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Ballard Spahr L

LP

1 East Washington Street, Suite 2300

Phoenix, A

Z 85004-2555

Telephone: 602.798.5400

Craig Solomon Ganz (217254) 

BALLARD SPAHR LLP 

1 East Washington Street, Suite 2300 

Phoenix, AZ 85004-2555 

Email: ganzc@ballardspahr.com 

Telephone: 602.798.5400 

Facsimile: 602.798.5595 

Stacy H. Rubin (228347) 

BALLARD SPAHR LLP 

One Summerlin 

1980 Festival Plaza Drive, Suite 900 

Las Vegas, NV 89135-2958 

Email: rubins@ballardspahr.com 

Telephone: 702.471.7000 

Attorneys for Realty Income Corp. 

IN THE UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re

PG&E CORPORATION 

- and - 

PACIFIC GAS & ELECTRIC 

COMPANY, 

Debtors. 

Bankruptcy Case No. 19-30088

(Lead Case) 

Chapter 11 

RESERVATION OF RIGHTS OF 

REALTY INCOME CORPORATION 

TO THE DEBTORS’ MOTION 

PURSUANT TO 11 U.S.C. § 365(a), FED. 

R. BANKR. P. 6006, AND B.L.R. 6006-1 

FOR AN ORDER APPROVING 

ASSUMPTION OF CERTAIN REAL 

PROPERTY LEASES 

(“LEASE ASSUMPTION MOTION”)

☐ PG&E Corporation 

☐ Pacific Gas and Electric Company 

☒ Both Debtors 

Date: September 24, 2019

Time: 9:30 a.m. 

Place: Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Landlord Realty Income Corporation (“RIC”), by and through its undersigned 

counsel, hereby files this Reservation of Rights to the Debtors’ Motion Pursuant to 11 

U.S.C. § 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 for an Order Approving 

Assumption of Certain Real Property Leases (the “Lease Assumption Motion”), and in 

support hereof, respectfully states as follows: 

Case: 19-30088 Doc# 3859 Filed: 09/10/19 Entered: 09/10/19 12:54:19 Page 1 of

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Ballard Spahr L

LP

1 East Washington Street, Suite 2300

Phoenix, A

Z 85004-2555

Telephone: 602.798.5400

Debtors filed their voluntary petitions for relief under Chapter 11 of Title 11 of the 

United States Code on January 29, 2019. RIC is the owner or agent for the property located 

at 425 Beck Avenue, Fairfield, California (the “Property”), which Debtor Pacific Gas and 

Electric Company leases from RIC pursuant to that certain written unexpired Lease 

Agreement dated December 1, 1983 (including all amendments thereto). 

In the Lease Assumption Motion, the Debtors seek an order for approval of the 

Debtors’ assumption of certain nonresidential real property leases and other land-related 

agreements, authorization for the Debtors to make cure payments and remove liens that 

were placed on the various properties, and following such payments and removal of liens, 

barring lessors from asserting any existing default. The Property was identified and 

included in a schedule of leases with a lien associated thereto (marked as Exhibit B to the 

Lease Assumption Motion). 

RIC is currently unaware of any third-party liens on the Property. However, RIC 

expects the Debtors to remove any and all such liens by the time of the proposed 

assumption. 

RIC reserves the right to make other objections as may be appropriate, and does not 

waive and hereby preserves all of its rights, remedies, and arguments with respect to the 

Property and the treatment of the Property by the Debtors in this matter. 

DATED: September 10, 2019 BALLARD SPAHR LLP 

By: /s/ Stacy H. Rubin

Craig Solomon Ganz (217254) 

1 E. Washington Street, Suite 2300 

Phoenix, AZ 85004-2555 

Email: ganzc@ballardspahr.com 

Telephone: 602.798.5400 

Facsimile: 602.798.5595 

Stacy H. Rubin (228347) 

One Summerlin 

1980 Festival Plaza Drive, Suite 900 

Las Vegas, NV 89135-2958 

Email: rubins@ballardspahr.com 

Telephone: 702.471.7000 

Attorneys for Realty Income Corp. 

Case: 19-30088 Doc# 3859 Filed: 09/10/19 Entered: 09/10/19 12:54:19 Page 2 of

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