Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF JOSEPH ECHOLS ISO MOTION 

PURSUANT TO FED. R. BANKR. P. 4001(d) TO 

APPROVE STIPULATION BETWEEN DEBTORS AND 

MICHAEL S. DANKO AND MARY S. DANKO FOR 

MODIFICTION OF AUTOMATIC STAY 

Objection Deadline: October 25, 2019 

 4:00 pm (Pacific Time) 

 

No hearing requested absent timely objection. If timely 

objection is filed, hearing reserved for:

Date: November 13, 2019 

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

Place: United States Bankruptcy Court 

Courtroom 17, 16th Floor 

 San Francisco, CA 94102

Debtors.

 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# 4134 Filed: 10/04/19 Entered: 10/04/19 13:26:58 Page 1 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

I, Joseph Echols, hereby declare under penalty of perjury pursuant to section 1746 

of title 28 of the United States Code that the following is true and correct to the best of my 

knowledge, information, and belief: 

1. I am the Manager at Pacific Gas and Electric Company responsible for the 

implementation of the Community Pipeline Safety Initiative and am authorized to make this 

Declaration in that capacity. 

2. I file this Declaration in support of the Debtors’ Motion Pursuant to Fed. R. Bankr. P. 

4001(d) to Approve Stipulation Between Debtors and Michael S. Danko and Mary S. Danko for 

Modification of Automatic Stay (the “Motion”).1 Except as otherwise indicated, all statements in 

this Declaration are based on my personal knowledge, and, if called upon to do so, I could and 

would testify competently thereto. 

3. Since on or around April 30, 2003, the Dankos have been the owners in fee simple of 

the residential real property identified as San Mateo County Assessor’s Parcel Numbers 068-205-

050 and 068-205-040 (together, the “Property”). 

4. The Utility has at all times since February 14, 1947 owned an easement that gives it 

the right to excavate for, install, replace, maintain, and use an underground gas transmission pipeline 

within a 7.5 foot-wide strip of land located along the northern boundary line of the Property (the 

“Easement”). The Utility constructed a 24-inch diameter, high-pressure natural gas transmission 

pipeline within the Easement (the “Pipeline”), and the Utility continues to operate and maintain the 

Pipeline to transport natural gas to serve its customers. 

5. The Dankos have caused or permitted to be erected or constructed, and have 

maintained, a shed and a chicken coop on the Easement (collectively, the “Structures”). The 

Property also contains certain trees that the Dankos have caused or permitted to be planted and grow 

and maintained on the land subject to the Easement (the “Incompatible Trees”). 

6. Due to various factors, such as their size, species, and distance to the pipeline, the 

Incompatible Trees interfere with the Utility’s use of the land subject to the Easement in ways 

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 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Motion. 

Case: 19-30088 Doc# 4134 Filed: 10/04/19 Entered: 10/04/19 13:26:58 Page 2 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

including, but not limited to, potentially damaging the Utility’s underground pipe and pipeline, 

impeding maintenance crews, and interfering with inspections required by regulatory authorities. 

7. Since late 2015, the Utility has attempted to work with the Dankos to obtain their 

cooperation to remove the Structures and the Incompatible Trees, without success. 

8. The Utility has a business need—namely, the removal of the Structures and the 

Incompatible Trees—to confirm and protect, as promptly as possible, its rights under the Easement. 

Case: 19-30088 Doc# 4134 Filed: 10/04/19 Entered: 10/04/19 13:26:58 Page 3 of

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