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ROVENS LAMB LLP 

 

2601 Airport Drive, Suite 370 

Torrance, CA 90505 

Telephone: 310.536.7830 

Facsimile: 310.872.5026 

slamb@rovenslamb.com 

310.536.7830 

May 1, 2023 

By Electronic Mail Only 

Lawrence A. Jacobson 

COHEN & JACOBSON, LLP 

66 Bovet Road, Suite 285 

San Mateo, CA 94402 

laj@cohenandjacobson.com 

RE: Proof of Claim of Amir Shahmirza in PG&E Corporation, Case No. 19-30088 (DM), U.S. 

 Bankruptcy Court, N. D. Cal. 

 

Dear Mr. Jacobson: 

I represent PG&E Corporation and Pacific Gas and Electric Company (collectively, “PG&E”) in 

connection with their chapter 11 bankruptcy cases pending before the U.S. Bankruptcy Court for 

the Northern District of California (the “Bankruptcy Court”). I write to set forth PG&E’s 

position regarding Mr. Shahmirza’s denial of access to the site. 

We have been advised that Mr. Shahmirza has cut and removed the PG&E lock attached to the 

gate that allows access from Walnut Street to the PG&E Easement for Landscape and Access. 

Additionally, Mr. Shahmirza has parked buses/limousines up against the gate and throughout the 

PG&E Easement and denied PG&E access to the easement and the adjacent PG&E substation 

property. 

Attached is: 

1. The Record of Survey prepared by and Mr. Shahmirza’s surveyor that clearly reflects 

the PG&E Easement for Landscape and Access; 

2. The PG&E Easement for Landscape and Access (Director’s Deed) that provides “the 

right to use and ingress thereto and access therefrom, and as an appurtenance to the 

parcel of land described in the deed from the State of California to Pacific Gas and 

Electric Company dated April 3, 1997 [the PG&E substation property]”; 

3. Photo blocking access to the gate and parking buses/limousines blocking the gate and 

throughout the PG&E Easement for Landscape and Access; and 

4. Overhead photo of the above. 

Case: 19-30088 Doc# 13695-1 Filed: 05/04/23 Entered: 05/04/23 13:54:56 Page 2

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ROVENS LAMB LLP 

May 1, 2023 

Lawrence A. Jacobson 

Page 2 

Demand is hereby made that you ensure that Mr. Shahmirza immediately: (1) allow PG&E to 

replace the double lock mechanism on the gate so it has full access to the gate; (2) remove all 

vehicles that block PG&E’s vehicular access through the PG&E Easement for Landscape and 

Access to the appurtenant substation; and (3) confirm that Mr. Shahmirza will not in the future 

interfere with PG&E’s Easement for Landscape and Access to the appurtenant PG&E substation. 

The actions of Mr. Shahmirza that currently block access through the PG&E Easement for 

Landscape and Access present a substantial safety risk by precluding emergency access to the 

PG&E substation. PG&E requires full access to the substation at all times for safe and reliable 

substation operations. Interfering with access to the substation poses a risk to PG&E’s 

operations and subjects your client to liability for any damages PG&E may incur as a result of 

being unable to access the substation. 

Kindly confirm this and ensure that this is accomplished no later than May 3, 2023. Refusal to 

comply will require us to bring this matter to the attention of the Court. All rights are reserved. 

 

Best regards, 

Steven A. Lamb 

cc: David Taylor 

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Atachment 4

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Atachment 5

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Atachment 6

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Steven A. Lamb

From: Larry Jacobson <laj@cohenandjacobson.com>

Sent: Wednesday, May 3, 2023 2:46 PM

To: Steven A. Lamb

Cc: David Taylor; Thomas Rupp; Larry Jacobson

Subject: RE: Proof of Claim of Amir Shahmirza in PG&E Corporation, Case No. 19-30088 (DM), U.S. 

Follow Up Flag: Follow up

Flag Status: Flagged

Mr. Lamb 

Yes, I read your email in approximately late morning on Monday, May 1, 2023, while participating in a charity 

golf event that consumed the entire day. 

Yesterday I began drafting a detailed and comprehensive response that explains that PG&E holds no rights as 

you assert in your letter. 

Compare the easement reservation in the State’s Deed to Neil and Melanie Hildebrand recorded on June 30, 

1987 (easement for landscaping only) with the Director’s Deed recorded thereafter on December 16, 1988, to 

which you refer for your assertions regarding entry for purposes other than landscaping. The State had no 

ingress/egress rights to transfer to PG&E in December 1988, having transferred the entire fee interest to 

Hildebrands in June 1987. 

When PG&E wanted access for other purposes in April 2018, PG&E leased the area at the rate of $11,500 per 

month which arrangement it chose to terminate on September 30, 2022. Communications concerning renewal 

continued in February 2023, but that did not occur. Now, by the demand in your letter, PG&E apparently wants 

to obtain that access without continuing to pay for it. 

This morning I had a doctor appointment so I have a partial day to attempt to complete the response that I will 

more likely send you tomorrow morning by approximately 10:30 a.m. 

Larry Jacobson 

Lawrence A. Jacobson 

Cohen and Jacobson, LLP 

66 Bovet Road, Suite 285 

San Mateo, CA 94402 

Office Phone: (650) 261-6280 

Cell Phone: (650) 642-4906 

Fax: (650) 745-0720 

Email: laj@cohenandjacobson.com 

From: Steven A. Lamb <slamb@rovenslamb.com> 

Sent: Wednesday, May 3, 2023 1:06 PM 

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To: Larry Jacobson <laj@cohenandjacobson.com> 

Cc: David Taylor <dtaylor@kbkllp.com>; Thomas Rupp <trupp@kbkllp.com> 

Subject: RE: Proof of Claim of Amir Shahmirza in PG&E Corporation, Case No. 19-30088 (DM), U.S. 

Mr. Jacobson: 

See email and letter to you of May 1st. 

You received and read this email on May 1, 2023 at 1145 a.m. 

Your message 

 To: Larry Jacobson 

 Subject: Proof of Claim of Amir Shahmirza in PG&E 

Corporation, Case No. 19-30088 (DM), U.S. 

 Sent: Monday, May 1, 2023 10:55:29 AM (UTC-08:00) 

Pacific Time (US & Canada) 

 was read on Monday, May 1, 2023 11:44:45

I subsequently sent you a voicemail asking that you respond and confirm 

that you would comply with PG&E’s request. 

As you know, you have not responded. 

As I explained, this is a health and safety issue and your client is 

impermissibly blocking access to the gate that allows access to the PG&E 

Easement for landscape and access and the appurtenant access to the 

PG&E substation. 

We reserve all rights and trust that you will respond and comply 

immediately so we can avoid alerting the Court. 

Regards 

lamb 

STEVEN A. LAMB 

Rovens Lamb LLP

2601 Airport Drive, Suite 370 

Torrance, CA 90505 

Main Line/ 310.536.7830 

Facsimile/310.872.5489 

slamb@rovenslamb.com/ www.rovenslamb.com

Case: 19-30088 Doc# 13695-1 Filed: 05/04/23 Entered: 05/04/23 13:54:56 Page

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Attention: This message is sent by a law firm and may contain information that is privileged or confidential. If you 

received this transmission in error, please notify the sender by reply e-mail and delete the message and any 

attachments. 

=========================================================== 

CIRCULAR 230 DISCLOSURE: Pursuant to Regulations Governing Practice Before the Internal Revenue Service, any tax 

advice contained herein is not intended or written to be used and cannot be used by a taxpayer for the purpose of 

avoiding tax penalties that may be imposed on the taxpayer. 

=========================================================== 

CONFIDENTIALITY NOTICE: 

This electronic mail message and any attached files contain information intended for the exclusive use of the individual 

or entity to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or 

exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any 

viewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Please 

notify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message 

without making any copies. Thank you. 

From: Steven A. Lamb <slamb@rovenslamb.com> 

Sent: Monday, May 1, 2023 10:55 AM 

To: Lawrence A. Jacobson (laj@cohenandjacobson.com) <laj@cohenandjacobson.com> 

Cc: David Taylor <dtaylor@kbkllp.com>; Thomas Rupp <trupp@kbkllp.com> 

Subject: Proof of Claim of Amir Shahmirza in PG&E Corporation, Case No. 19-30088 (DM), U.S. 

Mr. Jacobson: 

See below and attached. Pleaase contact me at your earliest convenience 

so we can resolve this. 

By Electronic Mail Only 

Lawrence A. Jacobson

COHEN & JACOBSON, LLP 

66 Bovet Road, Suite 285 

San Mateo, CA 94402 

laj@cohenandjacobson.com

RE: Proof of Claim of Amir Shahmirza in PG&E Corporation, Case No. 19-30088 (DM), U.S. 

 Bankruptcy Court, N. D. Cal. 

Dear Mr. Jacobson: 

I represent PG&E Corporation and Pacific Gas and Electric Company (collectively, “PG&E”) in connection 

with their chapter 11 bankruptcy cases pending before the U.S. Bankruptcy Court for the Northern District of 

California (the “Bankruptcy Court”). I write to set forth PG&E’s position regarding Mr. Shahmirza’s denial of 

access to the site. 

Case: 19-30088 Doc# 13695-1 Filed: 05/04/23 Entered: 05/04/23 13:54:56 Page

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We have been advised that Mr. Shahmirza has cut and removed the PG&E lock attached to the gate that allows 

access from Walnut Street to the PG&E Easement for Landscape and Access. Additionally, Mr. Shahmirza has 

parked buses/limousines up against the gate and throughout the PG&E Easement and denied PG&E access to 

the easement and the adjacent PG&E substation property. 

Attached is: 

1. The Record of Survey prepared by and Mr. Shahmirza’s surveyor that clearly reflects the PG&E

Easement for Landscape and Access;

2. The PG&E Easement for Landscape and Access (Director’s Deed) that provides “the right to use and

ingress thereto and access therefrom, and as an appurtenance to the parcel of land described in the

deed from the State of California to Pacific Gas and Electric Company dated April 3, 1997 [the

PG&E substation property]”;

3. Photo blocking access to the gate and parking buses/limousines blocking the gate and throughout

the PG&E Easement for Landscape and Access; and

4. Overhead photo of the above.

Demand is hereby made that you ensure that Mr. Shahmirza immediately: (1) allow PG&E to replace the double 

lock mechanism on the gate so it has full access to the gate; (2) remove all vehicles that block PG&E’s 

vehicular access through the PG&E Easement for Landscape and Access to the appurtenant substation; and (3) 

confirm that Mr. Shahmirza will not in the future interfere with PG&E’s Easement for Landscape and Access to 

the appurtenant PG&E substation. 

The actions of Mr. Shahmirza that currently block access through the PG&E Easement for Landscape and 

Access present a substantial safety risk by precluding emergency access to the PG&E substation. PG&E 

requires full access to the substation at all times for safe and reliable substation operations. Interfering with 

access to the substation poses a risk to PG&E’s operations and subjects your client to liability for any damages 

PG&E may incur as a result of being unable to access the substation. 

Kindly confirm this and ensure that this is accomplished no later than May 3, 2023. Refusal to comply will 

require us to bring this matter to the attention of the Court. All rights are reserved. 

Best regards, 

Steven A. Lamb 

cc: David Taylor 

STEVEN A. LAMB 

Rovens Lamb LLP

2601 Airport Drive, Suite 370 

Torrance, CA 90505 

Main Line/ 310.536.7830 

Facsimile/310.872.5489 

slamb@rovenslamb.com/ www.rovenslamb.com

Case: 19-30088 Doc# 13695-1 Filed: 05/04/23 Entered: 05/04/23 13:54:56 Page

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Attention: This message is sent by a law firm and may contain information that is privileged or confidential. If you 

received this transmission in error, please notify the sender by reply e-mail and delete the message and any 

attachments. 

=========================================================== 

CIRCULAR 230 DISCLOSURE: Pursuant to Regulations Governing Practice Before the Internal Revenue Service, any tax 

advice contained herein is not intended or written to be used and cannot be used by a taxpayer for the purpose of 

avoiding tax penalties that may be imposed on the taxpayer. 

=========================================================== 

CONFIDENTIALITY NOTICE: 

This electronic mail message and any attached files contain information intended for the exclusive use of the individual 

or entity to whom it is addressed and may contain information that is proprietary, privileged, confidential and/or 

exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any 

viewing, copying, disclosure or distribution of this information may be subject to legal restriction or sanction. Please 

notify the sender, by electronic mail or telephone, of any unintended recipients and delete the original message 

without making any copies. Thank you. 

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