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EX PARTE APPLICATION TO ALLOW CONSIDERATION OF UNTIMELY FILING OF OPPOSITION TO 

OBJECTION TO CLAIM 3002 1

CHARLES L. HASTINGS 

CA State Bar No.: 88599

NATALI A. RON

CA State Bar No.: 302927

Law Office of Hastings & Ron

PMB 270, 4719 Quail Lakes Drive, Suite G

Stockton, CA 95207

(209) 476-1010

Attorneys for JACKSON RANCHERIA DEVELOPMENT CORP

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

EX PARTE APPLICATION TO FILE LATE 

OPPOSITION TO REORGANIZED 

DEBTORS’ ONE HUNDRED TWENTIETH 

OMNIBUS OBJECTION TO CLAIMS – BY

JACKSON RANCHERIA DEVELOPMENT 

CORP (CLAIM NO. 3002)

Date: May 24, 2023

Time: 10:00 a.m. 

Location: (Video/Teleconference Only)

U.S. Bankruptcy Court 

Courtroom 17, 16th floor

San Francisco, CA 94102

Judge: Honorable Dennis Montali

Creditor, JACKSON RANCHERIA DEVELOPMENT CORP (hereinafter referred to as 

“Jackson”), by and through its undersigned counsel, opposes the Reorganized Debtors’, PG&E 

CORPORATION and PACIFIC GAS AND ELECTRIC COMPANY’S (hereinafter collectively

referred to as the “PG&E”) ONE HUNDRED TWENTIETH OMNIBUS OBJECTION TO 

CLAIMS as set forth herein. However, for reasons more fully stated herein, and as set forth in 

the supporting Declaration of counsel, Jackson inadvertently did not timely file this opposition, 

which was due to be filed on May 10, 2023, in accordance with this Court’s ORDER 

APPROVING (A) PROCEDURES FOR FILING OMNIBUS OBJECTIONS TO CLAIMS AND 

Case: 19-30088 Doc# 13754 Filed: 05/18/23 Entered: 05/18/23 18:00:43 Page 1

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EX PARTE APPLICATION TO ALLOW CONSIDERATION OF UNTIMELY FILING OF OPPOSITION TO 

OBJECTION TO CLAIM 3002 2

(B) THE FORM AND MANNER OF THE NOTICE OF OMNIBUS OBJECTIONS. [Docket 

No. 8228]. Accordingly, Claimant respectfully requests this court to consider the late filed 

opposition.

I. INTRODUCTION

Jackson’s claim arises out of fire damage caused by an electrical malfunction of PG&E’s 

power pole and grade transformer which caused a fire to erupt damaging Jackson’s property. 

The fire perimeter was approximately five acres and burned a barn causing it to collapse, 

damaging its contents and other surrounding property, including an adjacent fence, graze land, 

and cattle. The estimated cost to repair the barn is approximately $142,988. The cost to repair 

and/or replace the fence, the cattle, the grazing land, and clean-up costs is $17,525. Jackson’s 

total claim is $160,513.

As set forth in the Reorganized Debtors’ One Hundred Twentieth Omnibus Objection to 

Claims, Jackson’s claim was originally channeled to the Fire Victim Claims, and preliminarily 

identified as a Fire Victim Claim to be administered, processed, settled, disallowed, resolved, 

liquidated, satisfied, and/or paid by the Fire Victim Trust in accordance with its governing 

documents. However, upon the discovery that this was not an appropriate Fire Victim Claim, 

counsel notified the Fire Victim Claims administrator. After months of waiting and follow-up, 

the claim was finally re-channeled to the appropriate General Unsecured Claims. Approximately 

two weeks later, the subject Reorganized Debtors’ One Hundred Twentieth Omnibus Objection 

to Claims was filed. 

This Court’s Order Approving (A) Procedures for Filing Omnibus Objections To Claims

And (B) the Form and Manner of the Notice of Omnibus Objections sets forth the Omnibus 

Claim Objection Notice procedure (paragraph F), which requires “[t]he Omnibus Claim 

Objection Notice [to] be served on the individual Claimant by mail, not less than 37 days before

the date set for hearing of the Omnibus Objection, at the address specified in the Proof of 

Claim.” However, Jackson’s counsel, whose address is on file as specified in the Proof of Claim, 

has no record of having received the One Hundred Twentieth Omnibus Objection to Claims via 

mail. Upon review of the certificate of service, it appears Counsel’s office address is listed; 

Case: 19-30088 Doc# 13754 Filed: 05/18/23 Entered: 05/18/23 18:00:43 Page 2

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EX PARTE APPLICATION TO ALLOW CONSIDERATION OF UNTIMELY FILING OF OPPOSITION TO 

OBJECTION TO CLAIM 3002 3

however, there is a change of address on file with the Post Office, and mail should be delivered 

to Counsel’ Post Mail Box; however, there have been many instances of mailing issues and mail 

being returned to sender. 

Counsel for Jackson appears to have received the filings via email on April 14, 2023, at 

1:21 p.m.; however, at that time, Counsel was preparing for and commencing a deposition in the 

matter if Irrigation Design & Construction, LLC v. Parker Technical Sales, Monterey County 

Superior Court case no.: 20CV003182, which was scheduled for and proceeded to trial on May 

8, 2023, and is still in trial set to resume May 22, 2023. Moreover, the Monday following eservice, which was April 17, 2023, Counsel for Jackson had an all-day binding arbitration in the 

matter of Jaspreet Singh v. Reedy Mechanical Inc., San Joaquin County Superior Court case no.: 

STK-CV-UCC-2021-11339, which took place at ADR Services in Oakland, California. The 

week of April 17, 2023, counsel also had two retained expert witness depositions, and two nonretained expert witness depositions in the matter of Irrigation Design & Construction, LLC v. 

Parker Technical Sales. Between the five depositions in that two-week period, preparation for 

and appearance at arbitration, and continued preparation for the Monterey County Court trial, 

Counsel inadvertently did not see the service email come through on the Reorganized Debtors’ 

One Hundred Twentieth Omnibus Objection to Claims. Counsel received the Reorganized 

Debtors’ Report on Responses to One Hundred Twentieth Omnibus Objection to Claims and 

Request for Order by Default as to Unopposed Objections [Doc. No. 13738] in today’s service 

email, and immediately undertook review to discover the motion to which this document applied, 

only to discover the service email of April 14, 2023. Counsel immediately prepared the 

Opposition to the Objection with the supporting Declaration, this Ex Parte Application, and the 

Declaration in support hereof. 

Federal Rules of Bankruptcy Procedure, Rule 9006, provides “when an act is required or 

allowed to be done at or within a specified period by these rules or by a notice given thereunder 

or by order of court, the court for cause shown may at any time in its discretion (1) with or 

without motion or notice order the period enlarged if the request therefor is made before the 

expiration of the period originally prescribed or as extended by a previous order or (2) on motion 

Case: 19-30088 Doc# 13754 Filed: 05/18/23 Entered: 05/18/23 18:00:43 Page 3

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EX PARTE APPLICATION TO ALLOW CONSIDERATION OF UNTIMELY FILING OF OPPOSITION TO 

OBJECTION TO CLAIM 3002 4

made after the expiration of the specified period permit the act to be done where the failure to act 

was the result of excusable neglect.” (Fed. Rules Bankruptcy Proc. Rule 9006(b)(1).)

Accordingly, and based on this inadvertent and excusable neglect, Counsel for Jackson 

respectfully request this Court to allow the late filing of Jackson’s Opposition to the Omnibus 

Objection, to consider it prior to the hearing scheduled for May 24, 2023, and to hear oral 

argument on said matter.

Furthermore there is no danger of prejudice to the Reorganized Debtors or their 

bankruptcy estate in deeming the Creditor’s Opposition to Objection to its claim as timely filed 

because there has been no plan confirmation, and no distributions have been made to general 

unsecured creditors.

II. CONCLUSION

For the foregoing reasons, Jackson respectfully request this Court to allow the filing of its 

Opposition to Objection to Claim, based on counsel’s inadvertent, excusable neglect resulting in 

the untimely filing of said Opposition.

 

Dated: May 18, 2023 LAW OFFICE OF

HASTINGS & RON

 BY: /s/Natali A. Ron ___________________ NATALI A. RON Attorney for JACKSON 

RANCHERIA DEVELOPMENT CORP

Case: 19-30088 Doc# 13754 Filed: 05/18/23 Entered: 05/18/23 18:00:43 Page 4

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