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REQUEST FOR RELIEF UPON DEFAULT AND DECLARATION IN SUPPORT 

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, Cherish Cram 

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 

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Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case–Jointly Administered) 

REQUEST FOR RELIEF UPON 

DEFAULT IN SUPPORT OF MOTION 

FOR ORDER AUTHORIZING 

WITHDRAWAL OF COUNSEL 

[RE: Dkt. Nos. 12878, 12879, 12880, and 12881]

Affects: 

 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# 13048 Filed: 10/06/22 Entered: 10/06/22 23:54:56 Page 1

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REQUEST FOR RELIEF UPON DEFAULT AND DECLARATION IN SUPPORT 

REQUEST FOR ENTRY OF ORDER BY DEFAULT 

Under B.L.R. 9014-1(b)(4), Robins Cloud LP (“Firm”) hereby requests that Court enter an 

order by default on its Motion for Order Authorizing Withdrawal of Counsel to Cherish Cram 

(“Creditor”)1, Dkt. No. 12878 (“Motion”). 

RELIEF REQUESTED IN THE MOTION 

The Motion seeks an order authorizing the Firm to withdraw as counsel of record to the 

Creditor. 

NOTICE AND SERVICE 

A Notice and Opportunity for Hearing on Motion for Order Authorizing Withdraw of 

Counsel to Cherish Cram was filed concurrently with the Motion on August 27, 2022, Dkt. No. 

12880 (“Notice and Opportunity for Hearing”). The Motion, the supporting declaration of Robert 

Bryson, Dkt. No. 12879, and the Notice and Opportunity for Hearing were served as described in the 

Certificate of Service filed on August 27, 2022, Dkt. No. 12881. 

The deadline to file a response or opposition to the Motion has passed, and no opposition has 

been filed with the Court or received by the Firm. 

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 individual over 18 years of age and competent to make this Declaration. 

2. I am the founder of Grimshaw Law Group, P.C., and an attorney at law duly 

admitted to practice before all courts of the State of California and the United States District Court 

for the Northern District of California. 

3. I am counsel for the law firm of Robins Cloud LP (the “Firm”), attorneys of record 

for Cherish Cram (“Creditor”).2

1

 Robins Cloud LLP retained Grimshaw Law Group, P.C. as bankruptcy counsel to, among other 

things, assist it in filing this motion. Grimshaw Law Group 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. 2

 Grimshaw Law Group has no contractual or attorney/client relationship with Creditor. 

Case: 19-30088 Doc# 13048 Filed: 10/06/22 Entered: 10/06/22 23:54:56 Page 2

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REQUEST FOR RELIEF UPON DEFAULT AND DECLARATION IN SUPPORT 

4. I have reviewed the Court’s docket in these Chapter 11 Cases and determined that 

no response or opposition has been filed with respect to the Motion. 

5. A proposed order will be lodged concurrently as provided for in B.L.R. 9014-

1(b)(3)(A). 

WHEREFORE, the Firm hereby requests that the Court enter the proposed order filed 

concurrently herewith granting the Motion for the reasons set forth therein. 

Executed on October 6, 2022. 

 GRIMSHAW LAW GROUP, P.C. 

/s/ Matthew W. Grimshaw 

Matthew W. Grimshaw 

Attorneys for Robins Cloud LLP 

Case: 19-30088 Doc# 13048 Filed: 10/06/22 Entered: 10/06/22 23:54:56 Page 3

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REQUEST FOR RELIEF UPON DEFAULT AND DECLARATION IN SUPPORT 

CERTIFICATE OF SERVICE 

I hereby certify that on October 6, 2022, I caused the forgoing REQUEST FOR 

RELIEF UPON DEFAULT IN SUPPORT OF MOTION FOR ORDER AUTHORIZING 

WITHDRAWAL OF COUNSEL to be electronically filed with the Clerk of the Court using 

the CM/ECF system, which, in turn, caused a notification to be sent to the interested parties, with 

the exception of Lacey Devereux. 

I further certify that, on the same date, I caused the foregoing document to be sent via 

first-class mail, postage prepaid, to the following interested party: 

Cherish Cram 

P.O. Box 5181 

Oroville, CA 95966 

/s/ Matthew W. Grimshaw 

MATTHEW W. GRIMSHAW 

Case: 19-30088 Doc# 13048 Filed: 10/06/22 Entered: 10/06/22 23:54:56 Page 4

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