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BROWN RUDNICK LLP 

David J. Molton (SBN 262075) 

(DMolton@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, 

 - and – 

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 

NON-OPPOSITION TO 

CONSOLIDATED LATE 

CLAIM MOTIONS 

[Relates to Docket Number 13701] 

Case: 19-30088 Doc# 13716 Filed: 05/10/23 Entered: 05/10/23 10:06:59 Page 1

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

“Trust”), by and through her undersigned counsel, respectfully states as follows: 

1. On January 29, 2019, PG&E Corporation (“PG&E Corp.”) and Pacific Gas and 

Electric Company (“Utility”), as debtors and debtors in possession (collectively, “PG&E” or the 

“Debtors”), commenced with the Court voluntary cases under chapter 11 of the Bankruptcy Code 

(the “Chapter 11 Cases”). The Reorganized Debtors filed the Chapter 11 Cases to address the 

billions of dollars of damage and loss relating to the devastating 2015, 2017 and 2018 California 

fires and to provide compensation to wildfire victims. 

2. By Order dated July 1, 2019, the Court established October 21, 2019 (the “Bar 

Date”) as the last date to file proofs of claim in the Chapter 11 Cases [Docket No. 2806]. By Order 

dated November 11, 2019, the Court extended the Bar Date to December 31, 2019 (the “Extended 

Bar Date”) for unfiled, non-governmental Fire Claimants [Docket No. 4672]. 

3. By Order dated June 20, 2020 [Docket No. 8053] the Bankruptcy Court confirmed 

the Debtors’ and Shareholder Proponents’ Joint Chapter 11 Plan of Reorganization Dated June 

19, 2020 (as may be further modified, amended or supplemented from time to time, and together 

with any exhibits or scheduled thereto, the “Plan”). The Effective Date of the Plan occurred on 

July 1, 2020. See Dkt. No. 8252. 

4. Pursuant to the Plan, the Trustee was appointed as the representative of each of the 

Debtors’ estates pursuant to sections 1123(a)(5), (a)(7), and (b)(3)(B) of the Bankruptcy Code was 

vested with the authority and power (subject to the Fire Victim Trust Agreement1

 and the Plan) to, 

among other things: (i) administer, object to or settle Fire Victim Claims; (ii) make distributions to 

holders of Fire Victim Claims in accordance with the terms of the Plan and the Fire Victim Trust 

Agreement, and (iii) carry out the provisions of the Plan related to the Trust and the Fire Victim 

Claims. See Plan § 6.8(b). 

/ / / 

1

 Capitalized terms used but not otherwise herein defined have the meanings ascribed to such terms 

in the Plan. 

Case: 19-30088 Doc# 13716 Filed: 05/10/23 Entered: 05/10/23 10:06:59 Page 2

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5. Also pursuant to the Plan, all Fire Victim Claims were channeled to the Trust on the 

Effective Date and are subject to the Channeling Injunction, and any liabilities of the Debtors or the 

Reorganized Debtors, as applicable, for any Fire Victim Claims have been fully assumed by, and 

are the sole responsibility of, the Trust, and shall be satisfied solely from the assets of the Trust. 

See Plan §§ 4.7(a), 4.26(c), 6.7(a). 

6. To be eligible for compensation from the Trust a holder of a Fire Victim Claim must 

have timely filed a proof of claim. See Dkt. No. 8057-1. 

7. On July 6, 2022 counsel for Kelly, Heather, Jason and Bryan Navarro filed the 

Motion to Allow/Deem Timely Late Filing of Proof of Claim by Kelly Navarro and Heather 

Navarro and Jason Navarro and Bryan Navarro, Memorandum of Points and Authorities; 

Declaration of Regina Bagdasarian in Support [Dkt 12591]. Counsel attached a copy of an unfiled

proof of claim to the motion.

8. On July 6, 2022 counsel for Lisa and Vincent Raczynski filed the Motion to 

Allow/Deem Timely Late Filing of Proof of Claim by Lisa Raczynski and Vincent Raczynski, 

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

12592]. Counsel attached a copy of an unfiled proof of claim to the motion. 

9. 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”), on September 15, 2022 the Trustee filed a 

statement of non-opposition to a group of late claims consolidated by the Court, including the 

Navarro and Raczynski claims described above. [Docket No. 12963] 

10. On September 20, 2022 the Court entered an order deeming the claims listed in the 

Supplemental Consolidation Order “timely filed for the purpose of claim administration by the Fire 

Victim Trust so long as the Unfiled Proofs of Claim are filed and the Trustee is notified of the 

filing of each of the Proofs of Claim by email to Trustee counsel . . . no later than September 30, 

2022” [Docket No. 12985]. 

/ / / 

Case: 19-30088 Doc# 13716 Filed: 05/10/23 Entered: 05/10/23 10:06:59 Page 3

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11. No proofs of claim were filed on behalf of Kelly, Heather, Jason or Bryan Navarro 

or Lisa or Vincent Raczynski on or before September 30, 2022. Therefore, the order at Docket No. 

12985 did not operate to deem the Navarro or Raczynski claims timely, and the holders of those 

claims remained ineligible for compensation from the Fire Victim Trust. 

12. On 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 “Consolidated Motion”). The 

Consolidated Motion covered the claims of Linnise Maria and David Montgomery; Jesse, Christa, 

Tenli, Viggo, and Luke McCord; Jason, Maria, Jason, Jordan, Taylor, and Kealia McCord; Atilava 

Togafau; Gary Lynn and Lorraine Gail Koch; Michael and Sharan Keene; and Tyler Allen Dwelle. 

Counsel attached copies of unfiled proof of claim to the motion. 

13. On September 16, 2022 the Trustee filed a statement of non-opposition to the relief 

requested in the Consolidated Motion [Docket No. 12969]. 

14. On September 20, 2022 the Court entered the Order Granting Motions to Deem 

Late-Filed Claims Timely for the Purpose of Administration by the Fire Victim Trust [Docket No. 

12983], which provided that the proofs of claim for Linnise Maria and David Montgomery; Jesse, 

Christa, Tenli, Viggo, and Luke McCord; Jason, Maria, Jason, Jordan, Taylor and Kealia McCord; 

Atilava Togafau; Gary Lynn and Lorraine Gail Koch; Michael and Sharan Keene; and Tyler Allen 

Dwelle “shall be deemed timely filed for the purpose of claim administration by the Fire Victim 

Trust so long as the Proofs of Claim are filed no later than September 30, 2022 and the Trustee is 

notified of the filing of each of the Proofs of Claim by email to Trustee counsel as provided in the 

Trustee Statement.” Docket No. 12983 at 2:10-14. 

15. No proofs of claim were filed on behalf of Linnise Maria or David Montgomery; 

Jesse, Christa, Tenli, Viggo, or Luke McCord; Jason, Maria, Jason, Jordan, Taylor or Kealia 

McCord; Atilava Togafau; Gary Lynn or Lorraine Gail Koch; Michael or Sharan Keene; or Tyler 

Allen Dwelle on or before September 30, 2022. Therefore, the order at Docket No. 12983 did not 

operate to deem those claims timely, and the holders of those claims remained ineligible for 

compensation from the Fire Victim Trust. 

Case: 19-30088 Doc# 13716 Filed: 05/10/23 Entered: 05/10/23 10:06:59 Page 4

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16. On April 13 and April 20, 2023 proofs of claim were filed on behalf of each of the 

claimants listed on Exhibit 1 hereto. The Exhibit 1 claimants are comprised of all claimants who 

were denied relief in September due to the failure to have their proofs of claim timely filed. 

17. On May 5, 2023 the claimants on Exhibit 1 filed the Motion to Allow/Deem Timely 

Late Filing of Proof of Claim by Certain Claimants; Memorandum of Points and Authorities

[Docket No. 13701] to cure the prior failures to timely file proofs of claim. 

18. Given the fact that the claimants listed on Exhibit 1 would have had their claims 

deemed timely no later than September 30, 2022 if counsel had filed their proofs of claim as 

directed, the Trustee does not object to this Court deeming the Proofs of Claim timely. 

19. Nothing herein is intended to, nor shall it be construed to be, a waiver by the Fire 

Victim Trust, or any other party in interest of any right to object to the Proof of Claim on any 

grounds other than the untimely filing thereof. 

DATED: May 10, 2023 BROWN RUDNICK LLP 

By: /s/ David J. Molton

 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

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EXHIBIT 1

LIST OF CLAIMANTS AND PROOFS OF CLAIMS 

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LIST OF CLAIMANTS 

DATE ORIGINAL 

MOTION FILED 

ORIGINAL 

DOCKET CLAIMANT(S) POC NUMBER 

7-6-2022 12591 

Kelly Navarro 

Heather Navarro 

Jason Navarro 

Bryan Navarro 

109873 

7-6-2022 12592 Lisa Raczynski 

Vincent Raczynski 109871 

9-1-2022 12921 Linnise Maria Montgomery 

David Montgomery 10974 

9-1-2022 12921 

Jesse McCord 

Christa McCord 

Tenli McCord 

Viggo McCord 

Luke McCord

109870 

9-1-2022 12921 

Jason McCord 

Maria McCord 

Taylor McCord 

Jordan McCord 

Atilava Togafau

109876 

9-1-2022 12921 Kealia McCord 109878 

9-1-2022 12921 Gary Lynn Koch 

Lorraine Gail Koch 109875 

9-1-2022 12921 Michael Keene 

Sharan Keene 109877 

9-1-2022 12921 Tyler Allen Dwelle 109872 

Case: 19-30088 Doc# 13716 Filed: 05/10/23 Entered: 05/10/23 10:06:59 Page 7

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