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DOWNEY BRAND LLP 

Jamie P. Dreher (Bar No. 209380) 

621 Capitol Mall, 18th Floor 

Sacramento, CA 95814 

Telephone: (916) 444-1000 

Facsimile: (916) 444-2100 

Attorneys for 

Teichert Pipelines, Inc. and A. Teichert &Sons, Inc. 

d/b/a Teichert Aggregates 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

and 

PACIFIC GAS AND ELECTRIC COMPANY, 

Debtors. 

❑ Affects PG&E Corporation 

❑ Affects Pacific Gas and Electric Company 

D Affect both Debtors 

Case Nos.: 

19-30088 (DM) —Lead Case 

19-30089 (DM) 

Chapter 11 Case 

NOTICE OF CONTINUED 

PERFECTION OF MECHANICS 

LIEN PURSUANT TO 11 U.S.C. § 

546(b)(2) 

TEICHERT PIPELINES, Inc. ("TEICHERT"), by and through its undersigned 

counsel, hereby gives notice of continued perfection of its mechanics lien under 11 U.S.C. 

§ 546(b)(2), as follows: 

1. TEICHERT is a corporation that has provided and delivered labor, services, 

equipment, and/or materials for a work of improvement located in the County of 

Sacramento, State of California (the "Pro~ert~"~ and owned by PG&E Corporation and/or 

1564709.1 1 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 1 of NOTICE OF CONTINUED PERFECTION OF MECHANICS LIEN PURSUANT TO 1 I U.S.C. § 546 

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Pacific Gas and Electric Company (collectively, the "Debtors" . 

2. Through June 26, 2019, the amount owing to TEICHERT is at least 

$672,877.22, exclusive of accruing interest and other charges, with additional amounts owed 

and accrued after June 26, 2019. 

3. Teichert properly perfected its mechanics lien under California Civil Code §§ 

8400, et seq. by timely recording its Mechanics Lien (Claim of Lien) in the Official Records 

of Sacramento County, State of California, as more fully described in its Mechanics Lien, a 

true copy of which is attached hereto as E~iibit A, on or about June 27, 2019. 

4. Pursuant to California Civil Code § 8460, an action to enforce a lien must be 

commenced within 90 days after recordation of the claim of lien. However, due to the 

automatic stay set forth in 11 U.S.C. § 362, TEICHERT is precluded from filing a state court 

action to enforce its mechanics lien. 11 U.S.C. § 546(b)(2) provides that when applicable law 

requires seizure of property or commencement of an action to perfect, maintain, or continue 

the perfection of an interest in property, and the property has not been seized or an action has 

not been commenced before the bankruptcy petition date, then the claimant shall instead give 

notice within the time fixed by law for seizing the property or commencing an action. See 

11 U.S.C. § 546(b)(2); see also In re Baldwin Builders (Village Nurseries v. Gould~232 B.R. 

406, 410-411 (9'~' Cir. 1999); Village Nurseries v. Greenbaum, 101 Cal.App.4~' 26, 41 (Cal. 

Ct. App. 2002).) 

5. Accordingly, TEICHERT hereby provides notice of its rights as a perfected 

lienholder in the Property pursuant to California's mechanics lien law. TEICHERT is filing 

and serving this notice to preserve, perfect, maintain, and continue the perfection of its lien 

and its rights in the Property to comply with the requirements of California state law, 11 

U.S.C. §§ 362(a), 362(b}(3), and 546(b)(2), and any other applicable law. This notice 

constitutes the legal equivalent of having commenced an action to foreclose the lien in the 

proper court. By this notice, the Debtors and other parties in interest are estopped from 

claiming that the lawsuit to enforce TEICHERT's mechanics lien was not timely commenced 

pursuant to applicable state law. TEICHERT intends to enforce its lien rights to the fullest 

1564709.1 2 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 2 of NOTICE OF CONTINUED PERFECTION OF MECHANICS LIEN PURSUANT TO I 1 U.S.C. § 546 

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extent permitted by applicable law. The interests perfected, maintained, or continued by 

11 U.S.C. § 546(b)(2) extend in and to the proceeds, products, offspring, rents, or profits of 

the Property. 

6. The filing of this notice shall not be construed as an admission that such filing 

is required under the Bankruptcy Code, the California mechanics lien law, or any other 

applicable law. In addition, TEICHERT does not make any admission of fact or law, and 

TEICHERT asserts that its lien is senior to and effective against entities that may have 

acquired rights or interests in the Property previously. 

7. The filing of this notice shall not be deemed to be a waiver of TEICHERT's 

right to seek relief from the automatic stay to foreclose its mechanics lien and/or a waiver of 

any other rights or defenses. 

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

this notice. 

DATED: June 28, 2019 DOWNEY BRAND LLP 

By: /s/Jamie P. Dreher 

JAMIE P. DREHER 

Attorney for 

TEICHERT PIPELINES,INC. AND 

A. TEICHERT &SONS, 1NC. D/B/A TEICHERT 

AGGREGATES 

15647091 3 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 3 of NOTICE OF CONTINUED PERFECTION OF MECHANICS LIEN PURSUANT TO 11 U.S.C. § 546 

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Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 4 of

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20~9062~0$91 

RECORDING REQU~STEO BY 

REQUESTED BY SCOTT MCELHERf\E 

WHEN RECQRQED MAIL TO 

NAME dOWNEY BRAND LLP 

MAILING Scott McElhem 

ADDRESS 621 Capitol Ma11, 18th Floor 

Sacramento, CA 95814 

PHClhlE (916} 4441000 

NUMBEt~ 

o~r~~~a~ 

Accepted far R~ct~rdirig 

CQPY-NpT C~i~Ti~iED 

CLAIM OF MECHAIITICS L~'EN 

(CsL Civ. Cody ~ 8416) . 

Sacramento County 

Clerk-Recorder 

1. Teichert Pipelines, Iona ("Claimant"} olaims a mechanics lien for tie labor, services, equipment and/or 

tnateriaLs desczabed in Paragraph 2, fiunished fir a Pacific des &Electric Compacty work of improvement located in 

the City of Sacramenttr, County of Sacramento, State of California, and mare particularly described as follows: 

Gas mainlines and gas service lines for the loc~ions listed an the at~ched Exhibit A. 

2. After deducting all just credits and offsets, the s~mn of ~672,8?7.22, plus interest accrued end acciving 

thererni at the maximum legal rate, is due Claimant for the following generally descn'bed labor, materials, services, 

andlor equipment construction and instaliatian of a~nch low pressure plastic gas main; gas service replaceme~s; 

and deactivation of 6-inch, 4-inch, and 3-inch low press~e gas main. 

3. Claimant #anaished the work and materials at the request of and under contract with Pacific Gas &Electric 

Company, 77 Beale Street, 32nd Floor, San Francisco, CA 94105. 

4. The.name snd address o£the owner or reputed owner of the improvements is Pacific Gas ~ Etectric 

Company, 77 Beale Street, 32nd Flonr, San Francisco, CA 94105. Claimant asserts this lien on the distinct anct 

vested property rights of Pacific Gras &Electric Company in the improvements, and not on the interest of any 

private or public fce owners. 

5. Claimant's address is: 3500 American River Drive, Sacramento, CA 95864. 

DATED: ,~~ TEICHERTP~I'FL. , INC. 

• $y,

llins, GYectit Manager 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 5 of

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VERIFICATION 

T, Sean Collins, am the Credit Manager of Teichert Pipelines, Inc., and am authorized to make this verification for 

and an its behalf. I have read the foregoing claim of mechanics lien and know the contents of the clazm of 

mechanics lien to be true of my own knowledge. 

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 

DATED: ~Q ~~ TEICHERT 

~: er~r~j~~ririri~ .,,~, _ . 

-. 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 6 of

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EXHIBIT A 

101 4th Avenue, Sacramento, CA 95818 

1703 4th Avenue, Sacramento, CA 95818 

1'705 4th Avenue, Sacramento, CA 95818 

1600 4th Avenue, Sacramento, CA 9581$ 

16Q4 4th Avenue, Sacramento, CA 95818 

1608 4th Avenue, Sacramento, CA 95818 

1612 4th Avenue, Sacramento, CA 95818 

1616 4th Avenue, Sacramento, CA 95 $18 

1620 4th Avenue, Sacramento, CA 95818 

2900 17th Sfireet, Sacramento, CA 95818 

2929 Marty VVay, Sacramento, CA 95818 

1609 Vallejo Way, Sacramento, CA 9581$ 

1613 Vallejo Way, Sacramento, CA 95818 

1617 Vallejo Way, Sacramento, CA 95818 

1621 Vallejo Way, Sacramento, CA 95818 

1709 4#h Avenue, Sacramento, CA 95818 

1717 4th Avenue, Sacramento, CA 9581$ 

2725 4th Avenue, Sacramento, CA 95818 

1733 4th Avenue, Sacramento, Ct3 95818 

1741 4th Avenue, Sacramento, CA 95818 

1755 4th Avenue, Sacramento, CA 95818 

287Q 18th Street, Sacramento, CA 95818 

1801 4th Avenue, Sacramento, CA 95818 

1809 4th Avenue, Sacramento, CA 45818 

1817 4th Avenue, Sacramento, CA 95818 

1$314th Avenue, Sacramento, CA 95818 

1833 4th Avenue, Sacramento, CA 95818 

1841 4th. Avenue, Sacramento, CA 95818 

1844 4th Avenue, Sacramento, CA 95818 

1857 4th Avenue, Sacramento, CA 95818 

1700 4th Avenue, Sacramento, CA 95818 

1724 4th Avenue, Sacramento, CA 95818 

1732 4th Avenue, Sacramento, CA 95818 

1?40 4th Avenue, Sacramento, CA 95818 

1748 4th Avenue, Sacramento, CA 95818 

1756 4th Avenue, Sacramento, CA 95818 

1764 4th Avenue, Sacramento, CA 95$18 

1800 4th Avenue, Sacramento, CA 95818 

1810 4th Avenue, Sacramento, CA 95818 

1822 4th Avenue, Sacramento, CA 95818 

1832 4th Avenue, Sacramento, CA 9581 S 

1840 4th Avenue, Sacramento, CA 45 S 1$ 

1848 4th Avenue, Sacramento, CA 95818 

1862 4th Avenue, Sacramento, CA 95818 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 7 of

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Nt~TICE OF MECHAl~ICS LIEN CLAIM 

ATTENTION! 

Upon the recording of the enclosed MECHANICS LIEN with the county recorder's 

office of the county where the property is located, your property is subject to the filing of a 

legal action seeking acourt-ordered foreclosure sale of the real property on which the lien 

has been recorded. That legal action must be filed with the court no later than 90 days 

after the date the mechanics lien is recorded. 

The party identified in the enclosed mechanics lien may have provided labor or 

materials far improvements to your property and may not have been paid for these items. 

You are receiving this notice because it is a required step in filing a mechanics lien 

foreclosure action against your property. The foreclosure action will seek to pay for 

unpaid labor, materials, or improvements provided to your property. This may affect your 

ability to borrow against, refinance, or sell the property until the mechanics lien is released. 

BECAUSE THE LIEN AFFECTS YOUR PROPERTY, YOU MAY WISH TO 

SPEAK WITH YOUR CONTRACTOR IMMEDIATELY, OR CONTACT AN 

ATTORNEY, OR FOR MORE INFORMATION ON MECHANICS LIENS GO TO THE 

CC)NTRAC~'t3RS' STATE LICENSE BOARD WEB SITE. AT www.clb.ca.gov. 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 8 of

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I, Sandy Russell declare: 

On June 27, 2019, at Sacramento, California, I served. the enclosed: 

CLAIM OF MECHANIC'S LIE1rT 

by enclosing true and correct copies thereof in sealed envelopes, with postage thereon fully 

prepaid, using one of the following described mailing methods: 

Registered Mail, Return Receipt Requested; 

Certified Mail, Return Receipt Requested 

Express Mail; ar 

Overnight delivery by an express service carrier. 

The envelope was addressed as follows: 

Pacific Gas &Electric Company 

77 Beale Street, 32nd Floor 

San Francisco, CA 94105 

I declare under penalty of perjury under the laws of the State of California that the foregoing is 

true and correct. 

Signed on June 27, 2019, at Sacramento, California. 

~l E ~ ~ ~~ /I ~ ~~ . it ~ __....1. - - y 

~~ 

:~. 

1522ISS.1 

Case: 19-30088 Doc# 2799 Filed: 07/01/19 Entered: 07/01/19 10:55:11 Page 9 of

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