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MICHAEL W. MALTER, #96533

ROBERT G. HARRIS, #124678

JULIE H. ROME-BANKS, #142364

Binder & Malter, LLP

2775 Park Avenue

Santa Clara, CA 95050

Telephone: (408)295-1700

Facsimile: (408) 295-1531

Email: julie@bindermalter.com

Attorneys for Creditor

Brookview MHP Investors, LLC dba

Thunderbird Mobile Home Park

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA, DIVISION 3 

In re:

PG&E CORPORATION, 

and, 

PACIFIC GAS AND ELECTRIC

COMPANY,

 Debtors.

9 Affects PG&E Corporation

9 Affects Pacific Gas and Electric

Company

9 Affects both Debtors

Case No. 19-30088 (DM)

Chapter 11 (Lead Case)

(Jointly Administered)

Date: June 26, 2019

Time: 9:30 a.m. 

STATEMENT IN SUPPORT OF DEBTORS’ MOTION PURSUANT TO FRBP 4001(d)

TO APPROVE STIPULATION WITH CALIFORNIA PUBLIC UTILITIES COMMISSION

IN RESPECT OF CERTAIN PROCEEDINGS 

Creditor Brookview MHP Investors, LLC dba Thunderbird Mobile Home Park

(“Brookview”) hereby advises the Court that it supports the DEBTORS’ MOTION

PURSUANT TO FRBP 4001(d) TO APPROVE STIPULATION WITH CALIFORNIA

PUBLIC UTILITIES COMMISSION IN RESPECT OF CERTAIN PROCEEDINGS

(docket #2414) (the “Motion”) and related STIPULATION BETWEEN DEBTORS AND

CALIFORNIA PUBLIC UTILITIES COMMISSION IN RESPECT OF CERTAIN

STATEMENT IN SUPPORT OF DEBTORS’ MOTION PURSUANT TO FRBP 4001(d) TO APPROVE STIPULATION WITH

CALIFORNIA PUBLIC UTILITIES COMMISSION IN RESPECT OF CERTAIN PROCEEDINGS PAGE 1

x

Case: 19-30088 Doc# 2501 Filed: 06/12/19 Entered: 06/12/19 15:45:30 Page 1 of

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COMMISSION PROCEEDINGS (docket #2416) (the “Stipulation”) filed in these cases. 

In support thereof, Brookview advises the Court of the following: 

1. Brookview is one of the parties described in the Motion and in the

Stipulation that had a complaint pending against Debtor Pacific Gas and Electric

Company before the California Public Utilities Commission (“CPUC”) at the time these

bankruptcy cases were filed. Brookview is identified as one of the “Proceeding Parties”

in Exhibit “A” to the Stipulation executed by the Debtors and the CPUC. Brookview’s

action before the CPUC is in the early stages: just prior to the petition date an

Administrative Law Judge as assigned and a briefing schedule ordered by the assigned

commissioner. The Debtor as defendant then filed a notice of stay on March 4, 2019.

2. At the time the instant Motion and Stipulation were filed and served,

Brookview was in the process of preparing a motion for relief from stay to be permitted

to liquidate its claims against the Debtor before the CPUC, but not to enforce any

resulting claim except through filing a proof of claim in the bankruptcy case. Brookview

also contends that it has claims against a general contractor in connection with the

same facts giving rise to Brookview’s claims against the Debtor. However, Brookview

cannot pursue third parties as a matter of law until Brookview has exhausted its

administrative remedies against the Debtor before the CPUC. 

3. By granting the Motion and approving the Stipulation between the Debtors

and the CPUC, the Court will alleviate the need for creditors like Brookview to file

individualized motions for relief from stay. Brookview’s claims against the Debtor must

eventually be liquidated before the CPUC in any event, and granting the relief

requested by the Motion will facilitate that judicial exercise in a forum other than this

Court. 

Accordingly, Brookview supports the Motion and Stipulation and requests that

they be approved. 

STATEMENT IN SUPPORT OF DEBTORS’ MOTION PURSUANT TO FRBP 4001(d) TO APPROVE STIPULATION WITH

CALIFORNIA PUBLIC UTILITIES COMMISSION IN RESPECT OF CERTAIN PROCEEDINGS PAGE 2

Case: 19-30088 Doc# 2501 Filed: 06/12/19 Entered: 06/12/19 15:45:30 Page 2 of

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Dated: June 12, 2019 BINDER & MALTER LLP

By /s/ Julie H. Rome-Banks

 Julie H. Rome-Banks

 Attorneys for Creditor

STATEMENT IN SUPPORT OF DEBTORS’ MOTION PURSUANT TO FRBP 4001(d) TO APPROVE STIPULATION WITH

CALIFORNIA PUBLIC UTILITIES COMMISSION IN RESPECT OF CERTAIN PROCEEDINGS PAGE 3

Case: 19-30088 Doc# 2501 Filed: 06/12/19 Entered: 06/12/19 15:45:30 Page 3 of

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