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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 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION, 

-andBankruptcy Case No. 3:19-bk-030088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered)

OBJECTION OF FIRE VICTIM 

TRUSTEE TO MOTION OF WILLIAM 

B. ABRAMS PURSUANT TO FEDERAL

RULE OF BANKRUPTCY

PROCEDURE 2004 FOR ENTRY OF AN

ORDER AUTHORIZING DISCOVERY

AND HEARINGS REGARDING THE

ACTS AND CONDUCT OF JAMS

NEUTRALS GIVEN NEW EVIDENCE

[Relates to Docket No. 12766]

Hearing to be Determined by the Court 

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).

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TABLE OF CONTENTS 

Page

MEMORANDUM OF POINTS AND AUTHORITIES .................................................................. 2

I. PRELIMINARY STATEMENT ........................................................................................... 2

II. BACKGROUND ................................................................................................................... 3

A. The Chapter 11 Plan and the Establishment of the Fire Victim Trust. ..................... 3

B. Mr. Abrams’s Repeated Requests for Broad Discovery Under Rule 2004. .............. 5

C. Mr. Abrams’s Statements Regarding Trustee Cathy Yanni. ..................................... 9

D. JAMS’ Services to the Fire Victim Trust. ............................................................... 10

III. OBJECTION ....................................................................................................................... 13

A. The Expanded Discovery Motion Should be Denied Because the Allegations are 

Contrary to the Trust’s Accomplishments. ......................................................................... 13

B. The Expanded Discovery Motion Should be Denied Because Mr. Abrams Has Not 

Shown Any Cause, and His Resort to Innuendo, Mischaracterization and Inaccurate 

Hearsay Cannot be Not a Sufficient Basis for the Discovery Sought. ................................ 14

CONCLUSION ............................................................................................................................... 18

 

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TABLE OF AUTHORITIES 

 Page(s) 

Federal Cases 

Federal Nat. Mortg. Ass'n v. Cobb, 

738 F.Supp. 1220 (N.D. Ind. 1990) ........................................................................................... 2

Hildebrandt v. Veneman

233 F.R.D. 183 (D.D.C. 2005) .................................................................................................. 2 

Pigford v. Veneman, 

225 F.R.D. 54 (D.D.C. 2005) .................................................................................................... 2 

Federal Statutes 

11 U.S.C.

§ 363 .......................................................................................................................................... 4 

§ 1103 ........................................................................................................................................ 4 

§ 2004 ...................................................................................................................... 2, 5, 6, 9, 16 

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Cathy Yanni, in her capacity as the Trustee1 (the “Trustee Yanni”) of the PG&E Fire Victim 

Trust (the “Trust,” and its beneficiaries, the “Fire Victims”), hereby submits this objection (the 

“Objection”) to the Motion of William B. Abrams Pursuant to Federal Rule of Bankruptcy Procedure 

2004 for Entry of an Order Authorizing Discovery and Hearings Regarding the Acts and Conduct of 

JAMS Neutrals Given New Evidence [Docket No. 12766] (the “Expanded Discovery Motion”). In 

support of the Objection, Trustee Yanni respectfully states as follows: 

MEMORANDUM OF POINTS AND AUTHORITIES 

I. PRELIMINARY STATEMENT

The Expanded Discovery Motion seeks broad and unprecedented Rule 2004 discovery from 

numerous individuals who have not yet been properly served by Mr. Abrams and makes unfounded, 

specious allegations regarding an even larger group of individuals and entities. In the face of these 

ubiquitous, baseless, non-germane and conspiratorial allegations,2 Trustee Yanni can and only does 

respond through this Objection on behalf of herself and the Trust. Other targets, who may not 

properly be before the Court, may be disinclined to step into Mr. Abrams’s “field of fire” without 

proper service or process. But, given the utter lack of merit in the Expanded Discovery Motion, they 

should not have to, nor should their silence be attributed as acceptance of the inferences, innuendo, 

and allegations replete in the Expanded Discovery Motion. 

The Expanded Discovery Motion does not set forth any evidence – new or otherwise – that 

establishes cause to expand discovery beyond the disclosure outlined in the Court’s Order on Motion 

of William B. Abrams Authorizing Discovery Regarding Administration of the Fire Victim Trust 

1 As the Court is aware, prior to Ms. Yanni becoming the Successor Trustee pursuant to the terms of 

the Fire Victim Trust Agreement, the Honorable John K. Trotter (Ret.) served as Trustee of the Fire 

Victim Trust. Accordingly, “Trustee Yanni” is used herein to describe actions taken by Cathy Yanni 

in her capacity as Trustee of the Fire Victim Trust and “Trustee Trotter” is used to describe actions 

taken by Justice Trotter in his capacity as Trustee of the Fire Victim Trust. 

2 In cases with similarly scandalous and groundless accusations, courts have determined it necessary 

to strike the offensive pleadings or portions thereof, and this Court should not show any reticence in 

doing so here. See, e.g., Hildebrandt v. Veneman 233 F.R.D. 183 (D.D.C. 2005); Pigford v. 

Veneman, 225 F.R.D. 54 (D.D.C. 2005); Federal Nat. Mortg. Ass'n v. Cobb, 738 F.Supp. 1220 (N.D. 

Ind. 1990). 

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[Docket No. 12682] (the “Initial Discovery Order”). Instead, the pleading is being used as a vehicle 

to republish a sensational and inaccurate “newspaper report with no foundation” [Sept. 13, 2022 Hr’g 

Tr. 34:7-8 (comment of the Court)] and other inadmissible hearsay far removed from these cases, all 

in an attempt to question the integrity of individuals and entities (both the Trust and JAMS) and sow 

public doubt and discord without regard to the veracity of the allegations or their connection to the 

Trust and the Trust’s operation. As the Trust’s counsel stated during the September 13, 2022 hearing 

before the Court, Mr. Abrams makes no allegation (let alone offer any evidence) of any misdeeds or 

wrongdoing by or at the Trust, and instead resorts only to innuendo and unfounded inferences to 

support his motion. See Sept. 13, 2022 Hr’g Tr. 51:16-18 (“There’s not a single allegation in the 

papers submitted that anything wrong has actually occurred at the Trust or in connection with the 

Trust.”). While this Objection provides information necessary to correct the false and misleading 

allegations in the Expanded Discovery Motion that concern Trustee Yanni and the Trust, Trustee 

Yanni submits that Mr. Abrams’s irresponsible (and arguably sanctionable) compilation of baseless 

accusations and innuendo fails to establish cause for any of the requested discovery and that no 

further disclosure from Trustee Yanni, the Trust, and the Trust’s agents is warranted or appropriate.

II. BACKGROUND

A. The Chapter 11 Plan and the Establishment of the Fire Victim Trust. 

On January 29, 2019 (the “Petition Date”), 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 (the “Bankruptcy Cases”) under 

chapter 11 of the Bankruptcy Code. On February 15, 2019, the United States Trustee appointed an 

Official Committee of Tort Claimants (the “TCC”) to represent the interests of Fire Victims in the 

Bankruptcy Cases. 

On December 9, 2019, the Debtors filed their Tort Claimants RSA Motion [Dkt. No. 5038] 

which sought entry of an order authorizing the Debtors and the TCC to enter into and perform under 

the Restructuring Support Agreement dated December 6, 2019 (the “TCC RSA”). The TCC RSA 

provided critical provisions of the Plan (defined below) and included various commitments by the 

parties to represent the interests of Fire Victims in the post-effective date Trust, including granting 

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representatives of Fire Victims approval rights with respect to certain definitive documents related 

to the Plan3 and the appointment of a Trust Oversight Committee (the “TOC”).4 On December 19, 

2019, the Bankruptcy Court entered an order granting the Tort Claimants RSA Motion and 

authorizing the TCC RSA. [Dkt. No. 5174]. 

On April 14, 2020, the Bankruptcy Court entered the Order Granting Application of the 

Official Committee of Tort Claimants Pursuant to 11 U.S.C. §§ 1103 and 363 and Fed. R. Bankr. P. 

2014 and 5002 to Retain and Employ Cathy Yanni as Claims Administrator Nunc Pro Tunc to 

January 13, 2020 [Dkt. No. 6759] and the Order Granting Application of the Official Committee of 

Tort Claimants Pursuant to 11 U.S.C. §§ 1103 and 363 and Fed. R. Bankr. P. 2014 and 5002 to 

Retain and Employ Hon. John K. Trotter (Ret.) as Trustee Nunc Pro Tunc to January 13, 2020 [Dkt. 

No. 6760], which granted the TCC’s applications to retain and employ Ms. Yanni as Claims 

Administrator of the Fire Victim Trust5

 and the Honorable John K. Trotter as trustee of the Fire 

Victim Trust, both effective as of January 13, 2020. 

On June 19, 2020, the Debtors filed the Debtors’ and Shareholder Proponents’ Joint Chapter 11 

Plan of Reorganization dated June 19, 2020 [Dkt. No. 8048] (as may be modified, supplemented, or 

3 The term sheet appended to the TCC RSA provides that “All definitive documents relating to the 

Plan, capitalization, equity and debt financing shall be in form and substance reasonably acceptable 

to the Plan Proponents and the Requisite Consenting Fire Claimant Professionals.” 

4 Plan Section 6.8(e) provides that “[t]he Fire Victim Trust Oversight Committee shall be appointed 

on the Effective Date. The Fire Victim Trust Oversight Committee shall consist of members selected 

and appointed by the Consenting Fire Claimant Professionals and the Tort Claimants Committee. 

The rights and responsibilities of the Fire Victim Trust Oversight Committee shall be set forth in the 

Fire Victim Trust Agreement.” 

5

 Prior to her appointment as Claims Administrator, Ms. Yanni served as the Administrator of the 

Wildfire Assistance Program in the Bankruptcy Cases, having been jointly selected by the Debtors, 

the Creditors Committee, and the TCC, and approved by this Court by order dated June 5, 2019. See 

Supplemental Order (A) Approving Appointment of Administrator and Establishing Guidelines for 

the Wildfire Assistance Program and (B) Granting Related Relief [Dkt. No. 2409]. 

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amended from time to time, and together with all schedules and exhibits thereto, the “Plan”). Over 

85% of Fire Victims who submitted ballots voted in favor of the Plan.6

On June 20, 2020, the Bankruptcy Court entered the Order Confirming Debtors’ and 

Shareholder Proponent’s Joint Chapter 11 Plan of Reorganization Dated June 19, 2020 [Dkt. No. 

8053] (the “Confirmation Order”). On June 29, 2020, Trustee Trotter filed the Notice of 

Appointment of Fire Victim Trust Oversight Committee in Accordance with Confirmation Order 

[Dkt. No. 8195], and the Effective Date of the Plan occurred on July 1, 2020. Pursuant to the Plan 

and Confirmation Order, the PG&E Fire Victim Trust Agreement dated as of July 1, 2020 (the “Trust 

Agreement”) became effective on the Effective Date, and the Trust was established and funded with 

a combination of cash, stock, rights to deferred cash, and causes of action. 

Consistent with Justice Trotter’s commitment to his family that he would serve as Trustee for 

only two years, Justice Trotter resigned as Trustee of the Fire Victim Trust effective as of the close 

of business on June 30, 2022. See Letter from Trustee of the Fire Victim Trust, filed on the docket 

as Exhibit A to the Notice of Filing of Letter to Fire Victims on Behalf of the Fire Victim Trust [Dkt. 

No. 12528] and posted on the Fire Victim Trust website (www.firevictimtrust.com). On July 1, 2022, 

Ms. Yanni became the Successor Trustee of the Trust pursuant to Section 5.2(d) of the Trust 

Agreement. [Dkt. No. 8750-1]. 

B. Mr. Abrams’s Repeated Requests for Broad Discovery Under Rule 2004. 

On May 23, 2022, Mr. Abrams filed the Motion of William B. Abrams Pursuant to Federal 

Rule of Bankruptcy Procedure 2004 for Entry of an Order Authorizing Discovery and Hearings 

Regarding the Administration of the Fire Victim Trust [Dkt. No. 12440] (the “Initial Discovery 

Motion”). The Court held a preliminary hearing regarding the Initial Discovery Motion on June 7, 

2022. Pursuant to the Court’s direction at the June 7, 2022 hearing, Trustee Trotter filed the 

Objection of Fire Victim Trustee to Motion of William B. Abrams Pursuant to Fed. R. Bankr. 2004 

6 See Declaration of Christina Pullo of Prime Clerk LLC Regarding Solicitation of Votes and 

Tabulation of Ballots Cast with Respect to the Debtors’ and Shareholder Proponents’ Joint Chapter 

11 Plan of Reorganization [Dkt. No. 7507]. 

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for Entry of an Order Authorizing Discovery and Hearings Regarding the Administration of the Fire 

Victim Trust [Dkt. No. 12527] (the “Initial Discovery Objection”) on June 21, 2022 and 

contemporaneously filed a supplemental exhibit to the 2021 Annual Report providing additional 

detail regarding information contained in the 2021 Annual Report. On July 6, 2022, Mr. Abrams 

filed the William B. Abrams Reply to the Objection of the Fire Victim Trustee Pursuant to Fed. R. 

Bankr. 2004 for Entry of an Order Authorizing Discovery and Hearings Regarding the 

Administration of the Fire Victim Trust [Dkt. No. 12593] (the “Abrams Reply”). 

After considering the Initial Discovery Motion, the Initial Discovery Objection, the Abrams 

Reply and the statements presented to the Court at the June 7, 2022 hearing, the Court entered the 

Initial Discovery Order on August 2, 2022. The Initial Discovery Order denied the Initial Discovery 

Motion in part and granted it in part by, inter alia, directing the Trust to post a copy of the retention 

agreement pertaining to each third-party litigation firm retained by the Trust through the “request for 

proposal” interview process described in the Initial Discovery Objection. 

On August 18, 2022, Mr. Abrams filed the Expanded Discovery Motion,7 along with a 

supporting declaration [Dkt. No. 12767] (the “Abrams Declaration”). 

On August 24, 2022, Trustee Yanni filed a Motion of the Fire Victim Trustee to File Redacted 

Versions of Certain Retention Agreements Until Litigation Related to Such Retention Agreements is 

Finally Resolved [Dkt. No. 12871] (the “Litigation Redaction Motion”). On August 29, 2022, the 

Court entered the Order Granting Motion of the Fire Victim Trustee to File Redacted Versions of 

7 Unfortunately, it does not appear that resolution of the Expanded Discovery Motion will end Mr. 

Abrams’s attempts to gain wildly broad discovery in the hope of proving his apparent conspiracy 

theories regarding the Trust. On September 22, 2022, Mr. Abrams filed the Motion of William B. 

Abrams to Federal Rule of Bankruptcy Procedure 2004 for Entry of an Order Authorizing Discovery 

and Hearings Regarding Debtors’ Acts, Conduct and Agreements That May Obstruct or Limit the 

Just and Fair Management of the Fire Victim Trust [Dkt. No. 12995] and the Declaration of William 

B. Abrams in Support of the Motion of William B. Abrams to Federal Rule of Bankruptcy Procedure 

2004 for Entry of an Order Authorizing Discovery and Hearings Regarding Debtors’ Acts, Conduct 

and Agreements That May Obstruct or Limit the Just and Fair Management of the Fire Victim Trust 

[Dkt. No. 12996]. On September 26, 2022, the Court entered the Order Directing Reorganized 

Debtors to Respond To Motion Filed by William B. Abrams, directing the Reorganized Debtors to 

file any opposition they may have to the motion at Docket No. 12995 no later than October 12, 2022. 

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Certain Retention Agreements Until Litigation Related to Such Retention Agreements is Finally 

Resolved [Dkt. No. 12884] (the “Litigation Redaction Order”), granting the Litigation Redaction 

Motion after in camera review of the retention agreements subsequently filed on the Court’s docket 

in response to the Initial Discovery Order. 

On August 29, 2022, the Trust and the Reorganized Debtors filed the Reorganized Debtors 

and Fire Victim Trust’s Joint Ex Parte Motion to Extend, In Part, Deadline to Comply with Order 

on Motion of William B. Abrams Authorizing Discovery Regarding Administration of the Fire Victim 

Trust [Dkt. No. 12887] (the “Joint Motion”), the Joint Ex Parte Motion to File Redacted Version of 

Reorganized Debtors and Fire Victim Trust’s Joint Ex Parte Motion to Extend, In Part, Deadline to 

Comply with Order on Motion of William B. Abrams Authorizing Discovery Regarding 

Administration of the Fire Victim Trust [Dkt. No. 12889] (the “Joint Motion for Redaction”) and 

the Declaration of Robin J. Reilly in Support of Reorganized Debtors and Fire Victim Trust’s Joint 

Ex Parte Motion to Extend, In Part, Deadline to Comply with Order on Motion of William B. Abrams 

Authorizing Discovery Regarding Administration of the Fire Victim Trust [Dkt. No. 12890]. On 

August 31, 2022 the Court entered orders granting both the Joint Motion for Redaction and the Joint 

Motion. [Dkts. No. 12898 and 12899]. 

On September 1, 2022, Mr. Abrams filed a Motion for Reconsideration and Related Relief 

from the Order Granting Motion of the Fire Victim Trustee to File Redacted Versions of Certain 

Retention Agreements Until Litigation Related to Such Retention Agreements is Finally Resolved and 

Pursuant to Federal Rule of Civil Procedure 59(e) [Dkt. No. 12916] (the “Reconsideration 

Motion”) and supporting declaration [Dkt. No. 12917]. On September 6, 2022, the Court entered 

the Order on Motion for Reconsideration [Dkt. No. 12929] (the “Reconsideration Order”). 

On September 6, 2022, Trustee Yanni filed the Fire Victim Trustee’s Responses in 

Connection with the Court’s August 2, 2022 Discovery Order [Dkt. No. 12931], answering the 

Court’s specific questions and providing copies of the requested retention agreements, temporarily 

redacted as authorized by the Litigation Redaction Order. 

The Court held a preliminary hearing regarding the Expanded Discovery Motion on 

September 13, 2022. 

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On September 15, 2022, Trustee Yanni filed the Fire Victim Trustee’s Disclosures Directed 

by September 6, 2022 Order on Motion for Reconsideration [Dkt. No. 12972] pursuant to the 

Reconsideration Order.8 On September 27, 2022, the Court entered the Order Denying Motion for 

Reconsideration [Dkt. No. 13008]. 

On September 29, 2022, the Reorganized Debtors filed the Reorganized Debtors’ Motion for 

Entry of an Order (I) Approving Settlements Resolving Disputes with Certain Insurers, and (II) 

Granting Related Relief [Dkt. No. 13015]. Also on September 29, 2022, the Trust filed the Fire 

Victim Trust’s Notice of Filing D&O Settlement Agreement [Dkt. No. 13020] to provide an 

unredacted copy of the Settlement and Release Agreement by and among the Trustee, certain former 

directors and officers of PG&E, and the Debtors. 

On September 30, 2022, the Trust filed the Fire Victim Trust’s Notice of Filing D&O Firms’ 

Engagement Letter [Dkt. No. 13024] to provide an unredacted copy of the Engagement Letter 

between the Trust and the law firms it engaged in connection with potential claims against certain 

former directors and officers of PG&E. The D&O Settlement Agreement and D&O Firms’ 

Engagement Letter Fire Victim Trust are in the process of being posted on the Fire Victim Trust 

website and will be available for viewing on the website by the close of business on October 3, 2022. 

Trustee Yanni respectfully submits this objection pursuant to the Court’s direction at the 

September 13, 2022 hearing. 

8 Counsel for Trustee Yanni interpreted the Reconsideration Order, which was specifically directed 

only to the Court’s Litigation Redaction Order (and not to the Court’s earlier Initial Discovery Order, 

the relief granted thereby and Trustee Yanni’s other disclosures made pursuant thereto), as directing 

Trustee Yanni to respond to the Reconsideration Motion by (1) explaining why she thought it 

necessary to redact the name and other identifying information about the FVT’s “Authorized Agent” 

in the Retention Agreements (rather than providing arguments to support the redaction of the identity, 

Trustee Yanni decided to disclose Mr. Kelly’s identity in the spirit of transparency), and (2) filing 

any agreements between the Trust and the Authorized Agent, including any provisions for 

compensation (which Trustee Yanni did by attaching a copy of the Mr. Kelly’s engagement letter 

and explaining that it is the only agreement between the Trust and the Authorized Agent). Trustee 

Yanni was not attempting to avoid addressing the other points raised in the Motion for 

Reconsideration, which Trustee Yanni’s counsel interpreted as a misunderstanding of the process 

outlined in the Procedures for Filing Redacted or Sealed Confidential or Highly Sensitive Documents 

adopted by the United States Bankruptcy Court for the Northern District of California rather than an 

argument to which Trustee Yanni needed to respond. 

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C. Mr. Abrams’s Statements Regarding Trustee Cathy Yanni. 

In the Expanded Discovery Motion, Mr. Abrams makes numerous statements about Trustee 

Yanni which are untrue or misleading. These deceptive insinuations harm Fire Victims by 

undermining their faith in the work of the Trustee and detracting from the objectively positive results 

the Trust has achieved to date. For that reason alone, it is necessary to refute Abrams’s gross 

misrepresentations. 

Perhaps the most insidious fabrication in Abrams’s brief is that Trustee Yanni somehow 

mismanaged funds in her work on a prior matter. Mr. Abrams refers to Trustee Yanni’s appointment 

as Special Master in connection with the In re Ethicon, Inc. Pelvic Repair System Products Liability 

Litigation (the “Pelvic Mesh Litigation”).9 Expanded Discovery Motion at 10. This is particularly 

outrageous because Ms. Yanni never, at any point during her work in the Pelvic Mesh engagement, 

had custody or control over settlement funds. In the Pelvic Mesh Litigation, Ms. Yanni was selected 

by the parties and appointed by that MDL’s supervising United States District Court Judge, The Hon. 

Joseph R. Goodwin (S.D.W. Va.), to mediate settlements between plaintiffs and corporate 

pharmaceutical defendants. Additionally, Ms. Yanni was asked to evaluate injuries suffered by 

plaintiffs and assign compensation amounts to individual cases based on their severity. She 

performed these tasks effectively and with great compassion for the injured plaintiffs she served. 

During her work on the Pelvic Mesh Litigation, Ms. Yanni did not at any time manage or oversee 

payments, nor was she involved in the allocation of common benefit attorneys’ fees. For Mr. Abrams 

to suggest that she did is intentionally dishonest. 

Next, Mr. Abrams implies that a lawsuit by a group of Pelvic Mesh plaintiffs against their 

attorney had some relation to Ms. Yanni. He makes this inference by referring to an article in the 

9 Allegations made in the Expanded Discovery Motion are further addressed in The Partial Response 

of Steven J. Skikos, Esq. to William B. Abrams’ Motion Pursuant to Federal Rule of Bankruptcy 

Procedure 2004 for Entry of Order Authorizing Discovery and Hearings Regarding the Acts and 

Conduct of Jams Neutrals Given New Evidence and the Response of Former Trustee John K. Trotter 

to Motion of William B. Abrams Pursuant to Federal Rule of Bankruptcy Procedure 2004 for Entry 

of an Order Authorizing Discovery and Hearings Regarding the Acts and Conducts of JAMS Neutrals 

Given New Evidence, filed contemporaneously herewith. 

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New York Times and a pleading in the Pelvic Mesh Litigation. In reality, neither the New York 

Times article or the Sheller pleading cited by Mr. Abrams contains any mention of Ms. Yanni, nor 

do they touch on any aspect of her work in the Pelvic Mesh Litigation. Mr. Abrams’s attempt to 

connect Trustee Yanni to the issues described in these documents is deliberately misleading. 

Finally, Abrams alleges that fees charged by Ms. Yanni during her work on the Pelvic Mesh 

Litigation were arbitrary or inconsistent, implying that she tried to conceal the costs associated with 

her work. The opposite is true. During her service as Special Master in the Pelvic Mesh Litigation, 

the fees and costs were regularly referenced in appointment orders, those same costs were determined 

to be reasonable by Judge Goodwin, and a final accounting was provided to plaintiffs in their ultimate 

settlement statements.10 

In each instance cited above, Mr. Abrams makes reckless if not knowingly false and 

unfounded accusations to malign Trustee Yanni as part of an attempt to generate suspicion and 

undermine her role in and work for the Fire Victim Trust. Each of his allegations are provably false. 

More importantly, they have absolutely nothing to do with the Fire Victim Trust and merely serve to 

distract from the diligent work done to date under Ms. Yanni’s leadership (both as Claims 

Administrator and now as Trustee). Mr. Abrams should be required to withdraw his outrageous 

misrepresentations regarding Trustee Yanni and the others whose reputations the Expanded 

Discovery Motion attempts to discredit and those pleadings should be struck from the docket. See

note 2 supra. 

D. JAMS’ Services to the Fire Victim Trust. 

The Trust retained JAMS to provide skilled professionals to fulfill the roles of Special Master, 

Appeals Officer and Neutrals, each as defined in the Trust Agreement. 

Ms. Yanni is not an employee of JAMS but a shareholder and an independent contractor. 

JAMS provides administrative services for all independent contractors, including Ms. Yanni. Prior 

to assuming the role of Trustee, Ms. Yanni participated in a profit-sharing agreement whereby JAMS 

10 See Pretrial Order Nos. 236, 253, 257, 274, 284, 287, 335, and 349, available at 

https://www.wvsd.uscourts.gov/mdl/ethicon/orders.html. 

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shareholders received a deferred distribution of earnings, typically three years after the income was 

actually generated. That is, a JAMS profit computation for the year 2017 instead of being paid in 

the year immediately following, 2018, would typically be distributed to JAMS shareholders in the 

year 2021. Effective July 1, 2022, when Ms. Yanni became the Trustee and henceforth for the 

duration of her services to the Trust, she agreed to waive all rights to participate in the JAMS profitsharing agreement. Thus, Ms. Yanni will not receive any profit-sharing distributions from JAMS 

earned during the entire the period she serves as Trustee. 

Mr. Abrams misstates the roles of many of the individuals listed in the Expanded Discovery 

Motion, characterizing as “neutrals” individuals who have never served as Neutrals (as that term is 

defined in Section 7.1 of the Trust Agreement) and other individuals who have never had any 

involvement in claims administration for the Trust: 

 Hon. Randall Newsome (Ret.) – Judge Newsome was appointed by Judge 

Montali on October 28, 2019, to serve as a mediator with respect to issues 

pertaining to the reorganization plan in the Bankruptcy Cases.11 Later Judge 

Newsome served as an appellate Neutral for the Trust, where he decided one 

appeal. Judge Newsome resigned from JAMS on December 31, 2021. Judge 

Newsome has no role in the administration of the Fire Victim Trust. 

 Hon. Jay Gandhi (Ret.) – Judge Gandhi was selected by all counsel to serve as 

a mediator in connection with the pre-confirmation settlement of the claims of 14 

public entities arising from the 2015 Butte Fire, the 2017 North Bay Fires, and the 

2018 Camp Fire. Judge Gandhi was then selected by all counsel to serve as a 

mediator in connection with certain third-party causes of action to the Trust.12

Judge Gandhi has no role in the administration of the Fire Victim Trust. 

11 See Order Appointing Mediator [Dkt. No. 4499]. 

12 This mediation is ongoing and sensitive in nature. The resolution of these causes of action will 

be disclosed once final, as directed by the Initial Discovery Order. 

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 Viggo Boserup, Esq. – Mr. Boserup serves as the Appeals Officer (also referred 

to as the Appeals Coordinator) for the Trust. In this role, Mr. Boserup reviews 

and evaluates claimants’ appeals from Determinations to determine whether a 

given appeal should be assigned to a complex panel of Neutrals, or, alternatively, 

a non-complex panel of Neutrals. Thereafter, each appeal is randomly assigned 

to a Neutral. Mr. Boserup has no oversight role or involvement in the Claims 

Administration process. 

 Hon. Ellen S. James (Ret.) – Judge James was appointed by the Honorable 

Haywood S. Gilliam, Jr., United States District Court Judge, to serve as Special 

Master on behalf of minors and incapacitated adults.13 Judge James approves all 

minors’ compromises in conjunction with the evaluation, disallowance, 

resolution, settlement, and approval of any and all Fire Victim Claims in 

accordance with the CRP. See Trust Agreement § 2.1(e)(xxvii). Judge James has 

no oversight role or involvement in the Claims Administration process 

 “Other JAMS Mediators” – The Trust does not have a “Panel of Mediators for 

Standard Mediations” as Mr. Abrams asserts. None of the following individuals 

named by Mr. Abrams have served as Neutrals or otherwise been involved in the 

Claims Administration process: 

o Hon. Wynn S. Carvill (Ret.) 

o Hon. Catherine A. Gallagher (Ret.) 

o Patricia K. Gillette, Esq. 

o Hon. Ken M. Kawaichi (Ret.) 

o Hon. Risë Jones Pichon (Ret.) 

Neutrals associated with JAMS have limited roles with the Trust that are narrowly focused 

on the appellate review of claims. Very few claims have even required an appeal, as more than 99% 

have been resolved by the claims process. To date, only 166 Claims Questionnaires have been 

13 See Order for Appointment of a Special Master Pursuant to Fed. R. Civ. Proc. 53 [Dkt. No. 9721]. 

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appealed, which represents no more than 0.7% of all those adjudicated. Out of over 54,000 Fire 

Victims who have received Determination Notices, only a handful have had any occasion to interact 

with any Neutral in their appeal of a claim. In his Expanded Discovery Motion, Mr. Abrams greatly 

exaggerates the role that JAMS Neutrals play in the administration of the Fire Victim Trust. 

III. OBJECTION

A. The Expanded Discovery Motion Should be Denied Because the Allegations are 

Contrary to the Trust’s Accomplishments. 

The allegations, hearsay, innuendo, and inferences set forth in the Expanded Discovery 

Motion depict an imagined story of shirked duties and deceit to the detriment of Fire Victims. But 

the undeniable facts of the claims distribution process thus far tell a far different story. Indeed, this 

Court has recognized the impressive work being done by the Trust with respect to claims 

administration.14 Thus, the Court should deny the far-reaching relief requested in the Expanded 

Discovery Motion because Trustee Yanni and other Trust professionals are fulfilling the Trust goals 

of protecting and maximizing the corpus of the Trust for the benefit of nearly 70,000 Fire Victim 

claimants and compensating Fire Victims for their injuries as equitably and efficiently as possible. 

Unlike most mass tort bankruptcy cases that address no more than a few types of claims, this case 

involves many distinct and different types of claims, including wrongful death, personal injury, 

emotional distress, real property damage, and business loss. Trustee Yanni is administering one of 

the most complicated victim compensation programs in history. Unlike many post-confirmation 

mass tort trusts, the Fire Victim Trust was not provided distribution procedures with a matrix of claim 

values, factors, and rules. Instead, the Claims Resolution Procedures charged the Trustee and Claims 

Administrator with developing evaluation protocols that result in fair and reasonable compensation 

14 See, e.g., Initial Discovery Order 4:19-24 and 5:8-9 (“It should not go unnoticed, and the court 

acknowledges, that the former Trustee and the present Trustee, and their professionals and support 

staff, have accomplished an impressive record of progress in the two years of the Trust. This has 

occurred in the midst of an unprecedented worldwide pandemic under trying circumstances. . . 

Despite the criticisms of Mr. Abrams and others, the progress has been impressive.”) 

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of almost 70,000 Fire Victims. The result of the tens of thousands of hours of work by hundreds of 

people to launch the Trust and administer claims as quickly as possible is simply astounding: 

 Approximately 36,000 Claims Questionnaires have been submitted by Fire Victim 

claimants. Those filings advance nearly 240,000 unique claims, each one of which 

requires adjudication by the Trust. 

 Over $5 billion has been paid to Fire Victims with approximately 49,000 Fire 

Victims having received compensation. 

 The Trust has issued Determination Notices for 82% of submitted Claims 

Questionnaires. 

 99.3% of all Determination Notices to date have been resolved without an appeal. 

These numbers belie Mr. Abrams’s unfounded charges against the Trust and its 

Administration. Granting the far-reaching discovery that Mr. Abrams requests would serve only to 

undermine the efficient operation of the Trust and slow the distribution of payments to Fire Victims. 

B. The Expanded Discovery Motion Should be Denied Because Mr. Abrams Has 

Not Shown Any Cause, and His Resort to Innuendo, Mischaracterization and 

Inaccurate Hearsay Cannot be Not a Sufficient Basis for the Discovery Sought. 

Mr. Abrams has not shown any cause for the broad discovery requested in the Expanded 

Discovery Motion, much less good cause. As one of its sources of “new evidence,” the Expanded 

Discovery Motion relies upon a Los Angeles Times article on matters related to disgraced attorney 

Tom Girardi, which Mr. Abrams found necessary to misquote in order to connect it to the Trust.15 

The Expanded Discovery Motion also relies upon a law review article advocating for MDL reform, 

and citations to filings by disgruntled plaintiffs’ attorneys in matters unrelated to the Bankruptcy 

15 For example, Mr. Abrams claims that discovery requests should be expanded “to ensure that the 

‘multifaceted victimization of injured people’ referred to by Chief Justice Tani Cantil Sakauye 

regarding the influences of JAMS has not undermined the well-intentioned efforts of this Court to 

ensure fair and just outcomes.” The actual quote from the Chief Justice in the article cited by Mr. 

Abrams has nothing to do with JAMS or anyone involved with the Fire Victim Trust: “CantilSakauye, the chief justice, lamented the ‘multifaceted victimization of injured people’ in the Girardi 

case.” See https://www.latimes.com/california/story/2022-08-09/chief-justice-calls-for-newregulation-of-private-judging-in-light-of-girardi-scandal. 

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Cases or any individual retained by the Trust or involved in the administration of Fire Victim 

Claims.16 Again, the Expanded Discovery Motion does not contain a single allegation that anything 

improper has actually occurred at the Trust or in connection with the Trust. Instead, Mr. Abrams 

attempts to convince the Court to grant his requested relief solely because he was able to dredge up 

reports of nefarious dealings by an attorney having no connection to the Bankruptcy Cases or the 

16 Mr. Abrams also cites a select excerpt from Trustee Trotter’s May 2021 presentation to Fire 

Victims as support for his claim that that “Justice Trotter is one of the individuals who ‘struck a deal’ 

with PG&E and shaped the financial terms which are now undermining victims [sic] ‘made whole’ 

settlement.” Expanded Discovery Motion at 12. Mr. Abrams quotes Trustee Trotter as stating that 

“in April -- I think it was April [2020, i.e., before Plan confirmation] -- we struck a deal with PG&E 

that they would pay tranches of money that would be used to pay claims processing, and in April I 

was still part-time, I was an advisor, I was learning more about it, I was helping your lawyers write 

the rules by which the Trust would be governed, the claims resolution processes.” Id. The earlier 

part of the quote, which Mr. Abrams fails to disclose, sets the fuller context: “A group of lawyers 

had gotten together and gone to PG&E and said, you know, we want to hire Justice Trotter, we want 

to hire a claims administrator named Cathy Yanni to help us begin to put together the process that 

will ultimately be the methodology by which we resolve these cases. Now PG&E had no obligation 

to pay any money at that time. They were still in bankruptcy and the Trust hadn't been funded yet, 

but they did work out a deal where some pre-funding was arranged, and I don't have the details about 

that but in April. . .” See Notice of Filing of Transcript of Status of Trust Distribution Video 

Presentation by Justice John Trotter (Ret.), Trustee of the PG&E Fire Victim Trust [Dkt. No. 10654] 

(attached hereto as Exhibit 1) at 3:8-24. In light of this context – i.e., at a time prior to the Effective 

Date of the Plan, when the Plan documents, including the Claims Resolution Procedures, were still 

not yet final and were being reviewed and commented on by all the Plan parties, and when the 

plaintiff parties to the TCC RSA had consent and approval rights over such documents (see note 3 

supra) – it was neither remarkable nor improper for Justice Trotter (who received his pre-Effective 

Date appointment [Dkt. No. 6760]) to provide assistance and advice regarding claims resolution 

procedures to the parties who had approval rights over the final documents setting forth such 

procedures. Indeed, the Court’s approval of the pre-Effective Date appointments of Justice Trotter 

and Ms. Yanni and funding was critical to enable the Trust, when it went effective, to be in a position 

to receive, administer and pay Fire Victim claims as promptly as possible after the Effective Date of 

the Plan. Moreover, as part of the applications to employ Justice Trotter as Trustee and Ms. Yanni 

as Claims Administrator, publicly filed with this Court on April 13, 2020, the TCC expressly 

disclosed that Justice Trotter and Ms. Yanni had “been working since January 13, 2020 to develop 

the Trust and CRP and [had] started the process of claims analysis.” See Dkt. No. 6746 at ¶ 15. See 

also Dkt. No. 5726 at ¶ 13 (TCC sought retention of Justice Trotter “nunc pro tunc to January 13, 

2020, shortly after Justice Trotter began doing substantive work.”); Dkt. No. 5723 at ¶ 12 (TCC 

sought retention of Ms. Yanni “nunc pro tunc to January 13, 2020, shortly after Ms. Yanni began 

doing substantive work.”). Mr. Abrams’s insinuations that Justice Trotter was part of the negotiation 

of economic terms of the deals undergirding the Plan or that the actual administration of claims by 

the Trust was somehow delegated to plaintiff lawyers are simply false and misleading.

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Trust. Mr. Abrams asks for authority to pursue what the Court described as discovery of “incredible 

breadth . . . under a procedure that is almost unprecedented”17 just in case there is the most remote 

possibility – although he does not mean to imply that there actually has been – that an individual or 

entity with any tie to the Trust could have engaged in similar behavior. Rule 2004 is not so broad as 

to allow it to be abused to enable discovery based on a sensational hypothetical and unfounded 

hyperbole.18

C. The Broad and Unwarranted Discovery Sought by Abrams’s Expanded 

Discovery Motion Should be Denied Because the Costs Thereof Consume Trust 

Funds that Would Otherwise be Paid to Fire Victims. 

Mr. Abrams has sought relief from the Court with respect to the Trust more often than any 

other party in the Bankruptcy Cases.19 Over the past two-plus years since the inception of the Trust, 

the Trustee has given Mr. Abrams access to the Trust’s professionals in an effort to address his 

inquiries and concerns. In recent months, however, Mr. Abrams’s refusal to accept the Trust’s 

responses20 to his inquiries has developed into a conspiracy theory fueled by sensational news reports 

and social media posts. The cost to the Trust, especially of responding to Mr. Abrams’s many filings 

and appearing in Court, is substantial and growing. More importantly, Mr. Abrams is diverting the 

attention of the Trustee and other Trust professionals from the important business of adjudicating 

claims and making payments to Fire Victims who badly need compensation. 

The Trust should not have to bear the cost of the baseless and unprecedented “broad 

discovery” sought by the Expanded Discovery Motion, particularly when such costs would deplete 

17 See Sept. 13, 2022 Hr’g Tr. 44:19-24. 

18 See 11 U.S.C. § 2004(b) (The scope of Rule 2004 “may relate only to the acts, conduct, or property 

or to the liabilities and financial condition of the debtor, or to any matter which may affect the 

administration of the bankruptcy estate.”). 

19 See Table of Abrams Filings attached hereto as Exhibit 2. 

20 For example, Mr. Abrams has refused to accept (1) that the Trust should not act in a manner that 

might negatively impact the value of the stock, and (2) that the Trust cannot discuss plans regarding 

the disposition of stock with anyone other than its retained financial advisors and professionals and, 

when appropriate, the TOC in accordance with the Trust Agreement. 

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Trust dollars that would otherwise be paid to Fire Victims. In addition to the costs associated with 

seeking discovery from the Trust, the Trust is responsible for costs and expenses that would be borne 

by many of the individuals at whom Mr. Abrams directs his motion.21 

Contrary to Mr. Abrams’s assertion that he is “not engaged in activities to undermine the 

value of the Fire Victim Trust or to slow the Trust administration process,”22 the Expanded Discovery 

Motion and similar filings are doing just that. Moreover, the constant unfounded attacks from Mr. 

Abrams undermine the public’s confidence in the Trust’s administration of claims. This traumatizes 

Fire Victims anew by subverting their faith in the system that is earnestly working to compensate 

them. The Court should not condone the continued imposition of unnecessary and unwarranted 

expenses on Trust assets to the detriment of Fire Victims, nor the further drain of Trust administration 

resources that would otherwise be devoted to accelerating the distribution of funds to Fire Victims. 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

21 As is standard for businesses, trusts and other entities that retain and employ individuals to act on 

their behalf, the Trust indemnifies the Trustee, TOC, Claims Administrator, Special Master, Neutrals 

and others in their performance of their duties to the Trust. See Trust Agreement §§ 5.7 and 7.5. 

22 See Abrams Declaration at 2. 

Case: 19-30088 Doc# 13035 Filed: 10/03/22 Entered: 10/03/22 11:57:17 Page 19

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CONCLUSION 

WHEREFORE, for the good cause shown and reasons presented herein, the Fire Victim 

Trustee respectfully requests that the Court sustain this Objection, deny the Expanded Discovery 

Motion, and grant such other and further relief as may be just, including requiring Mr. Abrams to 

withdraw his salacious pleadings and/or striking those pleadings. 

DATED: October 3, 2022 BROWN RUDNICK LLP 

By: /s/ 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# 13035 Filed: 10/03/22 Entered: 10/03/22 11:57:17 Page 20

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EXHIBIT 1 

Notice of Filing of Transcript of Status of Trust Distribution Video Presentation 

by Justice John Trotter (Ret.), Trustee of the PG&E Fire Victim Trust 

 

Case: 19-30088 Doc# 13035 Filed: 10/03/22 Entered: 10/03/22 11:57:17 Page 21

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EXHIBIT 2 

Table of Abrams Filings to Which Trust has Replied 

43

Case: 19-30088 Doc# 13035 Filed: 10/03/22 Entered: 10/03/22 11:57:17 Page 43

of 44
FILINGS BY WILLIAM B. ABRAMS IN THE CHAPTER 11 CASES

TO WHICH THE FIRE VICTIM TRUST HAS RESPONDED

Date Docket Title Disposition

June 16, 2020 7974 Motion to Reconsider Order Approving Joint Stipulation re:

Reg Rights Agreement Overruled

June 19, 2020 8045 Opposition to Second Revised Draft Proposed Findings of

Fact, Conclusions of Law and Confirmation Order Overruled

July 1, 2020 8247 Motion for Just Treatment of Victims Through

Reconstitution of TOC Denied1

May 26, 2021 10715 Motion to Amend Judgment and Replace All Members of

TOC and Support Efficient Trust Administration Denied

June 6, 2021 10748

Motion to Enforce Victim Trust Agreement and Replace all

Members of the TOC and Support Efficient Trust

Administration

Denied

August 2, 2021 11005

Motion to Enforce Disclosure Requirements or

Reconstitute the TOC Given New Evidence of Self‐ Dealing

and Conflicts of Interest

Denied

May 23, 2022 12440 Motion for an Order Authorizing Discovery and Hearings

Regarding the Administration of the Fire Victim Trust

Granted in

Part and

Denied in

Part

July 6, 2022 12593

Reply to the Objection of the Fire Victim Trustee Pursuant

to Fed. R. Bankr. 2004 for Entry of an Order Authorizing

Discovery and Hearings Regarding the Administration of

the Fire Victim Trust

Underlying

Motion

Granted in

Part and

Denied in

Part  

August 18, 2022 12766

Motion of William B. Abrams Pursuant to Federal Rule of

Bankruptcy Procedure 2004 for Entry of an Order

Authorizing Discovery and Hearings Regarding the Acts and

Conduct of JAMS Neutrals Given New Evidence

Pending

September 1,

2022 12916

Motion for Reconsideration and Related Relief from the

Order Granting Motion of the Fire Victim Trustee to File

Redacted Versions of Certain Retention Agreements Until

Litigation Related to Such Retention Agreements is Finally

Resolved and Pursuant to Federal Rule of Civil Procedure

59(e)

Denied

September 22,

2022   12995

Motion of William B. Abrams Pursuant to Federal Rule of

Bankruptcy Procedure 2004 for Entry of an Order

Authorizing Discovery and Hearings Regarding Debtors

Acts, Conduct and Agreements that May Obstruct or Limit

the Just and Fair Management of the Fire Victim Trust

Pending

1 Treated, along Emergency Pleading Requesting Reconsideration of the Identification of Parties who

Timely Objected to the Fire Victims Claims Resolution Procedure [Dkt. No. 8137] as a motion for

reconsideration.  See Order Denying Motions for Reconsideration [Dkt. No. 8478].

44 Case: 19-30088 Doc# 13035 Filed: 10/03/22 Entered: 10/03/22 11:57:17 Page 44

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