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MACDONALD | FERNANDEZ LLP

RENO F.R. FERNANDEZ III (SBN 251934)

MATTHEW J. OLSON (SBN 265908)

221 Sansome Street, Third Floor

San Francisco, CA 94104

Telephone: (415) 362-0449

Facsimile: (415) 394-5544

Attorneys for Creditor, WENDY NATHAN

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

In Re:

PG&E CORPORATION

and

PACIFIC GAS AND ELECTRIC 

COMPANY

Debtors.

Affects PG&E Corporation

Affects Pacific Gas and Electric Co.

Affects both Debtors

* All papers shall be filed in Lead Case, 

No. 19-30088-DM

Case Nos. 19-30088-DM-11

19-30089-DM-11

Chapter 11

(Jointly Administered)

NOTICE OF HEARING ON MOTION FOR 

RELIEF FROM THE AUTOMATIC STAY

Date: June 11, 2019

Time: 9:30 a.m.

Place: Courtroom 17

450 Golden Gate Ave., 16th Floor

San Francisco, California

Opposition Deadline: June 6, 2019, 4 p.m. PDT

Hon. Dennis Montali

NOTICE IS HEREBY GIVEN that a hearing on the Motion for Relief from the Automatic

Stay (the “Motion”) of Wendy Nathan, Creditor herein, pursuant to 11 U.S.C. § 362(d), Fed. R. 

Bankr. P. 4001(a), and Bankr. Local Rule 4001-1, to liquidate Creditor’s claims asserted in an action

pending before the Superior Court of California in and for the County of Alameda styled Wendy 

Nathan v. Ann D. Grcevich, Successor Trustee of the Survivor’s Trust, Grcevich Trust dated June 7, 

1991; Jane Inok Hong; and Pacific Gas and Electric Company (Case No. RG17873549) concerning 

certain pre-petition personal injuries suffered by the Creditor, will be held on June 11, 2019, at 

9:30 a.m., or as soon thereafter as the matter may be heard, before the Honorable Dennis Montali, 

United States Bankruptcy Judge, at 450 Golden Gate Ave., 16th Floor, Courtroom 17, San Francisco, 

California. Ms. Nathan will move the Court for relief from stay for cause on the basis that the Court 

should abstain from resolving the underlying claims under 28 U.S.C. § 1334(c). Ms. Nathan further 

requests the order granting relief from stay be made effective immediately and that the fourteen (14) 

day waiting period of Bankruptcy Rule 4001(a)(3) be waived.

This Motion is based upon this Notice of Hearing, the Motion, the Declaration of Seth I. 

Rosenberg, exhibits served with the Motion, any reply, and any arguments presented to the Court at 

the hearing hereon. Copies of the Motion and its supporting pleadings are served herewith.

You are hereby informed that any objection by the Debtor or by the two official creditors’

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committees shall be filed on or before 4:00 p.m. prevailing Pacific time five days prior to the 

hearing. See Second Amended Order Implementing Certain Notice and Case Management 

Procedures ¶ 27. For all other parties, no written response is required in order to oppose this 

motion; if you or your counsel do not appear at the hearing on this motion, the relief requested may 

be granted. See id.; see also L.B.R. 4001-1(f). You may be able to appear at the hearing by 

telephone and should consult the Court’s Procedures for Appearances by Telephone.

If you file written opposition or response to the Motion: (i) you must file and serve it 

pursuant to the Order Implementing Certain Notice and Case Management Procedures (as amended, 

the “Case Management Order”) [Dkt No. 759] entered on March 6, 2019, which was amended on 

March 27, 2019 [Dkt. No. 1093] and on May 13, 2019 [Dkt. No. 1996]; and (ii) you must serve it 

upon the undersigned and on all “Standard Parties” as defined in paragraph 5 of the Case 

Management Order.

Copies of each pleading identified herein can be viewed or obtained: (i) by accessing the 

Court’s website at http://www.canb.uscourts.gov; (ii) by contacting the Office of the Clerk of the 

Court at 450 Golden Gate Avenue, San Francisco, CA 94102; or (iii) from the Debtors’ notice and 

claims agent, Prime Clerk LLC, at https://restructuring.primeclerk.com/pge or by calling (844) 339- 4217 (toll free) for U.S.-based parties, or +1 (929) 333-8977 for International parties, or by e-mail at: 

pgeinfo@primeclerk.com. Note that a PACER password is needed to access documents on the 

Bankruptcy Court’s website.

DATED: May 16, 2019 MACDONALD | FERNANDEZ LLP

By: /s/ Matthew J. Olson 

Matthew J. Olson

Attorneys for Creditor, WENDY NATHAN

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