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Stephen D. Finestone (125675)

Jennifer C. Hayes (197252)

Ryan A. Witthans (301432)

FINESTONE HAYES LLP

456 Montgomery Street, 20th Floor

San Francisco, California 94104

Telephone: (415) 616-0466

Facsimile: (415) 398-2820

sfinestone@fhlawllp.com

jhayes@fhlawllp.com

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 

NOTICE OF CONTINUED PERFECTION 

OF MECHANIC’S LIEN PURSUANT TO 

11 U.S.C. § 546(b)(2)

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

of Mechanic’s Lien Pursuant to 11 U.S.C. § 546(b)(2) (the “Notice”) and in support thereof states 

as follows:

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

filed voluntary Chapter 11 bankruptcy petitions.

Case: 19-30088 Doc# 1853 Filed: 05/06/19 Entered: 05/06/19 11:31:46 Page 1 of

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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.

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 El 

Dorado County, California (among others). Roebbelen has lien rights related to these works of 

improvement (the “Lien”). See Cal. Civ. Code § 8050(a) (defining works of improvement).

Through May 3, 2019, the amount owing to Roebbelen on account of the Lien is at least 

$16,376.36, not including interest and other charges.

Roebbelen properly perfected the Lien pursuant to California Civil Code §§ 8400 et. seq.

by timely recording it in the above-named county. See Cal. Civ. Code § 8412 (establishing 

deadlines for contractor to record lien claims). An authentic copy of the Lien is attached to this 

Notice as Exhibit A.

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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 mechanic’s 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 (9th Cir. BAP 1999); see Village 

 1 To the extent that there is a discrepancy as to any of the information contained within this 

Notice, the attached recorded lien documents shall control. Roebbelen reserves the right to 

modify the Lien, such as to increase or decrease the amount.

Case: 19-30088 Doc# 1853 Filed: 05/06/19 Entered: 05/06/19 11:31:46 Page 2 of

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

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

California’s mechanic’s lien law as to the Lien. 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 

Lien and its lien rights in the properties identified therein. This Notice constitutes the legal 

equivalent of having commenced an action to foreclose the Lien 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 Lien extend to the proceeds, products, rents, and profits of the 

liened properties.

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

Dated: May 3, 2019 FINESTONE HAYES LLP

By: Jennifer C. Hayes Jennifer C. Hayes

Attorneys for Creditor 

Roebbelen Contracting, Inc.

Case: 19-30088 Doc# 1853 Filed: 05/06/19 Entered: 05/06/19 11:31:46 Page 3 of

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