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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,

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 12906]

Case: 19-30088 Doc# 12955-1 Filed: 09/14/22 Entered: 09/14/22 14:55:54 Page 1

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1 

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 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.

1

2. In keeping with current Trust policy, the Trustee does not oppose the Consolidated 

Motion to Allow/Deem Timely Late Filing of Claimants, and Memorandum of Points and 

Authorities and Declaration of Peter Simon in Support Thereof [Docket No. 12906] (the “Late 

Claim Motion”) with respect to the claimants listed on Exhibit A hereto. Given the number of late 

claim motions filed in recent months2 and the amount of time that has passed since the December 

31, 2019 bar date for Fire Victim Claims and the February 26, 2021 deadline to submit claims 

questionnaires to the Trust, the Trustee will be discontinuing the current non-opposition policy with 

respect to late claim motions filed after September 30, 2022.

3. The proofs of claim listed on Exhibit A and any claims asserted in connection with 

such proofs of claim are subject to the requirements of the CRP and are not allowed or approved by 

the filing of this statement. Nothing herein shall be construed to be a waiver by the Trust of any 

right to object to the proofs of claim listed on Exhibit A or any claims asserted in connection with 

such proofs of claim on any grounds other than the untimely filing thereof.

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.

2 Of the 394 late claim motions filed since the December 31, 2019 extended bar date, 216 have been 

filed in the last six months and 161 were filed in August alone. To put these numbers in perspective, in 

2020, which included the months immediately after 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.

Case: 19-30088 Doc# 12955-1 Filed: 09/14/22 Entered: 09/14/22 14:55:54 Page 2

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2

DATED: September 14, 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# 12955-1 Filed: 09/14/22 Entered: 09/14/22 14:55:54 Page 3

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3

EXHIBIT A

LIST OF CLAIMANTS

Case: 19-30088 Doc# 12955-1 Filed: 09/14/22 Entered: 09/14/22 14:55:54 Page 4

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6

DATE

POC FILED POC NO. CLAIMANT(S)

8-19-2022 108782 Richard Baum

8-19-2022 108783 Dustin Baxter, Tamara Baxter, 

Blaine Baxter and Reid Baxter

8-23-2022 108811 Dolores Meyer and Bradley Meyer

1-6-2020

8-30-2022

96365

108833

(Amending 96365)

David Qin

1-8-2020

8-30-2022

96435

108860

(Amending 96435)

Lynn Marie Didier

8-30-2022 108861 William Klemme

8-30-2022 108866 E. Lawrence Armstrong 

and Karen Jacobson Armstrong

Case: 19-30088 Doc# 12955-1 Filed: 09/14/22 Entered: 09/14/22 14:55:54 Page 5

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