IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
) )
)
Chapter 11
PACIFIC ENERGY RESOURCES LTD., et al., 1
[Link] 10,2009 at 10:30 a.m. prevailng Eastern time )) Hearing Date:
NOTICE OF HEARING ON FIRST DAY MOTIONS
PLEASE TAKE NOTICE that on March 9, 2009, the captioned debtors and debtors in
Case No. 09-10785(KJC) (Jointly Administered)
possession herein (collectively, the "Debtors") fied voluntar petitions for relIefunder chapter
11 oftitle 11 ofthe United States Code (the "Banptcy Code") with the Clerk of
the United
States Banptcy Cour for the District of Delaware. The Debtors are continuing to operate
their businesses and manage their affairs as debtors and debtors in possession pursuant to
sections 1107(a) and 1108 of
the Banptcy Code.
PLEASE TAKE FURTHER NOTICE that the Debtors wil present the Motions set
forth below at a hearing on March 10, 2009 at 10:30 a.m. prevailng Eastern time before the
Honorable Kevin J. Carey, at the United States Bankptcy Cour for the District of
Delaware,
located at 824 Market Street, 5th Floor, Courroom No.5, Wilmington, Delaware 19801.
First Dav Administrative Motions
1. Debtors' Motion For Order Directing Joint Administration Of
Related Chapter 11 Cases.
(Docket No.3 filed 03/10/09)
the Debtors' federal tax identification number, are: Pacific Energy Resources Ltd. (3442); Petrocal Acquisition Corp. (6249); Pacific Energy Alaska
1 The Debtors in these cases, along with the last four digits of each of
Holdings, LLC (tax LD. # 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 ILL W. Ocean Boulevard, Suite 1240, Long Beach, CA 90802. mailng address for all of
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2. Application of
Debtors Pursuant to 28 U.S.c. 156(c) and Local Rule 2002-1 (F) for Authorization to (1) Employ and Retain Omni Management Group, LLC as Claims, Balloting, Noticing and Administrative Agent for the Debtors and (2) Appoint Omni Management Group, LLC as Agent of the Banptcy Cour Nunc Pro Tunc to the Petition Date. (Docket No.4 filed 03/9/09)
First-Dav Motions Pertainine to Business Operations
3. Motion Of
Debtors For Order Under Banptcy Code Sections 105,345,363,364, Existing Ban Accounts, (II) 503(b), 1107 And 1108 Authorizing (I) Maintenance Of Existing Cash Existing Business Forms, (III) Continued Use Of Continued Use Of Management System, (IV) Providing Administrative Priority Status To Postpetition Intercompany Claims, And (V) Waiver Of Section 345(b) Deposit And Investment
Requirements. (Docket No.9 fied 03/9/09)
4. Debtors' Motion Pursuant To Banptcy Code Sections 105(a), 363, And 507(a) For An
Order Authorizing The Debtors To (I) Pay Prepetition Wages, Salaries, Employee Benefits, And Other Compensation; (II) Remit Withholding Obligations; (III) Maintain Employee Compensation And Benefits Programs And Pay Related Administrative OblIgations; And (IV) Have Applicable Bans And Other Financial Institutions Receive, Process, Honor, And Pay Certain Checks Presented For Payment And Honor Certain Fund Transfer Requests. (Docket No. 10 fied 03/9/09)
5. Motion Of
The Debtors For An Order (I) Authorizing The Debtors To Pay Certain Prepetition Taxes And Regulatory Fees In The Ordinar Course Of Business And (II) Authorizing Bans And Financial Institutions To Honor And Process Checks And Transfers Related Thereto. (Docket No. 11 fied 03/9/09)
The Debtors For An Order Under Section 366 Of
6. Motion Of
The Banptcy Code (A)
Futue Performance, And (C)
Prohibiting Utility Providers From Altering, Refusing, Or Discontinuing Service, (B)
Deeming Utility Providers Adequately Assured Of
EstablIshing Procedures For Determining Adequate Assurance Of Payment. (Docket No.
12 fied 03/9/09)
7. Debtors' Motion For An Order Authorizing, But Not Requiring, The Payment Of
Prepetition Claims Of
Critical Vendors. (Docket No. 13 filed 03/9/09)
8. Debtors' Motion For Interim And Final Orders EstablIshing Procedures And Restrictions
On Claims And Equity Transfers. (Docket No. 14 fied 03/9/09)
9. Debtors' Emergency Motion For Authority To Pay Or Honor Prepetition And
Postpetition OblIgations To Royalty Interest. (Docket No. 15 filed 03/9/09)
10. Motion Of
Debtors For An Order Granting Debtors The Authority To (1) Make Payments Pursuant To A Prepetition Insurance Premium Financing Agreement, (2) Enter Into New
68773-001 \DOCS_LA: 198192.1
Premium Financing Agreements And Pay Related Brokers Fees. (Docket No. 16 filed 03/9/09)
First-Day Motions Pertainine to Financine
11. Motion to Approve Interim and Final Orders Pursuant to 11 U.S.C. 105,361,362,
363,364,365 and 507: (1) Approving Senior Secured Superpriority Postpetition
Financing; (2) Authorizing Use of Cash Collateral; (3) Granting Liens and Providing Superpriority Administrative Expense Status; (4) Granting Adequate Protection; (5) Modifying Automatic Stay; and (6) SchedulIng a Final Hearng. (Docket No. 18 fied 03/9/09)
Copies ofthe above-noted Motions can be obtained through the United States Banptcy Cour's website at [Link], referencing Case No. 09-10785, or from the
undersigned Debtors' proposed counseL.
Dated: March , 2009
P ACHULSKI STANG ZIEHL & JONES LLP
(Proposed) Counsel for Debtor and Debtor in Possession Pacific Energy Resources Ltd.
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