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#52868505 v2

Francis J. Lawall (admitted pro hac vice)

Pepper Hamilton LLP

3000 Two Logan Square

18th and Arch Streets

Philadelphia, PA 19103-2799

Telephone: (215) 981-4481

Fax: (215) 981-4750

E-mail: lawallf@pepperlaw.com

Counsel for HydroChemPSC

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION and

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors. 

□ Affects PG& E Corporation

□ Affects Pacific Gas and Electric Company

■ Affects both Debtors

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM)

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 (Lead Case) (Jointly 

Administered)

NOTICE PURSUANT TO 11 U.S.C. 

§ 546(b)(2) RELATED TO PERFECTION,

MAINTENANCE AND ENFORCEMENT

OF MECHANICS LIEN CLAIMS

HYDROCHEM’S NOTICE OF PERFECTION, MAINTENANCE AND ENFORCEMENT 

OF MECHANICS LIEN CLAIMS PURSUANT TO

BANKRUPTCY CODE SECTION 546(b)(2)

PLEASE TAKE NOTICE THAT pursuant to section 546(b)(2) of title 11 of the United 

States Code (11 U.S.C. §§ 101 et seq., the “Bankruptcy Code”), HydroChemPSC, Hydrochem, 

LLC and other affiliated entities (collectively the “HydroChem Entities”) hereby provide notice 

of mechanics liens, corresponding secured claims, and enforcement rights held one or more of the

HydroChem Entities against property of one or both of the above-referenced debtors (the 

Case: 19-30088 Doc# 1640 Filed: 04/24/19 Entered: 04/24/19 09:01:34 Page 1 of

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#52868505 v2

“Debtors”) and (ii) reserve all related and other rights, claims and interests they may have in the 

subject Chapter 11 cases. 

PLEASE TAKE FURTHER NOTICE THAT one or more of the HydroChem Entities 

filed certain lien statements (the “Lien Statements”) reflecting properly recorded and perfected 

mechanics liens against certain property owned by one or both of the Debtors. True and correct 

copies of the Lien Statements are attached hereto as Exhibit A.

PLEASE TAKE FURTHER NOTICE THAT pursuant to and consistent with 

Bankruptcy Code sections 362(b)(3) and 546(b)(1), one or more of the HydroChem Entities filed 

the Lien Statements and hereby give notice of their lien interest in all of the property that is 

subject to the liens, its corresponding secured claims, and its enforcement rights against the 

property, within the time fixed by California law for the commencement of an action to enforce 

its mechanics lien rights. The HydroChem Entities have filed this single Notice in the abovecaptioned Chapter 11 cases intending it to apply or pertain separately and individually to (a) the 

continued perfection of each and every one of the subject liens set forth in the Lien Statements, 

(b) the actions that otherwise would have been commenced by one or more of the HydroChem

Entities in accordance with California state law to maintain, enforce and realize upon their 

corresponding secured claims and (c) the HydroChem Entities’ exercise of any other rights under 

or satisfaction of any other requirements of Bankruptcy Code section 546(b)(2) in the 

circumstances. The HydroChem Entities reserve all of their rights under applicable state and 

federal law. 

Dated: April 24, 2019 Pepper Hamilton LLP

/s/ Francis J. Lawall

Francis J. Lawall, Esquire

Pepper Hamilton, LLP

3000 Two Logan Square

18th & Arch Streets

Philadelphia, PA 19103-2799

Telephone: (215) 981-4451

Facsimile: (215) 981-4750

Email: lawallf@pepperlaw.com

Counsel for the HydroChem Entities

Case: 19-30088 Doc# 1640 Filed: 04/24/19 Entered: 04/24/19 09:01:34 Page 2 of

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