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BROWN RUDNICK LLP

David J. Molton (SBN 262075)

(DMolton@brownrudnick.com)

Eric R. Goodman (admitted pro hac vice)

(EGoodman@brownrudnick.com) 

Seven Times Square

New York, New York 10036

Telephone: (212) 209-4800

Facsimile: (212) 209-4801

BROWN RUDNICK LLP

Joel S. Miliband (SBN 077438)

(JMiliband@brownrudnick.com)

2211 Michelson Drive, Seventh Floor

Irvine, California 92612

Telephone: (949) 752-7100

Facsimile: (949) 252-1514

Attorneys for Fire Victim Trustee

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

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).

Case No. 19-30088 (DM)

Chapter 11

(Lead Case) 

(Jointly Administered)

FIRE VICTIM TRUSTEE’S 

STATEMENT OF NONOPPOSITION TO AMENDED 

CONSOLIDATED MOTIONS 

TO ENLARGE TIME FOR 

CLAIMANTS TO FILE 

PROOFS OF CLAIM FOR 

THE PURPOSE OF CLAIM 

ADMINISTRATION BY THE 

FIRE VICTIM TRUST 

[Relates to Docket Number 12921]

Case: 19-30088 Doc# 12969 Filed: 09/16/22 Entered: 09/16/22 12:41:57 Page 1

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1 

Cathy Yanni, in her capacity as the Trustee (the “Trustee”) of the Fire Victim Trust (the 

“Trust”), by and through her undersigned counsel and as directed by the Order Consolidating 

Motions to File Late Claims entered August 24, 2022 [Docket No. 12875] (the “Consolidation 

Order”) and the Order re Supplemental Exhibit to Order Consolidating Motions to File Late 

Claims entered September 1, 2022 [Docket No. 12923] (the “Supplemental Consolidation 

Order”), respectfully states as follows:

1. The Trust has been monitoring all motions filed with this Court that seek to have 

late-filed proofs of claim deemed “timely” for the purpose of having such claims administered by 

the Trust.

1

2. The Amended Consolidated Motion to Allow/Deem Timely Late Filing of Claimants, 

and Memorandum of Points and Authorities; Declaration of Regina Bagdasarian in Support; 

Related to Docket No 12919 [Docket No. 12921] (the “Late Claim Motion”) seeks to have the 

time in which to file proofs of claim extended with respect to the proofs of claim of the claimants 

listed on Exhibit 1 hereto (the “Proofs of Claim”). None of the Proofs of Claim appear to have 

been filed as of the date hereof and counsel for the claimants listed on Exhibit 1 hereto did not 

respond to an email request from counsel for the Trustee regarding the Proofs of Claim. 

3. In keeping with the current Trust policy of allowing as many Claimants as possible 

to receive compensation on account of their Fire Victim Claims, the Trustee does not oppose the 

Late Claim Motion with respect to the claimants listed on Exhibit 1 hereto, so long as the Proofs of 

Claim are filed no later than September 30, 2022 and the Trustee is notified of the filings of each of 

the Proofs of Claim by email to Trustee counsel at ssieger-grimm@brownrudnick.com. 

4. Given the number of late claim motions filed in recent months2 and the amount of 

1 The Fire Victim Trust Claims Resolution Procedures (“CRP”) mandate that claimants must have 

timely filed a proof of claim to be eligible to receive compensation from the Trust. See CRP §I.

2 Of the 395 late claim motions filed since the December 31, 2019 extended bar date, 217 have been 

filed in the last six months and 161 were filed in August alone. To put these numbers in perspective, in 

2020, which included the months immediately after the Extended Bar Date and the effective date of the 

Trust (both events that could be expected to prompt the filing of late claim motions), the total number of late 

claim motions filed alleging Fire Victim Claims was 55. In 2021, the total number was only 22.

Case: 19-30088 Doc# 12969 Filed: 09/16/22 Entered: 09/16/22 12:41:57 Page 2

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2

time that has passed since the December 31, 2019 bar date for Fire Victim Claims and the February 

26, 2021 deadline to submit claims questionnaires to the Trust, the Trustee will be discontinuing 

the current non-opposition policy with respect to late claim motions filed after September 30, 2022.

5. The Proofs of Claim and any claims asserted in connection with the Proofs of Claim

are subject to the requirements of the CRP and are not allowed or approved by the filing of this 

statement. Nothing herein shall be construed to be a waiver by the Trust of any right to object to 

the Proofs of Claim or any claims asserted in connection with the Proofs of Claim on any 

grounds other than the untimely filing thereof. The Trust may object to any Proof of Claim filed 

after September 30, 2022 on the ground of untimeliness.

DATED: September 16, 2022 BROWN RUDNICK LLP

By: Eric R. Goodman

Eric R. Goodman (admitted pro hac vice)

(EGoodman@brownrudnick.com)

David J. Molton (SBN 262075)

(DMolton@brownrudnick.com)

Seven Times Square

New York, New York 10036

Telephone: (212) 209-4800

Facsimile: (212) 209-4801

and 

Joel S. Miliband (SBN 077438)

(JMiliband@brownrudnick.com)

2211 Michelson Drive

Seventh Floor

Irvine, California 92612 

Telephone: (949) 752-7100

Facsimile: (949) 252-1514

Attorneys for Fire Victim Trustee

Case: 19-30088 Doc# 12969 Filed: 09/16/22 Entered: 09/16/22 12:41:57 Page 3

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EXHIBIT 1 

LIST OF CLAIMANTS

Case: 19-30088 Doc# 12969 Filed: 09/16/22 Entered: 09/16/22 12:41:57 Page 4

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DATE POC 

FILED

POC 

NUMBER CLAIMANT(S)

No POC Filed N/A Linnise Maria and David Montgomery

No POC Filed N/A Jesse, Christa, Tenli, Viggo, and Luke McCord

No POC Filed N/A Jason, Maria, Jason, Jordan, Taylor and Kealia McCord 

Atilava Togafau

No POC Filed N/A Gary Lynn and Lorraine Gail Koch

No POC Filed N/A Michael and Sharan Keene

No POC Filed N/A Tyler Allen Dwelle

64837495 v2-WorkSiteUS-035945/0001

Case: 19-30088 Doc# 12969 Filed: 09/16/22 Entered: 09/16/22 12:41:57 Page 5

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