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LAWRENCE A. JACOBSON, SBN 057393

SEAN M. JACOBSON, SBN 227241

COHEN AND JACOBSON, LLP

66 Bovet Road, Suite 285

San Mateo, CA 94402

Telephone: (650) 261-6280

laj@cohenandjacobson.com

Attorneys for Amir Shahmirza

(Agent for Komir, Inc.) and Komir, Inc.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION,

- and - 

PACIFIC GAS AND ELECTRIC

COMPANY,

Debtors.

G Affects PG&E Corporation

G Affects Pacific Gas and Electric Company

O Affects both Debtors

Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

EVIDENTIARY OBJECTIONS TO THE

DECLARATION OF ROB SULLIVAN IN

SUPPORT OF

(1) CLAIMANT’S REPLY TO PG&E’S

OPPOSITION TO MOTION FOR

PARTIAL SUMMARY JUDGMENT OF

ISSUES IN REORGANIZED DEBTORS 

OBJECTION TO CLAIM #2090 AND

CLAIMANT’S RESPONSE THERETO

AND 

(2) CLAIMANT’S RESPONSE TO THE

COUNTER-MOTION FOR SUMMARY

JUDGMENT BY DEBTORS

[Response to Counter-Motion Filed

Separately]

Date: April 11, 2023

Time: 10:00 a.m.

Place: (Tele/Videoconference Appearances

Only)

United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

EVIDENTIARY OBJECTIONS TO THE DECLARATION OF ROB SULLIVAN 1

Case: 19-30088 Doc# 13654-6 Filed: 04/03/23 Entered: 04/03/23 16:38:58 Page 1

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Amir Shahmirza, as agent of, and acting on behalf of, Komir, Inc. (“Komir” or “Claimant”),

submits the following Evidentiary Objections to the Declaration of Rob Sullivan in Support of (1) 

Claimant’s Reply to PG&E’s Opposition to Motion for Partial Summary Judgment of Issues in

Reorganized Debtors Objection to Claim #2090 and Claimant’s Response Thereto and (2)

Claimant’s Response to the Counter-Motion for Summary Judgment by Debtors. 

For the reasons and on the grounds stated below, Claimant objects to and seeks the exclusion

of the statements in and exhibits to the Declaration of Rob Sullivan as follows:

1. Paragraph 4

(a) Paragraph 4, page 1, lines 17-20, in its entirety on grounds of lack of relevance to

Claimant’s Motion for Partial Summary Judgment.

The entire content of this paragraph lacks relevance to the Claimant’s Motion for

Partial Summary Judgment in that the motion seeks adjudication of the

extinguishment of all easements referenced in Sullivan Declaration such that the

location of any area described in any of the extinguished easements is irrelevant.

(b) Paragraph 4, page 1, lines 17-20, in its entirety on grounds of lack of relevance to

Claimant’s Motion for Partial Summary Judgment.

The entire content of this paragraph lacks relevance to the Debtors’ Counter Motion

for Summary Judgment in that the location of easement areas in recorded documents

is irrelevant to any claim of entitlements based upon actual occupancy of whatever

portion of Claimant’s Property the Debtors contend that they have acquired rights

based of prescriptive easement.

(c) Exhibit E is inadmissible as lacking foundation as to the manner of its preparation,

i.e., the Declarant may be a licensed surveyor but the Declaration lacks foundation as

to the procedures followed by him to properly and accurately prepare the Exhibit.

(d) Exhibit E is inadmissible as a form of Survey for which the Debtors and the Declarant

failed to comply with the requirements of the Land Surveyor’s Act, Business &

EVIDENTIARY OBJECTIONS TO THE DECLARATION OF ROB SULLIVAN 2

Case: 19-30088 Doc# 13654-6 Filed: 04/03/23 Entered: 04/03/23 16:38:58 Page 2

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Professions Code § 8762(b)(2) through (b)(5) that require the submission of the

Survey to the County Surveyor for review and authorization or refusal of

authorization for recordation, and as lacking a statement of purpose and Surveyor’s

stamp required by B&P § 8760(c) and (d), respectively.

Respectfully submitted.

 Dated: April 3, 2023 COHEN AND JACOBSON, LLP

By: /s/ Lawrence A. Jacobson 

 Attorneys for Claimant

EVIDENTIARY OBJECTIONS TO THE DECLARATION OF ROB SULLIVAN 3

Case: 19-30088 Doc# 13654-6 Filed: 04/03/23 Entered: 04/03/23 16:38:58 Page 3

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