ML020450387
| ML020450387 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/16/2002 |
| From: | Fong V Howard, Rice, Nemerovski, Canady, Falk & Rabkin |
| To: | Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California |
| References | |
| 94-0742640, Case No 01 30923 DM | |
| Download: ML020450387 (3) | |
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13 RKE NCS 14 15 16 17 18 In re PACIFIC GAS AND ELECTRIC COMPANY, a California corporation, Debtor.
Federal I.D. No. 94-0742640 No. 01 30923 DM Chapter 11 Case Date:
Time:
Place:
Judge:
February 8, 2002 2:30 p.m.
235 Pine St., 22nd Floor San Francisco, California Hon. Dennis Montali DECLARATION OF VALERIE 0. FONG IN SUPPORT OF DEBTOR'S MOTION FOR ORDER APPROVING EXPENDITURE OF FUNDS TO UPGRADE SUBSTATIONS AND, IF NECESSARY, RECONDUCTOR A 230 KV TRANSMISSION LINE TO SUPPORT THE LOS BANOS-GATES 500 KV TRANSMISSION PROJECT
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t DECL. OF. V. FONG ISO OF DEBTOR'S MOT. FOR ORDER APPROVING EXPENDITURE OF FUNDS FOR PATH 15 UPGRADE PROJECT i
JAMES L. LOPES (No. 63678)
JEFFREY L. SCHAFFER (No. 91404)
JANET A. NEXON (No. 104747)
HOWARD, RICE, NEMEROVSKI, CANADY, FALK & RABKIN A Professional Corporation Three Embarcadero Center, 7th Floor San Francisco, California 94111-4065 Telephone:
415/434-1600 Facsimile:
415/217-5910 Attorneys for Debtor and Debtor in Possession PACIFIC GAS AND ELECTRIC COMPANY UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 19 20 21 22 23 24 25 26 27 28
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10 11 12 13 HOWARD1 RIME caN'DI 14 MIK 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Valerie 0. Fong, declare as follows:
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I am the Director, Capital and Expense Program Management Pacific Gas and Electric Company ("PG&E"), a position I have held since November 1, 2000. I make this Declaration based upon my personal knowledge of PG&E's capital programs, and upon my review of PG&E's records concerning the matters stated herein. If called as a witness, I could and would testify competently to the facts stated herein.
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On November 29, 2001, PG&E submitted a notice and description of the project to design and build 500 kV and 230 kV substation equipment, and, if needed, to reconductor 230 kV transmission lines, all in conjunction with the "Path 15 Upgrade Project," to the Official Committee of Unsecured Creditors (the "Creditors' Committee"),
pursuant to Judge Dennis Montali's Order Re: Motion for Authority to Make Capital Expenditures in the Ordinary Course of Business in PG&E's Chapter 11 case in front of the U.S. Bankruptcy court, Northern District of California, San Francisco Division (Case No.
01-30923 DM). Attached hereto as Exhibit A is a true and correct copy of PG&E's notice to the Creditors' Committee.
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On December 12, 2001, the Creditors' Committee notified me by email that it did not oppose the Project "but would be appreciative if [it] could monitor critical events leading up to the actual cash outlay." Attached hereto as Exhibit B is a true and correct copy of the Creditors' Committee email.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this
- day of January, 2002, at San Francisco, California.
Valerie q. Fog DECL. OF V. FONG ISO OF DEBTOR'S MOT. FOR ORDER APPROVING EXPENDITURE OF FUNDS TO SUPPORT PATH 15 PROJECT SFDOCS\\321712. I [W2000]
023907-0031
Exhibits are not attached to the service copies of this document.
You may obtain copies of the Exhibits in one of the following ways: through the "Pacific Gas & Electric Company Chapter 11 Case" link accessible through the Bankruptcy Court's website (www.canb.uscourts.gov), or by written request to Howard, Rice, Nemerovski, Canady, Falk & Rabkin, Attn: Racquel Lopez, Three Embarcadero Center, 7th Floor, San Francisco, California 94111-4065 WD 071801/1-1419901/gff/932202/vI