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BROWN RUDNICK LLP 

David J. Molton (SBN 262075) 

(DMolton@brownrudnick.com) 

Eric R. Goodman (admitted pro hac vice) 

(EGoodman@brownrudnick.com) 

Seven Times Square 

New York, New York 10036 

Telephone: (212) 209-4800 

Facsimile: (212) 209-4801 

BROWN RUDNICK LLP 

Joel S. Miliband (SBN 077438) 

(JMiliband@brownrudnick.com) 

2211 Michelson Drive, Seventh Floor 

Irvine, California 92612 

Telephone: (949) 752-7100 

Facsimile: (949) 252-1514 

Attorneys for Fire Victim Trustee 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 - and – 

PACIFIC 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 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

FIRE VICTIM TRUSTEE’S 

STATEMENT OF NONOPPOSITION TO 

CONSOLIDATED MOTIONS TO 

DEEM LATE-FILED CLAIMS 

TIMELY FOR THE PURPOSE 

OF CLAIM ADMINISTRATION 

BY THE FIRE VICTIM TRUST 

[Relates to Docket Number 12939] 

Case: 19-30088 Doc# 12997 Filed: 09/22/22 Entered: 09/22/22 15:28:55 Page 1

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Cathy Yanni, in her capacity as the Trustee (the “Trustee”) of the Fire Victim Trust (the 

“Trust”), by and through her undersigned counsel and as directed by the Order Consolidating 

Motions to File Late Claims entered August 24, 2022 [Docket No. 12875] (the “Consolidation 

Order”) and the Order re Supplemental Exhibit to Order Consolidating Motions to File Late 

Claims entered September 1, 2022 [Docket No. 12923] (the “Supplemental Consolidation 

Order”), respectfully states as follows: 

1. The Fire Victim Trust Claims Resolution Procedures (“CRP”) mandate that 

claimants must have timely filed a proof of claim to be eligible to receive compensation from the 

Trust. See CRP § I. Accordingly, the Trust has been monitoring all motions filed with this Court 

that seek to have late-filed proofs of claim deemed “timely” for the purpose of having such claims 

administered by the Trust. 

2. On September 8, 2022, the claimants listed on Exhibit 1 hereto (“Movants”) filed 

the Amended & Consolidated Motion to Allow/Deem Timely Late Filing of Claimants, and 

Memorandum of Points and Authorities and Declaration of Joseph K. Feist in Support Thereof 

[Docket No. 12939], through which Movants assert that they should be permitted to file late claims 

for damages allegedly sustained as a result of the Camp Fire (the “Asserted Fire Victim Claims”). 

Specifically, Movants request that this Court enter an order finding that the proofs of claim listed 

on Exhibit 1 hereto (the “Proofs of Claim”) “are to be allowed as having been timely filed.” 

3. In keeping with the current Trust policy of allowing as many Claimants1

 as possible 

to receive compensation on account of valid Fire Victim Claims, the Trustee does not oppose the 

entry of an order deeming the Proofs of Claim “timely” for the purpose of allowing the Trust to 

administer the Asserted Fire Victim Claims provided that the Asserted Fire Victim Claims are not 

thereby deemed “allowed” or “approved” and remain subject to the requirements of the CRP. 

4. Nevertheless, the Trustee is concerned by the volume of late claim motions being 

filed. As this Court is aware, the number of motions seeking to have late claims deemed timely has 

1

 Capitalized terms used but not otherwise herein defined have the meanings ascribed to such terms in 

the CRP. 

Case: 19-30088 Doc# 12997 Filed: 09/22/22 Entered: 09/22/22 15:28:55 Page 2

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skyrocketed in recent months. Of the 331 late claim motions filed since the December 31, 2019 

extended bar date for non-governmental Fire Claimants, 237 (more than 70%) have been filed in 

the last six months. One hundred fifty-five (155) of those late claim motions were filed in August 

alone. To put these numbers in perspective, in 2020, which included the months immediately after 

both the extended bar date and the effective date of the Trust (both events that could be expected to 

prompt the filing of late claim motions), the total number of late claim motions filed alleging Fire 

Victim Claims was 55. In 2021, the total number was only 22. 

5. As of the date of this statement, 996 days have passed since the extended bar date. 

Five hundred seventy-three days (573) have passed since the deadline to file Claims Questionnaires 

with the Trust. Yet form late claim motions asserting only that Reorganized Debtors will not be 

prejudiced continue to be filed by the dozens, without consideration of the potential effect of 

granting these motions on the Trust and its beneficiaries. 

6. The Trustee must balance a desire to ensure as many fire victims as possible are 

compensated injuries arising from the Fires against the fact that tens of thousands of fire victims 

were able to timely file proofs of claim in these cases. The Trustee also recognizes there is a 

fundamental difference between claimants who file motions to have long-filed late proofs of claims 

deemed timely after receiving notice from the Trust of this necessity and those who file motions 

shortly after (or before) late proofs of claim are filed. Accordingly, the Trustee will discontinue the 

Trust’s liberal non-opposition policy with respect to late claim motions filed after September 30, 

2022. 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

Case: 19-30088 Doc# 12997 Filed: 09/22/22 Entered: 09/22/22 15:28:55 Page 3

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7. Nothing herein shall be construed to be a waiver by the Trust of any right to object 

to the Proofs of Claim or the Asserted Fire Victim Claims on any grounds other than the untimely 

filing thereof. 

DATED: September 22, 2022 BROWN RUDNICK LLP 

By: /s/ERIC R. GOODMAN 

 Eric R. Goodman (admitted pro hac vice) 

(EGoodman@brownrudnick.com) 

David J. Molton (SBN 262075) 

(DMolton@brownrudnick.com) 

Seven Times Square 

New York, New York 10036 

Telephone: (212) 209-4800 

Facsimile: (212) 209-4801 

and 

Joel S. Miliband (SBN 077438) 

(JMiliband@brownrudnick.com) 

2211 Michelson Drive 

Seventh Floor 

Irvine, California 92612 

Telephone: (949) 752-7100 

Facsimile: (949) 252-1514 

Attorneys for Fire Victim Trustee

 

Case: 19-30088 Doc# 12997 Filed: 09/22/22 Entered: 09/22/22 15:28:55 Page 4

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EXHIBIT 1 

LIST OF CLAIMANTS AND PROOFS OF CLAIM 

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64843616 v1-WorkSiteUS-035945/0001 

DATE POC FILED POC NO. CLAIMANT(S) 

9-7-2022 108894 Eric Rix 

9-8-2022 108932 Amanda Stoffer, Kylia Jenkins, 

Minors C. J.& L.S 

Case: 19-30088 Doc# 12997 Filed: 09/22/22 Entered: 09/22/22 15:28:55 Page 6

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