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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

RUTAN & TUCKER, LLP

Roger F. Friedman (State Bar No. 186070)

rfriedman@rutan.com

Philip J. Blanchard (State Bar No. 192378)

pblanchard@rutan.com

Ashley M. Teesdale (State Bar No. 289919)

ateesdale@rutan.com

611 Anton Boulevard, Suite 1400

Costa Mesa, California 92626-1931

Telephone: 714-641-5100

Facsimile: 714-546-9035

Attorneys for Creditor ARB, INC.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION

and

PACIFIC GAS AND ELECTRIC 

COMPANY

Debtors.

Case No. 19-30088 DM (Lead Case)

(Jointly Administered with Case No.

19-30089 DM)

Chapter 11

NOTICE OF WITHDRAWAL OF 

CERTAIN NOTICES OF CONTINUED 

PERFECTION OF MECHANICS 

LIENS AND AMENDED MECHANICS 

Affects PG&E Corporation LIENS

Affects Pacific Gas and Electric 

Company

Affects both Debtors.

* All papers shall be filed in the Lead

Case No. 19-30088 DM.

ARB, Inc. (“ARB”), by and through its undersigned counsel, hereby gives notice of

withdrawal of certain of its previously-filed Notices of Continued Perfection of Mechanics

Liens Pursuant to 11 U.S.C. § 546(b)(2). 

1. ARB is a corporation that provided and delivered labor, services, equipment, 

and materials for the construction and improvement of projects on real property owned by 

PG&E Corporation and/or Pacific Gas and Electric Company (collectively, the “Debtors”)

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

before January 29, 2019 (the “Petition Date”).

2. Before the Petition Date, ARB properly perfected various mechanics liens 

under California Civil Code §§ 8400, et seq. by timely recording Mechanics Liens in various

counties in the State of California.

3. Pursuant to California Civil 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, ARB is precluded from filing a state court action 

to enforce its mechanics liens. 11 U.S.C. § 546(b)(2) provides that 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 of its intent to enforce the lien within the time fixed by law for seizing the 

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

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

Nurseries v. Greenbaum, 101 Cal.App.4th 26, 41 (Cal. Ct. App. 2002).

4. Accordingly, after the Petition Date, ARB filed in the Debtor’s jointlyadministered bankruptcy case various Notices of Continued Perfection of Mechanics Liens

with respect to various Mechanics Liens that ARB recorded in various counties in the State 

of California. 

5. After ARB filed its Notices of Continued Perfection of Mechanics Liens, ARB 

received payment in full of the invoices underlying certain of its recorded Mechanics Liens. 

Accordingly, with respect to the Mechanics Liens for which ARB has received payment in 

full, ARB has recorded with the applicable county recorders the following Releases of 

Mechanics Lien, and therefore, hereby withdraws and provides notice of withdrawal of the 

following related Notices of Continued Perfection of Mechanics Liens which ARB 

previously filed in this bankruptcy case:

(a) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 553, relating to the Mechanics Lien recorded in the Official 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Records of San Mateo County, State of California, on January 25, 2019, as Doc. No. 

2019-005553, and the Amended Mechanics Lien recorded in the Official Records of 

San Mateo County, State of California, on July 2, 2019, as Doc. No. 2019-051384,

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of San Mateo County, State of California, on 

July 22, 2019, as Doc. No. 2019-056876.

(b) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 559, relating to the Mechanics Lien recorded in the Official 

Records of Yolo County, State of California, on January 24, 2019, as Doc. No. 2019-

0001354-00, and the Amended Mechanics Lien recorded in the Official Records of 

Yolo County, State of California, on July 2, 2019, as Doc. No. 2019-0014718-00, 

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of Yolo County, State of California, on July 23, 

2019, as Doc. No. 2019-0016601-00.

(c) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 560, relating to the Mechanics Lien recorded in the Official 

Records of Marin County, State of California, on January 24, 2019, as Doc. No. 2019-

0002261, which has been released by the Release of Mechanics Lien recorded in the 

Official Records of Marin County, State of California, on June 24, 2019, as Doc. No. 

2019-0021845.

(d) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 561, relating to the Mechanics Lien recorded in the Official 

Records of Marin County, State of California, on January 24, 2019, as Doc. No. 2019-

0002262, which has been released by the Release of Mechanics Lien recorded in the 

Official Records of Marin County, State of California, on June 24, 2019, as Doc. No. 

2019-0021844.

(e) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 562, relating to the Mechanics Lien recorded in the Official 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Records of Marin County, State of California, on January 25, 2019, as Doc. No. 2019-

0002416, which has been released by the Release of Mechanics Lien recorded in the 

Official Records of Marin County, State of California, on June 24, 2019, as Doc. No. 

2019-0021842.

(f) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 564, relating to the Mechanics Lien recorded in the Official 

Records of Alameda County, State of California, on January 24, 2019, as Doc. No. 

2019011142, which has been released by the Release of Mechanics Lien recorded in 

the Official Records of Alameda County, State of California, on June 24, 2019, as 

Doc. No. 2019119773.

(g) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 565, relating to the Mechanics Lien recorded in the Official 

Records of Santa Clara County, State of California, on January 24, 2019, as Doc. No. 

24102937, which has been released by the Release of Mechanics Lien recorded in the 

Official Records of Santa Clara County, State of California, on June 24, 2019, as Doc. 

No. 24209654.

(h) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 566, relating to the Mechanics Lien recorded in the Official 

Records of Santa Clara County, State of California, on January 24, 2019, as Doc. No. 

24102932, and the Amended Mechanics Lien recorded in the Official Records of 

Santa Clara County, State of California, on July 2, 2019, as Doc. No. 24216359, 

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of Santa Clara County, State of California, on 

July 22, 2019, as Doc. No. 24235796.

(i) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 567, relating to the Mechanics Lien recorded in the Official 

Records of Alameda County, State of California, on January 24, 2019, as Doc. No. 

2019011143, and the Amended Mechanics Lien recorded in the Official Records of 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Alameda County, State of California, on July 2, 2019, as Doc. No. 2019126319, 

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of Alameda County, State of California, on July 

22, 2019, as Doc. No. 2019139339.

(j) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 568, relating to the Mechanics Lien recorded in the Official 

Records of San Mateo County, State of California, on January 24, 2019, as Doc. No. 

2019-004928, and the Amended Mechanics Lien recorded in the Official Records of 

San Mateo County, State of California, on July 2, 2019, as Doc. No. 2019-051383, 

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of San Mateo County, State of California, on 

July 22, 2019, as Doc. No. 2019-056875.

(k) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 569 relating to the Mechanics Lien recorded in the Official 

Records of San Mateo County, State of California, on January 24, 2019, as Doc. No. 

2019-004927, and the Amended Mechanics Lien recorded in the Official Records of 

San Mateo County, State of California, on July 2, 2019, as Doc. No. 2019-051382, 

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of San Mateo County, State of California, on 

July 22, 2019, as Doc. No. 2019-056874.

(l) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 570, relating to the Mechanics Lien recorded in the Official 

Records of San Mateo County, State of California, on January 24, 2019, as Doc. No. 

2019-004925, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of San Mateo County, State of California, on 

June 24, 2019, as Doc. No. 2019-048511.

(m) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 571, relating to the Mechanics Lien recorded in the Official 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Records of Mendocino County, State of California, on January 24, 2019, as Doc. No. 

2019-01033, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of Mendocino County, State of California, on 

June 25, 2019, as Doc. No. 2019-07177.

(n) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 572, relating to the Mechanics Lien recorded in the Official 

Records of Santa Clara County, State of California, on January 24, 2019, as Doc. No. 

24102935, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of Santa Clara County, State of California, on 

June 24, 2019, as Doc. No. 24209653.

(o) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 573 relating to the Mechanics Lien recorded in the Official 

Records of Santa Clara County, State of California, on January 24, 2019, as Doc. No. 

24102936, and the Amended Mechanics Lien recorded in the Official Records of 

Santa Clara County, State of California, on July 2, 2019, as Doc. No. 24216360, 

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of Santa Clara County, State of California, on 

July 22, 2019, as Doc. No. 24235795.

(p) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 577 relating to the Mechanics Lien recorded in the Official 

Records of Marin County, State of California, on January 25, 2019, as Doc. No. 2019-

0002414, and the Amended Mechanics Lien recorded in the Official Records of 

Marin County, State of California, on July 2, 2019, as Doc. No. 2019-0023041, which 

have been released by the recording of the Release of Amended Mechanics Lien 

recorded in the Official Records of Marin County, State of California, on July 22, 

2019, as Doc. No. 2019-0025692.

(q) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 578, relating to the Mechanics Lien recorded in the Official 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Records of Sonoma County, State of California, on January 24, 2019, as Doc. No. 

2019004831, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of Sonoma County, State of California, on June 

24, 2019, as Doc. No. 2019042320.

(r) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 579, relating to the Mechanics Lien recorded in the Official 

Records of Santa Clara County, State of California, on January 24, 2019, as Doc. No. 

24102933, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of Santa Clara County, State of California, on 

June 24, 2019, as Doc. No. 24209655.

(s) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 580, relating to the Mechanics Lien recorded in the Official 

Records of Marin County, State of California, on January 24, 2019, as Doc. No. 2019-

0002260, which has been released by the recording of the Release of Mechanics Lien 

recorded in the Official Records of Marin County, State of California, on June 24, 

2019, as Doc. No. 2019-0021843.

(t) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 581 relating to the Mechanics Lien recorded in the Official 

Records of San Mateo County, State of California, on January 25, 2019, as Doc. No. 

2019-005554, and the Amended Mechanics Lien recorded in the Official Records of 

San Mateo County, State of California, on July 2, 2019, as Doc. No. 2019-051380, 

which have been released by the recording of the Release of Amended Mechanics 

Lien recorded in the Official Records of San Mateo County, State of California, on 

July 22, 2019, as Doc. No. 2019-056873.

(u) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 582, relating to the Mechanics Lien recorded in the Official 

Records of San Mateo County, State of California, on January 24, 2019, as Doc. No. 

2019-004926, which has been released by the recording of the Release of Mechanics 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Lien recorded in the Official Records of San Mateo County, State of California, on 

June 24, 2019, as Doc. No. 2019-048512.

(v) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 583, relating to the Mechanics Lien recorded in the Official 

Records of Marin County, State of California, on January 24, 2019, as Doc. No. 2019-

0002263, which has been released by the recording of the Release of Mechanics Lien 

recorded in the Official Records of Marin County, State of California, on June 24, 

2019, as Doc. No. 2019-0021841.

(w) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 584, relating to the Mechanics Lien recorded in the Official 

Records of Sacramento County, State of California, on January 28, 2019, as Doc. No. 

201901280645, which has been released by the recording of the Release of 

Mechanics Lien recorded in the Official Records of Sacramento County, State of 

California, on May 3, 2019, as Doc. No. 201905031088.

(x) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 585, relating to the Mechanics Lien recorded in the Official 

Records of El Dorado County, State of California, on January 28, 2019, as Doc. No. 

20190002792, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of El Dorado County, State of California, on 

May 3, 2019, as Doc. No. 2019-0016828-00.

(y) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 586, relating to the Mechanics Lien recorded in the Official 

Records of San Mateo County, State of California, on January 25, 2019, as Doc. No. 

2019-005555, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of San Mateo County, State of California, on 

May 3, 2019, as Doc. No. 2019-032965.

(z) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 587, relating to the Mechanics Lien recorded in the Official 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Records of El Dorado County, State of California, on January 25, 2019, as Doc. No. 

20190002572, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records El Dorado County, State of California, on May 

3, 2019, as Doc. No. 2019-0016827-00.

(aa) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 590, relating to the Mechanics Lien recorded in the Official 

Records of Sacramento County, State of California, on January 28, 2019, as Doc. No. 

201901280643, which has been released by the recording of the Release of 

Mechanics Lien recorded in the Official Records of Sacramento County, State of 

California, on May 3, 2019, as Doc. No. 201905031089.

(bb) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 591, relating to the Mechanics Lien recorded in the Official 

Records of Contra Costa County, State of California, on January 25, 2019, as Doc. 

No. 2019-0010906-00, which has been released by the recording of the Release of 

Mechanics Lien recorded in the Official Records of Contra Costa County, State of 

California, on May 3, 2019, as Doc. No. 2019-0063542-00.

(cc) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 592, relating to the Mechanics Lien recorded in the Official 

Records of Humboldt County, State of California, on January 25, 2019, as Doc. No. 

2019-001361, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of Humboldt County, State of California, on 

May 3, 2019, as Doc. No. 2019-007715.

(dd) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 593, relating to the Mechanics Lien recorded in the Official 

Records of Contra Costa County, State of California, on January 25, 2019, as Doc. 

No. 2019-0010905-00, which has been released by the recording of the Release of 

Mechanics Lien recorded in the Official Records of Contra Costa County, State of 

California, on May 3, 2019, as Doc. No. 2019-0063541-00.

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

(ee) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 594, relating to the Mechanics Lien recorded in the Official 

Records of Sonoma County, State of California, on January 25, 2019, as Doc. No. 

2019005068, which has been released by the recording of the Release of Mechanics 

Lien recorded in the Official Records of Sonoma County, State of California, on May 

3, 2019, as Doc. No. 2019029450.

(ff) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 595, relating to the Mechanics Lien recorded in the Official 

Records of Napa County, State of California, on January 25, 2019, as Doc. No. 2019-

0001311, which has been released by the recording of the Release of Mechanics Lien 

recorded in the Official Records of Napa County, State of California, on May 3, 2019, 

as Doc. No. 2019-0007989.

(gg) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 596, relating to the Mechanics Lien recorded in the Official 

Records of Sacramento County, State of California, on January 28, 2019, as Doc. No. 

201901280644, which has been released by the recording of the Release of 

Mechanics Lien recorded in the Official Records of Sacramento County, State of 

California, on October 15, 2019, as Doc. No. 201910150484.

(hh) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 597, relating to the Mechanics Lien recorded in the Official 

Records of San Francisco County, State of California, on January 28, 2019, as Doc. 

No. 2019K724781, and the Amended Mechanics Lien recorded in the Official 

Records of San Francisco County, State of California, on July 11, 2019, as Doc. No. 

2019K793158, which have been released by the recording of the Release of Amended 

Mechanics Lien recorded in the Official Records of San Francisco County, State of 

California, on August 28, 2019, as Doc. No. 2019K820855.

(ii) Notice of Continued Perfection of Mechanics Lien filed on February 

22, 2019, as Doc. No. 598, relating to the Mechanics Lien recorded in the Official 

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NOTICE OF WITHDRAWAL OF CERTAIN 

NOTICES OF CONTINUED PERFECTION OF 

MECHANICS LIENS

Records of Kern County, State of California, on January 25, 2019, as Doc. No. 

219008686, and the Amended Mechanics Lien recorded in the Official Records of 

Kern County, State of California, on July 15, 2019, as Doc. No. 219083561, which 

have been released by the recording of the Release of Amended Mechanics Lien 

recorded in the Official Records of Kern County, State of California, on August 28, 

2019, as Doc. No. 219110409.

6. Except as otherwise set forth herein, all of ARB’s Notices of Continued 

Perfection of Mechanics Liens and Notices of Continued Perfection of Amended Mechanics 

Liens filed in this case, and the related Mechanics Liens and Amended Mechanics Liens 

recorded in various counties, remain in full force and effect, and ARB specifically reserves 

all of its rights, claims, and defenses relating thereto.

7. In addition, ARB does not make any admission of fact or law, and ARB asserts 

that its remaining Mechanics Liens and Amended Mechanics Liens against the Debtors’

properties are senior to and effective against entities that may have acquired rights or 

interests in the properties.

8. The filing of this Notice shall not be construed as an admission that such filing 

is required under the Bankruptcy Code, the California mechanics lien law, or any other 

applicable law.

9. ARB further reserves all rights, including the right to amend or supplement 

this Notice.

Dated: January 7, 2020 RUTAN & TUCKER, LLP

ROGER F. FRIEDMAN

PHILIP J. BLANCHARD

ASHLEY M. TEESDALE

By: /s/ Roger F. Friedman

Roger F. Friedman

Attorneys for Creditor ARB, INC.

Case: 19-30088 Doc# 5300 Filed: 01/07/20 Entered: 01/07/20 14:49:23 Page 11

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