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DOCS_SF:107916.2 1 

Debra Grassgreen

One Market Plaza, Spear Tower 

40th Floor, Suite 4000 

San Francisco, CA 94105 

E-mail: dgrassgreen@pszjlaw.com 

Fire Victim 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 -andPACIFIC GAS AND ELECTRIC COMPANY, 

Debtors. 

☐ Affects PG&E Corporation 

☐ Affects Pacific Gas and Electric 

Company 

 Affects both Debtors 

* All papers shall be filed in the lead case, 

No. 19-30088 (DM)

Case No. 19-30088 

Chapter 11 

Jointly Administered 

FIRE VICTIM’S RESPONSE TO FIRE 

VICTIM TRUSTEE’S STATEMENT OF 

NON-OPPOSITION TO CONSOLIDATED 

MOTIONS TO DEEM LATE-FILED 

CLAIMS TIMELY FOR THE PURPOSE 

OF CLAIM ADMINISTRATION BY THE 

FIRE VICTIM TRUST 

[Relates to Docket Numbers 12956 and 12915] 

Debra Grassgreen, individual fire victim (“Claimant”), hereby responds to the Fire Victim 

Trustee’s Statement of Non-Opposition to Consolidated Motions to Deem Late-Filed Claims Timely 

for the Purpose of Claim Administration by the Fire Victim Trust (the “Statement of NonOpposition”) [Dkt. No. 12956] and the Consolidated Motions to Deem Late-Filed Claims Timely 

For the Purpose of Claim Administration By the Fire Victim Trust [Dkt. No. 12915]. In support 

hereof, Claimant respectfully represents as follows: 

Case: 19-30088 Doc# 12960 Filed: 09/14/22 Entered: 09/14/22 17:53:54 Page 1

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DOCS_SF:107916.2 2 

The Trustee filed the Statement of Non-Opposition and indicated simply that it is “trust 

policy” not to oppose the filing of late claim (regardless of the reason(s) for filing the late claim) and 

indicating that she will not oppose any other motions (again, regardless of the reasons) so long as 

they are filed by September 30th without regard to the binding standard for seeking leave to file a late 

proof of claim under Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380 (1993). 

There is no indication that the Trustee reviewed any of the underlying motions and claims to 

determine whether or not each claimant’s individual circumstances and the evidence presented meet 

the standard for submitting claims nearly three years after the extended claims bar date of December 

31, 2019 and in some cases nearly five years after the applicable fire. 

While there may very well be reasons for some of these claims to have been filed late, had 

the Trustee done even a cursory review of some of the motions it would be evident that many of 

them say nothing more than “I didn’t know I had a claim” and almost every motion represents,

incorrectly, that there is no prejudice because this is a solvent case. Even attorneys who are 

members of the Trust Oversight Committee that are privy to detailed information regarding 

projected recoveries are nonetheless representing to this Court that there is no prejudice because all 

creditors will be paid in full, which is not correct. 

The Trustee’s predecessor has stated clearly and unequivocally that fire victims will never be 

paid in full: 

Lily Jamali: What is your sense of whether fire victims will ever be 

made whole from what you can tell right now? 

Justice Trotter: They never will. 

(August 16, 2021 Interview). Ms. Yanni has not indicated otherwise. Thus, the administrative 

expense of processing these late claims, along with any distributions to these claimants will dilute 

the recovery to the other fire victims that filed timely claims and delay the distributions to them. 

Inasmuch as the claims information that has been submitted to support the claims is only 

available to Trustee and her staff, the Trustee and her counsel are uniquely situated to review the 

motions and the claims to determine if the facts of the underlying claims satisfy the excusable 

neglect standard under Pioneer in each individual motion. If the Trustee is not going to review the 

Case: 19-30088 Doc# 12960 Filed: 09/14/22 Entered: 09/14/22 17:53:54 Page 2

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DOCS_SF:107916.2 3 

motions on a case-by-case basis and is simply relying on “trust policy,” Claimant respectfully 

requests that the Court give no weight to the Statement of Non-Opposition and instead review the 

motions and evidence submitted individually and determine if the standard is met on a case by case 

basis. 

Respectfully, 

Dated: September 14, 2022 By: /s/ Debra Grassgreen 

Debra Grassgreen 

Case: 19-30088 Doc# 12960 Filed: 09/14/22 Entered: 09/14/22 17:53:54 Page 3

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