Case No. 19-30088 (DM) - Declaration of Richard B. Gullen In Support of Joint Motion for Relief from Automatic

Stay

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Rossi, Hamerslough, 

Reischl & Chuck

1960 The Alameda

Suite 200

San Jose, CA

95126-1493

(408) 261-4252

Fax (408) 261-4292

RICHARD B. GULLEN (SBN 144513)

ROSSI, HAMERSLOUGH, REISCHL & CHUCK

1960 The Alameda, Suite 200

San Jose, CA 95126-1493

Tel: (408) 261-4252

Fax: (408) 261-4292

Email: rick@rhrc.net

Attorneys for Movants,

XIAOTIAN SUN and WEI LUO

Gordon J. Finwall (SBN 141777)

FINWALL LAW OFFICES, APC

1056 Lincoln Avenue 

San Jose, CA 95125

Tel: (408) 350-4041

Fax: (408) 350-4042

Email: Gordon@Finwalllaw.com

Attorneys for Movants,

CSABA MESTER and MARTA MESTER

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In Re:

PG&E CORPORATION, 

And

PACIFIC GAS AND ELECTRIC COMPANY,

Debtors.

Affects both Debtors.

Bankruptcy Case No. 19-30088 (DM)

DC NO.: RG-1

Chapter 11

(Lead Case)

(Jointly Administered)

DECLARATION OF RICHARD B. 

GULLEN IN SUPPORT OF JOINT 

MOTION FOR RELIEF FROM 

AUTOMATIC STAY

XIAOTIANSUN and WEI LUO, and 

CSABA WENDEL MESTER and MARTA M. 

MESTER individually and as trustees of the 

CSABA & MARTA MESTER FAMILY 

REVOCABLE LIVING TRUST DATED 

9/1/2011 and any amendments thereto,

Movants, 

Date: July 31, 2019

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

Place: United States Bankruptcy Court

450 Golden Gate Avenue

Courtroom 17, 16th Floor

San Francisco, CA 94102

Case: 19-30088 Doc# 3038 Filed: 07/17/19 Entered: 07/17/19 15:53:24 Page 1 of

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Case No. 19-30088 (DM) - Declaration of Richard B. Gullen In Support of Joint Motion for Relief from Automatic

Stay

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Rossi, Hamerslough, 

Reischl & Chuck

1960 The Alameda

Suite 200

San Jose, CA

95126-1493

(408) 261-4252

Fax (408) 261-4292

vs.

PG&E CORPORATION, PACIFIC GAS AND 

ELECTRIC COMPANY, Debtors,

Respondents.

I, RICHARD B. GULLEN, declare as follows:

1. I am attorney duly licensed to practice law in the State of California, and the 

attorney for Xiaotian Sun and Wei Luo (the “Suns” herein). I have personal knowledge of the 

facts stated herein, and if called as a witness could competently testify thereto.

2. I submit this declaration in support of the motion for relief from automatic stay 

filed jointly by the Suns and Csaba Wendel Mester and Marta M. Mester, individually and as 

trustees of the Csaba & Marta Mester Family Revocable Living Trust Dated 9/1/2011 and any 

amendments thereto. 

3. Attached as Exhibit “A” is a copy of the Suns’ First Amended Complaint filed in 

the State Court Action.

4. Attached as Exhibit “B” is a copy of the Mesters’ Cross-Complaint filed in the 

State Court Action.

5. Attached as Exhibit “C” is a copy of the stipulation executed by counsel for the 

Suns and the Mesters granting leave to the Suns to file the proposed Second Amended 

Complaint, a copy of which is attached the stipulation.

6. Attached as Exhibit “D” is a copy of the cover letter dated July 15, 2019 and 

proposed stipulation and order for relief from automatic stay forwarded to Debtors’ counsel prior 

to the filing of this Motion. At the time of the filing of this Motion, no response has been 

received from Debtors’ counsel to the proposed stipulation.

7. The State Court Action was scheduled to begin trial on April 29, 2019. Due to the 

Debtors’ bankruptcy, on March 29, 2019, the Court in the State Court Action vacated the trial 

date and set the State Court Action for a trial setting conference on July 23, 2019.

I declare under penalty of perjury under the laws of the State of California that the 

Case: 19-30088 Doc# 3038 Filed: 07/17/19 Entered: 07/17/19 15:53:24 Page 2 of

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Case No. 19-30088 (DM) - Declaration of Richard B. Gullen In Support of Joint Motion for Relief from Automatic

Stay

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Rossi, Hamerslough, 

Reischl & Chuck

1960 The Alameda

Suite 200

San Jose, CA

95126-1493

(408) 261-4252

Fax (408) 261-4292

foregoing is true and correct.

Executed this 17th day of July, 2019, at San Jose, California.

By: / s / Richard B. Gullen

RICHARD B. GULLEN

Case: 19-30088 Doc# 3038 Filed: 07/17/19 Entered: 07/17/19 15:53:24 Page 3 of

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