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

SUPPLEMENTAL DECLARATION OF DARRELL WEIGHT IN SUPPORT OF REFILED 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) 

SUPPLEMENTAL DECLARATION OF 

DARRELL WEIGHT IN SUPPORT OF 

REFILED 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 

I, Darrell Weight, hereby declare as follows: 

1. I make this Supplemental Declaration In Support Of The Refiled Conditional 

Objection Of Holt Of California To Motion Of Debtors Pursuant To 11 U.S.C. §§ 105(a), 363(b), 

Case: 19-30088 Doc# 508-3 Filed: 02/20/19 Entered: 02/20/19 15:19:50 Page 1

of 4
 

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

SUPPLEMENTAL 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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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 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 Pleasant 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. My duties as 

Operations Manager include supervisory responsibility for the rental of Caterpillar and related 

equipment to PG&E Corporation (“PG&E”). 

5. On or about February 20, 2019 I communicated with PG&E Contract Manager 

Richard Ho regarding Holt’s request to be considered by PG&E as an Operational Integrity 

Supplier (“Critical Vendor”) to obtain payment of Holt’s pre-petition claim. Mr. Ho is Holt’s 

primary contact at PG&E regarding Holt’s contracts and procurements with PG&E and has been 

my primary source of information regarding the affect of the PG&E bankruptcy filing on the 

relationship between Holt and PG&E. 

/ / / 

Case: 19-30088 Doc# 508-3 Filed: 02/20/19 Entered: 02/20/19 15:19:50 Page 2

of 4
 

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

SUPPLEMENTAL 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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6. During our conversation I told Mr. Ho the following: 

A. Holt would like to be considered a Critical Vendor, and Holt’s attorney appeared at 

the hearing in Bankruptcy Court for that purpose. 

B. PG&E informed Holt and the Bankruptcy Court at the hearing that to be considered a 

Critical Vendor, Holt is required to follow the PG&E procedure in place and contact 

Holt’s primary PG&E business contact person to make a formal application, which would 

then be reviewed and either approved or denied be a PG&E committee. The Bankruptcy 

Court approved this procedure. 

7. During our conversation Mr. Ho told me the following: 

A. There is currently no procedure in place at PG&E to process Holt’s request for 

Critical Vendor status; 

B. Mr. Ho is getting lots of calls from other vendors with the same concerns as Holt 

regarding Critical Vendor status and is telling them the same thing that he told me; 

C. There is nothing that he can do to process Holt’s request to be considered for Critical 

Vendor status; 

8. Mr. Ho was no help addressing Holt’s request to be considered for Critical 

Vendor status. Mr. Ho said he would send me the information that would answer Holt’s 

questions. Attached hereto as Exhibit A and Exhibit B are the documents that Mr. Ho sent me. 

9. Exhibit B is the same document that Mr. Ho had sent me approximately 2 weeks 

ago. 

10. Paragraph 15 of Exhibit A addresses Critical Vendor Status. This paragraph states 

that “We (PG&E) will coordinate with suppliers via normal channels to discuss 

eligibility...please reach out to your usual sourcing contact.” 

11. Mr. Ho deflected my questions regarding Holt’s request to be considered for 

Critical Vendor status and directed our conversation to discuss the post-petition rental of 

Caterpillar Equipment by Holt to PG&E. 

/ / / 

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