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SALLY J. ELKINGTON - SBN 142619 

JAMES A. SHEPHERD - SBN 264400

ELKINGTON SHEPHERD LLP 

Historic Tribune Tower 

409 - 13th Street, 10th Floor, 

Oakland, CA 94612

tel (510) 465-0404 

fax (510) 465-0202

email: jim@elkshep.com

Attorneys for Creditor-Lienholder

W. BRADLEY ELECTRIC, INC.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re 

PG&E CORPORATION, INC,

Debtor in Possession. __________________________________

In re 

PACIFIC GAS AND ELECTRIC

COMPANY,

Debtor in Possession.

9 Affects PG&E Corporation

: Affects Pacific Gas and Electric

Company

9 Affects both Debtors

* All papers shall be filed in the Lead

Case, No. 19-30088 (DM)

__________________________________

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Chapter 11

Case No. 19-30088 (DM)

(Lead Case)

(Jointly Administered)

NOTICE OF CONTINUED

PERFECTION OF MECHANICS

LIENS UNDER 11 U.S.C. § 546(b)(2);

CERTIFICATE OF SERVICE

NOTICE IS HEREBY GIVEN that W. BRADLEY ELECTRIC, INC. (“WBE”), 

a sub-contractor under certain pre-petition subcontracts (collectively, the “WBE Subcontracts”)

with Roebbelen Contracting, Inc., Seegert Construction and CB2 Builders, Inc., respectively,

which entities are or were general contractors under certain related general contract agreements

with Pacific Gas and Electric Company (“PG&E”), including but not limited to PG&E’s

agreements with the respective referenced general contractors as specified in Schedule G in this

case [Docket No. 907], as such subcontracts and general contracts may have been amended and

Case: 19-30088 Doc# 1664 Filed: 04/24/19 Entered: 04/24/19 22:23:40 Page 1 of

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restated or otherwise modified or supplemented from time to time. Under the WBE

Subcontracts, WBE provided certain electrical, HVAC, architectural support and engineering,

design, survey, sitework, interior upgrades related services at PG&E facilities and properties

throughout Northern California (collectively, the “Properties”) to the benefit of PG&E. Under

certain of the WBE Subcontracts, in accordance with California law WBE had filed mechanics

liens attaching to the Properties as of January 29, 2019, PG&E’s Chapter 11 petition filing date. 

Pursuant to California Civil Code § 8460, an action to enforce a mechanics lien must be

commenced within 90 days after recordation of the claim of lien. However, due to the automatic

stay herein, WBE is precluded from filing a state court action to enforce its liens. Under 11

U.S.C. § 546(b )(2), when applicable law requires seizure of property or commencement of an

action to perfect, maintain or continue the perfection of an interest in property, and the property

has not been seized or an action has not been commenced before the bankruptcy petition date,

the claimant shall instead file a notice in bankruptcy court within the time fixed by law for

seizing the property or commencing an action. 11 U.S.C. § 546(b )(2); see also In re Baldwin

Builders, 232 B.R. 406, 410-411 (9th Cir. 1999); Village Nurseries v. Greenbaum, 101

Cal.App. 4th 26, 41 (2002).

Under California Civ. Code §§ 8050(a) and 8412, WBE is entitled to assert and hereby

does assert its lien rights and under 11 U.S.C. § 546(b) and gives this Notice in lieu of the

commencement of any action to perfect, maintain or continue WBE’s liens. WBE requests

adequate protection of said liens. True and correct copies of each of WBE’s liens, recorded and

filed against the Properties in each respective California county, are attached hereto as

EXHIBIT A and further identified therein as Exhibit A-1 thru Exhibit A-12, together with a

summary of said liens. The outstanding amount due under these 12 liened projects currently

totals not less than $319,813.03 (altogether, the “WBE Liens”).

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Case: 19-30088 Doc# 1664 Filed: 04/24/19 Entered: 04/24/19 22:23:40 Page 2 of - 2 -

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WHEREFORE, WBE asserts secured interests in the Properties as reflected by the WBE

Liens to the fullest extent allowed by applicable law, including interest and attorneys’ fees.

Further, WBE reserves all rights to supplement and/or amend this Notice, and reserves any and

all other rights under applicable law.

DATED: April 24, 2019 ELKINGTON SHEPHERD LLP 

By: /s/ James A. Shepherd 

 Attorneys for Creditor-Lienholder 

 W. BRADLEY ELECTRIC, INC.

CERTIFICATE OF SERVICE

I, James A. Shepherd, state that I am over the age of eighteen years and not a party to the 

within action; that my business address is Elkington Shepherd LLP, 409 - 13th Street, 10th

Floor, Oakland, CA 94612; and that on the date below, I caused to be served a true copy of the

within court-filed

NOTICE OF CONTINUED PERFECTION OF MECHANICS

LIENS UNDER 11 U.S.C. § 546(b)(2); CERTIFICATE OF SERVICE (including

Exhibit A thereto),

electronically through the court’s ECF system on parties entitled to electronic notice in this case

in accordance with applicable law.

Executed at Walnut Creek, California on April 24, 2019. I declare under penalty of

perjury under the laws of the United States that the foregoing is true and correct.

 /s/ James A. Shepherd 

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