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UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE ) ) ) ) ) ) )

In re PACIFIC ENERGY RESOURCES LTD., et al., Debtors.

Chapter 11 Case No. 09-10785 (KJC) (Jointly Administered)


Related Docket No. 190

CERTIFICATION OF NO OBJECTION REGARDING 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 AUTHORIZING THE EMPLOYMENT AND RETENTION OF PEPPER HAMILTON LLP AS DELAWARE COUNSEL TO THE COMMITTEE NUNC PRO TUNC TO MARCH 19, 2009 On April 14, 2009, the Official Committee of Unsecured Creditors (the Committee) of the above captioned debtors and debtors-in-possession filed their Application Pursuant to Fed. R. Bankr. P. 2014(a) for Order Under Sections 328(a) and 1103(a) of the Bankruptcy Code Authorizing the Employment and Retention of Pepper Hamilton LLP as Delaware Counsel to the Committee Nunc Pro Tunc to March 19, 2009 (Docket No. 190; the Application). The Notice filed with respect to the Application provided an objection deadline of 4:00 p.m. (Prevailing Eastern Time) on April 24, 2009. 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.

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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 29, 2009

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 Proposed 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: PACIFIC ENERGY RESOURCES LTD., et al. Debtors. : : : : : : :: Chapter 11
Case No. 09-10785 (KJC)

(Jointly Administered) Related Docket No. 190

ORDER AUTHORIZING EMPLOYMENT AND RETENTION OF PEPPER HAMILTON LLP AS DELAWARE COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS NUNC PRO TUNC TO MARCH 19, 2009 UPON THE APPLICATION of the Official Committee of Unsecured Creditors (the Official Committee) of the above captioned debtors and debtors-inpossession (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) authorizing the employment and retention of Pepper Hamilton LLP (Pepper Hamilton) as Delaware counsel to the Official Committee nunc pro tunc to March 19, 2009 (the Application); and upon the affidavit of David B. Stratton, a member of Pepper, in support of the Application; and this Court possessing jurisdiction to consider the Application; and venue being proper; and upon the Court finding that Pepper represents no adverse interests in connection with this case and that it is a disinterested person as that term is defined in Bankruptcy Code section 101(14), as modified by Bankruptcy Code section 1107(b); and upon further finding that the employment of Pepper Hamilton effective as of March 19, 2009 is necessary and is in the best interests of the Official Committee; and notice of the Application having been proper; and the relief requested in the Application being warranted, IT IS HEREBY ORDERED THAT:

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1. 2.

The Application is GRANTED. In accordance with Bankruptcy Code sections 328(a) and 1103(a),

the Official Committee is hereby authorized to employ Pepper Hamilton effective as of March 19, 2009. 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. This Court shall retain jurisdiction over all matters pertaining to

this Order and the Application.

Dated: ____________________, 2009 Wilmington, DE

________________________________________________ THE HONORABLE KEVIN J. CAREY UNITED STATES BANKRUPTCY JUDGE

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