1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

PORTER LAW GROUP, INC.

William L. Porter, Esq. [133968]

Hannah C. Kreuser, Esq. [322959]

7801 Folsom Boulevard, Suite 101

Sacramento, California 95826

Telephone: 916-381-7868

Facsimile: 916-381-7880

Attorneys for

HANGTOWN ELECTRIC, INC.

dba MR. ELECTRIC OF RANCHO CORDOVA

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION

-andPACIFIC GAS & ELECTRIC

COMPANY,

Debtors

Case Nos. 19-30088 (DM)

 19-30089 (DM)

Chapter 11

(Jointly Administered)

G Affects PG&E Corporation

G Affects Pacific Gas and Electric

Company

X Affects both Debtors

*All papers shall be filed in the Lead Case,

No. 19-30088(DM)

AMENDED NOTICE PURSUANT TO 11

U.S.C. § 546(b)(2) RELATED TO

PERFECTION, MAINTENANCE AND

ENFORCEMENT OF MECHANICS LIEN

CLAIMS

-1-

Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 1 of

53
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

HANGTOWN ELECTRIC, INC. dba MR. ELECTRIC OF RANCHO CORDOVA

(“HANGTOWN”), by and through its undersigned counsel, hereby amends its Notice Pursuant to

11 U.S.C. § 546(b)(2) Related to Perfection, Maintenance and Enforcement of Mechanics Lien

Claims (“Notice”), filed April 22, 2019, as Doc # 1582, to reflect a reduction in the amount it is

owed. This amended Notice (i) provides notice pursuant to 11 U.S.C. § 546(b)(2) of mechanics

liens, corresponding to secured claims, and enforcement rights it holds against property of one or

both of PG&E CORPORATION and PACIFIC GAS & ELECTRIC COMPANY (collectively

“Debtors”); and (ii) reserves all related and other rights claims and interests it may have in the

subject Chapter 11 cases. In support hereof, HANGTOWN states as follows:

Section 546(b)(2) Notice

1. HANGTOWN is a California corporation authorized to do business under the laws

of the State of California, and duly licensed by the Contractors’ State License Board to operate as

contracted for, and holding a class C10 electrical license under license number 849839.

2. In accordance with Amendment Number 8 to Agreement Between Design-Builder

and Design-Build Subcontractor (“Agreement”) dated on or about November 29, 2018, and

entered into between HANGTOWN and Roebbelen Contracting, Inc., HANGTOWN agreed to

furnish labor, services, equipment and material in connection with works of improvement to

certain real property located at 343 Sacramento Street, Auburn, CA 95603, in the County of

Placer. (“Auburn Property”). A true and correct copy of the Agreement is attached hereto as

Exhibit 1. The works of improvement were performed under contract and/or at the special

request and instance of one or more of the Debtors and with their actual or constructive

knowledge. One or more of the Debtors holds or claims an ownership interest in the Auburn

Property.

3. On or about April 16, 2018, pursuant to California Civil Code §§ 8034(a), 8102,

8106-8118, 8200 et seq., HANGTOWN served a California Preliminary Notice on Debtors.

Attached hereto as Exhibit 2 is a true and correct copy of HANGTOWN’s California Preliminary

-2-

Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 2 of

53
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

Notice. 

4. After performance under the Agreement, demand for payment, and upon

nonpayment for labor, materials, services and equipment furnished, and within the time required

by California law, HANGTOWN recorded a verified claim of mechanics lien in the office of the

County Recorder of Placer. At the time of recording the verified claim of mechanics lien, the

principal amount remaining due, owing and unpaid for its work on the Auburn Property was

$214,110.69, excluding interest, and the cost of verifying and recording the mechanics lien claim.

Attached hereto as Exhibit 3 is a true and correct copy of HANGTOWN’s mechanics lien,

recorded on or about March 21, 2019, with the Placer County Recorder’s Office. 

5. On or about April 18, 2019, HANGTOWN recorded a Partial Release of Mechanics

Lien (“Partial Release”) in the office of the County Recorder of Placer. This Partial Release

reduced HANGTOWN’s claim of mechanics lien in the amount of $2,137.00. Thus,

HANGTOWN’s verified claim of mechanics lien remains in full force and effect in the amount

of $211,973.69. Attached hereto as Exhibit 4 is a true and correct copy of HANGTOWN’s

Partial Release.

6. In accordance with a Subcontract Agreement (“Subcontract”) dated on or about

November 14, 2018, and entered into between HANGTOWN and Roebbelen Contracting, Inc.,

HANGTOWN agreed to furnish labor, services, equipment and material in connection with

works of improvement to certain real property located at 14550 Tuolumne Road, Sonora, CA

95370 in the County of Tuolumne (“Sonora Property”). A true and correct copy of the

Subcontract is attached hereto as Exhibit 5. Further work was performed at the Sonora Property

in accordance with two signed Subcontract Change Orders. True and correct copies of the

Subcontract Change Orders are attached hereto as Exhibit 6. The works of improvement were

performed under contract and/or at the special request and instance of one or more of the Debtors

and with their actual or constructive knowledge. One or more of the Debtors holds or claims an

ownership interest in the Sonora Property.

-3-

Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 3 of

53
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

7. On or about November 16, 2018, pursuant to California Civil Code §§ 8034(a),

8102, 8106-8118, 8200 et seq., HANGTOWN served a California Preliminary Notice on

Debtors. Attached hereto as Exhibit 7 is a true and correct copy of HANGTOWN’s California

Preliminary Notice. 

8. After performance under the Subcontract and Subcontract Change Orders, demand

for payment, and upon nonpayment for labor, materials, services and equipment furnished, and

within the time required by California law, HANGTOWN recorded a verified claim of mechanics

lien in the office of the County Recorder of Tuolomne. At the time of recording the verified

claim of mechanics lien, the principal amount remaining due, owing and unpaid for its work on

the Sonora Property was $46,527.96, excluding interest, and the cost of verifying and recording

the mechanics lien claim. Attached hereto as Exhibit 8 is a true and correct copy of

HANGTOWN’s mechanics lien, recorded on or about March 19, 2019, with the Tuolumne

County Recorder’s Office. 

9. In total, and prior to the January 29, 2019 petition date (“Petition Date”), the

aggregate amount owed to HANGTOWN for the labor, services, equipment and material

furnished in connection with the works of improvement described above was at least

$258,501.65, exclusive of accruing interest and other charges, with additional amounts owing

and accruing after the Petition Date (collectively, “Indebtedness”). To the date of filing of this

Notice, $258,501.65 of the Indebtedness remains outstanding and owed to HANGTOWN.

10. Under California Civil Code § 8460(a), a claimant is ordinarily required to

commence an action to enforce a mechanics lien “within 90 days after recordation of the claim of

lien.” However, at present, HANGTOWN is prevented from commencing appropriate actions to

enforce its mechanics liens in Placer and Tuolomne Counties (“Actions”) as a result of the

institution of the subject Chapter 11 cases and the application of the automatic stay of 11 U.S.C.

§ 362(a) (“Automatic Stay”). 

11. Section 546(b)(2) of the Bankruptcy Code provides in pertinent part that when

-4-

Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 4 of

53
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

applicable law requires commencement of an action to perfect, or to maintain or continue the

perfection of, an interest in property and an action has not been commenced prior to the petition

date, then such perfection, or maintenance or continuation of perfection, may be accomplished by

a claimant instead “giving notice within the time fixed by such law” for commencement of such

action.

12. Accordingly, HANGTOWN hereby provides notice that (a) it is the holder of the

verified and recorded mechanics liens, as described above, and corresponding Secured Claims to

the Auburn and Sonora Properties under California law; (b) but for the Automatic Stay it would

have timely commenced appropriate Actions pursuant to California law in Placer and Tuolomne

Counties to enforce such mechanics liens and Secured Claims; and (c) it intends in all respects to

fully perfect, maintain, preserve and continue the perfection of its mechanics liens on the Auburn

and Sonora Properties and to enforce and realize upon its corresponding Secured Claims in

accordance with the requirements of California State law, 11 U.S.C. §§ 362(a), 362(b)(3) and

546(b)(2), and any other applicable law. Without limiting the generality of the foregoing, this

notice constitutes the legal equivalent of having filed mechanics liens in the Recorders Offices of

Placer and Tuolomne Counties for the pertinent works of improvement and respective amounts

of Indebtedness, and then having commenced Actions to enforce and foreclose such mechanics

liens in the proper courts.

Reservation of Rights

13. In the interests of economy and efficiency, HANGTOWN has filed this single

Notice in the above-captioned Chapter 11 cases intending and expecting it to apply or pertain

separately and individually to (a) the continued perfection of each one of the subject mechanics

liens; (b) the Actions that otherwise would have been commenced by HANGTOWN in

accordance with California State law to maintain, enforce and realize upon its corresponding

Secured Claims; (c) HANGTOWN’s exercise of any other rights under or satisfaction of any

other requirements of 11 U.S.C. § 546(b)(2) in the circumstances. 

-5-

Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 5 of

53
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

14. HANGTOWN reserves the right to supplement, amend or otherwise alter this

Notice from time to time as may be necessary or appropriate to conform to, or to adapt to

changes in, facts or law, determinations yet to be made in the subject Chapter 11 cases or in other

proceedings, or otherwise to further the purposes of filing this Notice. Without limiting the

generality of the foregoing, HANGTOWN reserves the right if deemed necessary or appropriate

to subdivide this Notice into several notices under Section 546(b)(2) based upon each of the

mechanics liens and potential Actions thereon, to include specific or additional pre-petition or

post-petition amounts, and to state a total amount of the Indebtedness or any component thereof

that would be owed by a Debtor upon the effective date of any plan of reorganization or

liquidation, the date of any distribution or payment with respect to HANGTOWN’s Secured

Claims or any other appropriate date(s).

15. HANGTOWN reserves the right to request modification of the Automatic Stay,

determinations with respect to the validity, priority or extent of its mechanics liens and Secured

Claims, and adequate protection of, or any other relief in relation to its mechanics liens and

Secured Claims. 

16. HANGTOWN reserves the right to assert against either of the Debtors any and all

claims and interests that are not encompassed by the mechanics liens and Secured Claims,

including additional secured claims, administrative-priority claims or other claims that may have

arisen before or after the Petition Date. Also, HANGTOWN reserves any rights, claims, actions,

setoffs, or recoupments to which it is or may be entitled under contract or otherwise in law or

equity with respect to either of the Debtors or their respective assets in the subject cases. In

addition, HANGTOWN reserves any and all rights, claims, actions, and remedies it has or may

have with respect to all entities other than Debtors, and nothing herein shall be considered an

election not to pursue remedies against such entities. 

//

//

-6-

Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 6 of

53
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

Dated: April 29, 2019 PORTER LAW GROUP, INC.

By: /s/ Hannah C. Kreuser 

Hannah C. Kreuser, Esq.

Attorneys for HANGTOWN ELECTRIC, INC.

dba MR. ELECTRIC OF RANCHO

CORDOVA

R:\Production\1\1000-1999 - Porter Law Group\1100-1199\1123 Hangtown Electric\PG&E\Amended Notice of Perfection.wpd

-7-

Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 7 of

53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 8 of

53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 9 of

53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 10

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 11

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 12

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 13

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 14

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 15

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 16

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 17

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 18

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 19

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 20

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 21

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 22

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 23

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 24

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 25

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 26

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 27

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 28

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 29

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 30

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 31

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 32

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 33

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 34

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 35

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 36

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 37

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 38

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 39

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 40

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 41

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 42

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 43

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 44

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 45

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 46

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 47

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 48

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 49

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 50

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 51

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 52

of 53
Case: 19-30088 Doc# 1743 Filed: 04/29/19 Entered: 04/29/19 11:27:32 Page 53

of 53