ML020450465

Declaration of Valerie O. Fong in Support of Debtor'S Motion for Order Approving Construction of Tri-Valley Project

ML020450465
Person / Time
Site:	Diablo Canyon
Issue date:	01/09/2002
From:	Fong V Howard, Rice, Nemerovski, Canady, Falk & Rabkin, Pacific Gas & Electric Co
To:	Montali D Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
01 30923 DM, 94-0742640
Download: ML020450465 (3)

Text

-, A r: -Y. .-

JS#!

1 JAMES L. LOPES (No. 63678) L' JEFFREY L. SCHAFFER (No. 91404) 2 JANET A. NEXON (No. 104747)

HOWARD, RICE, NEMEROVSKI, CANADY, 3 FALK & RABKIN A Professional Corporation 4 Three Embarcadero Center, 7th Floor San Francisco, California 94111-4065 5 Telephone: 415/434-1600 Facsimile: 415/217-5910 6

Attorneys for Debtor and Debtor in Possession 7 PACIFIC GAS AND ELECTRIC COMPANY 8

9 UNITED STATES BANKRUPTCY COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION In re No. 01 30923 DM 12 Chapter 11 Case 13 PACIFIC GAS AND ELECTRIC IRKE 14 COMPANY, a California corporation, Date: February 8, 2002 NEmQ Time: 2:30 p.m.

Debtor. Place: 235 Pine St., 22nd Floor

,AO., 15 San Francisco, California Judge: Hon. Dennis Montali 16 Federal I.D. No. 94-0742640 17 18 19 DECLARATION OF VALERIE 0. FONG IN SUPPORT OF 20 DEBTOR'S MOTION FOR ORDER APPROVING CONSTRUCTION OF TRI-VALLEY PROJECT 21 22 23 24 25 26 i

/4?( /

/1 ;.:*(

/1 ,/I. U 27 ' t( vi) 28 CONSTRUCTION OF TRI VALLEY PROJECT DECL. OF V. FONG ISO OF DEBTOR'S MOT. FOR ORDER APPROVING

1 I, Valerie 0. Fong, declare as follows:

2 1. I am the Director, Capital and Expense Program Management Pacific Gas 3

and Electric Company ("PG&E"), a position I have held since November 1, 2000. I make 4 this Declaration based upon my personal knowledge of PG&E's capital programs, and upon 5 my review of PG&E's records concerning the matters stated herein. If called as a witness, I 6 could and would testify competently to the facts stated herein.

7

2. On November 29, 2001, PG&E submitted a notice and description of the Tri 8

Valley Project to the Official Committee of Unsecured Creditors (the "Creditors' Committee"), pursuant to Judge Dennis Montali's Order Re: Motion for Authority to Make 10 Capital Expenditures in the Ordinary Course of Business in PG&E's Chapter 11 case in front 11 of the U.S. Bankruptcy court, Northern District of California, San Francisco Division (Case 12 No. 0 1-30923 DM). Attached hereto as Exhibit A is a true and correct copy of PG&E's 13 RKE notice to the Creditors' Committee.

S14 Max 3. On December 12, 2001, the Creditors' Committee notified me by email that

&RAEMU A - 15 it did not oppose the Tri Valley Project "but would be appreciative if [it] could monitor 16 critical events leading up to the actual cash outlay." Attached hereto as Exhibit B is a true 17 and correct copy of the Creditors' Committee email.

18 I declare under penalty of perjury under the laws of the United States of America 19 that the foregoing is true and correct. Executed this 4'T'day of January, 2002, at San 20 Francisco, California.

21 22 23 Valerie 0. Ton 24 25 26 27 28 DECL. OF V. FONG ISO OF DEBTOR'S MOT. FOR AUTH. TO MAKE CAPITAL EXP. IN THE ORD. COURSE OF BUS.

SFDOCS\320915.1[W2000] 023907-0034

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/vl