NOTICE OF HEARING ON BARBARA ZELMER AND ROBERT ZELMER’S MOTION FOR RELIEF 

FROM AUTOMATIC STAY TO EXERCISE SETOFF PURSUANT TO 11 U.S.C. §§ 362 AND 

553

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Manuel Corrales, Jr. SBN 117647

ATTORNEY AT LAW

17140 Bernardo Center Drive, Suite 358

San Diego, CA 92128

Tel: (858) 521-0634/Fax: (858) 521-0633

Email: mannycorrales@yahoo.com

Attorney for Creditors BARBARA JEAN ZELMER 

and ROBERT THOMAS ZELMER

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In Re

PG&E CORPORATION

and

PACIFIC GAS AND ELECTRIC 

COMPANY,

 Debtors.

Bankruptcy Cases

19-30088-DM (Lead Case)

19-30089-DM

(Jointly Administered)

NOTICE OF HEARING ON BARBARA 

ZELMER AND ROBERT ZELMER’S 

MOTION FOR RELIEF FROM 

AUTOMATIC STAY TO EXERCISE 

SETOFF PURSUANT TO 11 U.S.C. §§ 

362 AND 553

(11 U.S.C. §§ 362(d), 553(a), 562)

Date: June 25, 2019

Time: 9:30 a.m. (PT)

Ctrm: Hon. Dennis Montali 

450 Golden Gate Avenue 

16th Floor, Courtroom 17 

San Francisco, CA 94102

o Affects PG&E Corporation

o Affects Pacific Gas and 

Electric Corporation

Ä Affects both Debtors

**All papers shall be filed in 

the Lead Case No. 19-30088 DM

PLEASE TAKE NOTICE that Creditors BARBARA ZELMER and ROBERT 

ZELMER (“Zelmers”) have filed a motion for relief form automatic 

stay pursuant to 11 U.S.C. §§ 362(d)(1) to allow Debtor Pacific 

Gas and Electric Corporation and the Zelmers to complete an 

appeal of a stipulated judgment for purposes of effectuating a 

settlement reached by the parties (hereinafter “Motion”).

Case: 19-30088 Doc# 2185 Filed: 05/22/19 Entered: 05/22/19 11:41:16 Page 1 of

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NOTICE OF HEARING ON BARBARA ZELMER AND ROBERT ZELMER’S MOTION FOR RELIEF 

FROM AUTOMATIC STAY TO EXERCISE SETOFF PURSUANT TO 11 U.S.C. §§ 362 AND 

553

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PLEASE TAKE NOTICE that the Motion is based on the 

Memorandum of Points and Authorities filed concurrently, the 

Declaration of Manuel Corrales, Jr., and on other and further 

evidence the Court may consider at or before any hearing on the 

Motion. 

PLEASE TAKE NOTICE that the Motion is set for hearing on 

June 25, 2019 at 9:30 a.m., before the Honorable Dennis Montali 

at the United States Bankruptcy Court for the Northern District 

of California, San Francisco Division, located at 450 Golden 

Gate Avenue, 16th Floor, Courtroom 17, San Francisco, CA 94102.

PLEASE TAKE NOTICE that any responses or objections to the 

Motion shall be in writing and conform to the Federal Rules of 

Bankruptcy Procedure and the Local Bankruptcy Rules for the 

Northern District of California, shall be filed with the 

Bankruptcy Court in accordance with the customary practices of 

the Bankruptcy Court, and shall be served on:

(a) Chambers of the Honorable Judge Denis Montali;

(b) The Standard Parties as required by the Order 

Implementing Certain Notice and Procedures and Case 

Management Procedures;

(c) Counsel for the Zelmers, Manuel Corrales, Jr, 17140 

Bernardo Center Drive, Suite 358, San Diego, CA 92128; 

Martin Buchanan, Esq., Law Office of Martin N. 

Buchanan, APC, 655 West Broadway, Suite 1700, San 

Diego, CA 92101

(d) All other parties requesting notice pursuant to Rule 

2002 of the Federal Rules of Bankruptcy Procedure, to 

Case: 19-30088 Doc# 2185 Filed: 05/22/19 Entered: 05/22/19 11:41:16 Page 2 of

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NOTICE OF HEARING ON BARBARA ZELMER AND ROBERT ZELMER’S MOTION FOR RELIEF 

FROM AUTOMATIC STAY TO EXERCISE SETOFF PURSUANT TO 11 U.S.C. §§ 362 AND 

553

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be filed or received no later than fourteen (14) days 

after services of the Motion at 4:00 p.m. (PST).

PLEASE TAKE NOTICE that as provided by Local Rule 4001-

1(a), the Debtor, Pacific Gas & Electric Company, is advised to 

appear personally or by counsel at the preliminary hearing; and 

that failure to appear may result in the Court granting the 

relief requested by this Motion without further hearing, 

including the lifting of the automatic stay for the Zelmers to 

effectuate a setoff against its prepetition claims against the 

Debtor.

DATED: May 3, 2019

s/ Manuel Corrales, Jr.

Manuel Corrales, Jr., Esq.

Attorney for Creditors

BARBARA ZELMER and ROBERT 

ZELMER

Case: 19-30088 Doc# 2185 Filed: 05/22/19 Entered: 05/22/19 11:41:16 Page 3 of

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