hearing wil be scheduled for any such objection.

Dated: March 22,2010

LSKI STANG ZIEHL & JONES LLP

Ira D. Kharasch (CA Bar No. 109084) Maxim B. Litvak (CA Bar No. 215852) James E. O'Neil (Bar No. 4042) Scotta E. McFarland (Bar No. 4184) 919 Nort Market Street, 17th Floor P.O. Box 8705 Wilmington, DE 19899.8705
Telephone: 302/652-4100

Facsimile: 310/652-4400
Email: ikharasch~pszjlaw.com
mlitvak~pszyj law .com

j oneil~pszyj law.com
smcfarland~pszj law. com

Counsel for Debtors and Debtors in Possession

68773.002\DOCS_LA:217217.3

Exhibit A
(Amended and Superseded Claims)

68773-002\DOCS_LA:21727.3

Amnded Clim.

Reaon for
Claim Amount

Nama of Clalmanl

Remaining Amend Claim Claim Numbor

toboD_d
Dlssllownce
Daiel K. Donkel
Addr1 C/O PATRICK J. RUSSELL
5590 EAST YALE AVENUE. SUITE 201

1 Oaei K. Ool
GENERL PETOLEUM
$

507

46
$
68.617.00

Clim Amed
Claim Amnd
CORPORATION

Cnit
Addr2

Adr3
Denver CO 8022
CREIM MACIAS KOENIG & FREY LLP

Ad'"
63 W. AFT STREET 51ST

AdIS

GENERA PETOlEUM

2 CORPORATION

505

418

269 50.0
SAYBOLTlP,ACOE
C/O CORE LABORATORIES LP

C/O RICHARD C. MACI

SAYBL T LPI

COUNSel fOR GENER PETOlEUM CORPORATION

flOOR
HOUSON. TX 77040

LOS ANS CA 90071

SAYBOLT LP. A CORE CO. 3 LABORATOIES

442

10
S

2 171.00

Claim Amed LABORTORIES CO.

ATT: JAY A. WAL

6316 W1NDFRN RD.

Exhibit B
(Late Filed Claims)

68773-0D2\DOCS_LA:217217.3

lale Aled

ci.im

Nam of Ci.imanl
Addr2
P.O. BOX 808

Number ClalmAmun

la Fild - Recived Ja 15,

Re.son for DIssllowanc

Addc
Addr3

Crdior
MERCDES-ENZ CREOI CORPORATION AlT: DEBOR A BANFILl C/ SHERMETA ADAS & VON AlEN. P.C.

Addr4

Mercdes-Bnz Crrt Comolin

494

S 25.914.87

Late iea - K~~""~"" ".

OUINN POR SYSTEMS
ATTN: MIKE CESENA

2010
P.O. BOX 1265
FRESNO, CA 93778

ROCHESTR HILLS, MI480se

Quinn _Sysems

44

4.0E.36

Exhibit C
(Stockholder Claims)

68773-002\DOCS_LA:2172 i 7.3

St~ Claim OIlec.

Cllm
Reuon for

Name of Climant
stocl Claim

Clllm Numbcr

AmDU~

OIsSlIIoI1
Addr4

cm
Add
Add1
rnE ROSKEU REVOCABlE lRUST
IRA COIBORY

AddI
lU. AZ 85741

M ROS1EU & C RO TrEE

StOCClam

132

61UO

Addr1 ..osed Dlsn.."lo. \ Onler dlsalcno claim :i. ROSKE & C ROSlEu. TT ATT MILToN ROSK

3295 W FIREFAl PI

BARRY C WHITE

194

Onler dlsanono claim iBARY C WH

UTA CHAS SCAB & CO INC

om 1011/97

utA D1 05 3l SA DR

SAA YNEZ CA 93

IN THE UNITED STATES BANKRUPCY COURT

fu ~ )

FOR THE DISTRICT OF DBLA W ARE

Chapter I 1
)

PACIFIC ENERGY RESOURCES LTD., et al., 1 )

Debtors. ))
)

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

Objection Deadline: April

14, 2010 at 4;00 p.m. EDT Hearing Date: April 21, 201.0 at 3:00 p.m. EDT

DECLARATION OF JENNIFER KURITZ IN SUPPORT OF DEBTORS' FOURTH OMNffUS OBJECTION (NON-SUBSTANTIVE) TO CERTAIN (A) CLAIMS THAT HAVE BEEN AMENDED AND SUPERSEDED; (B) CLAIMS THAT WERE LATE FILED; AND (C) STOCKHOLDER CLAIS
I, Jennifer Kurtz, hereby declare that the following is true to the best of my

knowledge, infoimation and belief:

1. I am the Treasurer for the Debtors and I am responsible for overseeing the

claims review and objection process in these chapter 11 cases (the "Cases"). Except as otherwise
indicated, all statements in this Declaration are based upon my personal knowledge, my review

of the Debtors' books and recprds, relevant documents and other infonnation prepared or
collected by the Debtors' employees, professionals, or my opinion based on my experience with

the Debtors' operations and financial condition. In making my statements based on my review
of the Debtors' books and records, relevant documents and other information prepared or

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): Petroeal Acquisition Corp. (6249); Pacific Energy Alaska Holdings,

LLC (tax I.D. # not available); Cameros Acquisition Corp. (5866): Pacific Energy Alaska Operating LLC (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailng address for all of the Debtors is 1 i i W.
Ocean Boulevard. Suite) 240, Long Beach, CA 90802.

68773.(2\DOCS_I.I~ i 7317.2

collected by tbe Debtors' employees and/or professionals, I have relied upon these paries

accurately recording, preparing or collecting such documentation and other information.

2. I make this Declaration in support of

the Debtors' Fourth Omnibus

Objection (Non.-Substantive) to Certain () Claims That Have Been Amended and Superseded;
(b) Claims That Were Filed Late,' and (c) Stockholder Claims (the "Fourth Omnibus

O~iection"). i have reviewed the Fourth OmnibUs Objection and am, directly or through the
Debtors' personneL. familar with the information contained therein and in the exhibits annexed
thereto. The Debtors maIntain books and records (the "Books and Records") which retlect.

among other things, the Debtors' liabilties and respective amounts owed to their creditors and 1
am familar with the Books and Records.

3. If J were called to testify as a witness in this matter, I could and would

competently testify to each of the facts set forth herein based upon my personal knowledge,

review of documents, or opinion. I am authorized to submit this Declaration on behalf of the

Debtors. Capitalized tenns not otherwise defined herein shall have the meaning ascribed thereto

in the Fourth Omnibus Objection.

4. Under my supervision, considerable resources and time have been

expended to ensure a high level of dilgence in reviewing and reconciling the proofs of claim
filed in these Cases. The claims and the related Books and Records were carefully reviewed and
analyzed by appropriate personnel resulting in the identification of the claims to which

objections are raised in the Fourth Omnibus Objection.

6873.(2\DOC~U.i\:2173 11.2

The Amended Claims

5. The Debtors o~ject to the three (3) Amended Claims set forth on Exhibit

A to the Fourth Omnibus Objectioii upon the grounds Uiat each of these claims has beeii

amended and su perseded by the subsequently filed claim that is based on the same facts as the

Amended Claim. These subsequently fied claims are shown as the Remaining Claim Numbers
on said Exhibit A. The claims in the column on Exhibit A titled Amended Claims to Be
Disallowed should be disallowed.

Late Filed Claims

6. Claim No. 44 fied by Quinn Power Systems and Claim No. 494 tiled by

Mercedes-Benz Financial were filed after the bar date that was applicable to each and therefore

are late fied claims. The Bar Date Order established, among other bar dates, the bar dates of (i)
June 23, 2009 for claims arising prior to the Petition Date and (ii) thirty (30) days after the entry of the order approving the rejection of a contract or lease for the filing of rejection damage
claims.
7. I am informed and believe that Quinn Power Systems was served at P.O.

Box 905229, Charlotte, North Carolina 28290-5229 with the Bar Date Notice on May 9, 2009,
by the Debtors' claims and noticing agent, Omni Management Group, LtC. This address was

the address that the Debtors had for Quinn Power Systems. Quinn Power Systems tiled Claim
No. 444 on August 17. 2009, almost two months after the bar date. The claim is for prepetition

amounts and was subject to the June 23.2009 bar date.

68773-002\Dn'U .11:2 J 7317.2

8. J am informed and believe that Mercedes-Benz Financial was served with

the Bar Date Notice on May 9,2009, by Omni at P.O. Box 9001921, Louisvile, Kentucky
40290- 1 92J. This address was the only one of which the Debtors were aware for Mercedes-

Benz Financial.

9. On Apn127. 2007, Pacific Energy Resources Ltd. ("PERL") had entered

into a thirty-nine month lease of a 2007 Mercees-B ML 500 (the "Car Lease"). The Car Lease
was financed through Mercedes-Benz FinanciaL. The Debtors, soon after the filing of

these

chapter It cases, determined that the Mercedes was no longer needed because the employee who
iised the car was terminated prepetition and on March 19, 2009, advised Downtown L.A. Motors,

the dealer, that PERL was returning the car and PERL did so. On April 30, 2009, the Debtors

fied the Rejection Motion seeking this Court's approval of the rejection of the Car Lease

(Docket No. 259) effective as of March 19,2009. On June 2,2009, the Court entered an order
(the "Rejection Order") granting the Rejection Motion.
I O. I am informed and believe that a copy of the Rejection Order was email to

counseI for DSF USA LLC, successor in interest to Daimler Chrysler Financial Services
Americas LLC, on or about June 16,2009.

11. On January 15,2010, almost seven (7) months after receivIng service of

the Rejection Order, Mercedez-Benz Credit Corporation (an entity unknown to the Debtors) tiled
Claim No. 494 for damages for the rejection of the Car Lease.

68773-O2\OOClU.i\;ii 73 i 7.2

The Stockholder Claims

12. The Debtors object to the one two (2) Stockholder Claims set forth on

Exhibit C to the Fourth Omnibus Objection because, based on a careful review of the

Stockholder Claims, each of these claims is based upon the ownership of stock in Pacific Energy
Resources Ltd. I am advised by counsel that claims based solely on the ownership of stock in a

debtor are not valid claims.

Pursuant to 28 U.S.C. i 746, I declare under the penalty of perjury that the foregoing is
true and correct.

March 22, 2010

~~

6877).Q2\DOCs_I-i:il 73 17.2

to

IN THE UNITED STATES BANKUPTCY COURT

fu~ )

FOR THE DISTRCT OF DELA WARE

Chapter 11

PACIFC ENERGY REOURCES LTD., etal., 1)

Debtors. ))
)

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

Objection Deadline: April 14,2010 at 4:00 p.m. EDT 21, 2010 at 3:00 p.m. EDT Hearing Date: April

DECLARTION OF NOVA GEORGE IN SUPPORT OF DEBTORS' FOURTH

OMNmUS OBJCTION (NON-SUBSTAN)

TO CERTAI (A) CLAIS THT HAVE BEEN AMNDED AN SUERSEDED;
(8) CLAIMS THAT WERE LATE FILED: AND (C) STOCKHOLDER CLAIMS
I, Nova George, hereby declare tht the following is true to the best of my

knowledge, information and belief:

i. I am an employee of Oin Management Group, LLC ('40mni"), the

offcial noticing and claims agent for the above-captioned debtors and debtors in possession.

When the Debtors request that Omn serve documents in these chapter I i cases, I am responsible

for overseeing of the preparation and coordination of the service of documents. Except as
otherwse indicated, all statements in this Declaration are based upon my personal knowledge

other information prepared or collected by Omn's employees.

1 The Debtors in these cases, along with the last four digits of each of the Debtors' federal ta identication

number, are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska

Holdings, LLC (tax I.D. # not avaiable); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Oprating LLC (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of the
Debtors is 111 W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.

68773-002\DOCS _LA:2 17328.1

2. I make tls Declartion in support of the Debtors' Fourth Omnibus

Objection (Non-Substantive) to Certain (a) Claims That Have Been Amended and Superseded;

(b) Claims That Were Filed Late,' and (e) Stockholder Claims (the "Fourt Omnibus
Objection") .
3. If I were called to testify as a witness in this matter, I could and would

competently testify to each of the facts set fort herein. Capitalized tenns not otherwise
defined herein shal have the mearung ascribed thereto in the Fourt Omnibus Objection.
4. On May 9, 2009, I supervised the service of

the Bar Date Notice. As is

evidenced by the Affdavit of Service, fied with this Court on May 14,2009 (Docket No.
308), pages, 67 and 115, copies of which are attached hereto as Exhibit A, Quin Power

Systems was served the Bar Date Notice at P.O. Box 905229, Chalotte, Nort Carolina
28290-5229 and Mercedes~Benz Financial was served the Bar Date Notice at P.O. Box
9001921, Louisvile. Kentucky 40290-1921.

5. The Notices of Bar Date sent to Quin Power Systems and Mercedes-

Benz Financial were not retued to Omn as undeliverable.

Pursuant to 28 V.S.C. 1746, I declare under the penalty of

perjury that the foregoing

is true and correct.

March 22,2010

~~~.
No a George
2

68773-0\DOS _ LA:217328.1

Exhibit A

68773.002\DCS_LA:217217.3

IN THE UNITED STATES BANKUPTCY COURT

FOR THE DISTRICT OF DELAWARE

Chapter 1 i

In re:
Case No. 09-10785 (KJC)

PACIFIC ENERGY RESOURCES LTD., et al.,l

Jointly Administered

Debtor

AFFIDAVIT OF SERVICE

I, Nova George, am employed in the city and county of Los Angeles, State. of
the following document to be served via (i) first-class mail, postage pre-paid to the parties listed in Exhibit A attached hereto;
California. I hereby certify that on May 9, 2009, I caused a true and correct copies of

Notite of Bar Dates for Filng Proofs of Claim

. Proof of Claim Form

Dated: May 13,2009

~~~
Nova orge
)
) 5S.

Omni Management Group, L.L.C. 16501 Ventura Boulevard, Suite 440 Encino, California 9 i 436 (818) 906-8300

\ State of California
~

~ County of Los Angeles

Subscribed and sworn to (or affrmed) before me on this l2day of 'Il/ ,20 fJ , by
AJtJlkt. (Jeorjt , proved to me on the basis of

person(s) who appeared before me. .

satisfactory e~ to be the

~If/?~ 14'.~~=:-1 Notary Public 1- ~:;:: l

- - - - .,~.~~~
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); Petroeal Acquisition Corp. (6249); Pacific Energy Alaska Holdings, LLC (tax I.D. /I not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operation LLC (7021); San Pedro Bay Pipeline Company (1234); Cameros Energy, Inc. the Debtors is I i I W. Ocean (9487); and Gotland Oil, Inc. (5463). The mailing address for all of Boulevard, Suite 1240, Long Beach, CA 90802.

EXHIBIT A

Pacific Energy Resources, Ltd. . U.S. Mall

MCI

Serv 5/9/2009
MCINTOSH & ASSOCIATES 2001 WHEELAN COURT BAKERSFIELD, CA 93309

PO BOX 600607
JACKSONVILLE, FL 32260-0607

MCJUNKIN RED MAN CORP. P.O. BOX 31001-0340

PASADENA, CA 91110-0340

MCKINEL Y TOWERS 337 EAST 4TH AVENUE ANCHORAGE, AK 98501

MCKINEL V TOWERS 337 EAST 4TH AVENUE

ANCHORAGE, AK 998501

MCKINLEY TOWERS 337 E. 4TH AVE. ANCHORAGE. AK 98501

MCKINLEY TOWERS AVENUE ANCHORAGE. AK 98501

337 E. 4TH

MCKINLEY TOWERS 337 EAST 4TH AVENUE

MCKINLEY TOWES
337 EAST 4TH AVENUE ANCHORAGE, AK 98501

ANCHORAGE, AK 998501

MCLEAN BUDDEN f3ULK TRUST 200 BAY STREET, NORTH TOWER. 25 FLOOR

TORONTO. ON M5J 2J5

CANADA

MCMASTER CARR ATTN: L. SCHERCK 9630 NORWALK SANTA FE SPRINGS, CA 90670

MCMASTER CARR SUPPLY CO P.O. BOX 7690

CHICAGO, IL 6068D-7690

MCMASTER-CARR P.O. BOX 54960 LOS ANGELES, CA 90054-0960

MCMASTER-CARR SUPPLY CO. P.O. BOX 7690 CHICAGO, IL 60660-7690

M.D ELECTRIC 220 EAST MONTEREY AVENUE POMONA, CA 91767

MEAGAN CUNNINGHAM
2055A POWELL ST

SAN FRACISCO CA 94133

MEASUREMENT STANDARDS DIV 12060 INDUSTRY WAY # 0-6 ANCHORAGE, AK 99515

MECHANICAL SEAL REPAIR PO BOX 2088 SEAL BEACH. CA 90740

MEDEMA FAMIL V TRUST C/O MAX D. MEDEMA 2600 KEMPTON HILLS DRIVE ANCHORAGE, AK 99516

MEDEMA FAMILY TRUST C/O MAX D. MEDEMA 2800 KeMPTON HILLS DRIVE ANCHORAGE, AK 99516

MEOEMA FAMIL V TRUST C/O SWALLING & ASSOC.

C/O ROYALTY DISTRIBUTORS, INC. (AS

AGENT)

PO BOX 24118

TEMPE, AZ 85285

MEDEMA FAMILY TRUST. C/O SWALLING & ASSOC. D.M. DOWLING & M.D. MEDEMA, CO.TTEES 320'1 C STREET. 5UITE 405 ANCHORAGE, AK 99503

MEDEMA FAMILY TRUST, C/O SWALLING & ASSOCIATE D.M. DOWLING & M.D. MEDeMA, CO- TTEES

MEDEMA PROPERTIES LLC

C/O ROYALTY DISTRIBUTORS,

INC. (AS AGENT

:i:W1 C $11'1;1:, SUITE: 405

ANCHORAGE, AK 99503

24116 TEMPE, AZ 85285

POBOX

MEDEMA PROPERTIES LLC D.M. DOWLING & M.D. MEDEMA, CO.TTEES 2800 KEMPTON HILLS DRIVE ANCHORAGE, AK 99516

MEDIA RECOVERY, INC. PO BOX 676310

DALLAS, TX 75267-8310

MELANIE ROGERS 9690 WINSTON CHURCHILL ROAD NORVAL. ON LOP lKO CANADA

MELO'S GAS & GEAR 4580 STATE ROAD BAKERSFIELD, CA 93308

MELVIN PHILUPS

14l ?AVilON Re
UNION ME 04862

MEMORIAL MARITME CLINIC 160 SOUTH fllCO AVENUE LONG BEACH, CA 90802

MEMORIAL MARITIME CLINIC, INC.

150 SOUT PICO AVENUE LONG BEACH, CA 90802

MERCEDES.BENZ FINANCIAL P.O. BOX 9001921

LOUISVILLE, KY 40290-1921

MERLE GENE DIXON

CHALES SCHWAB & CO NC CUST

MERLE DIXON PSP PART QRP 419 S BREWER ST VINITA OK 74301

Page 67 of 147

Pacific Energy Resources, Ltd. - U.S. Mall

PONCEL REVOCABLE TRUST UA 10 04 05 JOSE LUIS PONCEL OR MARl 4775 COLLINS AVE
APT 3604

Served 5/9/2009
POPE & COMPANY LIMITED 15 DUNCAN ST TORONTO. ON M5H 3P9 CANADA
PORT SUPPLY PO BOX 50060 WATSONVILLE, CA 95077-5060

MIAMI BEACH FL 33140-3269

POWER CONTROL INTGRATED

PO BOX 3625 TUSTIN. CA 92781

PRAIR DISTRIBUTION INC

DEPT LA 21511

PREFERRED PLUMBING
80 AIRPORT BOULEVARD

PASADENA, CA 91185-1511

FREEDOM. CA 95019-2901

PREFERRED PLUMBING & HEATING 335 MAIN LOOP KENAI. AK 99611

PREFERRED PLUMBING & HEATING 335 MAIN LOOP

KENAI, AK 99611

PREMIER PUMPING UNIT SERVICES 7613 NORRIS ROAD BAKERSFIELD. CA 93308

PRIME BROKER SERVICES

1 FIRST CON PLACE 36TH FLOOR TORONTO. ON M5X 1H3 CANADA

PRODUCTON DATA INCORPORATED PO BOX 3266 BAKERSFIELD. CA 93385

PROF W MICHAEL MCCLARY

MRS SHIRLEY MCCLARY J1OS

543 CAMBRIDGE ST SE MEDICINE HAT AB, T1A OT3 CANADA

PROF. DAVID CHAPMAN

RR2. SITE 14A. COMPo 8

PRO-NET BEUCE INC

C/O JOHN RUSSELL 12825 46E AV SAINT-GEORGES.EST QC. G5Y 5B9 CANADA

BURNS LAKE, BC VOJ1EO CANADA

PROPERTY ASSESSOR PO BOX 196650 ANCHORAGE, AK 99519

PRUDENTIAL 136 CENTRAL AVENUE 3RO FLOOR CLARK, NJ 07066

PRUDENTIAL PO BOX 856138 LOUISVILLE. KY 40285

PSC INDUSTRIAL PO BOX 3070 HOUSTON. TX 77253

PTC CUST ROTH IRA FBO

ORA 0 MARTINDALE II PO BOX 94 HAVENSVILLE KS 86432

PTS LABORATORIES INCORPORATED 8100 SECURA WAY SANTA FE SPRINGS. CA 90670

PTS RENTALS INCORPORATED PO BOX 9328 BAKERSFIELD. CA 93389

PUBLIC EMPLOYMENT RELATIONS 3530 WILSHIRE BLVD # 1435

PUMASOFT
PO BOX 9041

PURETEC
P.O. BOX 5387

LOS ANGELES, CA 90010

BAKERSFIELD. CA 93389

OXNARD. CA 93031-5387

INCORPORATED 21021 VENTURA BOULEVARD. SUITE 100 WOODLAND HILLS. CA 91364

QUALIFIED BENEFITS.

QUALITY REFRIGERATION INC PO BOX 367

WILMINGTON, CA 90748

QUINN CAPITAL CORP. INTELLIGENT OFFICE FIRST CANADIAN PLACE 100 KING ST SUITE 5700 PO BOX 148 STN 1ST CAN PLACE TORONTO ON. M5X 1C7 CANADA

QUINN POWER SYSTEMS P.O. BOX 905229 CHARLOTTE, NC 28290-5229

R & S WHITSON INC.

R & S WHITSON, INCORPORATED

L1C #827029

PO BOX 1494 PASO ROBLES, CA 93447-1494

PO BOX 1494
PASO ROBLES. CA 93447-1494

R & T PACIFIC ASSOCIATES PO BOX 90155

R FESS & G FESS ITEE

FESS FAMILY TRUST U/A OTO 09/27/1988 14500 FRUITVALE AVE # 6141 SARATOGA CA 95070

R JOHNSON & C JOHNSON TTEE

J&J lIVING TRUST

UIA OTD 06/04/1998 495 S TAAFFE ST SUNNYVALE CA 94086

lONG BEACH. CA 90809

Page 115 of 147

IN TH UNITED STATES BANKRUPTCY COURT

In re: )

FOR THE DISTRICT OF DELAWARE

Chapter 11

PACIFIC ENERGY RESOURCES LTD., et al., 1 )

Debtors. ))
)

Case No. 09- i 0785(KJC) (Jointly Administered)

Objection Deadline: April 14,2010 at 4:00 p.m. EDT Hearing Date: April 21, 2010 at 3:00 p.m. EDT

DECLARATION OF SCOTTA McFARLAND IN SUPPORT OF DEBTORS' FOURTH

OMNIBUS OBJECTION (NON~SUBST ANTIVE)

TO CERTAIN (A) CLAIMS THAT HAVE BEEN AMENDED AND SUPERSEDED; () CLAIMS THAT WERE LATE FILED; AND (C) STOCKHOLDER CLAIMS
my

I, Scotta McFarland, hereby declare that the following is tre to the best of

knowledge, information and belief:

1. I am an attorney duly licensed to practice before the cours of the State of

Delaware and before this Cour and am of counsel to the law firm of Pachulski Stang Ziehl &
Jones LLP ("PSZ&J"), counsel for Pacific Energy Resources LLC., et aL.1 the above~captioned

debtors and debtors in possession (the "Debtors"). I make this Declaration based on my own
personal knowledge and if called upon could and would testifY competently thereto.
2. I make this Declaration in support of the Debtors' Fourth Omnibus

Objection (Non-Substantive) to Certain ra) Claims That Have Been Amended and Superseded,'

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 (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailng address for all of the Debtors is 11 I W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.

68773-002\DOCS_LA:217348.1

(b) Claims That Were Filed Late; and (c) Stockholder Claims (the "Fourh Omnbus

Objection"). Capitalized terms not otherwise defined herein shall have to meaning given them in
the Fourth Omnibus Objection.
3. During discussions regarding the withdrawal of

the Motion for RelIeffrom

Stay relating to the leased car fied by DSFS USA LLC, successor in interest to Daimler Chrsler
Financial Services Americas LLC ("DCFS"), record owner of

the leased car, on June 16,2009, I

the Order entered

sent to Krsti Doughty at kdoughty~aulgur.com, attorney for DCFS, a copy of

by this Court approving the rejection of the Car Lease. She acknowledged receipt of such email

by return emaiI. A tre and correct copy of the email chain is attached hereto as Exhibit 1.
Pursuant to 28 U.S.C. 1746, I declare under the penalty of

perjur that the foregoing is

true and correct.

March 22, 2010

s~)7f

68773-002\DOCS_LA:2

I 7348. i

Exhibit 1

(Email chain re Rejection Order for Car Leasel

68773-002\DOCS_LA:217217.3

Scott McFarland

From: Sent:
To:

Scotta McFarland Tuesday, June 16, 20094:51 PM

'kdoughty~aulgur.comr
Emailng: Copy of Order Rejecting Auto Lease.pdf, Motion re Approval of Rejection of

Subject:

Mercedes Lease.pdt

Attachments:

Copy of Order Rejecting Auto Lease.pdt; Motion re Approval of Rejection of Mercedes

Lease. pdt

-m

~ lS
t ached are a copy of the Motion re rej ection of the Mercedes Lease

Copy of Order MotIon re Approval Rejectng Auto L.n of Rejeclo..

and the Order approving that motion.

The message is ready to be sent with the following file or link attachments:

Copy of Order Rej ecting Auto Lease. pdf

Motion re Approval of Rej ection of Mercedes Lease. pdf

Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled.

Scotta McFarland
From:

Sent:
To: Cc:

Subject:

Kristi Doughty (kdoughty(gaulgur.coml Wednesday. June 24, 2009 7:25 AM Scotta McFarland Lindsay Perkins RE: Emailng: Copy of Order Rejecting Auto Lease.pdf, Motion re Approval of Rejection of

Mercedes Lease. pdt

Scotta,
I received your voicemail following up on this email and our prior conversation, and we 1 ve put in a call to our co-counsel to see if the motion can be withdrawn or agreed order worked out by this afternoon since today is the response deadline. I hope to get back to

you shortly.
Regards,

Thank you for your patience.

Kristi

- - - - -Original Message- - - -From: Scotta McFarland (mail

to: smcfarland~pszj law. com)

Sent: Tuesday, June 16, 2009 7:51 PM To: Kristi Doughty Subj ect: Emailing: Copy of Order Rej ecting Auto Lease. pdf, Motion re Approval of Rej ection

of Mercedes Lease. pdf

~~Copy of Order Rejecting Auto Lease.pdf~~ At ~~Motion re Approval of Rejection of Mercedes Lease.pdf~~ tached are a copy of the Motion re rejection of the Mercedes Lease and the Order approving that motion.

The message is ready to be sent with the following file or link

attachments:

Copy of Order Rejecting Auto Lease .pdf

Motion re Approval of Rej ection of Mercedes Lease. pdf

Note: To protect against computer viruses, e-mail 'programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled.

IN THE UNITED STATES BANKUPTCY COURT

In re: )

FOR THE DISTRICT OF DELA WARE

Chapter 11

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

Debtors. ))
)

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

Related to Docket No.

ORDER GRANTING DEBTORS' FOURTH OMNIBUS OBJECTION (NON-SUBSTANTIVE) TO CERTAIN (A) CLAIMS THAT HAVE BEEN AMENDED AND SUPERSEDED; (B) CLAIMS THAT WERE LATE FILED,; AND (C) STOCKHOLDER CLAIMS
Upon the Debtors' Fourth Omnibus Objection (Non-Substantive) to Certain (a)
Claims That Have Been Amended and Superseded; (b) Claims That Were Filed Late; and (c)
Stockholder Claims (the "Fourh Omnibus Objection"i of

the above-captioned debtors and

debtors in possession seeking entr of an order disallowing the Amended Claims, Late Filed
Claims and Stockholder Claims listed on Exhibits A, B and C attched to the Fourth Omnibus
Objection; and no previous application having been made; and upon consideration of

the Fourth

Omnbus Objection; and due and proper notice of

the Fourh Omnibus Objection having been

given, it is hereby

each of the Debtors' federal tax identification number. are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska Holdings,

i The Debtors in these cases, along with the last four digits of

2 Capitalized tenns not defined herein are as defined in the Fourth Omnibus Objection.

LLC (tax I.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailng address for all of the Debtors is III W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802.

DOCS_LA:217349.1

ORDERED that the Amended Claims listed on Exhibit A to the Fourh Omnibus
Objection are hereby disallowed; and it is further
ORDERED that the Late Filed Claims listed on Exhibit B to the Four Omnibus

Objection are hereby disallowed; and it is fuher

ORDERED that the Stockholder Claims listed on Exhibit C to the Fourh

Omnbus Objection are hereby disallowed; and it is fuher

ORDERED that this Cour shall retain jursdiction to hear and determine all
matters arsing from the implementation of

this Order.

Dated:

,2010
The Honorable Kevin J. Carey ChiefUnit~d States Banruptcy Judge

DOCS_LA:21749.1 2