In re Pacific Gas and Electric Company, Chapter 11 Case No. 19-30088 

REFILED DECLARATION OF DARRELL WEIGHT IN SUPPORT OF CONDITIONAL OBJECTION OF HOLT OF 

CALIFORNIA TO MOTION OF DEBTORS PURSUANT TO 11 U.S.C. §§ 105(a), 363(b), AND 503(b)(9) AND FED. 

R. BANKR. P. 6003 AND 6004 FOR INTERIM AND FINAL AUTHORITY TO PAY PREPETITION OBLIGATIONS 

OWED TO CERTAIN SAFETY AND RELIABILITY, OUTAGE, AND NUCLEAR FACILITY SUPPLIERS Page 1 

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Mark D. Poniatowski, Esq. (#123405) 

Kimberly F. Leding, Esq. (#233618) 

Meera T. Parikh, Esq. (#217996) 

PONIATOWSKI LEDING PARIKH PC 

20980 Redwood Road, Suite 200 

Castro Valley, California 94546 

Telephone: (510) 881-8700 

Facsimile: (510) 881-8702 

Attorneys for Creditor 

Holt of California, a California corporation 

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 

[X] Affects both Debtors 

* All papers shall be filed in the Lead 

Case, No. 19-30088 (DM). 

 / 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

REFILED DECLARATION OF DARRELL 

WEIGHT IN SUPPORT OF 

CONDITIONAL OBJECTION OF HOLT 

OF CALIFORNIA TO MOTION OF 

DEBTORS PURSUANT TO 11 U.S.C. §§ 

105(a), 363(b), AND 503(b)(9) AND FED. 

R. BANKR. P. 6003 AND 6004 FOR 

INTERIM AND FINAL AUTHORITY TO 

PAY PREPETITION OBLIGATIONS 

OWED TO CERTAIN SAFETY AND 

RELIABILITY, OUTAGE, AND 

NUCLEAR FACILITY SUPPLIERS 

DATE: February 27, 2019 

TIME: 9:30 a.m. 

CTRM.: 17 

Case: 19-30088 Doc# 508-1 Filed: 02/20/19 Entered: 02/20/19 15:19:50 Page 1

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In re Pacific Gas and Electric Company, Chapter 11 Case No. 19-30089 

DECLARATION OF DARRELL WEIGHT IN SUPPORT OF CONDITIONAL OBJECTION OF HOLT OF 

CALIFORNIA TO MOTION OF DEBTORS PURSUANT TO 11 U.S.C. §§ 105(a), 363(b), AND 503(b)(9) AND FED. 

R. BANKR. P. 6003 AND 6004 FOR INTERIM AND FINAL AUTHORITY TO PAY PREPETITION OBLIGATIONS 

OWED TO CERTAIN SAFETY AND RELIABILITY, OUTAGE, AND NUCLEAR FACILITY SUPPLIERS Page 1 

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Mark D. Poniatowski, Esq. (#123405) 

Kimberly F. Leding, Esq. (#233618) 

Meera T. Parikh, Esq. (#217996) 

PONIATOWSKI LEDING PARIKH PC 

20980 Redwood Road, Suite 200 

Castro Valley, California 94546 

Telephone: (510) 881-8700 

Facsimile: (510) 881-8702 

Attorneys for Creditor 

Holt of California, a California corporation 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

(SAN FRANCISCO DIVISION) 

In Re 

PG&E CORPORATION, 

Debtor. 

Tax I.D. No. 94-3234914 

 / 

In Re 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtor. 

Tax I.D. No. 94-0742640 

 / 

Chapter 11 Case No. 19-30089DM 

DECLARATION OF DARRELL WEIGHT 

IN SUPPORT OF CONDITIONAL 

OBJECTION OF HOLT OF CALIFORNIA 

TO MOTION OF DEBTORS PURSUANT 

TO 11 U.S.C. §§ 105(a), 363(b), AND 

503(b)(9) AND FED. R. BANKR. P. 6003 

AND 6004 FOR INTERIM AND FINAL 

AUTHORITY TO PAY PREPETITION 

OBLIGATIONS OWED TO CERTAIN 

SAFETY AND RELIABILITY, OUTAGE, 

AND NUCLEAR FACILITY SUPPLIERS 

DATE: January 31, 2019 

TIME: 10:00 a.m. 

DEPT.: 17 

I, Darrell Weight, hereby declare as follows: 

1. I make this Declaration In Support Of The Conditional Objection Of Holt Of 

California To Motion Of Debtors Pursuant To 11 U.S.C. §§ 105(a), 363(b), And 503(b)(9) And 

Fed. R. Bankr. P. 6003 And 6004 For Interim And Final Authority To Pay Prepetition 

Obligations Owed To Certain Safety And Reliability, Outage, And Nuclear Facility Suppliers. 

To the extent that I have personal knowledge of the facts set forth herein, I will set forth said 

personal knowledge. To the extent that I do not have personal knowledge, then I have gained 

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In re Pacific Gas and Electric Company, Chapter 11 Case No. 19-30089 

DECLARATION OF DARRELL WEIGHT IN SUPPORT OF CONDITIONAL OBJECTION OF HOLT OF 

CALIFORNIA TO MOTION OF DEBTORS PURSUANT TO 11 U.S.C. §§ 105(a), 363(b), AND 503(b)(9) AND FED. 

R. BANKR. P. 6003 AND 6004 FOR INTERIM AND FINAL AUTHORITY TO PAY PREPETITION OBLIGATIONS 

OWED TO CERTAIN SAFETY AND RELIABILITY, OUTAGE, AND NUCLEAR FACILITY SUPPLIERS Page 2 

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such knowledge in the course and scope of my employment at Plaintiff, by reviewing the 

records, documents, memoranda, reports and/or data compilations in Plaintiff’s files, by my 

knowledge of Plaintiff’s business practices. 

2. If called upon to testify in this action as to the matters set forth in this declaration, 

I could and would competently testify thereto. 

3. I am the Operations Manager of Holt of California, a California corporation 

(“Holt”). My duties as Operations Manager of Holt include managing the rental staff, 

operations, and sales creation procedure for Holt’s equipment rental division. I have held this 

position for approximately 3 years and have been employed by Holt for approximately 17 years. 

4. Holt is the Caterpillar equipment dealer in northern and central California with its 

corporate headquarters in Pacific Grove, Sutter County, California. Holt is in the business 

providing sales, rental, parts, service and related activities to its customers for Caterpillar 

construction, earthmoving, material handling, agricultural, power generation and related 

equipment. Holt has 16 locations throughout northern and central California. 

5. My duties as Operations Manager include supervisory responsibility for the rental 

of Caterpillar and related equipment to PG&E Corporation (“PGE”). On or about November 12, 

2015 Holt and PG&E entered into an agreement titled PG&E Contract No. 4400010093; Project 

Name: Rental Project; Job Location: Various PG&E Locations (collectively, the “Master Rental 

Agreement”). The Master Rental Agreement in currently in effect and expires on December 31, 

2019. A copy of the Master Rental Agreement with the rental pricing redacted is attached hereto 

as Exhibit A and is incorporated herein by reference. 

6. The Master Rental Agreement contains preferred rental pricing and rebates to 

PG&E that are not generally available to Holt’s other customers. 

7. I am informed and believe based on my discussions with PG&E Dispatch 

Manager Rory Parks and PG&E Contracts Manager Richard Ho that Holt is considered a critical 

vendor rated as one of the top equipment suppliers to PG&E based on a PG&E written scoring 

system that considers the criteria described in Exhibit B attached hereto and incorporated herein 

by reference. Also, I has been told that Holt is a critical vendor when PG&E considers its 3 

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In re Pacific Gas and Electric Company, Chapter 11 Case No. 19-30089 

DECLARATION OF DARRELL WEIGHT IN SUPPORT OF CONDITIONAL OBJECTION OF HOLT OF 

CALIFORNIA TO MOTION OF DEBTORS PURSUANT TO 11 U.S.C. §§ 105(a), 363(b), AND 503(b)(9) AND FED. 

R. BANKR. P. 6003 AND 6004 FOR INTERIM AND FINAL AUTHORITY TO PAY PREPETITION OBLIGATIONS 

OWED TO CERTAIN SAFETY AND RELIABILITY, OUTAGE, AND NUCLEAR FACILITY SUPPLIERS Page 3 

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areas of focus: safety, fire clean up and support. 

8. During the emergency conditions of the Camp Fire, Holt supplied Caterpillar 

Earth Moving Equipment to PG&E at the fire site within 5 hours of notification, which was 

critical in facilitating the staging areas for all of the first responders. Holt also supplied lighting 

and power on an emergency basis. 

9. Holt locations are close to the rental equipment locations so providing parts, 

service and support by Holt’s field personnel is available 24/7 and response time is minimized, 

which is particularly important in an emergency situation. 

10. During the past week PG&E had approximately 17 units on rent from Holt, 

primarily used for fire clean up and pipeline reconstruction purposes. 7 of these units have been 

returned to Holt pre-petition at Holt’s request and 10 of these units remain in the possession of 

PG&E. PG&E has advised Holt that it wants to continue to rent these 10 units post-petition. 

11. The current amount due to Holt by PG&E as of the petition date is $453,979.66. 

The approximate amount due from rentals for the 21 days prior to the petition date is 

approximately $150,458.69. A summary of the aging of the total amount due is attached hereto 

as Exhibit C and incorporated herein by reference. 

12. I believe that Holt qualifies as a “Safety and Reliability Vendor” for the 

following reasons: 

a. Holt provides Caterpillar rental equipment that is highly specialized and closely 

integrated into PG&E’s business operations; 

b. Holt was selected and qualified as a provider of critical goods; 

c. The Caterpillar equipment provided by Holt relates to services that PG&E has 

identified as critical, such as earth - moving and waste - removal; 

d. The Caterpillar equipment provided by Holt relates to providing base camp 

services for PG&E personnel; 

13. I believe that Holt qualifies as a “Regulatory Compliance Vendor” for the 

following reasons: 

/ / / 

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