1 WILLIAM F. ALDERMAN (State Bar No. 47381)
FREDERICK BROWN (State Bar No. 65316)
2 DENISE M. ALTER (State Bar No. 126605)
ORRICK, HERRINGTON & SUTCLIFFE LLP
3 Old Federal Reserve Bank Building
400 Sansome Street
4 San Francisco, California 94111-3143
Telephone: (415) 392-1122
5 Facsimile: (415) 773-5759
6 Attorneys for Defendants
PG&E Corporation, Robert D. Glynn, Jr.
7 and Peter A. Darbee
8
9 UNITED STATES DISTRICT COURT
10 NORTHERN DISTRICT OF CALIFORNIA
11 SAN JOSE DIVISION
12
13
14 JACK GILLAM, et al. CASE NO. C 01-20617 JF RS
15 Plaintiffs, REQUEST FOR JUDICIAL NOTICE AND
DECLARATION OF WILLIAM F.
16 v. ALDERMAN IN SUPPORT OF MOTION TO
DISMISS FIRST AMENDED COMPLAINT
17 PG&E CORPORATION, ROBERT D.
GLYNN, JR. and PETER A. DARBEE, Date: November 26, 2001
18 Time: 9:00 a.m.
Defendants. Place: Courtroom of the Hon. Jeremy Fogel
19 (Courtroom 3)
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SNIPPETS:
San Francisco,
PG&E Corporation, Robert D. Glynn, Jr.
respectfully request that the Court take judicial notice pursuant to Rule 201 of the Federal
with the Securities and Exchange Commission, orders and resolutions of the California
news reports, and historic trading information, and other information of which the Court may
MGIC Indemnity Corp. v. Weisman, 803 F. 2d 500, 504 (9th Cir.
to dismiss, court may take judicial notice of matters of public record outside pleadings).
12 routinely take judicial notice of SEC filings on motions to dismiss, even when those
Judicial notice of any document referenced in the complaint whose authenticity is
19 market as well as other publicly available stock information.
23 by counsel for plaintiffs in the Central District of California against Edison
declaration in support of Defendants' Motion to Dismiss Plaintiffs' First Amended Complaint
11 Public Utilities Commission (CPUC) Decision D.97-10-057,
PUC LEXIS 988 (Oct. 22,
PUC LEXIS 217
19 Accounting Standards Board's Statement of Financial Accounting Standards No. 71 printed
report dated July 21, 2000, from ABN-AMRO, Inc., as reported by Dan Ford.
10 Energy Service press release, dated July 27, 2000, which along with the remaining Dow Jones
13 report dated August 14, 2000, from Morgan Stanley Dean Witter, as reported by Kit Konolige.
19 Energy Service press release, dated September 1, 2000.
report dated September 12, 2000, from ABN-AMRO Inc., as reported by Dan Ford.
September 25, 2001, which I caused to have downloaded from www.iwon.com on the internet.
"Moody's Changes the Rating Outlook for Pacific Gas and Electric
28 Central District of California, CV 00-11516, which I caused to have copied from court
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