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TIMOTHY S. LAFFREDI (WI SBN 1055133) 

Assistant United States Trustee

JASON BLUMBERG (NY SBN 4055257)

Trial Attorney

MARTA E. VILLACORTA (NY SBN 4918280)

Trial Attorney

United States Department of Justice

Office of the U.S. Trustee 

450 Golden Gate Avenue, Suite 05-0153

San Francisco, CA 94102

Telephone: (415) 705-3333

Facsimile: (415) 705-3379

Email: jason.blumberg@usdoj.gov

marta.villacorta@usdoj.gov

Attorneys for Andrew R. Vara, Acting United States Trustee for Region 31

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

- and -

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

Date: July 24, 2019

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

Place: United States Bankruptcy Court

 Courtroom 17, 16th Floor

 San Francisco, CA 94102

PACIFIC GAS AND ELECTRIC 

COMPANY,

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)

DECLARATION OF LAURIE A. BRUGGER IN SUPPORT OF 

UNITED STATES TRUSTEE’S OBJECTION TO MOTION OF DEBTORS FOR 

ENTRY OF AN ORDER APPROVING KEY EMPLOYEE INCENTIVE PLAN

 

1 Andrew R. Vara, Acting United States Trustee for Region 3, is acting in this appointment for Tracy 

Hope Davis, United States Trustee for Region 17, who has recused herself.

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I, Laurie A. Brugger, declare as follows:

1. I am employed as a paralegal specialist in the Sacramento Office of the United 

States Trustee, Region 17 (the “UST”). I am the paralegal specialist assigned to the bankruptcy 

cases of PG&E Corporation and Pacific Gas and Electric Company (the “Debtors”), which are 

jointly administered in Chapter 11 Case No. 19-30088. I have personal knowledge of the facts 

set forth herein, and based on that personal knowledge, I assert that all such facts are true and 

correct to the best of my knowledge. To the extent I base my testimony upon information and 

belief or upon admissible evidence other than my personal knowledge, I will specifically so state.

2. On July 17, 2019, I accessed the UST’s electronic file for this case and located an 

email exchange between counsel for the UST and counsel for the Debtors on June 6, 2019 and 

June 7, 2019. Exhibit A hereto is a true and correct copy of this email exchange. 

3. On July 17, 2019, I accessed the electronic case filing system for Chapter 11 Case 

No. 19-30088 and downloaded copies of the Debtors’ monthly operating reports for February 

2019 (ECF No. 1137), March 2019 (ECF No. 1945) and April 2019 (ECF No. 2276). Exhibit B

hereto is a true and correct copies of the “Payment to Insiders” sections of those reports.

4. On June 18, 2019, I emailed a letter from Assistant United States Trustee Timothy 

S. Laffredi to the Debtors’ counsel, Mr. Goren. Exhibit C hereto is a true and correct copy of 

Mr. Laffredi’s letter.

5. On June 28, 2019, I received an email from the Debtors’ counsel, Mr. Schinckel. 

Attached to Mr. Schinckel’s email was a letter from Mr. Goren in response to Mr. Laffredi’s 

letter. Exhibit D hereto is a true and correct copy of Mr. Goren’s letter.

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EXHIBIT A

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Brugger, Laurie (USTP)

From: Goren, Matthew <matthew.goren@weil.com>

Sent: Friday, June 7, 2019 11:22 AM

To: Zipes, Greg (USTP)

Cc: Jane Kim

Subject: RE: PGE: MOR reporting

As we discussed, these payments were one a time, annual allowances for perquisite benefits.  This is a not a bonus; 

rather it is a lump‐sum annual cash stipend paid in lieu of providing broader perquisite benefits.  Here is a further 

description from the company’s 10K and a link to the complete 

filing  https://www.sec.gov/Archives/edgar/data/75488/000095015719000501/form10ka.htm 

Perquisites and Related Compensation

  

NEOs (Named Executive Officers) generally receive a limited range of perquisite benefits, typically encompassing a partial

subsidy for financial planning services from a third‐party financial advisory firm, partial reimbursement of certain health

club fees, on‐site parking, executive health services, and de minimis perquisites under a pre‐approved perquisite policy.  

The Compensation Committee (and the independent members of the PG&E Corporation Board in the case of Ms. Williams, 

and the independent members of the Utility Board in the case of Mr. Stavropoulos) also approved a 2018 lump‐sum annual 

stipend amount for each executive officer consistent with 2017, which ranged from $15,000 to $35,000 (the upper end

applicable only to Ms. Williams). This stipend is provided in lieu of providing the NEOs with additional perquisite benefits.

The NEOs have discretion to use this stipend as they see fit. 

From: Zipes, Greg (USTP) <Greg.Zipes@usdoj.gov>  

Sent: Friday, June 7, 2019 2:13 PM 

To: Goren, Matthew <matthew.goren@weil.com> 

Cc: Jane Kim <jkim@kellerbenvenutti.com> 

Subject: RE: PGE: MOR reporting 

Will get back to you soon.  Are you going to respond to the questions we had about the payments to insiders in 

March?  It is still unclear what these payments are for.    

From: Goren, Matthew <matthew.goren@weil.com>  

Sent: Thursday, June 6, 2019 8:35 PM 

To: Zipes, Greg (USTP) <Greg.Zipes@UST.DOJ.GOV> 

Cc: Jane Kim <jkim@kellerbenvenutti.com> 

Subject: PGE: MOR reporting 

Greg – We appreciate the time you and the rest of the team with the U.S. Trustee’s office have spent over the past few 

weeks working with us on these issues.  As discussed, below is a recitation of our understanding of the parties’ 

agreement to resolve the issues of the U.S. Trustee’s office regarding the form and deadlines for filing the Debtors’ 

monthly operating reports and the Debtors’ Motion dated May 1, 2019 [Docket No. 1788].  Please let us know if we have 

missed anything.  Otherwise, please confirm via reply email that the U.S. Trustee is in agreement with the below.  In 

addition, attached is a draft form of order for your review.  As discussed, the order is largely silent on the form and 

manner of filing the MORs and leaves it to the parties to reach an agreement amongst themselves or seek further order 

of the Court.  Once we have an agreement on the substance below and the form of order, we will submit to the court for 

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approval.  The attached and below remain subject to further comment and review.  Let us know if you have any 

questions.  Thank you, Matt 

1. Timing: The Debtors will continue to file MORs in accordance with the schedule set forth in the Motion, which, 

for the avoidance of doubt, is restated as follows: 

MOR Month  Local Rule  Proposed Filing under 

Debtors’ Motion 

Example 

Non‐SEC Reporting 

Months (Jan., Feb., 

Apr., May, Jul., Aug., 

Oct., & Nov.) 

No later than the 21st day 

of the month following the 

month to which the report 

pertains.

No later than the 31st day of 

the month following the 

month to which the report 

pertains. 

 (Requesting an additional 

~10 days) 

May MOR would be 

filed no later July 1 

(June 30 is a 

Sunday) 

SEC‐Quarterly 

Reporting Months 

(Mar., June, and 

Sept.) 

No later than the 21st day 

of the month following the 

month to which the report 

pertains.

No later than the 45 days 

following the month to which 

the report pertains. 

 (Requesting an additional 

~25 days) 

June MOR would be 

filed no later than 

Aug 15 

SEC‐Annual Reporting 

Month (Dec.) 

No later than the 21st day 

of the month following the 

month to which the report 

pertains.

No later than 60 days 

following the month to which 

the report pertains.  

(Requesting an additional 

~40 days) 

December MOR 

would be filed no 

later than February 

28 

2. Cash Flow Statement: The Debtors will include a statement of cash flows only in their MORs that correspond 

with SEC‐Quarterly or Annual Reporting Months (March, June, September, and December). 

3. Cumulative Income Statement:  The Debtors will include in their MORs going forward a cumulative income 

statement from the Petition Date through the applicable reporting period for each Debtor.  

4. Disbursements: The Debtors will report disbursements going forward in their MORs for each Debtor to the 

nearest dollar (e.g., not rounded figures). 

5. Payments to Retained Professionals:  The Debtors will include going forward in their MORs a breakdown of 

payments to each retained professional.  

Matthew P. Goren

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153 

matthew.goren@weil.com

+1 212 310 8440 Direct 

+1 212 310 8007 Fax

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The information contained in this email message is intended only for use of the individual or entity named above. If the 

reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended 

recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly 

prohibited. If you have received this communication in error, please immediately notify us by email, postmaster@weil.com, 

and destroy the original message. Thank you.

The information contained in this email message is intended only for use of the individual or entity named above. If the 

reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended 

recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly 

prohibited. If you have received this communication in error, please immediately notify us by email, postmaster@weil.com, 

and destroy the original message. Thank you.

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EXHIBIT B

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12. PAYMENTS ON PRE-PETITION DEBT 

The following reflects the payments for the month ended February 28, 2019 made in accordance with the authority granted by 

the Bankruptcy Court pursuant to the First Day Motions. 

(in millions) 

First Day Motions Disbursed in Month 

Operational Integrity Supplier —

Cash Management —

NGX - CAISO 25

Public Purpose Programs 86

Shippers / Liens 2

Tax 26

Employee Wage and Benefits 139

Total 278

13. PAYMENTS FOR RETAINED PROFESSIONALS 

There were no payments made to bankruptcy professionals retained under section 327 or 363 of the Bankruptcy Code during 

the month ended February 28, 2019. 

14. PAYMENTS TO INSIDERS 

The following reflects the cash payments made to insiders of the Corporation and the Utility during the month ended February 

28, 2019. Other than reimbursement for reasonable expenses incurred in connection with attending Board of Directors 

meetings, Board of Directors committee meetings, or participating in other activities undertaken on behalf of the Corporation 

and the Utility, there were no payments made to non-employee directors during the reporting period. 

(in ones) Total Payments 

for Month Name Title (1) (2)

Loraine Giammona Senior Vice President and Chief Customer Officer $ 40,000

Julie Kane 

Senior Vice President, Chief Ethics and Compliance Officer, and Deputy 

General Counsel, PG&E Corporation and Pacific Gas and Electric Company 39,433

Kathleen Kay Senior Vice President and Chief Information Officer 34,583

Michael Lewis Senior Vice President, Electric Operations 37,500

Janet Loduca 

Senior Vice President and Interim General Counsel, PG&E Corporation and 

Pacific Gas and Electric Company 87,296 (3) 

Steven Malnight Senior Vice President, Energy Supply and Policy 43,750

Dinyar Mistry 

Senior Vice President, Human Resources and Chief Diversity Officer, PG&E 

Corporation and Pacific Gas and Electric Company 42,667

John Simon Interim Chief Executive Officer, PG&E Corporation 135,078 (4) 

Jesus Soto Senior Vice President, Gas Operations 49,819

David Thomason 

Vice President, Chief Financial Officer, and Controller, Pacific Gas and 

Electric Company 

Vice President and Controller, PG&E Corporation 33,333

Fong Wan Senior Vice President, Energy Policy and Procurement 45,456

Jason Wells Senior Vice President and Chief Financial Officer, PG&E Corporation $ 52,500

(1) Except as otherwise noted, all positions have been held at the Utility.

(2) Payments primarily consist of salary and accrued vacation pay.

(3) Includes temporary monthly compensation increase as a result of promotion to position of Interim General Counsel.

(4) Approximately 60% of this amount reflects accrued vacation pay.

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14. PAYMENTS TO INSIDERS 

The following reflects the cash payments made to insiders of the Corporation and the Utility during the month ended March 31, 

2019. Other than reimbursement for reasonable expenses incurred in connection with attending Board of Directors meetings, 

Board of Directors committee meetings, or participating in other activities undertaken on behalf of the Corporation and the 

Utility, there were no payments made to non-employee directors during the reporting period. 

(in ones) Total Payments 

for Month Name Title (1) (2) (3)

Loraine Giammona Senior Vice President and Chief Customer Officer $ 60,000

Julie Kane 

Senior Vice President, Chief Ethics and Compliance Officer, and Deputy 

General Counsel, PG&E Corporation and Pacific Gas and Electric Company 59,433

Kathleen Kay Senior Vice President and Chief Information Officer 49,827

Michael Lewis Senior Vice President, Electric Operations 57,500

Janet Loduca 

Senior Vice President and Interim General Counsel, PG&E Corporation and 

Pacific Gas and Electric Company 101,833 (4) 

Steven Malnight Senior Vice President, Energy Supply and Policy 68,750

Dinyar Mistry 

Senior Vice President, Human Resources and Chief Diversity Officer, PG&E 

Corporation and Pacific Gas and Electric Company 62,667

John Simon Interim Chief Executive Officer, PG&E Corporation 75,317

Jesus Soto Senior Vice President, Gas Operations 67,917

David Thomason 

Vice President, Chief Financial Officer, and Controller, Pacific Gas and 

Electric Company 

Vice President and Controller, PG&E Corporation 42,083

Fong Wan Senior Vice President, Energy Policy and Procurement 54,483

Jason Wells Senior Vice President and Chief Financial Officer, PG&E Corporation $ 77,500

(1) Except as otherwise noted, all positions have been held at the Utility.

(2) Payments primarily consist of salary.

(3) Payments include annual perquisite allowances paid in March 2019.

(4) Includes temporary monthly compensation increase as a result promotion in January 2019 to position of Interim General Counsel.

15. REORGANIZATION ITEMS 

The following reflects net reorganization items as of March 31, 2019: 

Post-Petition Period Through March 31, 2019 

(in millions) 

Pacific Gas & 

Electric Company PG&E Corporation 

PG&E Corporation 

Consolidated 

Debtor-in-possession financing costs $ 97 $ 17 $ 114

Legal and other 23 1 24

Interest income (9) (2) (11)

Adjustments to LSTC — — —

Trustee fees — — —

Total reorganization items, net $ 111 $ 16 $ 127

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14. PAYMENTS TO INSIDERS 

The following reflects the cash payments made to insiders of the Corporation and the Utility during the month ended April 30, 

2019. Other than reimbursement for reasonable expenses incurred in connection with attending Board of Directors meetings, 

Board of Directors committee meetings, or participating in other activities undertaken on behalf of the Corporation and the 

Utility, there were no payments made to non-employee directors during the reporting period. 

(in ones) Total Payments 

for Month Name Title (1) (2)

Loraine Giammona Senior Vice President and Chief Customer Officer $ 40,465

Julie Kane 

Senior Vice President, Chief Ethics and Compliance Officer, and Deputy 

General Counsel, PG&E Corporation and Pacific Gas and Electric Company 40,444

Kathleen Kay Senior Vice President and Chief Information Officer 35,048

Michael Lewis Senior Vice President, Electric Operations 37,500

Janet Loduca 

Senior Vice President and Interim General Counsel, PG&E Corporation and 

Pacific Gas and Electric Company 52,298 (3) 

Steven Malnight Senior Vice President, Energy Supply and Policy 85,286 (4) 

Dinyar Mistry 

Senior Vice President, Human Resources and Chief Diversity Officer, PG&E 

Corporation and Pacific Gas and Electric Company 42,667

John Simon Interim Chief Executive Officer, PG&E Corporation 50,782

Jesus Soto Senior Vice President, Gas Operations 47,917

David Thomason 

Vice President, Chief Financial Officer, and Controller, Pacific Gas and 

Electric Company 

Vice President and Controller, PG&E Corporation 27,548

Fong Wan Senior Vice President, Energy Policy and Procurement 34,948

Jason Wells Senior Vice President and Chief Financial Officer, PG&E Corporation 52,965

James Welsch Vice President, Nuclear Generation and Chief Nuclear Officer $ 43,498

(1) Except as otherwise noted, all positions have been held at the Utility.

(2) Payments primarily consist of salary.

(3) Includes temporary monthly compensation increase as a result of promotion in January 2019 to position of Interim General Counsel.

(4) Steven Malnight resigned effective April 12, 2019, payment includes prorated salary and payout of accrued vacation.

15. REORGANIZATION ITEMS 

The following reflects reorganization items, net, post-petition through April 30, 2019: 

(in millions) 

Pacific Gas & 

Electric Company PG&E Corporation 

PG&E Corporation 

Consolidated 

Debtor-in-possession financing costs $ 97 $ 17 $ 114

Legal and other 39 1 40

Interest income (15) (3) (18)

Adjustments to LSTC — — —

Trustee fees — — —

Total reorganization items, net $ 121 $ 15 $ 136

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EXHIBIT C

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 U.S. Department of Justice

 United States Trustee

 Northern and Eastern

 Districts of California and Nevada

____________________________________________________________________________________ San Francisco Office 415-705-3333

450 Golden Gate Ave, Suite 05-0153 FAX 415-705-3367

San Francisco, California 94102

Website address: www.justice.gov/ust-regions-r17

June 18, 2019

Via electronic mail and U.S. Mail

Matthew Goren, Esq. 

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, New York 10153-0119

Re: In re PG&E Corporation, et al.

 Case No. 19-30088 (DM) (Bankr. N.D. Cal.)

Dear Matt: 

Reference is made to the email exchange between PG&E Corporation, et al. (the “Debtors”) and 

this Office in connection with certain payments to insiders of the Debtors, as reflected in the March 

2019 monthly operating report. A chart showing the increases in payments to insiders in March (and for 

one, in April).

In your most recent email to me on June 7, 2019, you described these payments as “annual 

allowances for perquisite benefits. This is a not a bonus; rather it is a lump-sum annual cash stipend paid 

in lieu of providing broader perquisite benefits.”

Absent further explanation, these payments appear to meet the definition of a bonus under 11 

U.S.C. § 503(c). See In re Residential Capital, LLC, 478 B.R. 154, 169 (Bankr. S.D.N.Y. 2012)

(discussing payments that fall under section 503(c)(1)). Congress enacted section 503(c) as part of the 

2005 BAPCPA amendments to the Bankruptcy Code to “eradicate the notion that executives were 

entitled to bonuses simply for staying with the Company through the bankruptcy process.” Id. (quoting 

In re Global Home Prods., LLC, 369 B.R. 778, 784 (Bankr. D. Del. 2007) (internal quotation marks 

omitted).

Accordingly, we ask for further disclosure. Have these payments been made to these employees 

in past years? Are they the subject of written contracts? Do you agree that these are payments are to 

insiders? Please provide a full basis for your contention that these payments are not bonuses under the 

Bankruptcy Code, requiring a motion seeking approval of these payments; please be sure to include any 

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PAYMENTS TO INSIDERS

MONTH ENDED 1/31/2019 2/28/2019 3/31/2019 4/30/2019

(in ones)

Name Title Cons. Cons. Cons. Cons.

Loraine Giammona Senior VP & Chief Customer Officer $ - $ 40,000 $ 60,000 $ 40,465

Julie Kane Senior VP, Chief Ethics and Compliance Officer $ - $ 39,433 $ 59,433 $ 40,444

Kathleen Kay Senior VP and Chief Information Officer $ - $ 34,583 $ 49,827 $ 35,048

Michael Lewis Senior VP. E;ectric Operations $ - $ 37,500 $ 57,500 $ 37,500

Janet Loduca Senior VP and Interim General Counsel $ - $ 87,296 $ 101,833 $ 52,298

Steven Malnight Senior VP, Energy Supply and Policy $ - $ 43,750 $ 68,750 $ 85,286

Dinyar Mistry Senior VP, Human Resources & Chief Diversity Officer $ - $ 42,667 $ 62,667 $ 42,667

John Simon Interim Chief Executive Officer $ - $ 135,078 $ 75,317 $ 50,782

Jesus Sota Senior VP, Gas Operations $ - $ 49,819 $ 67,917 $ 47,917

David Thomason VP and Controller $ - $ 33,333 $ 42,083 $ 27,548

Fong Wan Senior VP, Energy Policy and Procurement $ - $ 45,456 $ 54,483 $ 34,948

Jason Wells Senior VP and Chief Financial Officer $ - $ 52,500 $ 77,500 $ 52,965

James Welsch Vice President, Nuclear Generation and Chief Nuclear Officer $ - $ - $ - $ 43,498

Total $ - $ 641,415 $ 777,310 $ 591,366

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EXHIBIT D

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BY E-MAIL 

767 Fifth Avenue

New York, NY 10153-0119

+1 212 310 8000 tel

+1 212 310 8007 fax

June 28, 2019 

Matthew Goren

+1 (212) 310-8440

matthew.goren@weil.com

Timothy S. Laffredi 

U.S. Department of Justice 

United States Trustee 

Northern and Eastern Districts of California and Nevada 

450 Golden Gate Ave, Suite 05-0153 

San Francisco, CA 94102 

Re: In re PG&E Corporation and Pacific Gas and Electric Company - Case No. 19-30088 (DM) 

(Bankr. N.D. Cal.) 

Dear Mr. Laffredi: 

As you are aware, this firm represents PG&E Corporation and Pacific Gas and Electric Company 

(collectively, the “Debtors”) in connection with the above-referenced chapter 11 cases pending before 

the United States Bankruptcy Court for the Northern District of California. We are in receipt of your 

letter dated June 18, 2019 (the “Letter”), in which you request additional information regarding annual 

perquisite payments made to certain of the Debtors’ officers, as reflected in the Debtors’ March 2019 

monthly operating report [Docket No. 1945] (the “MOR”). 

As described in the 2019 PG&E Corporation and Pacific Gas and Electric Company Joint Proxy 

Statement,1

 the Debtors provide perquisite benefits to their officers as part of their fixed annual 

compensation as is typical for executives of large corporations. The perquisite benefits come in two 

forms: 

1. Limited perquisites directly provided by the Debtors, including parking, executive health 

services, insurance and a subsidy for financial advice services; and 

2. A lump-sum annual cash stipend which is paid in lieu of the Debtors providing broader 

perquisite benefits (the “Lump Sum Perquisite Allowance”). The Lump Sum Perquisite 

Allowance is a set stipend that each officer has discretion to use as they see fit, and it is intended 

 

1

 A copy of the 2019 Joint Proxy Statement is available at 

https://www.sec.gov/Archives/edgar/data/75488/000095015719000501/form10ka.htm. 

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Timothy S. Laffredi, Esq 

June 28, 2019 

Page 2 

to cover miscellaneous expenses, such as membership in professional organizations, which 

would otherwise be provided or reimbursed by the Debtors to their officers. 

The payments to the Debtors’ officers that were disclosed in the MOR and referenced in your Letter 

were made on account of the annual payment of the Lump Sum Perquisite Allowance. 

Payment of the Lump Sum Perquisite Allowance to the Debtors’ officers is a long-standing and normal 

part of these and other officers’ compensation and has been an established practice of the Debtors since 

at least 2002. The amount of the Lump Sum Perquisite Allowance is a fixed amount between $15,000 

and $35,000 determined based on the individual officers’ level within the Debtors, and has not changed 

in over ten years. 

As part of the normal compensation of the Debtors’ officers, the Lump Sum Benefits are not “bonuses” 

nor are they transfers that were made to induce the Debtors’ officers to remain with their business, 

which would render them subject to section 503(c) of the Bankruptcy Code. The Lump Sum Benefits 

represent a component of the Debtors’ ordinary course fixed compensation being provided to their 

officers, are indistinguishable from the fixed salaries for these officers, and represent a small percentage 

of their overall compensation. Courts have previously held that normal wages and compensation are not 

retention payments within the purview of section 503(c) of the Bankruptcy Code. See In re QuVIS, Inc., 

No. 09-10706, 2009 WL 4262077, at *5 (Bankr. D. Kan. Nov. 23, 2009); In re Nellson Nutraceutical, 

Inc., 369 B.R. 787, 802 (Bankr. D. Del. 2007) (The scrutiny of section 503(c)(1) is not applied to any 

payment made to an insider, and it is not applied to regular salary – to do so would be “an absurd 

result”.). 

The Lump Sum Perquisite Allowances are a long-running element of the Debtors’ compensation to their 

officers, consistent with their terms of employment and prepetition policies of the Debtors and are 

justified as appropriate compensation for the Debtors’ officers’ service as senior executives in a large 

and complex business. Indeed as indicated, these types of perquisites are normal course of business in 

many corporations. Accordingly, the requirements of section 503(c) do not apply to the Lump Sum 

Perquisite Allowance. 

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Timothy S. Laffredi, Esq

June 28, 2019

Page 3

Please let us know if you have any further questions, and, of course, we will be happy to discuss this 

further at your convenience.

Sincerely,

Matthew Goren

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