Professional Documents
Culture Documents
In Re:) : Debtors.)
In Re:) : Debtors.)
In Re:) : Debtors.)
In re: )
STATE OF ALASKA )
) ss:
Chapter 11
Debtors. ))
I, Michael Jungreis, hereby declare that the following is true to the best of
captioned debtors and debtors in possession (the "Debtors") to retain certain professionals in the ordinary course of business during the pendency of the Debtors' chapter 11 cases (the "Chapter
11 Cases").
i The Debtors in these cases, along with the last four digits of each of the Debtor's federal tax identification
number, are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska
Holdings, LLC (tax J.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 the Debtors is 111 W. Ocean Boulevard, Suite 1240, Long Beach, CA 90208. mailing address for all of
advised the Debtors as attorneys with respect to regulatory approval of acquisition of stock of
Cook Inlet Pipeline and other issues regarding Cook Inlet Pipeline, unitization and leasing issues
with respect to Cook Inlet oil and gas leases, the Forest OillUnocallawsuit regarding Trading
Bay, Alaska unit expenses pending in US District Court in Alaska, the Debtors' lawsuits against
the State of Alaska's Deparent of
case numbers 3AN-09-04145 CI and 3AN-09-05250 CI, and miscellaneous Alaska law issues,
title 11 of
the United
States Code (the "Bankruptcy Code") with respect to such matters. Additionally, the Debtors
have requested, and the Firm proposes to render, the following services to the Debtors: (Insert
description J.
5. The Firm's curent customary (hourly) rates, subject to change from time
to time, are $295 for Andrew Hoge, $275 for me, and $175 and $165 for associates.
In the normal course of
business, the Firm revises its regular (hourly) rates on January 1 of each
year and requests that, effective Januar i of each year, the aforementioned rates be revised to
of
employed by the Offce of the United States Trustee with respect to the matters upon which it is
to be engaged, and the Firm does not, by reason of any direct or indirect relationship to,
connection with, or interest in the Debtors, hold or represent any interest adverse to the Debtors,
their estates or any class of creditors or equity interest holders, except (list in detail).
7. Thus, I believe that the Firm's representation of such entities in matters
entirely unrelated to the Debtors is not adverse to the Debtors' interests, or the interests of
their
creditors or estates in respect ofthe matters for which the Finn wil be engaged, nor wil such
services impair the Firm's abilty to represent the Debtors in the ordinary course in these
Chapter 1 i Cases.
8. In addition, although unascertainable at this time after due inquiry, due to
the magnitude of the Debtors' potential universe of creditors and the Firm's clients, the Firm
may have in the past represented, currently represent, and may in the future represent entities that
are claimants ofthe Debtors in matters entirely unrelated to the Debtors and their estates. The
Firm does not and wil not represent any such entity in connection with these pending Chapter i 1
Cases and does not have any relationship with any such entity, attorneys or accountants that
biled or that have been biled but with respect to which payment has not yet been received, but
the foregoing, I believe that the Firm does not hold or represent
any interest materially adverse to the Debtors, their estates, creditors, or equity interest holders,
as identified to the Firm, with respect to the matters in which the firm wil be engaged.
1 1. Except as set forth herein, no promises have been received by the Firm or .
any partner, associate or other professional thereof as to compensation in connection with these
Chapter 11 Cases other than in accordance with the provisions of the Bankrptcy Code, the
Federal Rules of Bankptcy Procedure, the Local Rules of
of
this Court.
12. The Firm further states that it has not shared, nor agreed to share any
compensation received in connection with these Chapter 11 Cases with another party or person,
other than as permitted by section 504(b) ofthe Banruptcy Code and Bankruptcy Rule 2016.
13. To the extent that the Debtors and the Firm are party to an engagement
The foregoing constitutes the statement of the Finn pursuant to sections 329 and
504 of the Banptcy Code and Federal Rules of
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
,,\~~\ ~
'"
SUBSCRIBED AND SWORN TO before me, a notary public for the state of Alaska, this twenty fourth day of April, 2009.
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In re: )
STATE OF DELAWARE )
) ss:
Debtors. )
AFFIDAVIT OF SERVICE
Pachulski Stang Ziehl & Jones LLP, attorneys for the Debtors in
the above-captioned action, and that on the 28th day of April, 2009 she caused a copy of the
following document(s) to be served upon the paries on the attached service lists in the maner
indicated:
Disclosure Affidavit of Ordinary Course Professional - Michael Jungreis of Hartig Rhodes Hoge & Lekisch, P.e.
~~)f'4~
Kat n Forte Finlayso
DEBRA L. YOUNG NOTARY PUBLIC
STATE OF DELAWARE
My coission expires July 18, 20
Notary Public
Commission Exp.:
DOCS_DE:147542.1
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 mailng address for all of
12 - Hand Delivery
38 - First Class Mail 02 - FOREIGN First Class Mail
Hand Delivery (United States Attorney) Ellen W. Slights, Esq. United States Attorney's Offce District of Delaware
1007 N. Orange Street, Suite 700
Wilmington, DE 19801
Hand Delivery (Counsel for Silver Point Finance) Ian S. Fredericks, Esquire Skadden Ars, Slate, Meagher & Flom LLP One Rodney Square P.O. Box 636 Wilmington, DE 19899
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
Interoffice 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., 11 th Floor
Hand Delivery (Counsel for J. Aron & Company) Don A. Beskrone, Esquire Amanda M. Winfree, Esquire Ashby & Geddes, P.A.
500 Delaware Avenue, 8th Floor
Wilmington, DE 19899
Hand Delivery (Counsel for Union Oil Company of California, a California Corporation) Norman M. Monhait, Esquire
Rosenthal, Monhait & Goddess, P A
Citzens Bank Center, Suite l401 919 Market Street, P.O. Box 1070 Wilmington, DE 19899
Hand Delivery (Counsel for Westchester Fire Insurance Company and Noble Energy Inc.) Tobey M. Daluz, Esquire Joshua E. Zugerman, Esquire Ballard Spahr Andrews & Ingersoll, LLP
919 N. Market Street, 12th Floor
Wilmington, DE 19801
Hand Delivery (Copy Service)
Parcels, Inc.
Wilmington, DE 19801
Hand Delivery (Counsel for Oxy Long Beach Inc.) David L. Finger, Esquire
Finder, Slanina Liebesman, LLC
Creditors) David B. Stratton, Esquire James C. Carignan, Esquire Pepper Hamilton LLP
Hercules Plaza, Suite 1500
Hand Delivery (Counsel for Marathon Oil Company) Kevin J. Mangan, Esquire Womble Carlyle Sandridge & Rice, PLLC 222 Delaware Avenue, Suite 1501 Wilmington, DE 19801 Hand Delivery (Counsel for Cook Inlet Region, Inc.) Eric Lopez Schnabel, Esquire Dorsey & Whitney (Delaware) LLP
1105 North Market Street, Suite 16th Floor
Wilmington, DE 19801
Hand Delivery (Counsel for Area Energy LLC) Norman L. Pernick, Esquire Karen M. McKinley, Esquire Cole, Schotz, Meisel, Forman & Leonard, P.A. 500 Delaware Avenue, Suite 1410 Wilmington, DE 19801
District Director Internal Revenue Service 31 Hopkins Plaza, Room 1150 Baltimore, MD 21201
Houston, TX 77067
Washington, DC 20554
(Counsel for Union Oil Company of California, a California Corporation) Cabot Christianson, Esquire Christianson & Spraker
911 West 8th Avenue, Suite 201
Anchorage, AK 99501
Bankptcy Coordinator
MMS / Denver Federal Center POBox 25165 Mail Stop 370B2 Denver, CO 80225
Philadelphia, P A 19103
John 1. Haris, Esquire Rachel M. Feiertag, Esquire Meyers, Nave, Riback, Silver & Wilson 333 South Grand Avenue, Suite 1670 Los Angeles, CA 90071
Baltimore, MD 21209
Greenwich, CT 06830
E. Kathleen Shahan, Esquire U.S. Department of Justice 1100 L Street, NW Washington, D.C. 20005
Creditors)
Filberto Agusti, Esquire
(Counsel for Aera Energy LLC) Steven E. Rich, Esquire Mayer Brown LLP
350 South Grand Avenue, 25th Floor
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
Manager, Listed Issuer Services Toronto Stock Exchange 300 Fifth Avenue SA, 10th Floor Calgary, AB T2P 3C4
Anchorage, AK 99501
the Americas
Martin A. Mooney, Esquire Deily, Mooney & Glastetter, LLP 8 Thurlow Terrace Albany, NY 12203