ML022540392
| ML022540392 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/22/2002 |
| From: | Shefler D 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: ML022540392 (4) | |
Text
JEFFREY L. SCHAFFER (No. 91404)
ETHAN P. SCHULMAN (No. 112466)
DEBORAH A. KANE (No. 184326)
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 1
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10 11 In re PACIFIC GAS and ELECTRIC COMPANY, a California corporation, Debtor.
Federal I.D. No. 94-0742640 Case No. 01-30923 DM Chapter II Case DECLARATION OF DEBORAH S.
SHEFLER IN SUPPORT OF DEBTORS MOTION FOR VALUATION OF CLAIM FOR FEASIBILITY PURPOSES (DEANNE CANNON, CLAIM NO. 4898)
Date:
October 2, 2002 Time:
1:30 p.m.
Place:
235 Pine Street, 22nd Floor San Francisco, California Judge: Hon. Dennis Montali DECL. OF D. SHEFLER ISO DEBTOR'S MOTION FOR VALUATION OF CLAIM (CLAIM NO. 4898)
Attorneys for Debtor and Debtor in Possession PACIFIC GAS & ELECTRIC COMPANY UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 5 -6')
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15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Deborah S. Shefler, hereby declare:
- 1.
I am an attorney licensed to practice before this Court. I am employed by Pacific Gas & Electric Company ("PG&E") in its law department. I am one of the attorneys representing PG&E with respect to Deanne Cannon v. Pacific Gas & Electric Company, San Francisco Superior Court Case No. 402362 (the "Cannon Action"). The documents attached as exhibits to this declaration are maintained in the normal course of business by PG&E. I have personal knowledge of the matters set forth in this declaration and if called upon to testify thereto I could and would competently do so.
- 2.
Attached as Exhibit A is a true and correct copy of Proof of Claim number 4898 (the "Claim"), filed by Deanne Cannon ("Cannon") on or about August 22, 2001.
- 3.
Attached as Exhibit B is a true and correct copy of the partial Charge of Discrimination (the "Charge") filed by Cannon with the California Department of Fair Employment and Housing on or about October 20, 2000, which Cannon submitted as support for the Claim.
- 4.
Attached as Exhibit C is a true and correct copy of the Charge.
- 5.
Attached as Exhibit D is a true and correct copy of the Complaint filed by Cannon in the Cannon Action, on or about December 11, 2001.
- 6.
Attached as Exhibit E is a true and correct copy of PG&E's response to the Charge, dated March 7, 2001, prepared by Patricia Freeman, PG&E Equal Employment Opportunity Consultant.
- 7.
Attached as Exhibit F is a true and correct copy of an Attending Physician Statement dated December 13, 1999, from Dr. Laurence Alavezos, certifying that Cannon was unable to work.
- 8.
Attached as Exhibit G is a true and correct copy of an Attending Physician Statement dated September 28, 2000, from Dr. Laurence Alavezos, certifying that Cannon was able to return to work without restrictions or job modifications.
- 9.
Attached as Exhibit H is a true and correct copy of a Memorandum of Disposition -
North Coast Grievance, resolving Cannon's grievance over PG&E's bypass DECL. OF D. SHEFLER ISO DEBTOR'S MOTION FOR VALUATION OF CLAIM (CLAIM NO. 4898) 1 2
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&PAaaN 15 16 17 18 19 20 21 22 23 24 25 26 27 28 of her bid for a meter reader position, which became open in May 2000.
- 10.
Attached as Exhibit I is a true and correct copy of a Letter Agreement dated May 4, 2001, between PG&E and the International Brotherhood of Electrical Workers, Local 1245 (Cannon's union), certifying that PG&E will return Cannon to work in a meter reader position.
I declare under penalty of perjury under the laws of the State of California that the statements in this declaration are true and correct. Executed on this *2,,ay of August, at San Francisco, California.
QLDýEBýORAH S.'SJFE WD 082102/F-14199681Y6/1015537/vl DEC. OF D. SHEFLER ISO DEBTOR'S MOTION FOR VALUATION OF CLAIM (CLAIM NO. 4898) I6
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: Nathaniel H. Hunt, Three Embarcadero Center, 7th Floor, San Francisco, California 94111-4024.