IN THE UNITED STATES BANUPTCY COURT

In re: )

FOR THE DISTRICT OF DELAWAR

Chapter 11

PACIFIC ENERGY RESOURCES LTD., et a!., 1 )

Case No. 09-10785(KC)

(J ointly Administered)
Related Docket No. 456, 884, 902, 903

Debtors. ))

CERTIFICATION OF COUNSEL WITH RESPECT TO ORDER DENYING (I) EMERGENCY MOTION OF DANIEL K DONKEL FOR RECONSIDERATION TO STAY THE EFFECTIVE DATE FOR THE ABANDONMENT ORDER AND (II) EMERGENCY MOTION FOR IMMEDIATE APPROVAL OF SALE OF DEBTORS' WEST FORELAND LEASE TO DONKEL OIL & GAS, LLC OR IN THE ALTERNATIVE TO ENJOIN THE SHUTTING IN OF WEST FORELAND WELL NO.1 PENDING APPROVAL OF THE SALE
On June 16,2009, Pacific Energy Resources, et al. (the "Debtors") fied the
Alternative Motion of the Debtors for an Order Authorizing Abandonment 0/ Certain Interests in
Oil and Gas Properties in Alaska (Excluding Trading Bay) and Rejection 0/ Executory Contracts

Relating Thereto (Docket No. 456) (the "Motion").

Certain objections to the Motion were filed (the "Objections") and, on September
11,2009, after consideration of

the Objections and upon the record at the September 11, 2009

hearing, the Cour entered the Order Granting Alternative Motion o/the Debtors/or an Order
Authorizing Abandonment of Certain Interests in Oil and Gas Properties in Alaska(Excluding

Trading Bay) and Rejection 0/ Executory Contracts Relating Thereto (the "Order") (Docket No.
876).

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 J.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operating LLC (7021); San Pedro Bay Pipeline Company the Debtors is III W. Ocean (1234); Cameros Energy, Inc. (9487); and Gotland Oil, Inc. (5463). The mailing address for all of Boulevard, Suite 1240, Long Beach, CA 90802.

DOCS_DE:

153381.

On September 14,2009 Daniel K. Donkel fied the (Emergency) Motionfor

Reconsideration of the Stay Effective Date for the Abandonment Order (the "Emergency

Motion") (Docket No. 884) and on September 18, 2009 the Debtors filed their Objection to
Motion of Daniel K. Donkelfor Reconsideration of the

Abandonment Order ("Debtors'

Obj ection").

A hearng on the Emergency Motion was held September 18, 2009 (the
"Hearing") and the Court considered of

the Emergency Motion, the Debtors' Objection thereto

and another motion fied by Mr. Donkel, the Emergency Motion for Immediate Approval of Sale
of Debtors' West Foreland Lease to Donkel Oil & Gas, LLC or in the Alternative to Enjoin the

Shutting In of West Foreland Well No.1 Pending Approval of the Sale, (the "Second Emergency

Motion").
At the conclusion of

Hearing, the Court ruled on both the Emergency Motion and

the Second Emergency Motion. Attached is a proposed form of Order Denying (I) Emergency
Motion of Daniel K. Donkel for Reconsideration to Stay the Effective Date for the Abandonment
Order and (II) Emergency Motion for Immediate Approval of Sale of

Debtors' West Foreland

Lease to Donkel Oil & Gas, LLC or in the Alternative to Enjoin the Shutting In of West Foreland
Well No.1 Pending Approval of

the Sale (the "Proposed Order") reflecting the Cour's rulings at

the Hearng.
A copy ofthe Proposed Order was circulated to Mr. Donkel and his counsel. On
September 23,2009, counsel for Donkel Oil & Gas LLC contacted counsel for the Debtors to
indicate that they may wish to make changes to the Proposed Order based on a possible

DOCS_DE:153381.

transaction. Given the current state of

matters, the Debtors indicated that they would proceed

with submission of

the Proposed Order in its curent form.

The Debtors respectfully request that the Court enter the attached form of

Proposed Order at its earliest convenience. Should the Court have any questions regarding the Proposed Order, the Debtors
stand ready to respond.
Dated: September 23, 2009

PACHULSKI STANG ZIEHL & JONES LLP

. Kharasch (CA Bar No. 109084) otta E. McFarland (DE Bar No. 4184, CA Bar No. 165391) Robert M. Saunders (CA Bar No. 226172) James E. O'Neill (DE Bar No. 4042) Kathleen P. Makowski (DE Bar No. 3648) 919 North Market Street, 1 ih Floor P.O. Box 8705 Wilmington, DE 19899-8705
Telephone: 302/652-4100

Facsimile: 310/652-4400
Email: ikharaschpszjlaw.com

smcfarlandpszjlaw.com rsaunderspszjlaw.com joneillpszjlaw.com kmakowskipszjlaw.com

Counsel for Debtor and Debtor in Possession Pacific Energy Resources Ltd.

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153381.2

EXHIBIT A

Ii

IN THE UNITED STATES BANUPTCY COURT

In re: )
AN NOW, upon consideration of

FOR THE DISTRICT OF DELAWAR

Chapter 11

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

Debtors. ))

Case No. 09- 10785(KC) (Jointly Administered) Related Docket Nos. 884, 902, 903

ORDER DENYING (I) EMERGENCY MOTION OF DANIEL K DONKEL FOR RECONSIDERATION TO STAY THE EFFECTIVE DATE FOR THE ABANDONMENT ORDER AND (II) EMERGENCY MOTION FOR IMMEDIATE APPROVAL OF SALE OF DEBTORS' WEST FORELAND LEASE TO DONKEL OIL & GAS, LLC OR IN THE ALTERNATIVE TO ENJOIN THE SHUTTING IN OF WEST FORELAND WELL NO.1 PENDING APPROVAL OF THE SALE
the Emergency Motion of

Daniel K. Donkel

for Reconsideration to Stay the Effective Date for the Abandonment Order (the "Reconsideration
Motion") and the Emergency Motion For Imediate Approval of Sale of

Debtors' West Foreland

Lease to Donkel Oil Gas, LLC or in the Alternative to Enjoin the Shutting in of

West Foreland
the

Well No.1 Pending Approval of

the Sale (together, the "Motions") and upon consideration of

Debtors' Objection to the Reconsideration Motion and upon consideration ofthe arguents

made by the parties at the hearng on the Motions (the "Hearng"); and after due deliberation; it
is hereby

ORDERED that the Motions are denied for the reasons stated on the record at the

Hearing; and it is fuher

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 J.D. # not available); Cameros Acquisition Corp. (5866); Pacific Energy Alaska Operatig LLC (7021); San Pedro Bay Pipeline Company (1234); 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.

68773-00

\DOCS DE:153275.1

This Cour shall retain jursdiction to hear and determine all matters arising from
or related to the implementation of

this Order.

Dated:

,2009
The Honorable Kevin J. Carey
Chief

United States Banptcy Judge

68773-001 \DOCS_DE: 1 53275. 1