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Declaration of Narinderjit Singh -1-

1970 Broadway, Suite 600 Oakland, California 94612

ERIC A. NYBERG, ESQ. (Bar No. 131105)

CHRIS D. KUHNER, ESQ. (Bar No. 173291)

KORNFIELD, NYBERG, BENDES, KUHNER & LITTLE P.C.

1970 Broadway, Suite 600

Oakland, California 94612

Telephone: (510) 763-1000

Facsimile: (510) 273-8669

Email: e.nyberg@kornfieldlaw.com

Email: c.kuhner@kornfieldlaw.com

Attorneys for Movant Skyway Fuels, Inc.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

In re 

PG&E CORPORATION,

and

PACIFIC GAS AND ELECTRIC COMPANY,

Debtors.

Case No. 19-30088 DM

Chapter 11

DECLARATION OF

NARINDERJIT SINGH IN 

SUPPORT OF MOTION TO 

ALLOW/DEEM TIMELY LATE 

FILING OF SKYWAY FUELS, 

INC. AND MEMORANDUM OF 

POINTS AND AUTHORITIES

Date: TBD

Time: TBD

VIA-ZOOM

I, Narinderjit Singh, declare as follows:

1. I am the President of Skyway Fuels, Inc. (“Movant”). If called upon as a witness, I 

could and would competently testify as to the facts set forth in this Declaration, which are made 

based upon my personal knowledge.

2. Movant owned and operated a Chevron gas station and Kwik Stop Mini Mart in 

Paradise, California (the “Property”). The Property was substantially destroyed from the Camp Fire. 

As a result of the damages to the Property, Movant prepared a Proof of Claim to be filed in the 

PG&E bankruptcy case (the “Proof of Claim”). A true and correct copy of the Proof of Claim along 

Case: 19-30088 Doc# 12993 Filed: 09/21/22 Entered: 09/21/22 16:47:15 Page 1

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Declaration of Narinderjit Singh -2-

1970 Broadway, Suite 600 Oakland, California 94612

with the proof of mailing is attached hereto as Exhibit 1. The Proof of Claim was sent to Prime 

Clerk, LLC via USPS Priority Mail. The envelope containing the Proof of Claim was postmarked 

December 27, 2019. We received tracking information showing the expected delivery date was 

December 29, 2019. We believed that this was a reasonable form of mailing to insure the Proof of 

Claim was timely received and filed. We have searched our records for the delivery confirmation, 

but to date have not been able to locate this information.

3. In late August of 2022, we were informed by the Fire Victims Trust (“FVT”) for the 

first time that the Proof of Claim was marked received and filed on January 7, 2020. The Proof of 

Claim was Claim No. 96401. The FVT is taking the position that we are not eligible to participate 

in the FVT unless we have a timely filed proof of claim. This was the first time we learned that the 

Proof of Claim might not be timely.

I declare under penalty of perjury that the foregoing is true and correct and that this 

declaration was executed this 21st day of September, 2022 at Roseville, California. 

/s/ Narinderjit Singh

Case: 19-30088 Doc# 12993 Filed: 09/21/22 Entered: 09/21/22 16:47:15 Page 2

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EXHIBIT 1

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Claim Number: 96401

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