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ROEBBELEN CONTRACTING, INC.’S SECOND NOTICE OF CONTINUED PERFECTION OF 

MECHANICS LIENS PURSUANT TO 11 U.S.C. § 546(b)(2) 1/3

Stephen D. Finestone (125675)

Jennifer C. Hayes (197252)

Ryan A. Witthans (301432)

FINESTONE HAYES LLP

456 Montgomery Street, Floor 20

San Francisco, CA 94104

Telephone: (415) 616-0466

Facsimile: (415) 398-2820

Email: sfinestone@fhlawllp.com

Email: jhayes@fhlawllp.com

Email: rwitthans@fhlawllp.com

Attorneys for Creditor

Roebbelen Contracting, Inc.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E Corporation,

Debtor-in-Possession.

Case No. 19-30088-DM

Chapter 11

Hon. Dennis Montali

In re

Pacific Gas and Electric Company,

Debtor-in-Possession.

Case No. 19-30089-DM

Chapter 11

Hon. Dennis Montali

 Affects PG&E Corporation

 Affects Pacific Gas & Electric Company

 Affects both Debtors

ROEBBELEN CONTRACTING, INC.’S 

SECOND NOTICE OF CONTINUED 

PERFECTION OF MECHANICS LIENS 

PURSUANT TO 11 U.S.C. § 546(b)(2)

Roebbelen Contracting, Inc. (“Roebbelen”) hereby files its Second Notice of Continued 

Perfection of Mechanics’ Liens Pursuant to 11 U.S.C. § 546(b)(2) (the “Notice”) and in support 

thereof states as follows:

Case: 19-30088 Doc# 2073 Filed: 05/17/19 Entered: 05/17/19 15:12:07 Page 1 of

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ROEBBELEN CONTRACTING, INC.’S SECOND NOTICE OF CONTINUED PERFECTION OF 

MECHANICS LIENS PURSUANT TO 11 U.S.C. § 546(b)(2) 2/3

1. On January 29, 2019 (the “Petition Date”), the above-captioned debtors (the 

“Debtors”) filed voluntary Chapter 11 bankruptcy petitions.

2. As of the Petition Date, Roebbelen had approximately 80 projects under 

construction in support of the Debtors’ strategic initiatives of safety, reliability, affordability, and 

consumer focus. The improvements performed by Roebbelen are designed to result in quicker 

response times, improved vehicle maintenance, better logistics for replacement materials, hazardous 

materials storage, and improvements to dispatch conference centers, including solutions for 

mapping, tracking outages, and safety trainings. Roebbelen’s work also relates to a security program 

for these same facilities, which Roebbelen is informed and believes have been identified by the 

Department of Homeland Security as known targets, including upgrading their fencing and security 

systems to meet improved security standards.

3. Before and after the Petition Date, Roebbelen has provided labor, services, 

equipment, and materials for works of improvement owned by Pacific Gas & Electric Company 

located in the following counties, all of which are located in the State of California: Contra Costa, 

Humboldt, Marin, Mendocino, Merced, Monterey, Placer, Sacramento, San Benito, San Francisco, 

San Joaquin, San Mateo, and Solano. Roebbelen has lien rights (collectively the “February 2019 

Liens”) related to these works of improvement. See Cal. Civ. Code § 8050(a) (defining works of 

improvement). Roebbelen has also filed partial releases reflecting downward adjustments to some of 

the amounts originally claimed in the February 2019 Liens.

4. Through May 16, 2019, the amounts owing to Roebbelen on account of the 

February 2019 Liens is at least $1,447,728.64, not including interest and other charges, with 

additional amounts accrued and owed after May 16, 2019.

5. Roebbelen properly perfected its February 2019 Liens pursuant to California Civil 

Code §§ 8400 et. seq. by timely recording its liens in the above-named counties. See Cal. Civ. Code 

§ 8412 (establishing deadlines for contractor to record lien claims). An index of the February 2019 

Case: 19-30088 Doc# 2073 Filed: 05/17/19 Entered: 05/17/19 15:12:07 Page 2 of

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ROEBBELEN CONTRACTING, INC.’S SECOND NOTICE OF CONTINUED PERFECTION OF 

MECHANICS LIENS PURSUANT TO 11 U.S.C. § 546(b)(2) 3/3

Liens is attached as Exhibit A and authentic copies of the February 2019 Liens are attached as 

Exhibit B to this Notice.1

6. Pursuant to California Civil Code § 8460, an action to enforce a lien must be filed 

within 90 days after recordation of the lien. The automatic stay imposed by 11 U.S.C. § 362(a) 

precludes Roebbelen from filing an action to enforce its February 2019 Liens. When applicable law 

requires commencement of an action to perfect, maintain, or continue the perfection of an interest 

in property, and the action was not filed prior to the bankruptcy petition date, then the claimant 

must instead give notice within the time fixed by law for filing the action. 11 U.S.C. § 546(b); Village 

Nurseries v. Gould (In re Baldwin Builders), 232 B.R. 406, 410–15 (B.A.P. 9th Cir. 1999); see Village 

Nurseries v. Greenbaum, 101 Cal. App. 4th 26 (2002).

7. Roebbelen hereby provides notice of its rights as a perfected lienholder pursuant to 

California’s law as to the February 2019 Liens. To comply with all applicable law, including 

California state law and bankruptcy law, 11 U.S.C. §§ 362(a), 362(b)(3), and 546(b)(2), Roebbelen is 

filing and serving this Notice to preserve, perfect, maintain, and continue the perfection of its 

February 2019 Liens and its lien rights in the properties identified therein. This Notice constitutes 

the legal equivalent of having commenced an action to foreclose the February 2019 Liens in the 

proper court. Roebbelen intends to enforce its lien rights to the fullest extent permitted by law. The 

interests perfected, maintained, and/or continued by the February 2019 Liens extend to the 

proceeds, products, rents, and profits of the liened properties.

8. Roebbelen reserves all rights, including the right to amend or supplement this 

Notice.

Dated May 17, 2019 FINESTONE HAYES LLP

/s/ Ryan A. Witthans

Ryan A. Witthans

Counsel for Creditor

Roebbelen Contracting, Inc.

 1 To the extent that there is a discrepancy between this Notice, the index attached as Exhibit 

A, and the recorded liens attached as Exhibit B, the recorded lien documents shall control. 

Roebbelen reserves the right to modify the liens, such as to increase or decrease the amount.

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