1 

MOTION FOR ORDER AUTHORIZING WITHDRAWAL OF COUNSEL

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

Bill Robins III, Esq. (SBN 296101) 

Robert T. Bryson, Esq. (SBN 156953) 

Rex Grady, Esq. (SBN 232236) 

ROBINS CLOUD LLP 

808 Wilshire Blvd., Suite 450 

Santa Monica, California 90401 

Telephone: (310) 929-4200 

Facsimile: (310) 566-5900 

Attorneys for Creditor, Gail Mitcham

Matthew W. Grimshaw, Esq. (SBN 210424) 

GRIMSHAW LAW GROUP, P.C.

26 Executive Park, Ste. 250 

Irvine, California 92614 

Telephone: (949) 734-0187 

Facsimile: (208) 391-7860 

Counsel for Robins Cloud LLP 

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

(Lead Case–Jointly Administered)

MOTION FOR ORDER 

AUTHORIZING WITHDRAWAL OF 

Affects: COUNSEL TO GAIL MITCHAM

PG&E Corporation

Pacific Gas & Electric Company

Both Debtors

* All papers shall be filed in the Lead 

Case, No. 19-30088 (DM).

Case: 19-30088 Doc# 13068 Filed: 10/13/22 Entered: 10/13/22 17:20:17 Page 1

of 3
2 

MOTION FOR ORDER AUTHORIZING WITHDRAWAL OF COUNSEL

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

Robins Cloud LP (“Firm”), counsel of record1 for creditor, Gail Mitcham (“Creditor”), 

respectfully submits this Motion for Order Authorizing Withdrawal of Counsel (“Motion”) pursuant to 

Rules 1001-2, 9013-1, 9013-2, 9013-3 and 9014 of the Bankruptcy Court’s Local Rules. 

In support of this Motion, the Firm represents as follows: 

1. Relevant Facts

a. General Background

In January 2019, the Debtors filed voluntary Chapter 11 petitions, commencing these cases. 

Dkt. No. 1; Bryson Decl. ¶4. 

Initially, the Court set a claims bar of October 21, 2019. Dkt. No. 2806. The claims bar date was 

extended to December 31, 2019, to allow certain fire victims additional time to file claims against the 

Debtors. Dkt. No. 4651. 

Jointly, the Debtors proposed a chapter 11 plan of reorganization that, among other things, 

channeled all fire victim claims to the Fire Victim Trust (“Plan”). Dkt. No. 8048. On June 20, 2020, the 

Court entered an order confirming Debtors’ Plan. Dkt. No. 8053. 

b. Creditor’s Refusal to Communicate and Provide Necessary 

Information to the Firm 

On October 16, 2019, the Firm filed Proof of Claim No. 30184 on behalf of Gail Mitcham

(“Claim”), seeking damages from the North Bay Fire. Since the filing of the Claim, an irreconcilable 

difference has developed between Creditor and the Firm. As a result, the Firm notified Creditor that it 

must withdraw as counsel. Bryson Decl. ¶5. Based on these circumstances, good cause exists for the 

Court to enter an order relieving the Firm as counsel of record for Creditor. 

2. Argument

Pursuant to Rule 11-5 (a) of the Local Civil Rules in force in the Northern District of 

California, “counsel may not withdraw from an action until relieved by order of Court after written 

notice has been given reasonably in advance to the client and to all other parties who have appeared in 

1

 Robins Cloud LLP retained Grimshaw Law Group, P.C. (“GLG”) to, among other things, assist it in 

filing this motion. GLG has no contractual or attorney/client relationship with Creditor. Declaration of 

Robert Bryson in Support of Motion for Order Authorizing Withdrawal of Counsel (“Bryson Decl.”), 

¶2, fn.1. 

Case: 19-30088 Doc# 13068 Filed: 10/13/22 Entered: 10/13/22 17:20:17 Page 2

of 3
3 

MOTION FOR ORDER AUTHORIZING WITHDRAWAL OF COUNSEL

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

the case.”

Furthermore, California’s professional ethics Standing Committee has opined that when 

seeking leave of court to withdraw as counsel, it will “ordinarily...be sufficient [for an attorney] to say 

only words to the effect that ethical considerations require withdrawal or that there has been an 

irreconcilable breakdown in the attorney-client relationship.” Formal Opinion No. 2015-192. 

In the case at bar, an irreconcilable breakdown of the attorney-client relationship has arisen. 

This constitutes good cause for the Court to grant leave for the Firm to withdraw as counsel of record. 

To the extent that Creditor requests that the Firm turn over any files or information to which 

Creditor is entitled, the Firm will cooperate and transmit such files. Bryson Decl., ¶6. 

3. Conclusion

For the foregoing reasons and for the reasons set forth in the Declaration of Robert Bryson, 

submitted in support of this Motion, the Firm respectfully requests that the Court enter an Order

granting the Firm leave to withdraw as counsel of record for Creditor. 

DATED: October 13, 2022 ROBINS CLOUD LLP

ROBERT BRYSON

Attorneys for Creditor, Gail Mitcham

GRIMSHAW LAW GROUP, P.C.

_____________ 

MATTHEW W. GRIMSHAW

Counsel for Robins Cloud LLP

Case: 19-30088 Doc# 13068 Filed: 10/13/22 Entered: 10/13/22 17:20:17 Page 3

of 3