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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case

No. 19 - 30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

☐ Affects PG&E Corporation

☒ Affects Pacific Gas and Electric 

Company

☐ Affects both Debtors

* All papers shall be filed in the Lead 

Case, No. 19-30088 (DM)

NOTICE OF LIENS UNDER 11 U.S.C. § 546(b) 

BY TULSA INSPECTION RESOURCES –

PUC, LLC

PLEASE TAKE NOTICE that Tulsa Inspection Resources – PUC, LLC (“Tulsa”) is the prime 

contractor under a certain pre-petition Contract (Long Form), dated as of March 27, 2012, by and 

between Pacific Gas and Electric Company (“PG&E”) and Tulsa Inspection Resources, Inc. (Tulsa’s 

predecessor in interest), which contract is further referred to as PG&E Contract No. 4400006534, as 

Justin E. Rawlins (S.B. No. 209915)

jrawlins@winston.com

WINSTON & STRAWN LLP

333 S. Grand Avenue, 38th Floor

Los Angeles, CA 90071-1543

Telephone: (213) 615-1700

Facsimile: (213) 615-1750

David Neier (admitted pro hac vice)

dneier@winston.com

WINSTON & STRAWN LLP

200 Park Avenue, 40th Floor

New York, NY 10166-4193

Telephone: (212) 294-6700

Facsimile: (212) 294-4700

Attorneys for Creditor

Tulsa Inspection Resources – PUC, LLC

Case: 19-30088 Doc# 4869 Filed: 11/26/19 Entered: 11/26/19 14:42:22 Page 1 of

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such contract has been amended, amended and restated or otherwise modified or supplemented from 

time to time (the “Contract”). Tulsa was hired to provide inspection services related to gas and 

pipelines, connections, compression stations and related projects critical for safety and required by the 

United States Department of Transportation Pipeline and Hazardous Materials Administration and 

California law to ensure explosions leading to loss of life and property damage do not occur, including 

services related to maintenance and repair (collectively, the “Work”). 

Prior to the filing of the Debtors’ bankruptcy case, Tulsa provided labor, equipment, services 

and supplies to PG&E under the Contract along PG&E’s pipeline in the following California counties:

Nevada and San Bernardino (the “Properties”). The Work under the Contract is a “work of 

improvement” as defined under California Civ. Code § 8050(a). Under California Civ. Code § 8412,

A direct contractor may not enforce a lien unless the contractor records a claim of lien after 

the contractor completes the direct contract, and before the earlier of the following times:

(a) Ninety days after the completion of the work of improvement.

(b) Sixty days after the owner records a notice of completion or cessation.

Likewise, California Civ. Code § 8460(a) provides that,

(a) The claimant shall commence an action to enforce a lien within 90 days after 

recordation of the claim of lien. If the claimant does not commence an action to enforce 

the lien within that time, the claim of lien expires and is unenforceable

Pursuant to 11 U.S.C. § 546(b), Tulsa hereby gives notice in lieu of the commencement of 

any such action to perfect, maintain, or continue Tulsa’s liens. Accordingly, Tulsa requests adequate 

protection of its liens. A true and correct copy of Tulsa’s lien filed in Nevada County is attached 

hereto as Exhibit A. A true and correct copy of Tulsa’s lien filed in San Bernardino County is 

attached hereto as Exhibit B. 

Case: 19-30088 Doc# 4869 Filed: 11/26/19 Entered: 11/26/19 14:42:22 Page 2 of

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Tulsa asserts secured interests in the Properties to the fullest extent allowed by applicable law, 

including interest and attorneys’ fees. Further, Tulsa reserves the right to supplement and/or amend 

this Notice, and reserves any and all other rights under applicable law.

Dated: November 26, 2019

Respectfully submitted,

WINSTON & STRAWN LLP

By: /s/ Justin E. Rawlins

Attorneys for Creditor

Tulsa Inspection Resources – PUC, LLC

Case: 19-30088 Doc# 4869 Filed: 11/26/19 Entered: 11/26/19 14:42:22 Page 3 of

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