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 DEBTOR’S 

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

TO APPROVE STIPULATION BETWEEN DEBTOR 

PACIFIC GAS AND ELECTRIC COMPANY AND 

KATHLEEN PELLEY AND ALLAN PELLEY 

REGARDING MODIFICTION OF AUTOMATIC STAY 

Objection Deadline: October 2, 2019 

 4:00 pm (Pacific Time) 

No hearing requested absent timely objection. If timely 

objection is filed, hearing reserved for:

Date: October 22, 2019 

Time: 9:30 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# 3876 Filed: 09/11/19 Entered: 09/11/19 10:15:14 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 Utility’s Motion Pursuant to Fed. R. Bankr. P. 

4001(d) to Approve Stipulation Between Debtor and Kathleen Pelley and Allan Pelley Regarding 

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 December 30, 1998, Kathleen Pelley has had an ownership 

interest in the real property commonly known as 3906 Pennsylvania Avenue, Eureka, California, and 

more particularly identified as Assessor’s Parcel Number 016-172-007 (the “3906 Property”). 

Since on or around January 10, 2017, Kathleen Pelley has also been the owner in fee simple of an 

undivided fifty percent interest the real property commonly known as 3970 Pennsylvania Avenue, 

Eureka, California, and more particularly identified as Assessor’s Parcel Number 016-172-008 (the 

“3970 Property,” and, together with the 3906 Property, the “Property”). Since on or around 

January 10, 2017, Allan Pelley has been the owner in fee simple of the other undivided fifty percent 

interest the 3970 Property. 

4. Pursuant to an easement agreement created on August 23, 1945 and recorded on 

August 28, 1945 in the Official Records of the Humboldt County at Book 276 of Deeds, page 43 (the 

“1945 Easement”), the Utility owns an easement that gives it the right to install and use an 

underground gas transmission pipeline with necessary valves and other appliances within a ten foot 

wide strip of land located on the Property. Pursuant to an easement agreement dated January 11, 

1958 and recorded on January 24, 1958 in the Official Records of the Humboldt County at Volume 

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

Case: 19-30088 Doc# 3876 Filed: 09/11/19 Entered: 09/11/19 10:15:14 Page 2 of

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

476, page 225 (the “1958 Easement,” and, collectively with the 1945 Easement, the “Easement”), 

the Utility has the right to install and use an underground gas transmission pipeline, with necessary 

valves and other appliances, within a ten foot wide strip of land “contiguous to and northerly of the 

northern boundary line” of the 1945 Easement. 

5. 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 

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. 

6. Since 2016, the Utility has been working with the Pelleys to obtain their cooperation 

to remove the Incompatible Trees, without success. 

7. The Utility has a business need—namely, the removal of the Incompatible Trees—to 

confirm and protect, as promptly as possible, its rights under the Easement. 

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