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COLETTE F. STONE, ESQ. (SBN: 129773)

RONALD F. BERESTKA, JR. ESQ. (SBN: 155707

LYDIA V. KO, ESQ. (SBN: 272588)

STONE & ASSOCIATES

A Professional Corporation

2125 Ygnacio Valley Road, Suite 101

Walnut Creek, CA 94598

Telephone: (925) 938-1555

Facsimile: (925) 938-2937

Email: cstone@stonelawoffice.com

rberestka@stonelawoffice.com

Attorneys for Defendants,

GEORGE M. VLAZAKIS; MARIA BARBIS; JOHN BARBIS; 

and ATHANASIA V. VLAZAKIS

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

 Affects Both Debtors

*All papers shall be filed in the Lead Case, no. 

19-30088 (DM)

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CASE NO. 19-30088 (DM)

Chapter 11

DECLARATION OF RONALD F. 

BERESTKA, JR. IN SUPPORT OF 

MOTION AS TO INAPPLICABILITY 

OF STAY, AND IN THE 

ALTERNATIVE FOR RELIEF FROM 

STAY

Date: December 17, 2019

Time: 10:00 a.m.

Dept.: 17

450 Golden Gate Ave

San Francisco, CA 94102

Judge: Dennis Montali

Objection Deadline: December 12, 2019

Time: 4:00 p.m. (Pacific Time)

I, Ronald F. Berestka, Jr., declare:

1. I am an attorney licensed to practice law in the State of California and am an 

associate with the law firm Stone & Associates, A Professional Corporation, attorneys of record 

for Defendants GEORGE M. VLAZAKIS; MARIA BARBIS; JOHN BARBIS; and ATHANASIA 

V. VLAZAKIS (hereinafter collectively as “Defendants”) in this matter. I have personal 

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knowledge of the facts contained in this declaration and if called to testify thereto could 

competently do so.

2. Attached hereto as Exhibit 1 is a true and correct copy of Pacific Gas & Electric 

Company’s (PG & E) complaint filed in the California Superior Court, County of Alameda, Case

number RG19021463, with attached exhibits.

3. Attached hereto as Exhibit 2 is a true and correct copy of the answer to PG & E’s 

complaint filed by George Vlazakis, in the California Superior Court, County of Alameda, Case 

number RG19021463.

4. Attached hereto as Exhibit 3 is a true and correct copy of the Vlazakis’ proposed 

cross-complaint against PG & E in in the California Superior Court, County of Alameda, Case 

number RG19021463.

5. PG & E’s lawsuit, Alameda, Case number RG19021463 is set for a bench trial to 

commence on May 12, 2020. The trial court has determined that the current pleadings permit trial 

of the “equitable” issue of the permanent injunction sought by PG & E, first.

6. On October 1, 2019, the court in PG & E’s lawsuit, Alameda, Case number 

RG19021463, held a case management and trial setting conference. All parties appeared through 

their counsel, and George Vlazakis also appeared on his own behalf. At that conference I advised 

the court that the Vlazakis defendants planned to file an amended answer and a cross-complaint 

against PG & E. The court refused my requests to grant leave sua sponte, but invited the 

Vlazakises to seek leave via ex parte application.

7. At a hearing in the state court action on October 1, 2019, counsel for PG & E 

represented to the court that the lot line adjustment and construction of the PG & E substation 

could not be accomplished as agreed to in the November 17, 2018 letter agreement because the 

area need to shore up the brick wall adjacent to the Vlazakis property would not leave enough 

room for the PG & E substation to be built.

8. On October 28, 2019, I emailed PG & E counsel Kenyon Mark Lee a draft of the 

Vlazakis’ proposed cross-complaint and requested that he stipulate to the filing of that pleading. 

Attached hereto as Exhibit 4 is a true and correct copy of my email (attachment excluded). Two 

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days later, on the afternoon of October 30, 2019, Mr. Lee’s law partner, Monika Pleyer Lee,

responded to my request, refused to stipulate, asserted that the automatic bankruptcy stay 

prohibited the proposed cross-complaint, and threatened to seek costs and fees. Attached hereto as 

Exhibit 5 is a true and correct copy of Ms. Lee’s letter.

9. On November 1, 2019, I responded to Ms. Lee’s letter pointing out that the 

bankruptcy stay was not applicable give that PG & E filed for bankruptcy before the state court 

lawsuit and proposed cross-complaint and the fact that the Vlazakises had no reason to sue PG & E 

before PG & E filed for bankruptcy. Attached hereto as Exhibit 6 is a true and correct copy of my 

letter.

10. On November 4, 2019, the Vlazakis defendants sought leave to file their 

compulsory cross-complaint against PG & E. PG & E opposed the application arguing that the 

bankruptcy stay prohibited the filing of the cross-complaint. The trial court denied the Vlazakis’ 

request without prejudice, stating that it would not make the determination as to whether the 

automatic bankruptcy stay was applicable in this instance. The court instructed defense counsel to 

petition the bankruptcy court for adjudication of the applicability of the stay, and/or to obtain relief 

from the stay. 

11. Attached hereto as Exhibit 7 is a true and correct copy of the City of Oakland 

record history for PG & E’s property at 205 Brush Street in Oakland. The record indicates that the 

lot line adjustment which would have extended the Vlazakis’ property line to include the whole of 

the east facing brick wall, was approved by the City of Oakland.

I declare under penalty of perjury under the laws of the State of California that the 

foregoing is true and correct.

Executed on this 21st day of November, 2019, at Walnut Creek, California.

 

 RONALD F. BERESTKA

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EXHIBIT 1

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EXHIBIT 2 

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CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

VLAZAKIS

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COLETTE F. STONE, ESQ. (SBN: 129773)

RONALD F. BERESTKA JR., ESQ. (SBN: 155707)

STONE & ASSOCIATES

A Professional Corporation

2125 Ygnacio Valley Road, Suite 101

Walnut Creek, CA 94598

Telephone: (925) 938-1555

Facsimile: (925) 938-2937

Email: cstone@stonelawoffice.com

Attorneys for Defendants,

GEORGE M. VLAZAKIS; MARIA BARBIS; JOHN BARBIS; and ATHANASIA V. 

VLAZAKIS

SUPERIOR COURT OF CALIFORNIA

IN AND FOR THE COUNTY OF ALAMEDA

UNLIMITED JURISDICTION

PACIFIC GAS AND ELECTRIC COMPANY,

Plaintiff,

vs.

ATHANASIA V. VLAZAKIS, GEORGE M. 

VLAZAKIS, JOHN A. BARBIS, MARIA A. 

BARBIS, and DOES 1 to xx,

Defendants.

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CASE NO. RG 19021463

CROSS COMPLAINT OF GEORGE 

M. VLAZAKIS, MARIA BARBIS, 

AND JOHN BARBIS AND 

ATHANASIA V. VLAZAKIS FOR:

1) BREACH OF CONTRACT;

2) BREACH OF COVENANT OF 

GOOD FAITH AND FAIR DEALING;

3) NEGLIGENCE

4) QUITE TITLE (ADVERSE 

POSSESSION)

5) QUITE TITLE (PRESCRIPTIVE 

EASEMENT)

6) QUITE TITLE (IMPLIED 

EASEMENT BY EXISTING USE)

7) QUITE TITLE (EASEMENT BY 

NECESSITY)

8) DECLARATORY RELIEF

Complaint filed: June 4, 2019

Assigned for all purposes to Judge Noel 

Wise, Dept. 24

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CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

VLAZAKIS

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GEORGE M. VLAZAKIS, JOHN A. BARBIS, 

MARIA A. BARBIS and ATHANASIA V. 

VLAZAKIS

Cross-Complainant,

vs.

PACIFIC GAS AND ELECTRIC COMPANY

and ZOES 1 to 100,

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COMES NOW CROSS-COMPLAINANTS GEORGE M. VLAZAKIS; MARIA BARBIS; 

JOHN BARBIS and ATHANASIA V. VLAZAKIS (hereinafter collectively “CROSSCOMPLAINANTS”) and allege as follows: 

1. CROSS-COMPLAINANTS GEORGE M. VLAZAKIS; MARIA BARBIS; JOHN 

BARBIS and ATHANASIA V. VLAZAKIS are and were at all times herein mentioned residents 

of the County of Alameda and owners of real property and improvements located at APN 001-

0111-001 commonly known as 225-229 Brush Street and 751 Third Street, Oakland, California 

and APN 002-0111-002 (a vacant lot with no address assigned) (hereinafter collectively the “the 

CROSS-COMPLAINANTS’ Properties”).

2. CROSS-COMPLAINANTS are informed and believe that CROSS-DEFENDANT 

PACIFIC GASS AND ELECTRIC COMPANY (hereinafter PG&E) is a public utility corporation 

duly organized and existing under and by virtue of the laws of the State of California and has its 

principle place of business in the City and County of San Francisco, California. 

3. ZOES 1 through 100 were and now are individuals or entities residing, doing 

business in, or having legal significance in the State of California.

4. CROSS-COMPLAINANTS do not know the true names and capacities, whether 

individual, corporate or otherwise, of the CROSS-DEFENDANTS named herein as ZOES 1 

through 100, inclusive. CROSS-COMPLAINANTS therefore sues these CROSS-DEFENDANT 

by fictitious names and will amend this CROSS-COMPLAINT in accordance with Code of Civil 

Procedure section 474 to reflect the Zoe CROSS-DEFENDANTS’ true names and capacities when 

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they have been ascertained. CROSS-COMPLAINANTS are informed and believes and thereon 

alleges that each of the Zoe CROSS-DEFENDANTS is at fault in some manner for the acts and 

omissions alleged below and caused and/or is otherwise legally responsible for CROSSCOMPLAINANTS’ alleged injuries and damages. CROSS-COMPLAINANTS are further 

informed and believe and thereon alleges that whenever and wherever in this CROSSCOMPLAINT any of the CROSS-DEFENDANTS are the subject of any charging allegations by 

CROSS-COMPLAINANTS, said ZOES 1 through 100 are also responsible in some manner for the 

events and happenings alleged herein, and it shall be deemed that said Zoe CROSSDEFENDANTS, and each of them, are likewise the subject of said charging allegations herein. 

5. CROSS-COMPLAINANTS are informed and believe and thereon allege that 

PG&E and ZOES 1 through 50 are the owners of real property located at APN 001-0111-005 and 

commonly known as 205-209 Brush Street, Oakland, California and which is adjacent to the 

CROSS-COMPLAINANTS’ Properties (hereinafter the “Subject Property”). 

6. Hereinafter CROSS-DEFENDANTS PG&E and ZOES 1 through 100 will be 

collectively referred to as CROSS-DEFENDANTS. 

7. CROSS-COMPLAINANTS are informed and believe and thereon allege that at all 

times mentioned herein CROSS-DEFENDANTS and each of them were owners, of the agents, 

servants, or employees of the owners, of some right, title, or interest in or to the Subject Property. 

8. CROSS-COMPLAINANTS are informed and believe and thereon allege that at all 

times mentioned herein each of the CROSS-DEFENDANTS was the agent and employee of each 

other of the remaining CROSS-DEFENDANTS, and in doing the things herein alleged, was acting 

in the course and scope of such agency and employment and with the permission and consent of 

each other of the other remaining CROSS-DEFENDANTS. 

FIRST CAUSE OF ACTION 

(Breach of Contract against PG&E and ZOES 1 through 100)

9. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as though fully set forth at this point.

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CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

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10. On or about November 22, 2017, PG&E and CROSS-COMPLAINANTS agreed 

that CROSS-DEFENDANTS would convey title to a four-foot by fifty-foot (4’ x 50’) strip of real 

property along their common border that includes the brick wall in question and that this 

agreement was reduced to a writing which was signed by the parties, which is attached hereto as 

Exhibit A. 

11. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that 

CROSS-DEFENDANTS breached this contract by failing to convey the 4’ x 50’ strip of real 

property to them per the terms of the agreement. 

12. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that at 

all times mentioned herein CROSS-COMPLAINANTS either fully performed their obligations 

under this contract, were excused from performing them, or were prevented by CROSSDEFENDANTS from performing them. CROSS-COMPLAINANTS are informed and believe, 

and thereon allege, that this included fulfilling any and all required condition precedents to this

contract. 

13. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that as a 

result, they are entitled to specific performance of the contract attached hereto as Exhibit A 

transferring the 4’ x 50’ strip of real property pursuant to its terms, provisions, covenants and 

conditions, and upon such other conditions as the Court deems equitable, including but not limited 

to an aware of consequential and incidental damages. 

14. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that as a 

direct and proximate result of the aforementioned breaches, CROSS-COMPLAINANTS have

alternatively been damaged in an amount according to proof at trial. Such damages include not 

only general damages but also special damages including loss of use of portions of the CROSSCOMPLAINANTS Properties. 

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CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

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SECOND CAUSE OF ACTION

(Breach of Covenant of Good Faith and Fair Dealing Against PG&E and ZOES 1 through 

100)

15. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as through fully set forth at this point. 

16. California law implies a covenant of good faith and fair dealing in all contracts 

between parties entered into in the State of California. 

17. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that

CROSS-DEFENDANTS breached the covenant of good faith and fair dealing found in the written 

contract attached hereto as Exhibit A by failing to make a good faith effort to uphold their end of 

the bargain thereby frustrating CROSS-COMPLAINANTS rights to receive the benefits of the 

contract attached hereto as Exhibit A. 

18. As a direct and proximate result of the breaches of the covenant of good faith and 

fair dealing by CROSS-DEFENDANTS described above, CROSS-COMPLAINANTS have been 

damaged in an amount according to proof at trial. 

THIRD CAUSE OF ACTION 

(Negligence Against PG&E and ZOES 1 through 100)

19. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as through fully set forth at this point. 

20. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that

CROSS-DEFENDANTS owed CROSS-COMPLAINANTS a duty of care regarding the 

development, inspection, and planning for the conveyance of the 4’ x 50’ strip of real property that 

is the subject of the written contract attached hereto as Exhibit A by virtue of that agreement.

21. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that

CROSS-DEFENDANTS negligently, careless, and wrongfully failed to use reasonable care in the 

development, inspection, and planning of the work they agreed to perform per the written contract 

attached hereto as Exhibit A.

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CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

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22. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that

CROSS-DEFENDANTS negligently and carelessly failed to exercise reasonable care and 

diligence to avoid loss and to minimize and mitigate damages that could have been prevented by 

reasonable efforts or by expenditures that should have been made in the exercise of due care.

23. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that as a 

direct and proximate result of the negligence of CROSS-DEFENDANTS that CROSSCOMPLAINANTS have incurred and will continue to incur costs and expenses, including but not 

limited to, litigation costs, loss of use if CROSS-COMPLAINTS’ adjoining premises including but 

not limited to loss of rents, contractors’ fees, attorneys’ fees, consultant fees, and other expenses 

relating to the damages caused by CROSS-DEFENDANTS negligence in an amount according to 

proof at trial. 

FOURTH CAUSE OF ACTION

(Quite Title – Adverse Possession Against PG&E and ZOES 1 through 50)

24. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as through fully set forth at this point. 

25. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that they 

are the owners by adverse possession of any and all alleged encroachments onto the Subject 

Property, should they exist, from the five steel I-beams permanently affixed to the brick wall of the 

Subject Property on the border between the Subject Property and the CROSS-COMPLAINANTS’ 

Properties. 

26. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that they

and/or their predecessors in interest have been in actual, open, hostile, continuous, and exclusive 

use of these encroachments.

27. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that they

have been in actual, open hostile, continuous, and exclusive use of these alleged encroachments 

since at least some time in the 1960’s though the present, well in excess of the 5-year period set 

forth in Code of Civil Procedure sections 318, 319, and 321-323. 

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CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

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28. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that they

are therefore the owners of these portions of the Subject Property and thus bring this action to 

Quite Title thereto. 

FIFTH CAUSE OF ACTION

(Quite Title – Prescriptive Easement Against PG&E and ZOES 1 through 50)

29. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as through fully set forth at this point. 

30. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that, in 

the alternative to the above, a prescriptive easement exists for the benefit of the CROSSCOMPLAINTS’ Properties related to any and all alleged encroachments onto the Subject 

Property, should they exist, from the five steel I-beams permanently affixed to the brick wall of the

Subject Property on the border between the Subject Property and the CROSS-COMPLAINANTS’ 

Properties.

31. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that they

and/or their predecessors in interest have been in actual, open, hostile, and continuous use of these 

alleged encroachments since at least some time in the 1960’s though the present. 

32. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that there 

exists a prescriptive easement for the benefit of the CROSS-COMPLAINTS’ Properties of these

portions of the Subject Property and thus bring this action to Quite Title thereto.

SIXTH CAUSE OF ACTION

(Quite Title – Implied Easement by Existing Use Against PG&E and ZOES 1 through 50)

33. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as through fully set forth at this point. 

34. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that, in 

the alternative to the above, an implied easement by existing use exists for the benefit of the

CROSS-COMPLAINTS’ Properties related to any and all alleged encroachments onto the Subject 

Property, should they exist, from the five steel I-beams permanently affixed to the brick wall of the 

Case: 19-30088 Doc# 4846-2 Filed: 11/22/19 Entered: 11/22/19 13:43:21 Page 45

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-8-

CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

VLAZAKIS

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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Subject Property on the border between the Subject Property and the CROSS-COMPLAINANTS’ 

Properties.

35. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that any 

and all alleged encroachments, should they exist, onto the Subject Property relating to the five 

steel I-beams permanently affixed to the brick wall of the Subject Property on the border between 

the Subject Property and the CROSS-COMPLAINANTS’ Properties existed at a time when both 

the Subject Property and the CROSS-COMPLAINANTS’ Properties were owned by a single 

person or entity. 

36. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that

continued use of the five steel I-beams permanently affixed to the brick wall of the Subject 

Property was intended by this original single owner of the Subject Property and the CROSSCOMPLAINANTS’ Properties when it was subdivided and sold to the predecessors in interest of 

the Subject Property and the CROSS-COMPLAINANTS’ Properties. 

37. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that there 

exists an implied easement by existing use for the benefit of the CROSS-COMPLAINTS’ 

Properties of these portions of the Subject Property and thus bring this action to Quite Title 

thereto.

SEVENTH CAUSE OF ACTION

(Quite Title – Easement by Necessity Against PG&E and ZOES 1 through 50)

38. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as through fully set forth at this point. 

39. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that, in 

the alternative to the above, an easement by necessity exists for the benefit of the CROSSCOMPLAINTS’ Properties related to any and all alleged encroachments onto the Subject 

Property, should they exist, from the five steel I-beams permanently affixed to the brick wall of 

the Subject Property on the border between the Subject Property and the CROSSCOMPLAINANTS’ Properties.

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-9-

CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

VLAZAKIS

1

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3

4

5

6

7

8

9

10

11

12

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14

15

16

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19

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40. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that in 

the event that none of the causes of action above are found to apply, such an easement must exist 

as there are no other options to support the roof and two perpendicular walls relying on these five 

I-beams permanently affixed to the brick wall of the Subject Property on the border between the 

Subject Property and the CROSS-COMPLAINANTS’ Properties. 

41. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that there

therefore must exist such an easement by necessity for the benefit of the CROSS-COMPLAINTS’ 

Properties of these portions of the Subject Property and thus bring this action to Quite Title 

thereto.

SEVENTH CAUSE OF ACTION

(Declaratory Relief Against PG&E and ZOES 1 through 100)

42. CROSS-COMPLAINANTS refer to and incorporate herein by reference each and 

every preceding paragraph as through fully set forth at this point. 

43. CROSS-COMPLAINANTS herein assert multiple claims for relief against CROSSDEFENDANTS, and each of them, based on various legal and equitable theories. 

44. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that they 

have suffered damages as a result of actions and/or inactions on the part of CROSSDEFENDANTS and/or as the result of their failure to comply with he legal, contractual, and/or 

equitable obligations to CROSS-COMPLAINANTS. 

45. CROSS-COMPLAINANTS are informed and believe, and thereon allege, that

disputes have arisen and an actual controversy now exists between CROSS-COMPLAINANTS

and CROSS-DEFENDANTS in that CROSS-COMPLAINANTS content that they are entitled to 

certain forms of relief from CROSS-DEFENDANTS, which CROSS-COMPLAINANTS are 

informed and believes is disputed by CROSS-DEFENDANTS. 

46. CROSS-COMPLAINANTS, including but not limited to a determination by the 

Court and/or the jury that an equitable easement exists in favor of the CROSS-COMPLAINANTS 

and that an implied easement exists under California Civil Code section 801(12) since this is a 

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CROSS COMPLAINT OF GEORGE M. VLAZAKIS, MARIA BARBIS, JOHN BARBIS, AND ATHANASIA V. 

VLAZAKIS

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common party wall and hereby seek a declaration by the Court as to the respective rights and 

duties of CROSS-DEFENDANTS, and each of them, as to CROSS-COMPLAINANTS. 

PRAYER FOR RELIEF

WHEREFORE CROSS-COMPLAINANTS pray for Judgement against CROSSDEFENDANTS, including ZOES 1 through 100, and each of them, as follows:

1. For specific performance of the written contract attached hereto as Exhibit A. 

2. For money damages in an amount to be proven at trial as to the First Cause of 

Action, Second Cause of Action, and Third Cause of Action.

3. For judgment that CROSS-DEFENDANTS are the owners, in fee, of all rights,

titles, and interests in and to the described real property in the Fourth Cause of Action, and for 

judgment that CROSS-DEFENDANTS do not have any right, title, estate, or interest in the same. 

4. For judgement that an easement exists for the benefit of the CROSSDEFENDANTS’ Properties in the Subject Property as described in the Fifth Cause of Action, 

Sixth Cause of Action, and/or Seventh Cause of Action. 

5. A permanent injunction baring CROSS-DEFENDANTS from removing the brick 

wall between the Subject Property and the CROSS-COMPLAINANTS’ Properties. 

6. For a declaration of rights, duties, and responsibilities of the parties, including but 

not limited to a finding of equitable easement in favor of CROSS-COMPLAINANTS and an 

implied easement under California Civil Code section 801(12) herein related to the Subject 

Property and the CROSS-COMPLAINANTS’ Properties. 

7. For attorney’s fees and costs of suit incurred herein by contract or available at law. 

8. For such further and other relief as the Court deems just and proper. 

DATED: STONE & ASSOCIATES

By 

RONALD F. BERESTKA JR

Attorneys for Defendants/Cross-Complainants

GEORGE M. VLAZAKIS; MARIA A. BARBIS;

JOHN A. BARBIS; and ATHANASIA V. 

VLAZAKIS

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EXHIBIT 4 

Case: 19-30088 Doc# 4846-2 Filed: 11/22/19 Entered: 11/22/19 13:43:21 Page 49

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Ronald Berestka 

From: Ronald Berestka 

Sent: Monday, October 28, 2019 2:41 PM 

To: Kenyon Mark Lee 

Cc: Colette Stone; George Vlazakis 

Subject: PG & E v Vlazakis 

Attachments: crosscomplaint.pdf 

Hi Mark, 

Attached is our proposed cross complaint. Please let me know if you will stipulate to filing. 

Thanks, 

Ron 

Ronald F. Berestka 

Stone & Associates, APC 

2125 Ygnacio Valley Road, Suite 101 

Walnut Creek, CA 94598 

Direct Dial 925.400.9690 

General Office Line 925.938.1555 

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EXHIBIT 5 

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LEE LAW OFFICES 

October 30, 2019 

Via email 

Colette F. Stone, Esq. 

Ronald E Berestka, Jr., Esq. 

Stone & Associates 

2125 Ygnacio Valley Road, Suite 101 

Walnut Creek, CA 94598 

Re: Pacific Gas and Electric Company v. Athanasia V Vlazakis, et al., 

Alameda Superior Court Case No. RG19021463 

Dear Ms. Stone and Mr. Berestka, 

We are writing in response to your October 29, 2019 email advising PG&E of your 

intent to make an ex parte application for leave to file a Cross-Complaint in the above action 

and the papers relating to this application, which we received by email yesterday evening. 

As you well know, PG&E has filed for protection under the bankruptcy laws. This 

means, among other things, that an automatic stay is in effect prohibiting various acts against 

PG&E, including the "commencement or continuation . . . a judicial, administrative, or other 

action or proceeding against the debtor that was or could have been commenced before the 

commencement of the case under this title, or to recover a claim against the debtor that arose 

before the commencement of the case," and any act to obtain possession of or exercise 

control over, property of the estate. See 11 U.S.C. § 362(a). 

The automatic stay applies to defendants' proposed cross-complaint. See, e.g., In re 

International Forex of California, Inc., 247 B.R. 284, 288 (Bankr. S.D. Cal. 2000)(holding that the 

"filing of a cross-complaint in state court against a debtor in possession that could have been 

brought prepetition, without first obtaining relief from the stay, is a clear violation of § 362(a). 

. . .The filing of a cross-complaint in state court is the sine qua non of an affirmative act 

against the debtor.") 

We note that you have not informed the court of PG&E's bankruptcy and that 

defendants do not claim to have obtained relief from the automatic stay from the bankruptcy 

court. 

1700 SOUTH EL CAMINO REAL • SUITE 450 

SAN MATEO • CALIFORNIA • 94402-3051 

PHONE: (650) 212-3400 • FAX: (650) 212-3414 

EMAIL: MONIKALEE@LEELAWLLP.COM 

Case: 19-30088 Doc# 4846-2 Filed: 11/22/19 Entered: 11/22/19 13:43:21 Page 52

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Colette Stone, Esq. 

Ronald F. Berestka, Jr., Esq. October 30, 2019 

Page 2 

The filing of defendants' proposed cross-complaint would be a violation of the 

automatic stay. 11 U.S.C. § 362(k) sets forth the remedies for such violations. In addition, 

actions in violation of the automatic stay are void. In re Schwark, 954 F.2d 569, 571 (9th Cir. 

1992) (holding that "[j]udicial proceedings in violation of th [el automatic stay are void.") The 

court in the instant action will not issue an order granting your clients leave to file the proposed 

cross-complaint in violation of the automatic stay. If it did such an action by this court would 

be void. 

PG&E urges you promptly to withdraw your Application for Leave to File a CrossComplaint. Should you fail to do so PG&E will oppose your application on the grounds set 

forth above as well as other applicable grounds, including the fact that an ex parte application 

is inappropriate considering the history of this case. PG&E reserves the right to seek all 

appropriate relief should it be required to oppose defendants' ex parte application. 

Very truly yours, 

/s/ Monika Lee 

Monika P. Lee 

cc: Cesar Alegria, Esq. 

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 EXHIBIT 6 

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COLETTE F. STONE 

JENNIFER E. MCENEANEY 

JULIET MACMILLIN LOMPA 

RONALD F. BERESTKA, JR. 

MARISSA N. ACREE 

LYDIA V. KO 

SHAUN W. JOYCE 

PARALEGAL 

BARBARA BURKHARDT, CCLS 

STONE& ASSOCIATES,APC 2125 YGNACIO VALLEY ROAD 

SUITE 101 

WALNUT CREEK, CA 94598 

TELEPHONE: (925) 938-1555 

FACSIMILE: (925) 938-2937 

WWW.STONELAWOFFICE.COM 

ATTORNEYS AT LAW 

November 1, 2019 

Kenyon Mark Lee, Esq. 

Monika Pleyer Lee, Esq. 

LEE LAW OFFICES 

1700 South El Camino Real, Suite 450 

San Mateo, CA 94402 

Re: Pacific Gas & Electric v. Vlazakis, et aL 

Alameda County Superior Court Case No.: RG19021463 

Our File No.: 31564 

Dear Ms. Lee: 

We write in response to your October 30, 2019 letter in which you assert that PG&E's 

Chapter 11 Bankruptcy stay prohibits the Vlazakis defendants' cross-complaint. 

First, we do not believe that your cited authority applies in the present case. PG&E filed 

the present lawsuit against the Vlazakis defendants on June 4, 2019, well after filing for 

bankruptcy in January 2019. The proposed cross-complaint would therefore clearly be 

filed after the "commencement of the case" under Chapter 11. Our position is that the 

cross-complaint could not have been filed before PG&E's Chapter 11 filing since 1) there 

was no complaint against the Vlazakis defendants to which they could file a crosscomplaint, and 2) the Vlazakis did not see any reason to file an action against PG&E 

prior to PG&E's bankruptcy. 

With regard to informing the court about PG&E's bankruptcy, aside from the fact that it 

is common knowledge, Mr. Lee previously mentioned the bankruptcy to the Court at the 

last hearing, and as mentioned in your Opposition to our Ex Parte Application, this was 

also raised in our clients' answer. Moreover, it is the duty of the party who caused a stay 

to notify the Court of that stay. (See California Rules of Court, Rule 3.650.) 

As to the assertion that ex parte relief is unwarranted, at the October 1, 2019 hearing, the 

Court invited us to seek leave via ex parte application to file the subject cross-complaint, 

so that it would help frame the issues for the motions set to be filed on November 11. 

Finally, we write to meet and confer regarding the management of this lawsuit. If the 

bankruptcy stay does apply as PG&E contends, the current state court action cannot 

Case: 19-30088 Doc# 4846-2 Filed: 11/22/19 Entered: 11/22/19 13:43:21 Page 55

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Ronald F. Berestka, Jr. 

Kenyon Mark Lee, Esq. 

Monika Pleyer Lee, Esq. 

Re: Pacific Gas & Electric v. Vlazakis, et aL 

November 1, 2019 

Page 2 

proceed. The Vlazakis' proposed cross-complaint includes causes of action for 

prescriptive easement and adverse possession, among other things, that must be tried by a 

jury before the court can entertain PG&E's equitable claims. (See e.g. Arciero Ranches 

v. Meza (1993) 17 Cal.App.4th 114). Indeed, it is rather obvious that no injunction 

against future trespass/nuisance can be decided until after a determination of whether my 

clients have a right to burden or use the subject wall. In essence, PG&E is seeking to put 

the cart before the horse. 

Given the above facts, we suggest—and, as you have seen in our supplemental papers, 

are requesting—that the Court stay the present action and vacate the current trial date 

until such time as the bankruptcy stay is lifted to ensure that the Vlazakis' constitutional 

rights are not denied. We are confident that the state court will not permit PG&E to 

pursue relief in its case while the Vlazakis defendants are prohibited from defending and 

asserting affirmative rights that would defeat PG&E's claim as a matter of law. 

Please let us know if you are agreeable to staying the state court action and vacating the 

current trial date until such time as either PG&E's bankruptcy is resolved or the 

bankruptcy stay is lifted. 

Very truly yours, 

STONE & ASSOCIATES 

RFB:bb 

cc: Cesar V. Alegria, Esq. 

George Vlazakis, Esq. 

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 EXHIBIT 7 

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Descd. ion 

Reserve 30 (750') NON-METERED parking space(s) in front of parcel only for dumpster, construction vehlde, moving van or 

storage pod. Post No-parking signs 72 hours prior in residential areas. No impact on traffic lane or sidewalk allowed. No-parking 

signs picked up by applicant after payment, 4TH FLOOR. To Have Illegally Parked Vehicle Ticketed Call 510-777-3333. Applicant 

arranges towing. Comply with terms set forth in CVC Section 22651 (m). For Towed Vehicle: Call 510-238-3021. Utility PG&E 

100amp main service for PG&E gas regulation station. 

PG&E PM 84005201 Location A: Strength test for line 105-C. Mile Point 0.00-2.03 and 10X20'excavation wirth PG&E Station For 

Test Head. If working within 25' feet of a monument you must comply with State Law 8771, contact the Inspector prior to starting 

excavation: minimum $5,800.00 fine for non-compliance. Comply with all terms of aty of Oakland Public Works Standards, Street 

Excavation Rules, Revised Mardi 2015 and City Council Ordinance No. 13300 C.M.S. Five day prior notice required for work 

lasting five days or less in business/commerdal districts; 72 hour notice in residential districts. Ten day prior notice required for 

work lasting six days or more in all districts. Call PWA INSPECTION prior to start: 510-238-3651. email 

PWA inspections@oaldandnetcorn. 

Mastec Of North America Pm ES 2000002, Place 1322Lf fiber Cable into existing Underground Structure in Public Right of Way. If 

working within 25' feet of a monument you must comply with State Law 8771, contact the Inspector prior to starting excavation: 

minimum $5,800.00 fine for non-compliance. Comply with all terms of City of Oakland Public Works Standards, Street Excavation 

Rules, Revised March 2015 and City Council Ordinance No. 13300 C.M.S. Five day prior notice required for work lasting five days 

or less in business/commercial districts; 72 hour notice in residential districts. Ten day prior notice required for work lasting six 

days or more in all districts. USA # and date must be provided in order to have a permit issued. Permit valid 30 days. Call PWA 

INSPECTION prior to start: 510-238-3651. 4th FLOOR. USA # 

ABANDON SEWER W813700689 dATE: 6/14/18 

Grant of Modification to Install of a steel support structure to retrofit existing unreinforced masonry wall on adjacent property 

CITY OF OAKLAND 

Address History (Beginning 1987) 

205, BRUSH, ST 

APN 

001 

011100503 

Record ID 

FDB19-00667 

Date Opened EMT. Status Date 

4/24/2019 

001 Ol31900220 2/4/2019 Permit 2/20/2019 

011100503 Expired 12:09:59 AM 

001 E1900357 1/31/2019 Permit 8/23/2019 

011100503 Inactive 12:05:13 AM 

001 X1900073 1/25/2019 Permit 3/14/2019 

011100503 Expired 12:04:25 AM 

001 X1800770 8/14/2018 Application 2/20/2019 

011100501 Inactive 12:21:33 AM 

001 SL1801523 5/30/2018 Created 5/30/2018 

011100501 12:21:07 PM 

001 AMR1800085 3/14/2018 Application 9/13/2018 

011100501 Inactive 12:26:04 AM 

For real-time, direct access to information via the Internet, 24 hours a day - https://aca.accela.com/oakland 

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Record ID Date 0 ened Status Status Date Descri S tion L0205, BRUSH, ST 

001 

011100501 

001 

011100501 

001 

APN 

11100100 

Unit # 

Pl N1813Q 

PLN18130 

RB1705226 

001 

011100100 

001 

011100501 

001 

011100501 

B1705229 

B1705229 

ZW1700417 

001 X1501890 8/13/2015 

011100501 

001 

011100501 

PLN15056 3/5/2015 

001 

011100501 

X1402136 8/22/2014 

001 

011100501 

001 

011100501 

001 

011100501 

001 

011100501 

001 

011100501 

001 

011100501 

001 

011100501 

001 

011100501 

1301989 

X0802125 

ENMI08199 

E0702350 

E0701552 

M0700889 

80700564 

M8633060 

Approved 5/11/2018 Parcel Map Waiver to adjust lot lines between two parcels associated with the necessity to shore-up an existing wall. APN#'s: 

12:00:00 AM 001-0111-001-00 & 001-0111-005-02. NOTE: parcel 005-02 was sold by the City of Oakland to PG&E with a previous PMW. The 

old APN# was 005-01 (shown below, not yet updated). 

Approved 5/11/2018 Parcel Map Waiver to adjust lot lines between two parcels associated with the necessity to shore-up an existing wall. APN#'s: 

12:00:00 AM 001-0111-001-00 & 001-0111-005-02. NOTE: parcel 005-02 was sold by the City of Oakland to PG&E with a previous PMW. The 

old APN# was 005-01 (shown below, not yet updated). - 

Reinstated 2/19/2019 Demolish total 17,240 sq. brick commercial building (3 attached structure). Wall bracing work on remaining wall under B1705229 

12:00:00 AM 

Permit 3/29/2019 Installation of a steel support structure support unreinforced masonry wall after existing PG&E office buildings demoed under 

Inactive 12:03:27 AM RB1705226. ZW1700417 (To be cerified on property prior to final). 

Permit 3/29/2019 Installation of a steel support structure support unreinforced masonry wall after existing PG&E office buildings demoed under 

Inactive 12:03:27 AM RB1705226. ZW1700417 (To be cerified on property prior to final). 

Complete 7/19/2017 *Update 11/14/17: OK to demo per admin. ABR Applicant will provide written project scope in addition to existing and proposed 

12:00:00 AM dimensioned site plans, floor plans, elevations, and landscape plans describing the project. Authorization needed from property 

owner for 229 brush st. due to work on their building, which possibly crosses the property line. Applicant will provide survey. 

Project needs review by historic preservation planner for demolition of potentially historic structures. Driveway curb cut relocation 

dimensions/details needed. Required landscaping and street tree plan needed for removal/replacement of trees. Plan showing 

style, location, and height of proposed fencing needed. Need color photographs of existing buildings. Provided zone and parking 

chapter handouts and specified zone as C1X-1B/T 

Expired 1/1/2016 Replace 30' gas main & remove vault. If working within 25' feet of a monument you must comply with State Law 8771, contact the 

1:09:48 AM Inspector prior to starting excavation: minimum $5,800.00 fine for non-compliance. PG&E PM 31133776 Permit valid 90 days. 

Separate Obstruction permit required to reserve/block parking lane. Set up PWA PRE-CON prior to start work: 510-238-3651. 

Approved 4/16/2015 Parcel Map Waiver per 16.24.020 (B)(1)(a) division of land between a governmental agency (Port of Oakland) and a Public Utility 

12:00:00 AM (PG&E) 

Expired 12/12/2015 Remove joint pole from service across from this address; repair concrete as needed. Loc 4. AT&T lob 9619601 Permit valid 90 

1:07:57 AM days. Separate Obstruction permit required to reserve/block parking lane. Set up PWA PRE-CON prior to start work: 510-238- 

3651. 

GRAFI-III AND A HOMELESS ENCAMPMENT ON PROPERTY 

permit to place new power pole and anchor and ground rods part of package induding X0801887,X0801888 & X0801889. 

permit to place new power pole and anchor and groun rods 

Electrical TO ENEK17F GATE FOR 6' HIGH FENCE 

Electrical/1000 amps/Comp natural gas vehide fueling system 

Mechanical/gas tests/Comp natural gas vehide fueling system 2 med pipe 

Compressed natural gas vehicle fueling system 

4/18/2013 Open 

10/22/2008 Permit 11/24/2008 

Issued 12:00:00 AM 

10/22/2008 Fully 11/25/2008 

Executed 12:00:00 AM 

7/10/2007 Expired 2/7/2008 

12:00:00 AM 

5/7/2007 Final 9/5/2007 

12:00:00 AM 

5/7/2007 Expired 2/7/2008 

12:00:00 AM 

2/7/2007 Expired 2/7/2008 

12:00:00 AM 

4/28/1986 Final 7/26/1988 

12:00:00 AM 

3/7/2018 

3/7/2018 

11/14/2017 

11/14/2017 

11/14/2017 

7/19/2017 

For real-time, direct access to information via the Internet, 24 hours a day - https://aca.accela.cornioaldand 

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130OW311 DIA-30 I104 331AI3S 3/V R 9N11V31-1 341A02Id 586T/a/9 

pats 0 ale° al Papal' uorptvaati IMO dV 

WV 00:00:ZT 

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TOSOOTTTO 

1699ZSEM TOO 

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puEpreo/woo -gpoarTowrsdug - AB!) E smog tz `iotualui alp u[it uoputuiojut oI ssaom papp `atuu -irai 

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