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

-1- SMRH:4821-9263-6569.1 NOTICE

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

A Limited Liability Partnership

Including Professional Corporations

ORI KATZ, Cal. Bar No. 209561

okatz@sheppardmullin.com

MICHAEL M. LAUTER, Cal. Bar No. 246048

mlauter@sheppardmullin.com

Four Embarcadero Center, 17th Floor

San Francisco, California 94111-4109

Telephone: 415.434.9100

Facsimile: 415.434.3947

Counsel for Creditor, Citigroup Financial 

Products Inc.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E Corporation 

-andPacific Gas and Electric Company, 

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

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

NOTICE OF CONTINUED 

PERFECTION OF LIEN PURSUANT 

TO 11 U.S.C. § 546(b(2)

Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 1 of

9
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

-2- SMRH:4821-9263-6569.1 NOTICE

§ 

Citigroup Financial Products Inc. (“Citigroup”), as assignee of Campos EPC, LLC 

(“Campos”), by and through its undersigned counsel, hereby gives notice of continued 

perfection of its mechanics lien under 11 U.S.C. § 54(b)(2), as follows: 

1. Campos is a counterparty to certain contracts, work orders, and related

agreements (the “Agreements”) for engineering design and construction work related to 

Pacific Gas and Electric Company’s utility services in California. Pursuant to work 

performed by Campos pursuant to the Agreements, Campos is owed no less than 

$787,397.39, plus applicable interest. 

2. Pacific Gas and Electric Company (the “Debtor”) filed a voluntary petition

for relief under Chapter 11 of the Bankruptcy Code on January 29, 2019 (the “Petition 

Date”). 

3. Campos 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 the County of San Joaquin on March 27, 2019, as more fully described in its 

Mechanics Lien, a true copy of which attached hereto as Exhibit A. 

4. Pursuant to California 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, Citigroup is precluded from filing a state court 

action to enforce the mechanics lien. Pursuant to 11 U.S.C. 546(b)(2), 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. 

5. Accordingly, Citigroup hereby provides notice of its right as a perfected lien

holder pursuant to California’s mechanics lien law. 

6. This Notice shall not be construed as an admission that such filing is

required or to the necessity of recording, commencement or seizure. Additionally,

Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 2 of

9
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

-3- SMRH:4821-9263-6569.1 NOTICE

Citigroup gives notice that it has, or may be entitled to, additional mechanics’ liens rights 

to properties owned by the Debtor as they become due and owing according to prepetition 

contracts with the Debtor for improvements of real property. This Notice shall preserve 

and continue to preserved any and all of Citigroup’s rights as to the Bankruptcy Code and 

the California Civil Code. 

7. Citigroup expressly reserves its right to seek relief from the automatic stay to 

foreclose the mechanics lien and/or a waiver of any other rights or defenses. Citigroup 

further reserves the right to amend or supplement this notice. 

Dated: June 13, 2019

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

By /s/ Michael Lauter

ORI KATZ

MICHAEL LAUTER

Counsel for Citigroup Financial Products Inc.

Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 3 of

9
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

-1- SMRH:4821-9263-6569.1

EXHIBIT A

Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 4 of

9
Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 5 of

9
Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 6 of

9
Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 7 of

9
Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 8 of

9
Case: 19-30088 Doc# 2533 Filed: 06/14/19 Entered: 06/14/19 11:01:52 Page 9 of

9