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. 1478

CERTIFICATION OF NO OBJECTION REGARDING MOTION OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS: (I) FOR STANDING TO PURSUE CAUSES OF ACTION BELONGING TO DEBTORS ESTATES ARISING UNDER CHAPTER 5 OF THE BANKRUPTCY CODE; AND (II) FOR APPROVAL OF PROCEDURES AND AUTHORITY GOVERNING SETTLEMENT OF CHAPTER 5 CAUSES OF ACTION 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: (I) for Standing to Pursue Causes of Action Belonging to Debtors Estates Arising under Chapter 5 of the Bankruptcy Code; and (II) for Approval of Procedures and Authority Governing Settlement of Chapter 5 Causes of Action (Docket No. 1478; 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.

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

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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

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In Re:

) ) Chapter 11 PACIFIC ENERGY RESOURCES LTD., et al, ) ) Case No. 09-10785 (KJC) Debtors. ) Jointly Administered ) ) Re: D.I. No. ____ __________________________________________) ORDER GRANTING MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS: (I) FOR STANDING TO PURSUE CAUSES OF ACTION BELONGING TO DEBTORS ESTATES ARISING UNDER CHAPTER 5 OF THE BANKRUPTCY CODE; AND (II) FOR APPROVAL OF PROCEDURES AND AUTHORITY GOVERNING SETTLEMENT OF CHAPTER 5 CAUSES OF ACTION UPON THE MOTION of the Official Committee of Unsecured Creditors (the Committee) for entry of an Order: (i) granting standing to the Committee to pursue causes of action belonging to the Debtors estates and arising under Chapter 5 of the Bankruptcy Code; and (ii) for approval of procedures and authority governing settlements of such causes of action (the Motion);1 and this Court possessing jurisdiction over the Motion; and venue being proper; and notice of the Motion having been sufficient; and having reviewed the Motion and all papers related thereto heretofore filed; and the relief requested in the Motion being warranted, IT IS HEREBY ORDERED THAT: 1. 2. The Motion is GRANTED. The Committee is hereby given derivative standing to prosecute,

negotiate, settle and/or litigate the Avoidance Actions, including standing to take all actions the

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

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Committee determines in its sole discretion necessary or appropriate in connection with the prosecution, negotiation, settlement and/or litigation of the Avoidance Actions. 3. The following Settlement Procedures are approved and shall govern the

noticing, service, hearing requirements and further Court authorization attendant to the settlement of any Avoidance Action: a. For purposes of the proposed Settlement Procedures, only, the

gross amount (in each case, the Gross Settlement Amount)2 of consideration provided by a settling defendant shall include: (i) 100% of the actual dollar amount paid by the settling defendant to the Debtors estates in compromise of the particular Avoidance Action; (ii) 100% of the dollar amount of any secured claim to be waived or reduced in connection with the settlement; (iii) 100% of the dollar amount of any priority claim to be waived or reduced in connection with the settlement; and (iv) 10% of the dollar amount of any general, unsecured, non-priority claim to be waived or reduced in connection with the settlement (excluding any claim for the value of the settlement itself under section 502(d) of the Bankruptcy Code or otherwise). b. Without further hearing or notice, the Committee is authorized to

settle any Avoidance Action wherein the aggregate value of all potentially avoidable and recoverable transfers as determined by the Committee in its sole discretion (in each case, an Avoidance Action Claim) is less than $50,000.00, after accounting for new value that the applicable Avoidance Action defendant contributed that the Committee determines, in its sole
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It should be noted that the Committee proposes these levels of credit and reductions solely for the purpose of noticing and objection procedures to govern settlements the Committee reaches with various transferees. These credits and percentages should not be relied upon by transferees in estimating the settlement value of a particular Avoidance Action, because the Committee gives no weight to these percentages in determining the substantive value of a particular Avoidance Action.

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discretion, would qualify as subsequent new value that would shield such defendant from some portion of preference exposure pursuant to section 547(b)(4) of the Bankruptcy Code (as related to each individual defendant and for purposes of this Motion only, the New Value). c. The Committee is authorized to settle any Avoidance Action

without further notice or hearing: (i) where the Gross Settlement Amount is 50% of an Avoidance Action Claim, after accounting for New Value, between $50,000.01 and $75,000.00; (ii) where the Gross Settlement Amount is 65% of an Avoidance Action Claim, after accounting for New Value, between $75,000.01 and $100,000.00; (iii) where the Gross Settlement Amount is 75% of an Avoidance Action Claim, after accounting for New Value, between $100,000.01 and $250,000.00; or (iv) where the Gross Settlement Amount is 85% of an Avoidance Action Claim, after accounting for New Value, between $250,000.01 and $500,000.00. d. With respect to Avoidance Action Claims, after accounting for

New Value, between $75,000.01 and $500,000.00 that are settled for Gross Settlement Amounts that are less than the respective percentages in the immediately preceding paragraph, the Committee has authority to compromise such Avoidance Actions by filing a Notice of Settlement with the Court, stating the name of the transferees, the respective Avoidance Action Claim amounts and the respective Gross Settlement Amounts. The Committee shall serve the Notice(s) of Settlement upon counsel for the Debtors, the U.S. Trustee and the Debtors secured lenders, only (the Notice Parties). The settlements contemplated in the Notice of Settlement would be approved without further hearing unless an objection is filed within ten (10) days of service of the Notice of Settlement. e. With respect to Avoidance Action Claims, after accounting for

New Value, in excess of $500,000.01, the Committee will submit the proposed settlements for

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approval upon the filing of a motion pursuant to Bankruptcy Rule 9019(a) to be served upon the Notice Parties. Any motion filed pursuant to Bankruptcy Rule 9019(a) may seek approval of multiple settlements in a single motion. f. In connection with any settlement of an Avoidance Action, the

Committee shall be entitled, on behalf of the Debtors and their estates, to issue releases of all claims asserted or that could have been asserted under Chapter 5 of the Bankruptcy Code. g. Notwithstanding anything to the contrary herein, in each case

wherein the Committee reaches a settlement of an Avoidance Action, the Committee shall provide notice of the material terms of such proposed settlement to the Debtors through counsel, and shall provide Debtors ten (10) calendar days to comment with respect to such proposed settlement before finalizing same. In the event Debtors raise concerns with respect to such settlement with counsel to the Committee (which concerns may be raised informally through phone call or electronic mail), the Committee shall seek to resolve such concerns consensually with Debtors and the counterparty to the particular settlement at issue. If a consensual resolution cannot be reached, the Committee shall include the particular settlement in a motion for approval pursuant to Bankruptcy Rule 9019(a). 4. Nothing herein shall obligate, nor shall be deemed to obligate, the

Committee to settle, nor to discuss the settlement of, any Avoidance Action. 5. This Court shall retain jurisdiction over all matters arising from the

interpretation or implementation of this Order. Dated: April ____, 2010 Wilmington, DE __________________________________________ UNITED STATES BANKRUPTCY JUDGE

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