1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

KELLER BENVENUTTI KIM LLP

Jane Kim (#298192)

(jkim@kbkllp.com)

David A. Taylor (#247433)

(dtaylor@kbkllp.com)

Gabrielle L. Albert (#190895)

(galbert@kbkllp.com) 

650 California Street, Suite 1900

San Francisco, CA 94108

Tel: (415) 496-6723 

Fax: (650) 636 9251

Attorneys for Appellees (Debtors and 

Reorganized Debtors) 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered)

District Court Case No. 22-cv-00389-HSG

APPELLEES’ (I) RESPONSE TO SPIRO 

JANNINGS’ APPELLANT’S 

DESIGANTION OF RECORD AND 

STATEMENT OF ISSUES AND 

(II) DESIGNATION OF ADDITIONAL 

ITEMS TO BE INCLUDED IN THE 

RECORD ON APPEAL

Reorganized 

Debtors.

 Affects PG&E Corporation 

 Affects Pacific Gas and Electric Company 

 Affects both Reorganized Debtors 

* All papers shall be filed in the Lead Case, No. 

19-30088 (DM). 

Case: 19-30088 Doc# 13776 Filed: 05/26/23 Entered: 05/26/23 09:51:07 Page 1

of 5
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

PG&E Corporation and Pacific Gas and Electric Company (collectively, the “Appellees,” the 

“Debtors,” or as reorganized pursuant to the Debtors’ and Shareholder Proponents’ Joint Chapter 11 

Plan of Reorganization Dated June 19, 2020 [Dkt. No. 8048] (as it may be amended, modified, or 

supplemented and together with any exhibits or schedules thereto), the “Reorganized Debtors”) 

submit this response to the May 12, 2023, filing by Spiro Jannings (“Appellant”) of the Appellant’s 

Designation of Record and Statement of Issues on Appeal from Bankruptcy Court [Dkt. No. 13728], 

and designation of additional items to be included in the record on appeal, in connection with 

Appellant’s appeal from the Order Denying Motion for Reconsideration by Spiro Jannings, entered 

on March 27, 2023 [Dkt. No. 13646], by the United States Bankruptcy Court for the Northern District 

of California (the “Bankruptcy Court”). 

I. RESPONSE TO STATEMENT OF ISSUES ON APPEAL

The sole issue on appeal is whether the Bankruptcy Court abused its discretion in denying 

Appellant’s motion for reconsideration of the order disallowing his claim, as failing to meet the 

standard of Rule 60(b)(3) and untimely filed under Rule 60(c) of the Federal Rules of Civil Procedure, 

as adopted by Federal Rule of Bankruptcy Procedure (“FRBP”) 9024. 

II. DESIGNATION OF ADDITIONAL ITEMS TO BE INCLUDED IN RECORD ON 

APPEAL

Pursuant to FRBP 8009, the Reorganized Debtors hereby designate the following additional 

items to be included in the record on appeal, which include all exhibits and addenda attached thereto 

and filed therewith and all documents incorporated by reference therein: 

Docket items from In re PG&E Corp., et al., Case No. 19-30088 (DM): 

Dkt. No. Description Date

263 Amended Declaration of Jason P. Wells in Support of First Day 

Motions and Related Relief

02/01/2019

8048 Debtors’ and Shareholder Proponents’ Joint Chapter 11 Plan of 

Reorganization Dated June 19, 2020 

06/19/2020

8053 Order Confirming Debtors’ and Shareholder Proponents’ Joint 

Chapter 11 Plan of Reorganization Dated June 19, 2020 

06/20/2020

Case: 19-30088 Doc# 13776 Filed: 05/26/23 Entered: 05/26/23 09:51:07 Page 2

of 5
2 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Dkt. No. Description Date

10494 Order Further Extending Deadline for the Reorganized Debtors to 

Object to Claims and Granting Related Relief

04/05/2021

11392 Request for Judicial Notice in Support of Reorganized Debtors’ 

Objection to Claim (Claim No. 58462, Filed October 17, 2019, of 

Spiro Jannings) 

10/08/2021

11417 Certificate of Service of Sonia Akter 10/13/2021

11488 Notice of Continued Hearing on Reorganized Debtors’ Objection to 

Claim (Claim No. 58462, Filed October 17, 2019, of Spiro 

Jannings) 

10/26/2021

11838 Certificate of Service of Sonia Akter 01/20/2022

11853 Certificate of Service of Alain B. Francoeur 01/21/2022

11854 Certificate of Service of Sonia Akter 01/21/2022

11916 Certificate of Service of Xavi Flores 02/10/2022

11959 Certificate of Service of Alain B. Francoeur 02/21/2022

11969 Reply in Support of Motion for Relief From Order (Default Order; 

Dkt #11829; Sustaining Objection to Claim No. 58462; Dkt # 

11388) 

02/23/2022

12040 Certificate of Service of Sonia Akter 03/18/2022

13457 Notice of Deficiency 01/17/2023

13459 Certificate of Service of Dan Carney 01/17/2023

13464 Relief From Stay Cover Sheet 01/20/2023

13653 Certificate of Service of Alain B. Francoeur 04/01/2023

13664 Transmittal of Notice of Appeal to District Court 04/10/2023

13676 Certificate of Service of Victor Wong 04/20/2023

13683 Appellant’s Motion for Expansion of Time 04/26/2023

13694 Service of Notice of Failure to Perfect Appeal 05/04/2023

Case: 19-30088 Doc# 13776 Filed: 05/26/23 Entered: 05/26/23 09:51:07 Page 3

of 5
3 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Dkt. No. Description Date

13726 Appellant’s Motion for Leave to Expand Time for Designation of 

Record and Statement of Issues on Appeal from Bankruptcy Court 

05/12/2023

13727 Appellant’s Declaration in Support of Motion for Leave to Expand 

Time for Designation of Record and Statement of Issues on Appeal 

from Bankruptcy Court 

05/12/2023

13728 Appellant’s Designation of Record and Statement of Issues on 

Appeal from Bankruptcy Court 

05/12/2023

13729 Certificate of Mailing of Dan Carney 05/12/2023

13733 Order Granting Appellant Spiro Jannings’ Motion for Leave to 

Expand Time 

05/15/2023

Docket Text from In re PG&E Corp., et al., Case No. 19-30088 (DM): 

Dkt. No. Description Date

N/A DOCKET TEXT ORDER (no separate order issued:) Denied The

Motion to Extend Time filed by Spiro Jennings (#11768) is 

DENIED for the reasons stated by Debtors (#11775). The Motion to 

Abstain that Mr. Jennings filed (#11753) was not even set for 

hearing; the Objection to his claim was filed nearly three months 

ago. The Objection will remain on the January 18, 2022, calendar 

unless Debtors agree to continue it. (RE: related document(s)11768 

Motion to Extend Time filed by Creditor Spiro Jannings). (Montali, 

Dennis) 

12/31/2021

N/A DOCKET TEXT ORDER (no separate order issued:) The Motion 

For Relief From Order (Dkt 11871), filed by Spiro Jannings, and set 

on the March 2, 2022, 10:00 AM calendar, is DROPPED from the 

calendar. The court does not further argument, and the matter will 

stand as SUBMTTERD on the papaers. (RE: related 

document(s)11871 Motion Miscellaneous Relief filed by Creditor 

Spiro Jannings). (Montali, Dennis) 

02/28/2022

N/A Hearing Dropped. The hearing on 3/2/22 regarding Motion for 

Relief from Order (Default Order Dkt #11829; Sustaining Objection 

to Claim No. 58462) is dropped from the calendar pursuant to the 

Court's 2/28 Docket Text Order. (related document(s): 11871 

Motion Miscellaneous Relief filed by Spiro Jannings) (lp) 

03/01/2022

Case: 19-30088 Doc# 13776 Filed: 05/26/23 Entered: 05/26/23 09:51:07 Page 4

of 5
4 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Hearing Transcripts from in In re PG&E Corp., et al., Case No. 19-30088 (DM): 

Dkt. No. Description Date

13591 March 7, 2023 Hearing Transcript 03/08/2023

Proof of Claim filed in In re PG&E Corp., et al., Case No. 19-30088 (DM): 

Claim No. Claimant Date

58462 Spiro Jannings 10/17/2019

The Reorganized Debtors reserve the right to designate additional items for inclusion in the 

record or restate the issues presented on appeal.

Dated: May 26, 2023 

KELLER BENVENUTTI KIM LLP

By: /s/ Jane Kim 

Jane Kim

Attorneys for the Appellees (Debtors and 

Reorganized Debtors) 

Case: 19-30088 Doc# 13776 Filed: 05/26/23 Entered: 05/26/23 09:51:07 Page 5

of 5