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JAMES A. SHEPHERD - SBN 264400

LAW OFFICES OF JAMES SHEPHERD 

3000 Citrus Circle, Suite 204

Walnut Creek, CA 94598 

tel (925) 954-7554 

fax (925) 281-2341 

email: jim@elkshep.com

Attorneys for Creditor-Lienholder

W. BRADLEY ELECTRIC, INC.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re 

PG&E CORPORATION, INC,

Debtor in Possession. __________________________________

In re 

PACIFIC GAS AND ELECTRIC

COMPANY,

Debtor in Possession.

9 Affects PG&E Corporation

: Affects Pacific Gas and Electric

Company

9 Affects both Debtors

* All papers shall be filed in the Lead

Case, No. 19-30088 (DM)

__________________________________

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Chapter 11

Case No. 19-30088 (DM)

(Lead Case)

(Jointly Administered)

THIRD NOTICE OF CONTINUED

PERFECTION OF MECHANICS

LIENS UNDER 11 U.S.C. § 546(b)(2)

BY THIS THIRD1

 NOTICE IS HEREBY GIVEN that W. BRADLEY ELECTRIC, 

INC. (“WBE”), is a party under a certain pre-petition contract with Pacific Gas and Electric

Company (“PG&E”) and a subcontractor under certain pre-petition agreements with Roebbelen

Contracting, Inc., which was or is a general contractor under certain related general contract

agreements with PG&E (collectively, “WBE Contracts”), including but not limited to PG&E’s

agreements with the respective referenced general contractors as specified in Schedule G in this

case [Docket No. 907], as such subcontracts and general contracts may have been amended and

1 Notices of continued perfection of mechanics liens were filed previously by the same creditor at Docket

Nos. 1664 and 2586. Case: 19-30088 Doc# 4873 Filed: 11/26/19 Entered: 11/26/19 17:34:02 Page 1 of

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restated or otherwise modified or supplemented from time to time. Under the WBE Contracts,

WBE provided certain electrical, HVAC, sitework, interior upgrades and related services at

PG&E facilities and properties throughout Northern California (collectively, the “Properties”)

to the benefit of PG&E.

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

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

stay herein, WBE is precluded from filing a state court action to enforce its liens. Under 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,

the claimant shall instead file a notice in bankruptcy court within the time fixed by law for

seizing the property or commencing an action. 11 U.S.C. § 546(b )(2); see also In re Baldwin

Builders, 232 B.R. 406, 410-411 (9th Cir. 1999); Village Nurseries v. Greenbaum, 101

Cal.App. 4th 26, 41 (2002).

Under California Civ. Code §§ 8050(a) and 8412, WBE is entitled to assert and hereby

does assert its lien rights and under 11 U.S.C. § 546(b) and gives this Notice in lieu of the

commencement of any action to perfect, maintain or continue WBE’s liens. WBE requests

adequate protection of said liens. True and correct copies of each of WBE’s mechanics liens,

recorded and filed against the Properties in each respective California county, are attached

hereto as EXHIBIT A, together with a summary of said liens. The outstanding amount due

under these two (2) liened projects currently totals not less than $90,404.16 (altogether, the

“WBE Liens”).

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Case: 19-30088 Doc# 4873 Filed: 11/26/19 Entered: 11/26/19 17:34:02 Page 2 of

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WHEREFORE, WBE asserts secured interests in the Properties as reflected by the WBE

Liens to the fullest extent allowed by applicable law, including interest and attorneys’ fees.

Further, WBE reserves all rights to supplement and/or amend this Notice, and reserves any and

all other rights under applicable law.

DATED: November 26, 2019 LAW OFFICES OF JAMES SHEPHERD 

By: /s/ James A. Shepherd Attorney for Creditor-Lienholder 

W. BRADLEY ELECTRIC, INC.

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