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DECLARATION IN SUPPORT OF EX PARTE APPLICATION TO ALLOW CONSIDERATION OF 

UNTIMELY FILING OF OPPOSITION TO OBJECTION TO CLAIM 3002 1

CHARLES L. HASTINGS 

CA State Bar No.: 88599

NATALI A. RON

CA State Bar No.: 302927

Law Office of Hastings & Ron

PMB 270, 4719 Quail Lakes Drive, Suite G

Stockton, CA 95207

(209) 476-1010

Attorneys for JACKSON RANCHERIA DEVELOPMENT CORP

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

 PG&E CORPORATION 

- and -

 PACIFIC GAS AND ELECTRIC

 COMPANY,

Debtors.

Case No: 19-30088 (DM)

Chapter 11

DECLARATION IN SUPPORT OF EX 

PARTE APPLICATION TO FILE LATE 

OPPOSITION TO REORGANIZED 

DEBTORS’ ONE HUNDRED TWENTIETH 

OMNIBUS OBJECTION TO CLAIMS – BY

JACKSON RANCHERIA DEVELOPMENT 

CORP (CLAIM NO. 3002)

Date: May 24, 2023

Time: 10:00 a.m. 

Location: (Video/Teleconference Only)

U.S. Bankruptcy Court 

Courtroom 17, 16th floor

San Francisco, CA 94102

Judge: Honorable Dennis Montali

I, NATALI A. RON, declare as follows:

1. I am the attorney of record for JACKSON RANCHERIA DEVELOPMENT 

CORP, (hereinafter referred to as “Jackson”) the creditor in the above-captioned matter, which 

filed Claim No. 3002 on or about May 15, 2019. I have personal knowledge of the matter set 

forth herein, and if called upon to do so, could and would competently, truthfully, and accurately 

testify hereto.

Case: 19-30088 Doc# 13754-1 Filed: 05/18/23 Entered: 05/18/23 18:00:43 Page 1

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DECLARATION IN SUPPORT OF EX PARTE APPLICATION TO ALLOW CONSIDERATION OF 

UNTIMELY FILING OF OPPOSITION TO OBJECTION TO CLAIM 3002 2

2. As set forth in the Reorganized Debtors’ One Hundred Twentieth Omnibus 

Objection to Claims, Jackson’s claim was originally channeled to the Fire Victim Claims, and 

preliminarily identified as a Fire Victim Claim to be administered, processed, settled, disallowed, 

resolved, liquidated, satisfied, and/or paid by the Fire Victim Trust in accordance with its 

governing documents. However, upon the discovery that this was not an appropriate Fire Victim 

Claim, I notified the Fire Victim Claims administrator. After months of waiting and follow-up, 

the claim was finally re-channeled to the appropriate General Unsecured Claims. I received 

email confirmation of this on April 5, 2023. Approximately two weeks later, on April 14, 2023,

the subject Reorganized Debtors’ One Hundred Twentieth Omnibus Objection to Claims was 

filed. 

3. I received the Reorganized Debtors’ Report on Responses to One Hundred

Twentieth Omnibus Objection to Claims and Request for Order by Default as to Unopposed

Objections [Doc. No. 13738] in today’s service email. Upon receipt, I immediately undertook 

review to discover the motion to which this document applied, only to discover a service email 

of April 14, 2023. I reviewed my calendar and emails to confirm how I did not previously see 

this email. Because I had not previously received the Omnibus Objection, I inadvertently did not 

timely file opposition thereto, which was due to be filed on May 10, 2023, in accordance with 

this Court’s ORDER APPROVING (A) PROCEDURES FOR FILING OMNIBUS 

OBJECTIONS TO CLAIMS AND (B) THE FORM AND MANNER OF THE NOTICE OF 

OMNIBUS OBJECTIONS. [Docket No. 8228]. 

4. It appears I received the filings via email on April 14, 2023, at 1:21 p.m.; 

however, at that time, I was preparing for a non-retained expert deposition which was scheduled 

to commence at 3:00 p.m., in the matter if Irrigation Design & Construction, LLC v. Parker 

Technical Sales, Monterey County Superior Court case no.: 20CV003182. This matter was 

scheduled for and proceeded to trial on May 8, 2023, and I am still in trial which I believe will 

resume May 22, 2023. (We conducted four days of testimony, however, due to opposing 

counsel’s COVID-19 exposure, the matter has been delayed.) 

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DECLARATION IN SUPPORT OF EX PARTE APPLICATION TO ALLOW CONSIDERATION OF 

UNTIMELY FILING OF OPPOSITION TO OBJECTION TO CLAIM 3002 3

5. The Monday following e-service, which was April 17, 2023, I had an all-day

binding arbitration in the matter of Jaspreet Singh v. Reedy Mechanical Inc., San Joaquin County 

Superior Court case no.: STK-CV-UCC-2021-11339, which took place at ADR Services in 

Oakland, California. 

6. The week of April 17, 2023, I also had two retained expert witness depositions, 

and two non-retained expert witness depositions in the matter of Irrigation Design & 

Construction, LLC v. Parker Technical Sales. Between the five depositions in that two-week

period, preparation for and appearance at arbitration, and continued preparation for the Monterey 

County Court trial, I inadvertently did not see the service email come through on the

Reorganized Debtors’ One Hundred Twentieth Omnibus Objection to Claims. 

7. This Court’s Order Approving (A) Procedures for Filing Omnibus Objections To 

Claims And (B) the Form and Manner of the Notice of Omnibus Objections sets forth the 

Omnibus Claim Objection Notice procedure (paragraph F), which requires “the Omnibus Claim 

Objection Notice [to] be served on the individual Claimant by mail, not less than 37 days before 

the date set for hearing of the Omnibus Objection, at the address specified in the Proof of 

Claim.” However, I have no record of having received the One Hundred Twentieth Omnibus 

Objection to Claims via mail. Upon review of the certificate of service, it appears Counsel’s 

office address is listed; however, my office now has a designated mailing address, and although 

there is a change of address on file with the Post Office, and mail should be delivered to our Post 

Mail Box, there have been many instances of mailing issues and mail being returned to sender. 

As such, and in any event, I have not received the Omnibus Objection via mail. 

8. Accordingly, and based on my inadvertent and excusable neglect, I am 

respectfully requesting this Court to allow the late filing of Jackson’s Opposition to the Omnibus 

Objection, to consider it prior to the hearing scheduled for May 24, 2023, and to hear oral 

argument on said matter.

9. There is no danger of prejudice to the Reorganized Debtors or their bankruptcy 

estate in deeming the Creditor’s Opposition to Objection to its claim as timely filed because 

Case: 19-30088 Doc# 13754-1 Filed: 05/18/23 Entered: 05/18/23 18:00:43 Page 3

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DECLARATION IN SUPPORT OF EX PARTE APPLICATION TO ALLOW CONSIDERATION OF 

UNTIMELY FILING OF OPPOSITION TO OBJECTION TO CLAIM 3002 4 

there has been no plan confirmation, and no distributions have been made to general unsecured 

creditors. 

Executed under penalty of perjury under the laws of the State of California, this 18th day 

of May 2023, at Stockton, California. 

 BY: 

NATALI A. RON Attorney for JACKSON 

RANCHERIA DEVELOPMENT CORP

Case: 19-30088 Doc# 13754-1 Filed: 05/18/23 Entered: 05/18/23 18:00:43 Page 4

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