ML022540523
| ML022540523 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/22/2002 |
| From: | Fries M 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: ML022540523 (4) | |
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15 16 17 18 19 20 21 22 23 24 25 26 27 28 In re PACIFIC GAS and ELECTRIC COMPANY, a California corporation, Debtor.
Federal I.D. No. 94-0742640 Case No. 01-30923 DM Chapter 11 Case DECLARATION OF MAUREEN L.
FRIES IN SUPPORT OF DEBTOR'S VALUATION OF CLAIM FOR FEASIBILITY PURPOSES (GILBER MEDEIROS CLAIM NO. 7057)
Date:
October 2, 2002 Time:
1:30 p.m.
Place:
235 Pine Street, 22nd Floor San Francisco, California Judge: Hon. Dennis Montali DEC. OF M. FRIES ISO DEBTOR'S VALUATION OF CLAIM (CLAIM NO. 7057)
Poa JEFFREY L. SCHAFFER (No. 91404)
ETHAN P. SCHULMAN (No. 112466)
LINDA Q. FOY (No. 148764)
HOWARD, RICE, NEMEROVSKI, CANADY, FALK & RABKIN A Professional Corporation Three Embarcadero Center, 7th Floor San Francisco, California 94111-4065 Telephone:
415/434-1600 50" L-75 Facsimile:
415/217-5910 31.2 Attorneys for Debtor and Debtor in Possession PACIFIC GAS & ELECTRIC COMPANY UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
1 I, Maureen L. Fries, hereby declare:
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- 1.
I am an attorney licensed to practice before this Court. I am employed by 3
Pacific Gas & Electric Company ("PG&E") in its in-house counsel office. I am one of the 4
attorneys representing PG&E with respect to Medeiros v. Pacific Gas and Electric Company, 5
United States District Court for the Eastern District of California, Case No. Civ.-S-00-1042 6
LKK DAD PS (the "Medeiros Action"). The documents attached as exhibits to this 7
declaration are maintained in the normal course of business by PG&E. I have personal 8
knowledge of the matters set forth in this declaration and if called upon to testify thereto I 9
could and would competently do so.
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- 2.
Attached as Exhibit 1 to this declaration is a true and correct copy of the 11 Proof of Claim Filed by Mr. Medeiros in Pacific Gas and Electric Company's Bankruptcy 12 Proceeding.
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Attached as Exhibit 2 to this declaration is a true and correct copy of the RIM
""CtX 14 Memorandum of Points a Authorities in Support of Defendants' Motion for Summary 15 Judgment in Medeiros v. PG&E. et al., Case No. Civ-S-00-1042 LKK DAD PS in the 16 United States District Court, Eastern District of California (Sacramento).
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Attached as Exhibit 3 to this declaration is a true and correct copy of the 18 Separate Statement of Undisputed Facts in Support of Defendants' Motion for Summary 19 Judgment in Medeiros v. PG&E, et al., United States District Court, Eastern District of 20 California, Case No. Civ-S-00-1042 LKK DAD PS.
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Attached as Exhibit 4 to this Declaration is a true and correct copy of the 22 Declaration of Maureen L. Fries in Support of Defendants' Motion for Summary Judgment 23 in Medeiros v. PG&E, et al., United States District Court, Eastern District of California, 24 Case No. Civ-S-00-1042 LKK DAD PS, including Exhibits A-H to the Declaration.
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Attached as Exhibit 5 to this Declaration is a true and correct copy of the 26 Declaration of Gil Smith in Support of Defendants' Motion for Summary Judgment in 27 Medeiros v. PG&E, et al., Eastern District of California Case No Civ-S-00-1042 LKK DAD 28 PS, including Exhibits A-C to the Declaration.
DEC. OF M. FRIES ISO DEBTOR'S VALUATION OF CLAIM (CLAIM NO. 7057) 1 2
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Attached as Exhibit 6 to this Declaration is a true and correct copy of the Declaration of James Moore in Support of Defendants' Motion for Summary Judgment in Medeiros v. PG&E, et al., United States District Court, Eastern District of California, Case No. Civ-S-00-1042 LKK DAD PS, including Exhibits A-E to the Declaration.
I declare under penalty of perjury under the laws of the State of C~lifomia that the statements in this declaration are true and correct. Executed on this.-
day of August, 2002, at San Francisco, California.
7f/V ' +&
/L 7 MAUREEN L. FRIES WD 082102/F-1419968UY6/1017755/vi DEC. OF D. SHEFLER ISO DEBTOR'S VALUATION OF CLAIM (CLAIM NO. 7057)
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.