ML022140208
| ML022140208 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/22/2002 |
| From: | Elizabeth Wilson BP Canada Energy Co, Deutsche Bank Trust Co Americas, JPMorgan Chase Bank, Kelley, Drye & Warren, LLP |
| To: | Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California |
| References | |
| 01-30923-DM | |
| Download: ML022140208 (2) | |
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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ULEY DR YE &
- AKRvEN iiP UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION In re:
PACIFIC GAS AND ELECTRIC COMPANY, a California corporation, Debtor.
Case No. 01-30923-DM Chapter I 1 BANKRUPTCY RULE 2019 STAI EMENTFf OF KELLEY DRYE & WARREN LLP
[No Hearing Required]
TO THE CLERK OF THE BANKRUPTCY COURT AND TO ALL PARTIES !N INTEREST.
In accordance with Rule 2019(a) of.he Federal Rul:7 of Bankruptcy Procedure, Kelle)
Dryc & Warren LLP ("KDW"), as counsel to the parties designated herein in the above charter 11 case, subrm;its this verified statement and states as following:
i.
Names and Addresses of the Parties Represented by KDW KDW has been employed to represent the following creditors in this case: (i) JPMorgan Chase Bank ("JPMorgan'), 270 Park Avenue, New York, New York, 10017; (ii) Satellite Senior Income Fund and Satellite Income Fund H1 (together, "Satellite'), 623 Fifth Avenue, 20&' Floor, I/
Admined pro hac vice.
BANKUPTCI
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BANKRUPTCV RULE 2019 STATEMENT OF KELLEY DRYE & WARREN LiP ROBERT C. SHENFELD' ERIC R. WILSON (State Bar No. 192220)
KELLEY DRYE & WARREN LLP 777 South Figueroa Street, Suite 2700 Los Angeles, California 90017 Telephone: (213) 689-1300 Facsimile:
(213) 688-8150 Attorneys for DEUTSCHE BANK TRUST COMPANY AMERICAS, SATELLITE SENIOR INCOME FUND, SATELLITE SENIOR INCOME FUND II, BP CANADA ENERGY COMPANY, and JPMORGAN CHASE BANK
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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KELLFY DRYE &
WARREN LLP BANKRUPTCY RULE 2019 STATEMENT OF KELLEY DRYE & WARREN LLP New York, New York, 10022; (iii) Deutsche Bank Trust Company Americas ("Deutsche"), 90 Hudson Street, MS JCY05-0521 1, Jersey City, New Jersey, 07302; and (iv) BP Canada Energy Company ("BP") 240 4 h Avenue S.W., P.O. Box 200, Calgary, Alberta, T2P, 2H8 in the capti,-ned chapter I I case of Pacific Gas & Electric Company (the "Debtor").
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The Nature and Amount of the Claims and the Time of Acquisition Deutsche, as successor administrative agent, has claims against the Debtor, including, but not limited to, for sums due and owing under that certain reimbursement agreement dated May 1, 1996 (the "Rabobank Reimbursement Agreement"). In addition to being the successor administrative agent, Deutsche is also a beneficial interest holder pursuant to the Rabobank Reimbursement Agreement and a holder of other claims based on similar reimbursement agreements by and between the Debtor and various entities. Upon information and belief, Deutsche, in its individual capacity and not as agent, has filed an unsecured claim in the amount ofS15,000,000 in the above captioned case.
Satellite, as beneficial interest holders, has claims against the Debtor, including, but not limited to, for su-ns dues and owing under the Rabobank Reimbursement Agreeement. Upon information and belief, Satellite's claims have been preserved by an unsecured claim that was filed by the administrative agent, successor administrative agent or another party related to Satellite in connection with the Rabobank Reimbursement Agreement.
BP, as successor-in-interest, has claims against the Debtor, including, but not limited to, for surns dues and owing under that certain Master Gas Purchase and Sales Agreement dated on or about N,r(mber 1, 1995, as amended by the Confirmation and Amendment to Gas Supply Agreemeft doted on or about March 28, 2001, entered into among the Debtor and Amoco Canada Petroleum Company Ltd., the predecessor-in-interest to BP. BP has filed an unsecured claim in
!he amount of $796,392.91 in the above captioned case.
JPMorgan is a general unsecured creditor and a member of the Official Creditors' Committee of Pacific Gas and Electric Company (the "Committee'). KDW has and continues to serve as outside counsel to JPMorgan in connection with its participation on the Committee.
LAOIiKIMJ/2146241
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Amount of Claims Owned by KDW 2
KDW does not hold any claims against or hold any interest in the Debtor.
3 1, Eric R. Wilson, declare under penalty of perjury under the laws of the United States of 4
America that I have read the foregoing statement and that it is true and correct to the best of my 5 knowledge, information and belief.
6 DATED:
July' 2..
002 KELLEY DRYE & WARREN ROBERT C. SHENFELD 7
ERIC R. WILSO 8
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B y:f a
'A.RI CR. WILSN 10 Attorneys for Deutsche Bank Trust Company Americas, II Satellite Senior Income Fund, Satellite Senior Income Fund II, 12 BP Canada Energy Company, and JPMorgan Chase Bank 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
[LLY DRYE &
ARRPEN LLP LA01 INMJ/'14624 1
-3 BANKRUPTCY RULE 2019 STATEMENT OF KEr LEY DRYE & WARREN LLP