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

28

37170\12473458.1

Gary M. Kaplan (State Bar No. 155530) 

FARELLA BRAUN + MARTEL LLP 

235 Montgomery Street, 18th Floor 

San Francisco, CA 94104 

Telephone: (415) 954-4400 

Facsimile: (415) 954-4480 

Email: gkaplan@fbm.com 

Attorneys for Party in Interest 

TTR SUBSTATIONS, INC. 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

IN RE: 

PG&E CORPORATION 

-andPACIFIC 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. 

* * * * * * * * * * * * * * ** * * * * * * * * *

*

*

*

*

*

*

*

*

*

*

*

*

*

*

*

*

*

*

*

*

*

Case Nos. 19-30088 (DM) (Lead Case) 

Chapter 11

Jointly Administered 

NOTICE OF LIENS UNDER 11 U.S.C. § 546(b) BY TTR SUBSTATIONS, INC. 

TTR Substations, Inc. (“TTR”) is a subcontractor under Master Service Agreement No. 

4400007190 (the “MSA”) and related Contract Work Authorizations (“CWAs,” and collectively 

with the MSA, the “Contract”) with debtor Pacific Gas and Electric Company (“PG&E” or 

“Debtor”), pursuant to which TTR agreed to provide labor, equipment, services and/or materials to 

PG&E (collectively, the “Work”), as specified therein, including substation construction, at certain 

real property locations owned by PG&E, as specified therein (collectively, the “Properties”). 

Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 1 of

16
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

28

2

37170\12473458.1

Prior to and after the filing of the Debtor’s bankruptcy case on January 29, 2019, TTR has 

provided Work pursuant to the Contract at PG&E’s Properties, as listed on Exhibit 1 attached 

hereto, and has duly provided preliminary notices with respect thereto pursuant to California Civil 

Code Sections 8100 et seq. (true and correct copies attached hereto as Exhibit 2). The amounts 

currently owed to TTR for the Work are set forth on Exhibit 1 (not including interest and other 

charges), with additional amounts continuing to accrue. 

The Work under the Contract constitutes “works of improvement” as defined in 

California Civil Code Section 8050(a). Pursuant to California Civil Code Section 8414, a 

subcontractor may not enforce a lien unless the subcontractor records a claim of lien after the 

subcontractor finishes work, and before ninety (90) days after the completion of the work of 

improvement. California Civil Code Section 8460(a) provides that an action to enforce a lien 

must be filed within 90 days after recordation of the claim of lien, and if such action is not 

commenced within that time, then the claim of lien expires and is unenforceable. 

Bankruptcy Code Section 546(b) (11 U.S.C. § 546(b)) provides that 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.1See 

1

 Section 546(b) provides as follows: 

“(1) The rights and powers of a trustee under sections 544, 545, and 549 of [the Bankruptcy Code] 

are subject to any generally applicable law that— 

(A) permits perfection of an interest in property to be effective against an entity that acquires 

rights in such property before the date of perfection; or 

(B) provides for the maintenance or continuation of perfection of an interest in property to be 

effective against an entity that acquires rights in such property before the date on which action is 

taken to effect such maintenance or continuation. 

(2) If— (A) a law described in paragraph (1) requires seizure of such property or commencement 

of an action to accomplish such perfection, or maintenance or continuation of perfection of an 

interest in property; and 

(B) such property has not been seized or such an action has not been commenced before the date 

of the filing of the petition; 

such interest in such property shall be perfected, or perfection of such interest shall be maintained 

or continued, by giving notice within the time fixed by such law for such seizure or such 

commencement.” 

Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 2 of

16
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

28

3

37170\12473458.1

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

1999); Village Nurseries v. Greenbaum, 101 Cal.App.4th 26 (2002). 

Bankruptcy Code Section 362(b)(3) further provides that the filing of a bankruptcy petition 

“does not operate as a stay . . . under subsection (a) of this section, of any act to perfect, or to 

maintain or continue the perfection of, an interest in property to the extent that the trustee’s rights 

and powers are subject to perfection under Section 546(b) of [the Bankruptcy Code] . . . .” 

Pursuant to Bankruptcy Code Section 546(b), TTR hereby gives notice to preserve, perfect, 

maintain, and continue the perfection of its liens in lieu of the recording of claims of lien and/or 

the commencement of actions to enforce such liens pursuant to California Civil Code Sections 

8414 and 8460(a). This notice constitutes the legal equivalent of having filed liens and 

commenced actions to foreclose such liens. TTR’s liens extend to the proceeds, products, rents, 

and profits of the subject Properties. TTR reserves the right to record claims of lien in the Office 

of the County Recorder for the Counties in the State of California where the Properties are located, 

as permitted by Bankruptcy Code Section 362(b)(3). 

Dated: May 22, 2019 FARELLA BRAUN + MARTEL LLP 

By: 

Gary M. Kaplan 

Attorneys for Party in Interest 

TTR Substations, Inc.

Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 3 of

16
EXHIBIT 1 

NOTICE OF LIENS UNDER 11 U.S.C. § 546(B) 

BY TTR SUBSTATIONS, INC. 

In Re: PG&E Corporation and Pacific Gas and Electric Company 

Case No. 19-30088 (DM) (Lead Case) 

Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 4 of

16
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

28

4

37170\12473458.1

EXHIBIT 1 

Job Number Location Address County Prime 

Contractor 

Remaining 

Balance 

18176-01 Contra Costa 

Substation 

2111 Hillcrest 

Avenue, 

Antioch, CA 

94509 

Contra Costa Semper 

Electric, Inc 

$4,216.79 

18178-01 Arana 

Substation 

Bostwick 

Lane, West of 

7

th Avenue, 

Santa Cruz, 

CA 95062 

Santa Cruz Semper 

Electric, Inc. 

$51,271.16 

Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 5 of

16
EXHIBIT 2 

NOTICE OF LIENS UNDER 11 U.S.C. § 546(B) 

BY TTR SUBSTATIONS, INC. 

In Re: PG&E Corporation and Pacific Gas and Electric Company 

Case No. 19-30088 (DM) (Lead Case) 

Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 6 of

16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 7 of

16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 8 of

16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 9 of

16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 10

of 16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 11

of 16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 12

of 16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 13

of 16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 14

of 16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 15

of 16
Case: 19-30088 Doc# 2200 Filed: 05/22/19 Entered: 05/22/19 18:49:15 Page 16

of 16