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

ROEBBELEN CONTRACTING, INC.’S FOURTH NOTICE OF CONTINUED PERFECTION OF 

MECHANICS LIEN PURSUANT TO 11 U.S.C. § 546(b)(2) 1/3

Stephen D. Finestone (125675)

Jennifer C. Hayes (197252)

Ryan A. Witthans (301432)

FINESTONE HAYES LLP

456 Montgomery Street, Floor 20

San Francisco, CA 94104

Telephone: (415) 616-0466

Facsimile: (415) 398-2820

Email: sfinestone@fhlawllp.com

Email: jhayes@fhlawllp.com

Email: 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 

FOURTH NOTICE OF CONTINUED

PERFECTION OF MECHANICS LIEN 

PURSUANT TO 11 U.S.C. § 546(b)(2)

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

Perfection of Mechanics’ Lien Pursuant to 11 U.S.C. § 546(b)(2) (the “Notice”) and in support 

thereof states as follows:

Case: 19-30088 Doc# 2323 Filed: 05/31/19 Entered: 05/31/19 15:16:37 Page 1 of

3
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

ROEBBELEN CONTRACTING, INC.’S FOURTH NOTICE OF CONTINUED PERFECTION OF 

MECHANICS LIEN PURSUANT TO 11 U.S.C. § 546(b)(2) 2/3

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

“Debtors”) filed voluntary Chapter 11 bankruptcy petitions.

2. 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.

3. 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 Santa Clara County, California (among others). Roebbelen has lien rights (the “Lien”) 

related to these works of improvement. See Cal. Civ. Code § 8050(a) (defining works of 

improvement).

4. Through the filing of this Notice, the amount owing to Roebbelen on account of the 

Lien is at least $170,865.63 (calculated as the original lien amount of $190,792.92 less a partial release 

in the amount of $19,927.29), not including interest and other charges, with additional amounts 

accrued and owed after the filing of this Notice.

5. Roebbelen properly perfected its Lien pursuant to California Civil Code §§ 8400 et. 

seq. by timely recording its Lien in the above-named counties. See Cal. Civ. Code § 8412 (establishing 

deadlines for contractor to record lien claims). Roebbelen has also filed a partial release reflecting a 

downward adjustment to the amount originally claimed in the Lien. Authentic copies of the Lien 

and partial release are attached to this Notice as Exhibit A.

1

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

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

Lien, such as to increase or decrease the amount.

Case: 19-30088 Doc# 2323 Filed: 05/31/19 Entered: 05/31/19 15:16:37 Page 2 of

3
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

ROEBBELEN CONTRACTING, INC.’S FOURTH NOTICE OF CONTINUED PERFECTION OF 

MECHANICS LIEN PURSUANT TO 11 U.S.C. § 546(b)(2) 3/3

6. 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 Lien. 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 (B.A.P. 9th Cir. 1999); see Village 

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

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

California’s 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.

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

Notice.

Dated May 31, 2019 FINESTONE HAYES LLP

/s/ Ryan A. Witthans

Ryan A. Witthans

Counsel for Creditor

Roebbelen Contracting, Inc.

Case: 19-30088 Doc# 2323 Filed: 05/31/19 Entered: 05/31/19 15:16:37 Page 3 of

3