ML022540532
| ML022540532 | |
| 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: ML022540532 (4) | |
Text
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 Facsimile:
415/217-5910 1
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8 9
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 11 Case DECLARATION OF MAUREEN L.
FRIES IN SUPPORT OF DEBTOR'S VALUATION OF CLAIM FOR FEASIBILITY PURPOSES (GERI MARCHETTI CLAIM NO. 3831)
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. 3 83 1)
.10 lo 00 O j
Aoo01 Attorneys for Debtor and Debtor in Possession PACIFIC GAS & ELECTRIC COMPANY UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION Ko:-027 12 HO&14l 13 RXE m mCAaa, 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
1 I, Maureen L. Fries, hereby declare:
2
- 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 Marchetti v. Pacific Gas & Electric Company, 5
San Francisco Superior Court Case No. 317231 (the "Marchetti Action"). The documents 6
attached as exhibits to this declaration are maintained in the normal course of business by 7
PG&E. I have personal knowledge of the matters set forth in this declaration and if called 8
upon to testify thereto I could and would competently do so.
9
- 2.
Attached as Exhibit A is a true and correct copy of the Proof of Claim 10 number 3831 (the "Marchetti Claim") and attached exhibits, filed by Geri Marchetti 11
("Marchetti") on or about August 16, 2001 in the matter of In re Pacific Gas & Electric 12 Company.
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- 3.
Attached as Exhibit B is a true and correct copy of the First Amended RuE 14 Complaint for Damages in the Marchetti Action, filed on or about December 11, 2000.
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- 4.
Attached as Exhibit C is a true and correct copy of a document "Essential 16 Job Functions for Gas Associate Distribution Engineer," which was Marchetti's job 17 classification at all material times in the Marchetti Action.
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- 5.
Attached as Exhibit D is a true and correct copy of a portion of PG&E's 19 Summary of Benefits Handbook (Bargaining Unit Employees) entitled "Sick Leave and 20 Disability."
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- 6.
Attached as Exhibit E is a true and correct copy of the Payroll Change Tag 22 for Marchetti dated June 25, 1998.
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- 7.
Attached as Exhibit F is a true and correct copy of a letter from Dr. Lefkos 24 Aftonomos to Jeanne Mar, Workers' Compensation representative, dated August 3, 1998.
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- 8.
Attached as Exhibit G is a true and correct copy of a letter from Dr. Lefkos 26 Aftonomos to Jeanne Mar, Workers' Compensation representative, dated July 9, 1998.
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- 9.
Attached as Exhibit H is a true and correct copy of Grievance No. 02-33-99, 28 dated January 6, 1999, filed by Engineers and Scientists of California, Local 20 on behalf of DEC. OF M. FRIES ISO DEBTOR'S VALUATION OF CLAIM (CLAIM NO. 3831) 1 2
3 4
5 6
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.12 HOWARD 13 t
14 W9dK 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Geri Marchetti.
- 10.
Attached as Exhibit I is a true and correct copy of Grievance No. 02-02-99, dated January 6, 1999, filed by Engineers and Scientists of California, Local 20 on behalf of Geri Marchetti
- 11.
Attached as Exhibit J is a true and correct copy of a letter, and attachments, from Collins Arrengo, AAIEEO Consultant to Deborah Randall, dated June 23, 1999.
- 12.
Attached as Exhibit K is a true and correct copy of the Payroll Change Tag for Geri Marchetti, dated November 27, 2001.
- 13.
Attached as Exhibit L is a true and correct copy of a letter from Bryan J.
McCormack to the United States Bankruptcy Court, dated February 15, 2002
- 14.
Attached as Exhibit M is a true and correct copy of a Substitution of Attorney in the matter Marchetti v. Pacific Gas and Electric Company, filed on January 22, 2002, in San Francisco Superior.Court.
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.,
day of August, 2002. at San Francisco, California.
By:
7- -h,:x&.
MAUREEN L. FRIES WD 0821021F-14199681Y6/1015552/vI DEC. OF M. FRIES ISO DEBTOR'S VALUATION OF CLAIM (CLAIM NO. 3831)
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 9411-1-4024.