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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

-oOoIn Re:

PG&E CORPORATION AND PACIFIC 

GAS AND ELECTRIC COMPANY,

 Reorganized Debtors.

_____________________________

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Case No. 19-30088

Chapter 11

San Francisco, California

Tuesday, October 11, 2022

10:00 AM

REORGANIZED DEBTORS' 

OBJECTION TO PROOF OF CLAIM 

NO. 2090 FILED BY AMIR 

SHAHMIRZA FILED BY PG&E 

CORPORATION [12130]

TRANSCRIPT OF PROCEEDINGS

BEFORE THE HONORABLE DENNIS MONTALI

UNITED STATES BANKRUPTCY JUDGE

APPEARANCES (All present by video or telephone):

For the Reorganized 

Debtors:

THOMAS B. RUPP, ESQ.

Keller Benvenutti Kim LLP

650 California Street

Suite 1900

San Francisco, CA 94108

(415)469-6723

STEVEN A. LAMB, ESQ.

Rovens Lamb LLP

2601 Airport Drive

Suite 370

Torrance, CA 90505

(310)536-7830

For Amir Shahmirza: LAWRENCE A. JACOBSON, ESQ.

Cohen and Jacobson, LLP

66 Bovet Road

Suite 285

San Mateo, CA 94402

(650)261-6280

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Court Recorder: LORENA PARADA/ANKEY THOMAS

 United States Bankruptcy Court

450 Golden Gate Avenue

San Francisco, CA 94102

Transcriber: RIVER WOLFE

 eScribers, LLC

7227 N. 16th Street

Suite #207

Phoenix, AZ 85020

(973)406-2250

Proceedings recorded by electronic sound recording; 

transcript provided by transcription service.

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SAN FRANCISCO, CALIFORNIA, TUESDAY, OCTOBER 11, 2022, 10:00 AM

-oOo-

(Call to order of the Court.)

THE CLERK: Court is now in session, the Honorable 

Dennis Montali presiding. Calling the matter of PG&E 

Corporation.

THE COURT: Good morning. Who's appearing for PG&E 

today, please? 

MR. RUPP: Good morning, Your Honor. Thomas Rupp of 

Keller Benvenutti Kim for the reorganized debtors. 

THE COURT: And appearing for the claimant? 

MR. JACOBSON: Lawrence Jacobson. Good morning, Your 

Honor. 

THE COURT: Good morning, Mr. Jacobson. 

MR. RUPP: Your Honor, I think we have one more --

MR. LAMB: Good morning --

MR. RUPP: -- appearance for PG&E. 

MR. LAMB: Good morning, Your Honor. This is Steven 

Lamb on behalf of PG&E also. 

THE COURT: All right. So Mr. Jacobson, I just didn't 

see your name on the call. I saw some unidentified guest. 

MR. JACOBSON: Judge, I tried to log on through the 

computer, and I think I was following instructions correctly 

and it kept telling me my credentials were not correct. 

THE COURT: Yeah. I had some problems today, too, so 

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maybe it was AT&T's fault. 

Well, look, there are a bunch of things that are 

confusing about the way the papers are submitted because Mr. 

Jacobson, this is a claim objection, and you're asking for 

relief from stay and abstention. And there are no motions for 

either.

Mr. Rupp or Mr. Lamb, I'm confused from your point of 

view because you say I could dispose of this because there are 

no facts in dispute, but then you say some limited discovery is 

necessary. 

So let me just clarify a couple of things, and then 

I'll hear from both sides. From my reviewing of the papers, it 

doesn't seem to be an issue as to the lines that go across the 

property and whether the lines -- towers on the power lines, 

but rather whether PG&E violated the claimant's rights --

whomever the claimant is -- the claimant's rights by lowering 

the level of the power lines at some point later on. And I 

don't see any discussion in the papers about that. 

So I'm kind of confused about where we go from here. 

Why don't I let you start, Mr. Jacobson? You are the claimant. 

So what's your position today, and what do you think I ought to 

do? And --

MR. JACOBSON: Thank you. 

THE COURT: -- don't tell me you think I ought to -- I 

ought to abstain or grant relief from stay because you haven't 

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asked for either one of those properly. 

MR. JACOBSON: Well, thank you. Well, let me start 

with the bigger picture and then come to that last point. 

There was an event in 2018 that related to the 

lowering of the lines, as you articulated. There had been 

smaller-based towers on the adjacent properties at either end 

that were at a height. And in 2018, with no communication, no 

permission, no granted authority, PG&E installed massively 

larger towers and bigger lines and lowered them across the 

property, affecting the use and the value. 

The claimant's state court counsel promptly filed a 

complaint based upon the set of facts that was known at that 

point from his pleading perspective. That circumstance caused 

the claimant to procure the record of survey by which the 

surveyor, who is an expert, examined the entire chain of title 

and concluded that there are no easement rights of record at 

all, not just at a height, but at all. 

So that then raises the current issue, are there any 

easement rights at all, are there easement rights under some 

legal theory at a particular higher height, and whether there 

is some form of prescriptive use entitlement, as PG&E seems to 

argue. 

And it's also confusing from a timing standpoint 

because the complaint was filed in 2018. PG&E demurred to that 

complaint in early 2019 and then after the filing of the 

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petition, gave notice to the state court and parties about the 

filing and then took the additional act of withdrawing the 

hearing on the demurrer. 

THE COURT: Yeah, but that's all procedural history

that's of no particular relevance today. I mean, your --

MR. JACOBSON: Well, I (indiscernible) --

THE COURT: as to -- well, your recital as to what 

happened in 2018 obviously is critical, but well, I mean, we're 

back to my point. Today, I have to decide whether to act on a 

claim objection -- well, let's clarify one thing. 

Your surveyor says there were no easements of records, 

and yet the plat map that's in the record shows two recorded 

easements in 1923. No one has presented me with those actual 

easements, but do you think those don't exist, Mr. Jacobson?

MR. JACOBSON: Yes, I do think that. 

THE COURT: They don't exist? 

MR. JACOBSON: (Indiscernible) yeah. 

THE COURT: Where did they go? Where did they go? 

Are they still of record? 

MR. JACOBSON: Well, there are at least two issues 

about that. One is the surveyor, Mahoney (phonetic), indicates 

that they are in the approximate area of this property, but 

it's an area of fill, it's an area of change, and his statement 

is that you can't locate wherever that easement would be, other 

than that the City of San Francisco, I think in 2000 or so, did 

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its record of survey that shows the transmission lines on an 

adjacent property. So the first point is, whatever those 

easements were back then, they can't be identified as to a 

location. 

And then if you read Mahoney's report, that August 

11th report that is pages 4 through 8 of that compendium, he 

explains that there was a history of conveyances between the 

City of San Francisco and the State of California, and that the 

easements were extinguished or relocated by reason of the 

conveyances and the ordinance and that the deed from the 

claimant's predecessor -- the deed to the claimant's 

predecessor was a director's deed. 

And a director's deed, by definition, describes what 

is and isn't being conveyed and what rights exist or interests 

have been asserted against the property. And the director's 

deed by which the claimant's predecessor and the claimant took 

title have no easements, not the 1923 ones or any other ones, 

except for a sliver up at the end for landscaping of something 

that's now paved. So (indiscernible) --

THE COURT: But your client doesn't dispute -- wait, 

he doesn't dispute that the lines crossed the property when he 

bought the property, did he? 

MR. JACOBSON: That's correct. 

THE COURT: And if you and I were out there at the 

corner of 101 and 2380 (phonetic), I bet we'd see those lines. 

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So --

MR. JACOBSON: We sure would. 

THE COURT: -- are you saying that the lines should be 

removed or that your client should be provided damages if the 

lines were improperly lowered or both? 

MR. JACOBSON: Both. Well, or any alternative. They 

can move them, or they can compensate for them. They shouldn't 

be there. And the surveyor will testify that --

THE COURT: But Mr. Davidson (sic), he bought the 

property with them there over the property. Right. You just 

have --

MR. JACOBSON: Well --

THE COURT: -- stated that point, didn't you? 

MR. JACOBSON: -- but that goes back to what is the

effect of that? If they had no entitlement to be there in the 

first place, what is the legal fact, the fact that they were 

there when he bought it. And then they (indiscernible) --

THE COURT: Well, what if they were there -- well, 

you're back to prescriptive easement, that they may have been 

there for sixty years, whether or not there was an easement of 

record. 

MR. JACOBSON: And then it gets you to the -- so what 

is the easement, where is it located, and is it for the lines 

that were maintained at the height that existed in your sixtyyear (indiscernible) --

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THE COURT: I understand. I understand the height 

issue. To me, it's a more -- it's a very discreet question of 

the height issue. But last question for you, and then I want 

to hear from Mr. Lamb or Mr. Rupp. 

There's a lot of paper being spent on who the claimant 

is. Why isn't your corporate client substituted in as the 

claimant here? Do I suspect that maybe he doesn't want to pay 

the State Board of Equalization to reinstate a license? I 

mean, what is the big issue here of who the claimant is? 

MR. JACOBSON: If that's a question to me --

THE COURT: Yeah, it is to you because --

MR. JACOBSON: Oh, yeah --

THE COURT: -- one argument would be you don't have 

a -- your individual client doesn't have a claim. 

MR. JACOBSON: Well, he's here as the agent of the 

entity that is disclosed in the --

THE COURT: But I know that. I know he's an agent, 

but that doesn't make him the claimant. So why is there an 

argument about who the claimant is? 

MR. JACOBSON: I would be pleased to file an amended 

claim only in the name of the corporation. And there's no 

suspension issue. There's no franchise tax board issue. 

THE COURT: Okay. Well, then why didn't you? 

MR. JACOBSON: It just (indiscernible) caught up in 

this objection, and that's one of the things I'd like to be 

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allowed to do. 

THE COURT: Okay. But again, there's nothing in the 

papers that say that. 

All right. Mr. Lamb or Mr. Rupp, what do you think I

should do today? 

MR. LAMB: This is Steve Lamb, Your Honor. Thank you 

for your time. 

And I think that the Court is absolutely correct 

regarding the party. We've addressed that. I don't think we 

need to address that any further. 

I would just point out that we had a claim, and then 

we asked for an information request. And in docket number 

12131-4, there's a response, and it's Mahoney's report, not the 

survey, but the report. And in that report, he refers to this 

ordinance 3975 that Mr. Jacobson has referred to. And 

according to that report, it lists a series of easements. And 

as the Court noted, it identifies a plat map that clearly 

reflects those easements. 

And Mahoney's position in response to the report is, 

well, those easements have been relocated or extinguished, and 

he relies on 3975. We got a copy of that in the information 

request response. It did not include a legible copy of 3975. 

So we obtained it, and in response, we filed our objection. 

And the objection lists that, together with my declaration, 

which provides a legible copy and clearly states that that's 

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not what the ordinance says, that they weren't relocated or 

extinguished in any way. 

So from our position, what happens now is Mr. Mahoney 

submits a subsequent declaration which says, well, I've looked 

at this record of survey again, and it doesn't show any 

easements. He doesn't really address ordinance 3975. He 

doesn't address the initial statement of claim. He just 

changes positions. And we believe that they're judicially 

estopped from that and so have already submitted this position 

and haven't really responded, Your Honor. 

So that's what we're faced with, in addition to the 

fact that all this record of survey discussion is largely 

irrelevant because it doesn't have any legal impact. Is there 

an easement, and Mahoney's clearly identified them. He's 

attached them. They're part of the record. His position is 

they've been relocated or extinguished. 

When I pointed out that that's, in fact, not the case, 

they really don't address that. They just change position and 

say, well, we've taken another look, and there's no easement. 

And that doesn't really address it, Your Honor. 

THE COURT: Okay. Okay. But what about the lowering? 

Lowering is not a --

MR. LAMB: Well, the lowering --

THE COURT: -- a relocation. 

MR. LAMB: Sure. The lowering issue occurred quite 

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some time earlier, and what happened in that regard was they 

tried to say that it was too low. And we said, no, actually, 

there's a general order that says it is the appropriate height. 

So they really haven't addressed that. Now, they changed 

position to say, well, they should have been there in the first 

place. 

What they started with saying was they were there, and 

they were too low. We responded and said they're not too low. 

And then they said, well, they're not there in the first place. 

And then they said, well, I think they're there, but there's 

this 3975 ordinance, so they've been relocated or and

extinguished. 

So we provided them a copy of that. We showed that's 

not the case. And now they came back with another declaration 

that says, well, we've looked again, and they're not there. 

THE COURT: Okay. Why don't you make a motion for 

summary judgment? I mean, if you're confident that you can 

prove the case with competent evidence, we can take -- we can 

do --

MR. LAMB: Yeah. 

THE COURT: -- a motion for summary judgment on claim. 

I mean, Mr. Lamb --

MR. LAMB: Well, Your Honor, we have --

THE COURT: -- I don't know if you're -- well, wait a 

minute.

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MR. LAMB: -- we have to -- we have to --

THE COURT: I don't know if you're familiar with the 

procedures on the claim objection, but we have in dispute under 

the local rules whether I can dispose of it on a matter of law. 

And to me, there's enough to be concerned about that I could 

say, well, if you're right, make a motion for summary judgment. 

And if you do, then you can deal with -- and let's assume that

we're not going to get bogged down on who the actual claimant 

is. 

MR. LAMB: Sure. 

THE COURT: It's either the corporation or its owner. 

And if you're right, you'll win. And if you're wrong, then 

it'll either have to be resolved in a traditional fact dispute 

case, either by this Court or maybe it would be appropriate to 

send it back to state court. 

But I mean, is there any reason why you couldn't put 

it together as a motion for summary judgment? 

MR. LAMB: Well, absolutely not. But my 

understanding --

THE COURT: Okay. 

MR. LAMB: -- Your Honor -- I think that that could be 

done, and I am not a bankruptcy counsel, so I rely on Mr. Rupp. 

But frankly, my understanding is that what happens here is once 

you do the objection, the burden shifts, and they have to 

present something. And they didn't present anything. They 

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really didn't. 

THE COURT: Well --

MR. LAMB: They didn't really respond. 

THE COURT: Okay. But if I tell him -- but leave 

aside burden of proof because if Mr. Jacobson says we're 

ready and we're prepared to prove our case at a trial because 

there are facts in dispute, then your response to that is there 

are no material facts in dispute. I can win by summary 

judgment. 

I don't want to waste everybody's time, yours and mine 

included, on a motion for summary judgment that was doomed to 

fail because there are material facts in dispute. But based 

upon your recitation and your --

MR. LAMB: Okay. 

THE COURT: -- and I didn't take the time to parse out 

Mr. Mahoney's statement or -- I mean, I started with where the 

hell is the easement? Mr. Rupp is familiar with the fact that 

I have another matter pending in our court involving a great, 

big, powerful, high power line across somebody's home. And 

we're going to perhaps go to trial on that subject. 

And so I'm familiar with the doctrine, but I am used 

to looking at the easements. And if I had a declaration that 

says, here's the easement and it hasn't been reconveyed, then 

it'll be up to Mr. Jacobson to rebut that. 

Anyway. Well, Mr. Lamb, leave aside the question of 

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whether you should make that motion. What do you think I 

should do today? 

MR. LAMB: Well, our position is you should sustain 

the objection because they haven't met their burden and it 

hasn't been shifted, and I don't think it's appropriate to 

simply submit another declaration which is inconsistent with 

the prior one without addressing it. I don't think that that's 

consistent with the Plice v. Crone (phonetic) case that we 

cited. 

But I do understand your argument regarding summary 

judgment. I think it's a question, though, of whether or not 

procedurally we've gotten to the point where we need to do 

that. And I don't think we can. 

THE COURT: Okay. Okay. Mr. Jacobson. 

MR. JACOBSON: Yeah. Judge, I would just comment,

generally and preliminarily, that that was not an accurate 

assessment of Mr. Mahony's position or the positions of the 

claimant. There has never been a change in position. He's 

been perfectly consistent. He expressed the same conclusion 

he's expressing now in his report of August 11 of 2018. 

It's a five-page analysis of the San Francisco 

ordinance, the chain of title, all the ten or twelve documents 

involved in that process, and it supports his conclusion that 

is stated in his declaration at paragraphs 13, 14, 15, and 16

of PG&E does not hold any easements of record or traceable 

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through recorded documents for transmission across the power 

line -- across the property --

THE COURT: That does sound like a legal conclusion. 

That does sound like a legal --

MR. JACOBSON: Well --

THE COURT: -- conclusion by a surveyor. I mean, 

surveyors aren't --

MR. JACOBSON: Well, he's a --

THE COURT: -- qualified to give legal conclusions, 

are they? 

MR. JACOBSON: He has an expertise in analyzing these 

documents from a surveyor's perspective as to where are the 

boundaries and what are the interests of record on it. So it 

is consistent with his expertise. And the process with the 

record of survey is that it's prepared by the surveyor and then 

presented to the county (audio interference) --

(Off the record due to technical issues.)

THE COURT: So somehow the recording stopped while you 

were talking. 

Well, I mean, I think it's a stretch to have a 

surveyor, as qualified as he may be, to opine on the ultimate 

question that there is no easement of record -- I mean, no 

enforceable easement, when that's a leap. But if I set --

MR. JACOBSON: Well, the one thing --

THE COURT: -- this for trial -- if I set this for 

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trial --

MR. JACOBSON: One thing that --

THE COURT: -- would he be -- wait, if I set this --

MR. JACOBSON: Sorry. 

THE COURT: -- for trial, would he be your witness? 

MR. JACOBSON: He will be a witness -- 

THE COURT: He would be your --

MR. JACOBSON: -- yes. 

THE COURT: Would he be your expert witness on the 

subject? 

MR. JACOBSON: Yes. 

THE COURT: Well, okay. 

MR. JACOBSON: He will take you through the entire 

process of what surveying involves, what they do to identify, 

and how it's reviewed and approved by the county. 

But I want to say one thing I think is really 

important and missing here is all of the information in front 

of you has come from the claimant. In terms of where the hell 

is the easement, PG&E has never produced anything that shows 

any easement located where these power lines are. 

And they have got no diagrams. They've got no maps. 

They've got no records of survey. All they do is look at 

something from 1923 with no history, no analysis, and say you 

should grant summary judgment at this status conference. It is 

complicated --

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THE COURT: Well, I understand, but then I'll put the 

question to you. What if I told you to make a motion for 

summary judgment? You believe you could make one? In other 

words, you believe that, with no material facts in dispute, you 

can make a prima facie case and carry a burden that you have --

and leaving aside perhaps the measure of damages.

But your position seems to be that your client --

again, we'll leave aside which client -- one of your clients --

your client owns the property, and if you are standing on that 

property, you'd see towers and powerlines across the property. 

And your view is they don't belong there, and you're entitled 

to damages. And you can make the case? No material facts in 

dispute, you believe? 

MR. JACOBSON: Correct. On that legal issue, I agree, 

I can make a motion for summary judgment. I do want -- the 

reason I was giving you the state court history is because that 

complaint was filed since 2018. There's been a --

THE COURT: No, I know. 

MR. JACOBSON: -- continuing trespass, an additional 

trespass, and the procedure in state court, if it were to go 

forward there, is that the plaintiff, the claimant, files an 

amended complaint to deal with the demurrer issues. Then the 

case goes to trial on the amended complaint. So --

THE COURT: No, I know that. There's nothing 

really -- that's the same as federal practice. I mean, if it 

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had been a 12(b)(6) motion and withdrawn or amended complaint, 

it's the same. I know that. 

But my point is that it hasn't happened. We know 

why -- I mean, I don't know why they actually withdrew the 

demurrer, but it was a bankruptcy that stayed the action. And 

nobody in three years sought relief from stay. And so here we 

are. 

And to me, procedurally, it's perfectly proper for 

your client to file a claim and for the debtor to object to the 

claim. And as a matter of discretion whether I ship it back to 

state court or not is a different question. 

MR. JACOBSON: One procedural --

THE COURT: Well, I --

MR. JACOBSON: -- issue here is that the state court 

counsel who filed the proof of claim became physically --

THE COURT: No, I understand. 

MR. JACOBSON: -- (indiscernible) practice. 

THE COURT: You made that point, but that's not a 

procedural issue. That's a personal issue. 

But Mr. Jacobson, your client has a very capable 

lawyer representing him this morning, known to me as very 

capable lawyer. And so Mr. Capable Lawyer, you believe you can 

make the summary judgment? I think that's what I should tell 

you to do. I mean, Mr. Lamb thinks that I should put the 

burden on you, and I guess maybe that's true. 

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And so I guess my question is, well, why don't you 

just do that? And I mean, I realize I'm not trying to put your 

client to an unnecessary effort or expense, but the fact of the 

matter is, if you can do it, you'll get it from me very 

quickly, and we don't have to worry about the poor judge that 

was the subject of a portion of your argument who is going to 

have to deal with it if I send it back to her. 

So what's your response on that invitation? 

MR. JACOBSON: To accept it. 

THE COURT: Okay. 

MR. JACOBSON: The preferred alternative would be to 

go back to state court, amend the complaint, and finish it 

where it started. But if the bankruptcy process puts this 

issue in the bankruptcy court on the legal issue first, I'm 

prepared to make that motion. 

THE COURT: Mr. Jacobson, again, I have already 

complimented you about your skills, but you've had three years 

to file a motion for relief from stay, and you didn't. And you 

made a very passionate argument in writing and orally and 

tucked away at the end is I should get relief from stay. And 

you know that's not the way to do it procedurally. 

So the point is, if you're confident that you can show 

as a fact matter that the law is in your favor and there is 

some sort of trespass then -- maybe at this Court or maybe it 

should be sent out for measuring the damages, I don't know. 

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I'm not going to decide that because Mr. Lamb thinks he can 

beat you on the papers. You think you can beat him on the 

papers. 

So I'm going to -- unless Mr. Lamb or Mr. Rupp have a 

contrary view, I'm going to say, okay, let's have a motion from 

the claimant. First of all, you and counsel see if you can 

meet and confer on the subject of can we agree on who the 

claimant is. And if there's no agreement between the two of 

you, then the motion (indiscernible) should say who the 

claimant is and why the claimant is entitled to it. 

I'm not going to get bogged down on whether the 

corporate entity -- sorry, I forgot the name, but you know who 

I'm talking about -- whether it should have filed the proof of 

claim. I'll accept that the debtor was on notice as to an

assertion of rights by somebody affiliated with the property

that is the subject of this discussion. 

When can you file your motion? 

MR. JACOBSON: I am going to be away the first half of 

November. 

THE COURT: Okay. 

MR. JACOBSON: Say the first week of -- end of the 

first week of December. 

THE COURT: Okay. Mr. Lamb, any reason why we 

shouldn't go that way? 

MR. LAMB: Well, Your Honor, we've already addressed 

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the procedural aspect of the objection, but if we're going to 

proceed to an evidentiary finding under summary adjudication or 

summary judgment, then I don't see any reason to delay it. I 

mean, whenever they want to set it that's at the Court's 

convenience. 

I would just suggest that perhaps counsel can propose 

a briefing schedule, and I can confer with Mr. Rupp if that's 

what we're going to do, if that's what the Court's going to do, 

and then we should address it there. That would be my 

proposal. 

THE COURT: Well, remember, again, we're back to 

bankruptcy procedure. This extended discussion proves that it 

would be improper for me to make a ruling in favor of PG&E on 

this record even though you're confident, Mr. Lamb, that 

perhaps I could. And I don't feel that it would be faithful to 

our procedure when it's clear that there are no facts in 

dispute and therefore it's clear as a matter of law that you 

should win. For example, here, Mr. Jacobson believes it's well

established that there are facts that are not in dispute that 

are in his favor. 

So the correct thing to do, and it's what we would do

even if there had been no state court suit, I would have said, 

okay, let's set it for a trial or summary judgment. And Mr. 

Jacobson knows the procedure. And if I had decided to send 

this thing back to state court, presumably the same process 

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would happen. 

Mr. Lamb, you made a reference to a case called -- you 

said Crone (phonetic). I wasn't familiar with the case. And 

it doesn't matter what it says. The point is, for the reasons 

I've stated, I can't make a ruling in your favor today. 

And Mr. Jacobson is confident that he can establish as 

a matter of law that his client's rights need to be vindicated 

and quantified. And all you have to do is show that he doesn't 

have any rights to quantify and that the law would come out in 

favor of your side and no matter who his claimant is and no 

matter what their version of the facts are.

And I'm going to accommodate people's personal 

schedules, particularly when the matter is complicated like 

this. So I'm going to let Mr. Jacobson file a motion for 

summary judgment. And our rules have a normal procedure. Mr. 

Rupp's quite familiar with the routines of where we set things 

on the PG&E calendar. 

So what I think I'll do is I will give Mr. Jacobson a 

deadline to file his motion for summary judgment on the -- and

I guess it's a partial summary judgment -- I'm entitled to 

damages to be determined for the following reasons, A, B, C. 

Your response would be, you're not entitled to any damages, 

therefore your claim should be disallowed, period. 

And if I tell Mr. Jacobson I'll give you till December 

8th to file the motion, then we'll just set it on the regular 

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calendar for PG&E. I think, Mr. Rupp, you're with me. That 

would be in early January, right? Whatever our first January 

calendar date would be the normal way to set a motion that was 

filed on around December 8th; isn't that correct?

MR. RUPP: Yes, Your Honor, that would be early 

January. I don't want to speak for either Mr. Jacobson or Mr. 

Lamb, who'll be endeavoring to do all this. But it raises the 

issue of subsequent briefing coming up right around and through 

the holidays. But I think whatever date the Court wants to 

set, and if the parties come together and want to agree to make 

changes to those dates, the Court's always been very receptive 

to that. 

THE COURT: And I'll do that -- I'll continue to be 

that way. Mr. Jacobson's a veteran of my procedure, and he 

knows that too. And Mr. Jacobson, I'll let you meet and confer 

with Mr. Lamb to talk about an agreed schedule. 

But why don't we -- why don't we do the following. I 

will say that I'd like to have the procedural schedule resolved 

by the two counsel, and the tentative process will be a motion 

for summary judgment for the claimant to be filed no later than 

December 8th. 

Ms. Parada, what is our next PG&E calendar after 

December 8th? Just call that status conference. It's about 

the 11th, isn't it? No? Hmm? 

THE CLERK: One moment, Your Honor. We have December 

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13th. 

THE COURT: Okay. So Mr. Jacobson and Mr. Lamb, I 

think I'm about to lose my connection here. I'm going to --

I'm going to -- I'm going to just pencil in or put on the 

calendar a continued status conference on this claim objection 

for December 13th, but my hope is that I never have to do that. 

And it's there in case thing gets off track. 

But on the assumption that a motion is filed by 

December 8th, then Mr. Jacobson and Mr. Lamb can work out a 

mutually convenient schedule to accommodate their personal 

needs, their holiday schedules, and everything else. And it'll 

be on our routine and regular law and motion calendar. 

The December 13th date is just a safety valve in case 

this procedural scheduling doesn't work and there's any 

disagreement and we're just there. But if we get a motion on 

file on and an agreed briefing schedule between counsel, we'll

just cancel that December 13th date. Okay. Everybody clear? 

MR. JACOBSON: Yes, Your Honor. 

MR. LAMB: Clear, Your Honor. 

MR. JACOBSON: This is Jacobson. We've made mutual 

accommodations on timing, and I would be confident that we can 

make those arrangements. 

THE COURT: Yeah, that's good. Sounds good to me. 

Okay. Mr. Lamb, thank you for your time. I'll look 

forward --

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MR. LAMB: Thank you, Your Honor. 

THE COURT: -- to hearing from you, and I will 

conclude the matter. 

I'm going to conclude the hearing and -- I can talk to 

my staff. Thank you. Thank you for your time, all counsel. 

MR. JACOBSON: Thank you. 

MR. LAMB: Thank you, Your Honor. 

(Whereupon these proceedings were concluded at 10:33 AM)

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C E R T I F I C A T I O N

I, River Wolfe, certify that the foregoing transcript is a true 

and accurate record of the proceedings.

________________________________________ 

/s/ RIVER WOLFE, CDLT-265

eScribers

7227 N. 16th Street, Suite #207

Phoenix, AZ 85020

Date: October 12, 2022

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Case No. 19-30088 October 11, 2022

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Case No. 19-30088 October 11, 2022

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expertise (2)

 16:11,14

explains (1)

 7:7

expressed (1)

 15:19

expressing (1)

 15:20

extended (1)

 22:12

extinguished (5)

 7:9;10:20;11:2,16;

 12:12

F

faced (1)

 11:11

facie (1)

 18:5

fact (8)

 8:16,16;11:12,17;

 13:13;14:17;20:3,23

facts (10)

 4:9;5:12;14:7,8,12;

 18:4,12;22:16,19;

 23:11

fail (1)

 14:12

faithful (1)

 22:15

familiar (5)

 13:2;14:17,21;23:3,

 16

fault (1)

 4:1

favor (5)

 20:23;22:13,20;23:5,

 10

federal (1)

 18:25

feel (1)

 22:15

file (8)

 9:20;19:9;20:18;

 21:17;23:14,19,25;

 25:16

filed (9)

 5:11,24;10:23;18:17;

 19:15;21:13;24:4,20;

 25:8

files (1)

 18:21

filing (2)

 5:25;6:2

fill (1)

 6:23

finding (1)

 22:2

finish (1)

 20:12

first (10)

 7:2;8:16;12:5,9;

 20:14;21:6,18,21,22;

 24:2

five-page (1)

 15:21

following (3)

 3:23;23:21;24:17

forgot (1)

 21:12

form (1)

 5:21

forward (2)

 18:21;25:25

franchise (1)

 9:22

FRANCISCO (4)

 3:1;6:25;7:8;15:21

frankly (1)

 13:23

front (1)

 17:17

further (1)

 10:10

G

gave (1)

 6:1

general (1)

 12:3

generally (1)

 15:16

gets (2)

 8:22;25:7

giving (1)

 18:16

goes (2)

 8:14;18:23

Good (8)

 3:7,9,12,14,16,18;

 25:23,23

grant (2)

 4:25;17:24

granted (1)

 5:8

great (1)

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 14:18

guess (3)

 19:25;20:1;23:20

guest (1)

 3:21

H

half (1)

 21:18

happen (1)

 23:1

happened (3)

 6:8;12:1;19:3

happens (2)

 11:3;13:23

hear (2)

 4:12;9:4

hearing (3)

 6:3;26:2,4

height (7)

 5:7,17,20;8:24;9:1,3;

 12:3

hell (2)

 14:17;17:18

here's (1)

 14:23

high (1)

 14:19

higher (1)

 5:20

history (4)

 6:4;7:7;17:23;18:16

Hmm (1)

 24:24

hold (1)

 15:25

holiday (1)

 25:11

holidays (1)

 24:9

home (1)

 14:19

Honor (16)

 3:9,13,15,18;10:6;

 11:10,20;12:23;13:21;

 21:25;24:5,25;25:18,

 19;26:1,7

Honorable (1)

 3:4

hope (1)

 25:6

I

identified (2)

 7:3;11:14

identifies (1)

 10:17

identify (1)

 17:14

impact (1)

 11:13

important (1)

 17:17

improper (1)

 22:13

improperly (1)

 8:5

include (1)

 10:22

included (1)

 14:11

inconsistent (1)

 15:6

indicates (1)

 6:21

indiscernible (8)

 6:6,17;7:19;8:17,25;

 9:24;19:17;21:9

individual (1)

 9:14

information (3)

 10:12,21;17:17

initial (1)

 11:7

installed (1)

 5:8

instructions (1)

 3:23

interests (2)

 7:14;16:13

interference (1)

 16:16

invitation (1)

 20:8

involved (1)

 15:23

involves (1)

 17:14

involving (1)

 14:18

irrelevant (1)

 11:13

issue (15)

 4:13;5:18;9:2,3,9,22,

 22;11:25;18:14;19:14,

 19,19;20:14,14;24:8

issues (3)

 6:20;16:17;18:22

J

Jacobson (65)

 3:12,12,14,20,22;4:4,

 20,23;5:2;6:6,14,15,17,

 20;7:23;8:2,6,12,14,22;

 9:10,12,15,20,24;

 10:15;14:5,24;15:14,

 15;16:5,8,11,24;17:2,4,

 6,8,11,13;18:14,19;

 19:12,14,17,20;20:9,

 11,16;21:18,21;22:18,

 24;23:6,14,18,24;24:6,

 15;25:2,9,18,20,20;

 26:6

Jacobson's (1)

 24:14

January (3)

 24:2,2,6

Judge (3)

 3:22;15:15;20:5

judgment (17)

 12:17,21;13:6,17;

 14:9,11;15:11;17:24;

 18:3,15;19:23;22:3,23;

 23:15,19,20;24:20

judicially (1)

 11:8

K

Keller (1)

 3:10

kept (1)

 3:24

Kim (1)

 3:10

kind (1)

 4:19

known (2)

 5:12;19:21

knows (2)

 22:24;24:15

L

LAMB (36)

 3:16,18,19;4:7;9:4;

 10:4,6,6;11:23,25;

 12:20,22,23;13:1,10,

 18,21;14:3,14,25;15:3;

 19:24;21:1,4,23,25;

 22:14;23:2;24:7,16;

 25:2,9,19,24;26:1,7

landscaping (1)

 7:18

largely (1)

 11:12

larger (1)

 5:9

last (2)

 5:3;9:3

later (2)

 4:17;24:20

law (6)

 13:4;20:23;22:17;

 23:7,9;25:12

Lawrence (1)

 3:12

lawyer (3)

 19:21,22,22

leap (1)

 16:23

least (1)

 6:20

leave (3)

 14:4,25;18:8

leaving (1)

 18:6

legal (8)

 5:20;8:16;11:13;

 16:3,4,9;18:14;20:14

legible (2)

 10:22,25

level (1)

 4:17

license (1)

 9:8

limited (1)

 4:9

line (2)

 14:19;16:2

lines (13)

 4:13,14,14,17;5:5,9;

 7:1,21,25;8:3,5,23;

 17:20

lists (2)

 10:16,24

local (1)

 13:4

locate (1)

 6:24

located (2)

 8:23;17:20

location (1)

 7:4

log (1)

 3:22

look (4)

 4:2;11:19;17:22;

 25:24

looked (2)

 11:4;12:15

looking (1)

 14:22

lose (1)

 25:3

lot (1)

 9:5

low (3)

 12:2,8,8

lowered (2)

 5:9;8:5

lowering (6)

 4:16;5:5;11:21,22,

 23,25

M

Mahoney (2)

 6:21;11:3

Mahoney's (5)

 7:5;10:13,19;11:14;

 14:16

Mahony's (1)

 15:17

maintained (1)

 8:24

map (2)

 6:12;10:17

maps (1)

 17:21

massively (1)

 5:8

material (4)

 14:8,12;18:4,12

matter (13)

 3:5;13:4;14:18;

 19:10;20:4,23;22:17;

 23:4,7,10,11,13;26:3

may (2)

 8:19;16:21

maybe (6)

 4:1;9:7;13:14;19:25;

 20:24,24

mean (15)

 6:5,8;9:9;12:17,22;

 13:16;14:16;16:6,20,

 22;18:25;19:4,24;20:2;

 22:4

measure (1)

 18:6

measuring (1)

 20:25

meet (2)

 21:7;24:15

met (1)

 15:4

mine (1)

 14:10

minute (1)

 12:25

missing (1)

 17:17

moment (1)

 24:25

Montali (1)

 3:5

more (2)

 3:15;9:2

morning (7)

 3:7,9,12,14,16,18;

 19:21

motion (22)

 12:16,21;13:6,17;

 14:11;15:1;18:2,15;

 19:1;20:15,18;21:5,9,

 17;23:14,19,25;24:3,

 19;25:8,12,15

motions (1)

 4:5

move (1)

 8:7

mutual (1)

 25:20

mutually (1)

 25:10

N

name (3)

 3:21;9:21;21:12

necessary (1)

 4:10

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need (3)

 10:10;15:12;23:7

needs (1)

 25:11

next (1)

 24:22

nobody (1)

 19:6

normal (2)

 23:15;24:3

noted (1)

 10:17

notice (2)

 6:1;21:14

November (1)

 21:19

number (1)

 10:12

O

object (1)

 19:9

objection (10)

 4:4;6:10;9:25;10:23,

 24;13:3,24;15:4;22:1;

 25:5

obtained (1)

 10:23

obviously (1)

 6:8

occurred (1)

 11:25

OCTOBER (1)

 3:1

Off (2)

 16:17;25:7

once (1)

 13:23

one (15)

 3:15;5:1;6:10,13,21;

 9:13,25;15:7;16:24;

 17:2,16;18:3,8;19:12;

 24:25

ones (2)

 7:17,17

only (1)

 9:21

oOo- (1)

 3:2

opine (1)

 16:21

orally (1)

 20:19

order (2)

 3:3;12:3

ordinance (6)

 7:10;10:15;11:1,6;

 12:11;15:22

ought (3)

 4:21,24,25

out (7)

 7:24;10:11;11:17;

 14:15;20:25;23:9;25:9

over (1)

 8:10

owner (1)

 13:11

owns (1)

 18:9

P

pages (1)

 7:6

paper (1)

 9:5

papers (6)

 4:3,12,18;10:3;21:2,

 3

Parada (1)

 24:22

paragraphs (1)

 15:24

parse (1)

 14:15

part (1)

 11:15

partial (1)

 23:20

particular (2)

 5:20;6:5

particularly (1)

 23:13

parties (2)

 6:1;24:10

party (1)

 10:9

passionate (1)

 20:19

paved (1)

 7:19

pay (1)

 9:7

pencil (1)

 25:4

pending (1)

 14:18

people's (1)

 23:12

perfectly (2)

 15:19;19:8

perhaps (4)

 14:20;18:6;22:6,15

period (1)

 23:23

permission (1)

 5:8

personal (3)

 19:19;23:12;25:10

perspective (2)

 5:13;16:12

petition (1)

 6:1

PG&E (14)

 3:5,7,17,19;4:15;5:8,

 21,24;15:25;17:19;

 22:13;23:17;24:1,22

phonetic (4)

 6:21;7:25;15:8;23:3

physically (1)

 19:15

picture (1)

 5:3

place (3)

 8:16;12:6,9

plaintiff (1)

 18:21

plat (2)

 6:12;10:17

pleading (1)

 5:13

please (1)

 3:8

pleased (1)

 9:20

Plice (1)

 15:8

point (13)

 4:7,17;5:3,13;6:9;

 7:2;8:13;10:11;15:12;

 19:3,18;20:22;23:4

pointed (1)

 11:17

poor (1)

 20:5

portion (1)

 20:6

position (11)

 4:21;10:19;11:3,9,

 15,18;12:5;15:3,17,18;

 18:7

positions (2)

 11:8;15:17

power (5)

 4:14,17;14:19;16:1;

 17:20

powerful (1)

 14:19

powerlines (1)

 18:10

practice (2)

 18:25;19:17

predecessor (3)

 7:11,12,16

preferred (1)

 20:11

preliminarily (1)

 15:16

prepared (3)

 14:6;16:15;20:15

prescriptive (2)

 5:21;8:19

present (2)

 13:25,25

presented (2)

 6:13;16:16

presiding (1)

 3:5

presumably (1)

 22:25

prima (1)

 18:5

prior (1)

 15:7

problems (1)

 3:25

procedural (6)

 6:4;19:12,19;22:1;

 24:18;25:14

procedurally (3)

 15:12;19:8;20:21

procedure (6)

 18:20;22:12,16,24;

 23:15;24:14

procedures (1)

 13:3

proceed (1)

 22:2

proceedings (1)

 26:8

process (6)

 15:23;16:14;17:14;

 20:13;22:25;24:19

procure (1)

 5:14

produced (1)

 17:19

promptly (1)

 5:11

proof (3)

 14:5;19:15;21:13

proper (1)

 19:8

properly (1)

 5:1

properties (1)

 5:6

property (14)

 4:14;5:10;6:22;7:2,

 15,21,22;8:10,10;16:2;

 18:9,10,10;21:15

proposal (1)

 22:10

propose (1)

 22:6

prove (2)

 12:18;14:6

proves (1)

 22:12

provided (2)

 8:4;12:13

provides (1)

 10:25

put (5)

 13:16;18:1;19:24;

 20:2;25:4

puts (1)

 20:13

Q

qualified (2)

 16:9,21

quantified (1)

 23:8

quantify (1)

 23:9

quickly (1)

 20:5

quite (2)

 11:25;23:16

R

raises (2)

 5:18;24:7

rather (1)

 4:15

read (1)

 7:5

ready (1)

 14:6

realize (1)

 20:2

really (9)

 11:6,10,18,20;12:4;

 14:1,3;17:16;18:25

reason (5)

 7:9;13:16;18:16;

 21:23;22:3

reasons (2)

 23:4,21

rebut (1)

 14:24

receptive (1)

 24:11

recital (1)

 6:7

recitation (1)

 14:13

reconveyed (1)

 14:23

record (15)

 5:14,16;6:12,19;7:1;

 8:21;11:5,12,15;15:25;

 16:13,15,17,22;22:14

recorded (2)

 6:12;16:1

recording (1)

 16:18

records (2)

 6:11;17:22

reference (1)

 23:2

referred (1)

 10:15

refers (1)

 10:14

reflects (1)

 10:18

regard (1)

 12:1

regarding (2)

 10:9;15:10

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regular (2)

 23:25;25:12

reinstate (1)

 9:8

related (1)

 5:4

relevance (1)

 6:5

relief (5)

 4:5,25;19:6;20:18,20

relies (1)

 10:21

relocated (5)

 7:9;10:20;11:1,16;

 12:11

relocation (1)

 11:24

rely (1)

 13:22

remember (1)

 22:11

removed (1)

 8:4

reorganized (1)

 3:10

report (8)

 7:5,6;10:13,14,14,16,

 19;15:20

representing (1)

 19:21

request (2)

 10:12,22

resolved (2)

 13:13;24:18

respond (1)

 14:3

responded (2)

 11:10;12:8

response (7)

 10:13,19,22,23;14:7;

 20:8;23:22

reviewed (1)

 17:15

reviewing (1)

 4:12

right (7)

 3:20;8:10;10:4;13:6,

 12;24:2,8

rights (9)

 4:15,16;5:16,19,19;

 7:14;21:15;23:7,9

routine (1)

 25:12

routines (1)

 23:16

rules (2)

 13:4;23:15

ruling (2)

 22:13;23:5

RUPP (13)

 3:9,9,15,17;4:7;9:4;

 10:4;13:22;14:17;21:4;

 22:7;24:1,5

Rupp's (1)

 23:16

S

safety (1)

 25:13

same (4)

 15:19;18:25;19:2;

 22:25

SAN (4)

 3:1;6:25;7:8;15:21

saw (1)

 3:21

saying (2)

 8:3;12:7

schedule (5)

 22:7;24:16,18;25:10,

 16

schedules (2)

 23:13;25:11

scheduling (1)

 25:14

seem (1)

 4:13

seems (2)

 5:21;18:7

send (3)

 13:15;20:7;22:24

sent (1)

 20:25

series (1)

 10:16

session (1)

 3:4

set (10)

 5:12;16:23,25;17:3;

 22:4,23;23:16,25;24:3,

 10

shifted (1)

 15:5

shifts (1)

 13:24

ship (1)

 19:10

show (3)

 11:5;20:22;23:8

showed (1)

 12:13

shows (3)

 6:12;7:1;17:19

sic (1)

 8:9

side (1)

 23:10

sides (1)

 4:12

simply (1)

 15:6

sixty (1)

 8:20

sixty- (1)

 8:24

skills (1)

 20:17

sliver (1)

 7:18

smaller-based (1)

 5:6

somebody (1)

 21:15

somebody's (1)

 14:19

somehow (1)

 16:18

Sorry (2)

 17:4;21:12

sort (1)

 20:24

sought (1)

 19:6

sound (2)

 16:3,4

Sounds (1)

 25:23

speak (1)

 24:6

spent (1)

 9:5

staff (1)

 26:5

standing (1)

 18:9

standpoint (1)

 5:23

start (2)

 4:20;5:2

started (3)

 12:7;14:16;20:13

state (12)

 5:11;6:1;7:8;9:8;

 13:15;18:16,20;19:11,

 14;20:12;22:22,25

stated (3)

 8:13;15:24;23:5

statement (3)

 6:23;11:7;14:16

states (1)

 10:25

status (3)

 17:24;24:23;25:5

stay (5)

 4:5,25;19:6;20:18,20

stayed (1)

 19:5

Steve (1)

 10:6

Steven (1)

 3:18

still (1)

 6:19

stopped (1)

 16:18

stretch (1)

 16:20

subject (5)

 14:20;17:10;20:6;

 21:7,16

submit (1)

 15:6

submits (1)

 11:4

submitted (2)

 4:3;11:9

subsequent (2)

 11:4;24:8

substituted (1)

 9:6

suggest (1)

 22:6

suit (1)

 22:22

summary (18)

 12:17,21;13:6,17;

 14:8,11;15:10;17:24;

 18:3,15;19:23;22:2,3,

 23;23:15,19,20;24:20

supports (1)

 15:23

sure (3)

 8:2;11:25;13:10

survey (7)

 5:14;7:1;10:14;11:5,

 12;16:15;17:22

surveying (1)

 17:14

surveyor (7)

 5:15;6:11,21;8:8;

 16:6,15,21

surveyors (1)

 16:7

surveyor's (1)

 16:12

suspect (1)

 9:7

suspension (1)

 9:22

sustain (1)

 15:3

T

talk (2)

 24:16;26:4

talking (2)

 16:19;21:13

tax (1)

 9:22

technical (1)

 16:17

telling (1)

 3:24

ten (1)

 15:22

tentative (1)

 24:19

terms (1)

 17:18

testify (1)

 8:8

theory (1)

 5:20

therefore (2)

 22:17;23:23

Thomas (1)

 3:9

though (2)

 15:11;22:14

three (2)

 19:6;20:17

till (1)

 23:24

timing (2)

 5:23;25:21

title (3)

 5:15;7:17;15:22

today (8)

 3:8,25;4:21;6:5,9;

 10:5;15:2;23:5

together (3)

 10:24;13:17;24:10

told (1)

 18:2

took (2)

 6:2;7:16

towers (4)

 4:14;5:6,9;18:10

traceable (1)

 15:25

track (1)

 25:7

traditional (1)

 13:13

transmission (2)

 7:1;16:1

trespass (3)

 18:19,20;20:24

trial (7)

 14:6,20;16:25;17:1,

 5;18:23;22:23

tried (2)

 3:22;12:2

true (1)

 19:25

trying (1)

 20:2

tucked (1)

 20:20

TUESDAY (1)

 3:1

twelve (1)

 15:22

two (4)

 6:12,20;21:8;24:19

U

ultimate (1)

 16:21

under (3)

 5:19;13:3;22:2

unidentified (1)

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PG&E Corporation 

Case No. 19-30088 October 11, 2022

 3:21

unless (1)

 21:4

unnecessary (1)

 20:3

up (4)

 7:18;9:24;14:24;

 24:8

upon (2)

 5:12;14:13

use (2)

 5:10,21

used (1)

 14:21

V

value (1)

 5:10

valve (1)

 25:13

version (1)

 23:11

veteran (1)

 24:14

view (3)

 4:8;18:11;21:5

vindicated (1)

 23:7

violated (1)

 4:15

W

wait (3)

 7:20;12:24;17:3

wants (1)

 24:9

waste (1)

 14:10

way (6)

 4:3;11:2;20:21;

 21:24;24:3,14

week (2)

 21:21,22

weren't (1)

 11:1

what's (2)

 4:21;20:8

whenever (1)

 22:4

Whereupon (1)

 26:8

wherever (1)

 6:24

who'll (1)

 24:7

whomever (1)

 4:16

Who's (1)

 3:7

win (3)

 13:12;14:8;22:18

withdrawing (1)

 6:2

withdrawn (1)

 19:1

withdrew (1)

 19:4

without (1)

 15:7

witness (3)

 17:5,6,9

words (1)

 18:4

work (2)

 25:9,14

worry (1)

 20:5

writing (1)

 20:19

wrong (1)

 13:12

Y

year (1)

 8:25

years (3)

 8:20;19:6;20:17

1

10:33 (1)

 26:8

101 (1)

 7:25

11 (2)

 3:1;15:20

11th (2)

 7:6;24:24

12131-4 (1)

 10:13

12b6 (1)

 19:1

13 (1)

 15:24

13th (4)

 25:1,6,13,17

14 (1)

 15:24

15 (1)

 15:24

16 (1)

 15:24

1923 (3)

 6:13;7:17;17:23

2

2000 (1)

 6:25

2018 (6)

 5:4,7,24;6:8;15:20;

 18:17

2019 (1)

 5:25

2022 (1)

 3:1

2380 (1)

 7:25

3

3975 (5)

 10:15,21,22;11:6;

 12:11

4

4 (1)

 7:6

8

8 (1)

 7:6

8th (5)

 23:25;24:4,21,23;

 25:9

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(6) unless - 8th Case: 19-30088 Doc# 13063 Filed: 10/12/22 Entered: 10/12/22 13:14:54 Page 33

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