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KELLER BENVENUTTI KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Dara L. Silveira (#274923) 

(dsilveira@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized Debtors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

REORGANIZED DEBTORS’ REPORT ON 

RESPONSES TO ONE HUNDRED 

TWENTIETH OMNIBUS OBJECTION TO 

CLAIMS AND REQUEST FOR ORDER BY 

DEFAULT AS TO UNOPPOSED 

OBJECTIONS 

[Re: Dkt. Nos. 13670, 13698, 13719, 13730] 

Regarding Objections Set for Hearing 

May 24, 2023, at 10:00 a.m. (Pacific Time) 

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: 19-30088 Doc# 13738 Filed: 05/17/23 Entered: 05/17/23 12:49:11 Page 1

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REQUEST FOR ENTRY OF ORDER BY DEFAULT 

 PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the “Utility”), as 

debtors and reorganized debtors (collectively, the “Debtors” or the “Reorganized Debtors”) in the 

above-captioned chapter 11 cases (the “Chapter 11 Cases”) hereby request, pursuant to Rule 

9014-1(b)(4) of the Bankruptcy Local Rules for the United States District Court for the Northern District 

of California, as made applicable to these Chapter 11 Cases by the Second Amended Order Implementing 

Certain Notice and Case Management Procedures, entered on May 14, 2019 [Dkt No. 1996] (“Case 

Management Order”), that the Court enter an order by default on the Reorganized Debtors’ One 

Hundred Twentieth Omnibus Objection to Claims (No Liability Claims) [Docket No. 13670] (the 

“Omnibus Objection”). 

RELIEF REQUESTED IN THE OMNIBUS OBJECTION

 The Omnibus Objection seeks to disallow and expunge the Proofs of Claim listed in Exhibit 1 

to the Omnibus Objection. 

NOTICE AND SERVICE 

 The Reorganized Debtors filed a Notice of Hearing with respect to the Omnibus Objection 

[Docket No. 13672]. The Omnibus Objection was also supported by the declaration of Renee Records 

[Docket No. 13671]. The Omnibus Objection, the Notice of Hearing, and the Declaration were served 

as described in the Certificate of Service of Alain B. Francoeur, filed on April 20, 2023 [Docket 

No. 13677]: each holder of a Claim listed on Exhibit 1 to the Omnibus Objection received a notice 

customized to include the claim number, debtor, claim amount and priority, and the basis for 

Reorganized Debtors’ objection with respect to the applicable Claim to be disallowed and expunged. 

 The deadline to file responses or oppositions to the Omnibus Objection has passed. The 

Reorganized Debtors have received the following responses: 

Docket No. Claimant Claim No. Resolution 

13698 Quentin Keen 67135 The Reorganized Debtors 

have reached a settlement 

with Claimant. The hearing 

on the Omnibus Objection 

will be taken off calendar 

pending documentation of the 

settlement. 

Case: 19-30088 Doc# 13738 Filed: 05/17/23 Entered: 05/17/23 12:49:11 Page 2

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Docket No. Claimant Claim No. Resolution 

13719 Synergy Project Management, Inc. 72390 The Reorganized Debtors are 

investigating Claimant’s 

response to the Omnibus 

Objection. The Reorganized 

Debtors have attempted to 

contact Claimant but have 

not received a response to 

date. Accordingly, the 

hearing on the Omnibus 

Objection with respect to this 

Claim will be continued to 

July 26, 2023. 

13730 David Mitchell 2306 The Reorganized Debtors are 

investigating Claimant’s 

response to the Omnibus 

Objection. Mr. Mitchell has 

agreed to continue the 

hearing on the Omnibus 

Objection with respect to this 

Claim to July 26, 2023. 

DECLARATION OF NO OPPOSITION RECEIVED 

 The undersigned hereby declares, pursuant to 28 U.S.C. § 1746, under penalty of perjury that: 

1. I am an attorney with the law firm of Keller Benvenutti Kim LLP, co-counsel for the 

Reorganized Debtors. 

2. I have reviewed the Court’s docket in the Chapter 11 Cases and have determined that no 

responses have been filed with respect to the Omnibus Objection except as described herein. 

3. This declaration was executed in San Francisco, California. 

 WHEREFORE, the Reorganized Debtors hereby request entry of an Order disallowing and 

expunging the Proofs of Claim listed in Exhibit 1 to this Request, which listed Claims are identical to 

those listed in Exhibit 1 to the Omnibus Objection, except as otherwise discussed above. 

Dated: May 17, 2023 KELLER BENVENUTTI KIM LLP 

By: /s/ Dara L. Silveira 

 Dara L. Silveira 

Attorneys for Debtors and Reorganized Debtors 

Case: 19-30088 Doc# 13738 Filed: 05/17/23 Entered: 05/17/23 12:49:11 Page 3

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Debtor Original Creditor Secured Administrative Priority Unsecured Total

Claim/Schedule To Be 

Disallowed and 

Expunged

Exhibit 1 One Hundred Twentieth Omnibus Objection : PG&E Corporation and Pacific Gas and Electric Company

Case No 19-30088 Jointly Administered

Date Filed/ 

Scheduled: Claim Transferred To:

Basis for 

Objection

813 $0.00 $0.00 $0.00 $20,000.00 $20,000.00 PG&E 

Corporation and Pacific Gas and Electric Company

Calera Corporation (dba Chemetry Corporation)Chemetry Corporation 11500 Dolan Road (Corner of Dolan Road & Highway 1) 

Moss Landing, CA 95039

2/15/2019 Rule 2; No 

Liability Based 

on Investigation

3002 $0.00 $0.00 $0.00 $160,513.00 $160,513.00 PG&E 

Corporation and Pacific Gas and Electric Company

Jackson Rancheria Development Corporationc/o Law Offices of Charles L. Hastings 4568 Feather River Dr., Suite A 

Stockton, CA 95219

5/15/2019 No Liability 

Based on 

Investigation

59027 $0.00 $0.00 $0.00 $392,979.48 $392,979.48 PG&E 

Corporation and Pacific Gas and Electric Company

Jimenez-Padgett, Manuel CordBarr & Mudford LLP Estee Lewis #238358 1824 Court Street PO Box 994390

Redding, CA 96001

10/17/2019 Amended and 

Superseded

8599 $50,000.00 $0.00 $15,700.00 $134,300.00 $200,000.00 PG&E 

Corporation and Pacific Gas and Electric Company

Rameriz, HedgerPO Box 1392 

San Juan Bautista, CA 95045

9/9/2019 No Liability 

Based on 

Investigation

2676 $150,000.00 $0.00 $50,000.00 $0.00 $200,000.00 PG&E 

Corporation and Pacific Gas and Electric Company

Rameriz, HedgerPO BOX 1392 

San Juan Bautista, CA 95045

4/23/2019 No Liability 

Based on 

Investigation

4012 $0.00 $0.00 $0.00 $360,000.00 $360,000.00 PG&E 

Corporation and Pacific Gas and Electric Company

Sitterding, Linda15677 Betters Rd 

Madera, CA 93636

7/23/2019 Barred by 

Statute of 

Limitations; 

No Liability 

Based on 

Investigation

1951 $0.00 $0.00 $0.00 $360,000.00 $360,000.00 PG&E 

Corporation and Pacific Gas and Electric Company

Sitterding, Linda15677 Betters Rd 

Madera, CA 93636

4/1/2019 Barred by 

Statute of 

Limitations; 

No Liability 

Based on 

Investigation

Page 1

Count: 7 Claims To Be Expunged Totals $200,000.00 $1,693,492.48 $65,700.00 $1,427,792.48 $0.00

Case: 19-30088 Doc# 13738 Filed: 05/17/23 Entered: 05/17/23 12:49:11 Page 4

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