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MATTHEW D. METZGER (SBN 240437)

mmetzger@belvederelegal.com

BELVEDERE LEGAL, PC

1777 Borel Place, Suite 314

San Mateo, CA 94402

Telephone: (415) 513-5980

Facsimile: (415) 513-5985

STUART G. GROSS (SBN 251019)

sgross@grosskleinlaw.com

TIM KLINE (SBN 319227)

tk@grosskleinlaw.com

GROSS & KLEIN LLP

The Embarcadero

Pier 9, Suite 100

San Francisco, CA 94111

t (415) 671-4628

f (415) 480-6688

Attorneys for Creditor,

Dan Clarke

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION

- and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

 Debtors.

Bankruptcy Case

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered) 

NOTICE OF HEARING

ON MOTION FOR RELIEF FROM 

THE AUTOMATIC STAY

 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).

Date: July 23, 2019

Time: 9:30 a.m.

Ctrm: Hon. Dennis Montali

 450 Golden Gate Avenue

 16th Floor, Courtroom No. 17

 San Francisco, CA 94102

 

Case: 19-30088 Doc# 2824 Filed: 07/02/19 Entered: 07/02/19 12:59:37 Page 1 of

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PLEASE TAKE NOTICE that on July 23, 2019 at 9:30 a.m., at the United States 

Bankruptcy Court for the Northern District of California, located at 450 Golden Gate Ave., 16th Floor, 

San Francisco, California, in Courtroom 17 of the Honorable Dennis Montali, Dan Clarke, Creditor 

herein (“Clarke”), will bring on for hearing his motion for relief from the automatic stay under 11 

U.S.C. § 362(d)(1) (the “Motion”). Clarke brings this Motion to continue with certain pending 

proceedings before the United States District Court as raised pre-petition in the matter, San Francisco 

Herring Association and Dan Clarke vs. Pacific Gas and Electric Company; PG&E Corporation, 

United States District Court, Northern District of California Case No. 14-cv-04393 WHO (JCS) 

(the “District Court Case”), in order to liquidate Clarke’s claims and enforce injunctive relief 

related to ongoing waste contamination caused by manufactured gas plants (“MGPs”) in the city 

and county of San Francisco that the Debtor owns and operates. Mr. Clarke further requests the 

order granting relief from stay be made effective immediately and that the fourteen (14) day waiting 

period of Bankruptcy Rule 4001(a)(3) be waived.

The Motion is based upon this Notice of Hearing, the Motion, the Declaration of Stuart G. 

Gross, the Request for Judicial Notice, the Declaration of Matthew D. Metzger, the exhibits served 

with the Motion, any reply, and on such other and further evidence and matters that the Court may 

consider at the hearing on the Motion, as well as the March 13, 2019 Final Order Pursuant to 11 

U.S.C. §§ 105(a) 363(b), AND 507(a) (7) AND FED. R. BANKR. P. 6003 AND 6004 (I) 

Authorizing Debtors to (A) Maintain and Administer Customer Programs, Including Public 

Purpose Programs, and (B) Honor Any Prepetition Obligations Relating Thereto; and (II) 

Authorizing Financial Institutions to Honor and Process Related Checks and Transfers (Dkt. No. 

843).

PLEASE TAKE FURTHER NOTICE that you are hereby informed that any objection 

by the Debtor or by the two official creditors’ committees shall be filed on or before 4:00 p.m. 

prevailing Pacific standard time five days prior to the hearing and served upon the 

undersigned and on all “Standard Parties” as defined in paragraph 5 of the Case Management 

Case: 19-30088 Doc# 2824 Filed: 07/02/19 Entered: 07/02/19 12:59:37 Page 2 of

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Order. You may be able to appear at the hearing by telephone and should consult the Court’s 

Procedures for Appearances by Telephone.

PLEASE TAKE FURTHER NOTICE that as provided in 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 so appear may result in the Court granting the relief 

requested without further hearing, including determining that cause exists under § 362(d)(1) 

to grant Clarke relief from the automatic stay to liquidate Clarke’s claims as raised pre-petition 

in the District Court Case and to enforce related injunctive relief after the District Court defines 

and enters a final ruling on liability.

Dated: July 2, 2019

BELVEDERE LEGAL, PC

By: /s/ Matthew D. Metzger________

Matthew D. Metzger

 Attorneys for Creditor Dan Clarke

Case: 19-30088 Doc# 2824 Filed: 07/02/19 Entered: 07/02/19 12:59:37 Page 3 of

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