j 1 Peter S. Muioz (State Bar No. 66942) Gregg M. Ficks (State Bar No. 148093) 2 CROSBY, HEAFEY, ROACH & MAY Professional Corporation 3 Two Embarcadero Center San Francisco, CA 94111 4 Mailing Address: P.O. Box 7936 5 San Francisco, CA 94120-7936 6 Telephone: (41 5) 543-8700 Facsimile: (415) 391-8269 7 8 Attorneys for Placer County Water Agency, Oroville-Wyandotte Irrigation District, 9 Yuba County Water Agency, Nevada Irrigation District 10 Oakdale and South San Joaquin Irrigation Districts, Merced Irrigation District, 11 Humboldt Bay Municipal Water District Merrit Community Capital Corporation 12 z 0 13 W 0 UNITED STATES BANKRUPTCY COURT 0 14 w NORTHERN DISTRICT OF CALIFORNIA L 0 a: 0 z 15 0L SAN FRANCISCO DIVISION U 16 0 17 In re No. 01-30923 DM 18 PACIFIC GAS & ELECTRIC Chapter 11 COMPANY, a California 19 corporation, Date: May 25, 2001 Time: 1:30 p.m. 20 Debtor. Place: 235 Pine St., 22nd Fl., San Francisco, CA 94111 21 Federal I.D. No. 94-0742640 Judge: Honorable Dennis Montali 22 23 24 NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE 25 26 27 28 12252173.1 Notice of Appearance and Request for Special Notice 1. TO THE CLERK OF THE ABOVE-CAPTIONED COURT, DEBTOR PACIFIC GAS AND 2 ELECTRIC COMPANY AND ITS ATTORNEYS OF RECORD, THE OFFICIAL 3 COMMITTEE OF UNSECURED CREDITORS AND ITS ATTORNEYS OF RECORD, 4 ANY OFFICIAL OR UNOFFICIAL COMMITTEE IN THIS BANKRUPTCY CASE AND 5 THEIR ATTORNEYS OF RECORD, THE UNITED STATES TRUSTEE, ALL PARTIES 6 LISTED ON THE ATTACHED PROOF OF SERVICE, AND ALL OTHER CREDITORS, 7 AND PARTIES-IN-INTEREST, AND THEIR COUNSEL: 8 Pursuant to Federal Rules of Bankruptcy Procedure 2001 (a). 2002, 9 3017(a), 4001, 6006(c), 9007, 9013 and Bankruptcy Code Sections 102(1), 10 303(9), and 342, Placer County Water Agency, Oroville-Wyandotte Irrigation 11 District, Yuba County Water Agency, Solano County Water Agency, Nevada 2 12 Irrigation District, Oakdale and South San Joaquin Irrigation Districts, Humboldt Bay 0 < 13 Municipal Water District, and Merced Irrigation District, creditors holding claims, 0<0 a. >:o0.g 14 including, but not limited to administrative priority claims in this bankruptcy case, W 15 and creditor Merrit Community Capital Corporation ("Creditors"), hereby request in 16 special notice of all proceedings and other matters within the scope of the above 0 17 Rules and Code Sections, and all other notices given or required to be given, and all 18 papers filed or served in this bankruptcy case under the United States Bankruptcy 19 Code, the Federal Rules of Bankruptcy Procedure, or the Local Rules or practices of 20 this Court, whether sent by the Court, the Debtor, the Unsecured Creditors' 21 Committee, any Official or Unofficial Committee in this bankruptcy case, the United 22 States Trustee, or any other creditor or party-in-interest, or their attorneys, and that 23 all such notices and papers be sent to Creditors' attorneys of record at the 24 following address: 25 Peter S. Mufioz, Esq. 26 Gregg M. Ficks, Esq. CROSBY HEAFEY ROACH & MAY Professional Corporation 27 Two Embarcadero Center, Suite 200 San Francisco, CA 94111-4106 28 -1 - 122521 73.1 Notice of Appearance and Request for Special Notice 1 Mailing Address: P.O. Box 7936 2 San Francisco, CA 94120-7936 3 4, DATED: May 14, 2001. 5 CROSBY, HEAFEY, ROACH & MAY Professional Corporation 6 7 By 8 Peter S. Munoz Attorneys for Placer County Water 9 Agency, Oroville-Wyandotte Irrigation 10 District, Yuba County Water Agency; Solano County Water Agency, Nevada 11 Irrigation District, Oakdale and South San Joaquin Irrigation 12 District, Merced Z Irrigation District, Humboldt Bay 0 Municipal Water District, and c 13 Merrit Community Capital 0 0 o 0 Corporation 0C.) 14 L.I Z 15 I 2. 16 0 17 18 19 20 21 22 23 24 25 26 27 28 -2- 12252173.1 Notice of Appearance and Request for Special Notice 1 PROOF OF SERVICE 2 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. I am employed in the office of a member of the bar of this court at 3 whose direction the service was made. My business address is CROSBY, HEAFEY, ROACH & MAY Professional Corporation, Two Embarcadero Center, Suite 2000, San Francisco, CA 4 94111. On May 14, 2001, 1 caused to be served the following document(s) by the method indicated below: 5 NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE 6 [ by transmitting via facsimile on this date from fax number (415) 391-8269 the 7 document(s) listed above to the fax number(s) set forth below. The transmission was completed before 5:00 p.m. and was reported complete and without error. The 8 transmission report, which is attached to this proof of service, was properly issued by the transmitting fax machine. Service by fax was made by agreement of the parties, 9 confirmed in writing. 10 FR by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United States mail at San Francisco, California addressed as set forth below. I am readily familiar with the firm's practice of collection and processing of 11 correspondence for mailing. Under that practice, it would be deposited with the U.S. -< Postal Service on that same day with postage thereon fully prepaid in the ordinary course 2 12 of business. I am aware that on motion of the party served, service is presumed invalid if M: -the postal cancellation date or postage meter date is more than one day after the date of 0 13 deposit for mailing in this Declaration. O0 "0 14 [- by placing the document(s) listed above in a sealed envelope(s) and by causing personal U •delivery of the envelope(s) to the person(s) at the address(es) set forth below. A signed S15 proof of service by the process server or delivery service will be filed shortly. w 16 " bsy personally delivering the document(s) listed above to the person(s) at the address(es) co ccset forth below. W0 17 L' by placing the document(s) listed above in a sealed envelope(s) and consigning it to an express mail service for guaranteed delivery on the next business day following the date 18 of consignment to the address(es) set forth below. A copy of the consignment slip is attached to this proof of service. 19 SEE ATTACHED SERVICE LIST 20 21 I declare under penalty of perjury under the laws of the United States that the above is true and correct. Executed on May 14, 2001, at San Francisco, California. 22 23 24 y N. Pincus 25 26 27 28 12252163.1 PROOF OF SERVICE UNITED STATES BANKRUPTCY COURT NO. 01-30923 DM SPECIAL NOTICE LIST As of May.14, 2001 Debtor: Alan Z. Yudowsky PACIFIC GAS & ELECTRIC CO. Anne E. Wells P.O. Box 7442 Stroock & Stroock & Lavan LLP San Francisco, CA 94120 2029 Century Park East, Suite 1800 Los Angeles, California 90067 Attorneys for Debtor: [Counsel for Sempra Energy Trading James L. Lopes Corp] Howard, Rice, Nemerovski, Canday, et al. Alex Makler 3 Embarcadero Center, 7th Floor Calpine Corporation San Francisco, CA 94111-4065 6700 Koll Center Parkway, Suite 200 Pleasanton, California 94566 Special Counsel for Debtor: Martin S. Schenker Arlen Orchard Law Offices of Cooley Godward Sacramento Municipal Utility District 1 Maritime Plaza, 20th Floor 6201 S. Street, Mail Stop B408 San Francisco, CA 94111 Sacramento, California 95817 U.S. Trustee: Aron Mark Oliner Stephen L. Johnson Buchalter, Nemer, Fields & Younger, A Office of the U.S,. Trustee Professional Corporation 250 Montgomery Street # 1000 333 Market Street, 29th Floor San Francisco, CA 94104 San Francisco, California 94105 [Counsel for MBIA Insurance Adam A. Lewis Corporation] Morrison & Foerster 425 Market Street, 33rd Floor San Francisco, California 94105 B.C. Barmann, Sr. [Counsel for El Paso] County Counsel Attn: Jerri S. Bradley, Deputy Adam A. Lewis 1115 Truxtun Avenue, Fourth Floor Morrison & Foerster Bakersfield, California 93301 425 Market Street, 33rd Floor [Counsel for Phil Franey, Treasurer/Tax San Francisco, California 94105 Collector for Kern County] [Counsel for Idaho Power] Bank of America National Trust and Adrienne Vadell Sturges Savings Association Sodexho Marriott Services, Inc. Attn: Peggie Sanders 9801 Washingtonian Boulevard, 12th 1850 Gateway Boulevard Floor Concord, CA 94520 Gaithersburg, MD 20878 I 12252044.1 12252056.1 Bank of America National Trust and Bankers Trust Co. of California, NA Savings Association Structured Finance Group CA5-705-12-10 Attn: Peter Becker Attn: Adeline Tourunian 4 Albany St., 10th Floor 555 California Street, 12th Floor New York, NY 10006 San Francisco, CA 94104 Bankers Trust Co. Bank of America Trustee Corp. Trust Attn: Clara Strand Safet Kalabovic 555 South Flower Street 4 Albany Street, 4th Floor Mail Code CA9-706-11-21 New York, NY 10006 Los Angeles, CA 90071 Bankers Trust Company Bank of America, Admin. Agent Corporate Trust Services Attn: Katherine Kemerait Attn: Safet Kalabovic Bank of America 4 Albany Street, 4th Floor 555 California Street, 12th Floor New York, NY 10006 San Francisco, CA 94104-1502 Banque Nationale de Paris Bank of America, N.A. San Francisco Branch Admin. Agent Attn: Debra Wright Kathrine Kemerait 180 Montgomery St., 4th Floor 555 California Street, 12th Floor San Francisco, CA 94104 San Francisco, CA 94104-1502 Ben Whitwell Bank One Whitwell & Emhoff LLP Corporate Trust Administration 202 N. Canon Drive Attn: Janice Ott Rotunno Beverly Hills, California 90210 Mail Code IL1-0126 [Attorney for California Power 1 Bank One Plaza Exchange] Chicago, IL 60670-0126 Bennett G.