ML022540546
| ML022540546 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  (DPR-080, DPR-082) |
| Issue date: | 08/02/2002 |
| 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: ML022540546 (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 DEBORAH S.
SHEFLER IN SUPPORT OF DEBTOR'S MOTION FOR VALUATION OF CLAIM FOR FEASIBILITY PURPOSES (SAMUEL ANDERSON, CLAIM NO.
178)
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. 178)
&~r Ai 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 6,2 95 Telephone:
415/434-1600 Facsimile:
415/217-5910 Attorneys for Debtor and Debtor in Possession PACIFIC GAS & ELECTRIC COMPANY UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
1 I, Deborah S. Shefler, 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 law department. I am one of the attorneys 4
representing PG&E with respect to Samuel Anderson v. Corestaff Services, Inc., et al., San 5
Francisco Superior Court Case No. 302556 (the "Anderson 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.
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- 2.
Attached as Exhibit A is a true and correct copy of Proof of Claim Number 10 178 (the "Claim") filed by Samuel Anderson on or about June 8, 2001, in PG&E's 11 bankruptcy proceeding.
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- 3.
Attached as Exhibit B is a true and correct copy of the First Amended 13 Complaint filed by Anderson in the Anderson Action. This document is the only material N
14 Anderson submitted as support for the Claim.
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- 4.
Attached as Exhibit C is a true and correct copy of a letter dated July 19, 16 2002, from counsel for Corestaff Services, Inc. ("Corestaff'), Anderson's former employer, 17 acknowledging that Corestaff will fully indemnify and defend PG&E, without reservation, in 18 the Anderson Action.
19 I declare under penalty of perjury under the laws of the State of California that 20 the statements in this declaration are true and correct. Executed on thisi day of August, at 21 San Francisco, California.
22 23 B
DEBORAH S. SHEFLER 24 25 26 27 28 WD 082102/f-14199681Y6/1015526/vi DECL. OF D. SHEFLER ISO DEBTOR'S MOTION FOR VALUATION OF CLAIM (CLAIM NO. 178)
-I-
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.
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.