ML021060027

Declaration of Valerie O. Fong in Support of Debtor'S Motion for Order Approving Expenditure of Funds to Construct the Northeast San Jose Transmission Reinforcement Project

ML021060027
Person / Time
Site:	Diablo Canyon
Issue date:	03/29/2002
From:	Fong V Howard, Rice, Nemerovski, Canady, Falk & Rabkin, Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
01-30923 DM, 94-0742640
Download: ML021060027 (3)

Text

1 JAMES L. LOPES (No. 63678) 4 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 12 In re No. 01-30923 DM Chapter 11 Case HOWAD 13 PACIFIC GAS AND ELECTRIC a 14 COMPANY, a California corporation, Date: April 17,, 2002 Debtor. Time: 9:30 a.m.

Place: 235 Pine St., 22nd Floor

. 15 San Francisco, California 16 Federal I.D. No. 94-0742640 Judge: Hon. Dennis Montali 17 18 19 DECLARATION OF VALERIE 0. FONG IN SUPPORT OF 20 DEBTOR'S MOTION FOR ORDER APPROVING EXPENDITURE OF FUNDS TO CONSTRUCT THE NORTHEAST SAN JOSE TRANSMISSION 21 REINFORCEMENT PROJECT 22 23 24 25 26 (1.77 27 28 NESJ PROJECT DECL. OF V. FONG ISO OF DEBTOR'S MOT. FOR ORDER APPROVING CONSTRUCTION OF

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 January 10, 2002, PG&E submitted a notice and description of the 8

Northeast San Jose Transmission Reinforcement Project (the "NESJ Project") to the Official 9

Committee of Unsecured Creditors (the "Creditors' Committee"), pursuant to Judge Dennis 10 Montali's Order Re: Motion for Authority to Make Capital Expenditures in the Ordinary 11 Course of Business in PG&E's Chapter 11 case in front of the U.S. Bankruptcy court, 12 Northern District of California, San Francisco Division (Case No. 01-30923 DM). Attached HOWARD 13 RIE hereto as Exhibit A is a true and correct copy of PG&E's notice to the Creditors' Committee.

cANt" 14 EUK

3. On January 24, 2002 the Creditors' Committee notified me by email that it

,. A. _ 15 did not oppose the NESJ Project but asked PG&E "to notify the Committee immediately 16 should there be material changes to the scope of work/services (i.e., CPUC/FERC reviews, 17 delays, etc.)." Attached hereto as Exhibit B is a true and correct copy of the Creditors' 18 Committee email.

19 I declare under penalty of perjury under the laws of the United States of America 20 that the foregoing is true and correct. Executed this 11i"' day of March, 2002, at San 21 Francisco, California.

22 23 24 Valerie 0. Fonj 25 26 27 28 DECL. OF V. FONG ISO OF DEBTOR'S MOT. FOR ORDER APPROVING CONSTRUCTION OF NESJ PROJECT SFDOCS\324208.1 [W2000] 023907-0033

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