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KELLER BENVENUTTI KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Thomas B. Rupp (#278041) 

(trupp@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized Debtors

ROVENS LAMB LLP 

STEVEN A. LAMB (SBN 132534) 

slamb@rovenslamb.com 

Telephone: (310) 536.7830 

Facsimile: (310) 872.5489 

2601 Airport Drive, Suite 370 

Torrance, California 90505 

LAW OFFICES OF JENNIFER L. DODGE INC. 

Jennifer L. Dodge (#195321) 

(jdodgelaw@jenniferdodgelaw.com) 

2512 Artesia Blvd., Suite 300D 

Redondo Beach, California 90278 

Tel: (310) 372.3344 

Fax: (310) 861.8044 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Case Nos. 19-30088 (DM) 

(Lead Case) (Jointly Administered) 

PG&E’S SUPPLEMENTAL REPLY BRIEF 

IN SUPPORT OF COUNTER-MOTION FOR 

SUMMARY JUDGMENT 

Date: May 9, 2023 

Time: 10:00 a.m. (Pacific Time) 

Place: (Tele/Videoconference Only) 

 United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

 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: 19-30088 Doc# 13695 Filed: 05/04/23 Entered: 05/04/23 13:54:56 Page 1

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PG&E Corporation (“Holdco”) and Pacific Gas and Electric Company (“PG&E”), as debtors 

and reorganized debtors (collectively, the “Debtors,” or as reorganized, the “Reorganized Debtors”) in 

the above-captioned chapter 11 cases (the “Chapter 11 Cases”) submit this Supplemental Reply Brief 

in Support of PG&E’s Counter-Motion for Summary Judgment. 

After this matter had been briefed, it was discovered that Amir Shahmirza and Komir, Inc. 

(together, “Claimant” or “Komir”), have taken the unprecedented action of unilaterally blocking a gate 

through which PG&E has obtained access to the PG&E Substation. Claimant has blocked access by 

parking large vehicles directly in front of the gate. When requested to remove the vehicles, Claimant

asserted PG&E has no right of access. 

The PG&E Substation is critical infrastructure. Full access to the Substation without impediment 

is essential for safe operation of the electric grid. Despite repeated requests, Claimant continues to deny 

access. 

The State of California issued a Directors Deed in 1988, after the condemnation action at issue 

in Claimant’s Motion. That Director’s Deed is recorded, and provides an easement for landscaping and 

access (the “PG&E Easement for Landscaping and Access”) that affords PG&E the right to travel over 

and through the PG&E Easement for Landscaping and Access and into the PG&E Substation that is 

appurtenant to the PG&E Easement for Landscaping and Access. 

Claimant’s Bankruptcy claim attached a Survey, under penalty of perjury, that clearly reflects 

the PG&E Easement for Landscaping and Access. PG&E has had a lock on the gate providing access 

to and through the PG&E Easement for Landscaping and Access to the PG&E Substation. That lock 

had been in place for years and PG&E has accessed the PG&E Substation through the PG&E Easement 

for Landscaping and Access for decades. 

As with its numerous shifting legal theories and claims, Claimant now asserts that the State of 

California lacked the authority to grant the duly recorded 1988 Director’s Deed that provided the PG&E 

Easement for Landscaping and Access and has no right to enter or pass through the PG&E Easement for 

Landscaping and Access to the PG&E Substation. 

Case: 19-30088 Doc# 13695 Filed: 05/04/23 Entered: 05/04/23 13:54:56 Page 2

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Attachments 1-5 hereto are a letter dated May 1, 2023, to Claimant’s counsel, with the exhibits 

attached to it. Attachment 6 is the May 3, 2023 response from Claimant’s counsel. 

1. May 1, 2023 Letter to Claimant’s Counsel re Access 

2. Record of Survey from Claimant 

3. PG&E Easement for Landscape & Access 

4. Photo Blocking Gate and Access 

5. Overhead Photo of Site 

6. May 3, 2023 email from Claimant’s counsel 

Respectfully Submitted, 

May 4, 2023 

 KELLER BENVENUTTI KIM LLP 

 ROVENS LAMB LLP 

 LAW OFFICES OF JENNIFER L. DODGE INC. 

By: /s/__Steven A Lamb__________ 

Steven A. Lamb 

Attorneys for Debtors and Reorganized Debtors 

Case: 19-30088 Doc# 13695 Filed: 05/04/23 Entered: 05/04/23 13:54:56 Page 3

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