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EXHIBIT A 

(Statements Filed in Johnson and Robinson Pending Actions) 

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JOHN T. RICHARDS, ESQ. (SBN 159875)

John@richardswillispc.com

EVAN WILLIS, ESQ. (SBN 314797)

Evan@richardswillispc.com

RICHARDS WILLIS PC 

750 B Street, Suite 1760

San Diego, California 92101

T: (619) 237-9800 

Attorneys for Plaintiffs

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO

MARK JOHNSON, et al.

Plaintiffs,

v.

PG&E CORPORATION, et al.

Defendants.

Case No.: CGC-19-579965

PLAINTIFFS’ CASE MANAGEMENT 

STATEMENT REGARDING BANKRUPTCY 

STATUS; REQUEST FOR CONTINUANCE

Hearing Date: May 2, 2023

Hearing Time: 10:20a.m.

Dept. 610

Trial Date: [None]

/ / / /

/ / / /

/ / / /

/ / / / 

/ / / / 

/ / / /

/ / / /

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 TO THE HONORABLE COURT, AND TO ALL PARTIES AND THEIR 

ATTORNEYS OF RECORD

 PLEASE TAKE NOTICE that Plaintiffs Mark Johnson, et al. hereby oppose the Order to 

Show Cause regarding dismissal and request a continuance of this matter for 120 days and

hereby files this Case Management Statement with respect to the pending PG&E bankruptcy 

cases.

I. INTRODUCTION

 Plaintiffs’ filed suit against PG&E arising from the 2018 Camp Fire which PG&E admittedly 

caused. They filed bankruptcy as a result of causing numerous wildfires in Northern California, 

including the subject Camp Fire giving rise to this litigation. On January 29, 2019, PG&E filed 

bankruptcy and soon thereafter, settled with invidual fire victims, including all Plaintiffs to this 

action, for $13.5Billion Dollars. However, to date, fire victims have only received 60% of their 

settlement proceeds. Because they have only received 60% of their settlement proceeds, mainly 

because half of the $13.5Billion settlement was in stock, Plaintiffs’ respectfully request a 

continuance of this matter for approximately 120 days as the Trustee for the fire victims and 

Plaintiffs, the Fire Victim Trust, continues to sell stock to compensate Plaintiffs. Because of this 

uncertainty as to whether or not Plaintiffs will be made whole or not, Plaintiffs request a

continuance of this matter until the bankruptcy has resolved.

II. ARGUMENT

1. Pending Bankruptcy Proceedings

As the Court is aware, Defendant Pacific Gas & Electric Company ("PG&E") is currently 

undergoing bankruptcy proceedings, which resulted in a settlement agreement with the fire 

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victims, including the Plaintiffs. These bankruptcy proceedings have necessitated a stay of this 

civil litigation.

2. Partial Settlement Payment

The bankruptcy settlement stipulated payment of $13.5 billion to the fire victims. 

However, Plaintiffs have only received 60% of their due settlement proceeds, largely due to the 

fact that half of the settlement was in the form of stock. The Fire Victim Trust is in the process of 

selling stock to compensate the Plaintiffs fully.

3. Continuance is Justified

In accordance with case law such as In re Whitaker, 514 F.2d 922 (10th Cir. 1975), 

Matter of Texas Extrusion Corp., 844 F.2d 1142 (5th Cir. 1988), and In re Collins, 173 F.3d 924 

(4th Cir. 1999), a continuance of this civil case is not only justified due to the ongoing 

bankruptcy proceedings, but it is also in line with principles of judicial economy and fairness.

4. Risk of Inconsistent Judgments

Dismissing this case could lead to inconsistent judgments and might prevent Plaintiffs 

from receiving the full compensation to which they are entitled under the settlement. A stay or 

continuance would avoid this risk.

5. The Interest of Justice

In City of Fresno v. Superior Court (2007) 153 Cal.App.4th 590, the court noted that the 

interest of justice is a paramount concern in determining whether a continuance should be 

granted. Here, the interest of justice is served by ensuring that the Plaintiffs have sufficient time 

to be made whole, and to determine the full extent of their damages before proceeding to trial.

/ / / /

/ / / /

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For these reasons, Plaintiffs respectfully request that the Court deny the Order to Show 

Cause regarding dismissal and grant a continuance of 120 days to allow for the resolution of the 

bankruptcy proceedings and the receipt of the full settlement compensation.

Additionally, a key case is In re Whitaker, 514 F.2d 922 (10th Cir. 1975), where the court 

stated that "although a bankruptcy filing imposes an automatic stay on the commencement or 

continuation of judicial proceedings against the debtor, a bankruptcy court may exercise its 

discretion to stay proceedings that are not subject to the automatic stay." Moreover, in Matter of 

Texas Extrusion Corp., 844 F.2d 1142 (5th Cir. 1988), the court ruled that a bankruptcy court has 

the power to issue any order, process, or judgment that is necessary or appropriate to carry out 

the provisions of the bankruptcy laws. This has been interpreted to include the power to stay civil 

litigation pending in other forums. Furthermore, the case of In re Collins, 173 F.3d 924 (4th Cir. 

1999) is also relevant. Here, the court held that it could impose a stay of civil litigation where 

"unique circumstances" suggested that a stay would be in the interest of justice. The ongoing 

bankruptcy proceedings and the delay in the full payment of the settlement in the present case 

could be considered such "unique circumstances."

In the interest of justice and fairness, the court should consider granting a continuance in 

this case due to the unfortunate circumstance of attorney illness. It is well established that an 

attorney's physical or mental incapacity to proceed with scheduled legal proceedings can 

constitute "good cause" for a continuance. Courts, in exercising their discretion, often grant 

continuances when a party's attorney is seriously ill, recognizing the fundamental importance of 

competent representation to the integrity of the legal process. See, e.g., Smith v. Ayer (1985) 101 

Cal.App.3d 1003, 1009. Indeed, forcing a party to proceed without their chosen counsel due to 

circumstances beyond their control could significantly prejudice their case, infringe upon their 

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right to counsel of choice, and potentially deny them a fair opportunity to present their case. 

Therefore, given the gravity of the illness faced by the attorney in this case, a continuance would 

allow for their recovery and ensure that the Plaintiff receives the effective and vigorous 

representation that they are entitled to under the law.

Given these precedents, a continuance of the civil case due to PG&E's ongoing 

bankruptcy proceedings is not only reasonable but also aligns with principles of judicial 

economy and fairness to the parties involved.

III. REQUEST FOR CONTINUANCE

 The bankruptcy case is still pending and ongoing. All fire victims have only received .60 

cents to the dollar for their settlement with PG&E thus far and have not been made whole. 

Therefore, Plaintiffs’ respectfully request a continuance for approximately 120 days to allow for 

the Fire Victim Trust to continue to process claims and pay victims. This will allow more time 

for the Trustee to sell the remaining PG&E stock and for Plaintiffs to evaluate their claims as 

well, as they have only been paid 60% of their settlements.

Dated: May 1, 2023 RICHARDS WILLIS PC 

 By: ____ _________

JOHN T. RICHARDS, ESQ.

EVAN WILLIS, ESQ.

Attorneys for Plaintiffs

RICHARDS WILLIS PC

750 B Street, Suite 1760

San Diego, California 92101

T: (619) 237-9800 

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PROOF OF SERVICE

STATE OF CALIFORNIA

SUPERIOR COURT OF CALIFORNIA – COUNTY OF SAN FRANCISCO

Mark Johnson, et al. v. PG&E Corporation, et al.

CASE NO. CGC-19-579965

I am employed in the County of San Diego, State of California. I am over the age of 18 

and am not a party to the within action; my business address is 750 B Street, Suite 1760, San 

Diego, California 92101. 

On May 1, 2023, I served the foregoing documents, described as:

PLAINTIFFS’ CASE MANAGEMENT STATEMENT REGARDING BANKRUPTCY 

STATUS; REQUEST FOR CONTINUANCE

on all interested parties in this action by placing a true and correct copy thereof into the mail to:

_____ (By Mail) As follows:

_____ I placed such envelope with postage thereon prepaid in the United States mail at San 

Diego, California.

_____ I am readily familiar with the firm’s practice of collecting and processing

correspondence for mailing. Under that practice it would be deposited with the U.S. 

Postal Service on that same day with the postage thereon fully prepaid at San Diego, 

California, in the ordinary course of business. I am aware that on motion of the party 

served, service is presumed invalid if postal cancellation or postage meter date is 

more than one day after the date of deposit for mailing in affidavit.

__XX__ (By ELECTRONIC MAIL) I sent such document via electronic mail to:

_____ (STATE) I declare under penalty of perjury under the laws of the State of California 

that the above is true and correct.

_____ (FEDERAL) I declare that I am employed in the office of a member of the bar of this 

court at whose direction the service was made.

Dated: May 1, 2023, San Diego California. ___/s/ Connie Magat __________

Connie Magat

Keith Eggleton, Esq.

Wilson Sonsini Goodrich & Rosati, PC

650 Page Mill Road

Palo Alto, CA 94304

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JOHN T. RICHARDS, ESQ. (SBN 159875)

John@richardswillispc.com

EVAN WILLIS, ESQ. (SBN 314797)

Evan@richardswillispc.com

RICHARDS WILLIS PC 

750 B Street, Suite 1760

San Diego, California 92101

T: (619) 237-9800 

Attorneys for Plaintiffs

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO

EFREN ROBINSON, et al.

Plaintiffs,

v.

PG&E CORPORATION, et al.

Defendants.

Case No.: CGC-19-580073

PLAINTIFFS’ CASE MANAGEMENT 

STATEMENT REGARDING BANKRUPTCY 

STATUS; REQUEST FOR CONTINUANCE

Hearing Date: May 2, 2023

Hearing Time: 10:20a.m.

Dept. 610

Trial Date: [None]

/ / / /

/ / / /

/ / / /

/ / / / 

/ / / / 

/ / / /

/ / / /

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 TO THE HONORABLE COURT, AND TO ALL PARTIES AND THEIR 

ATTORNEYS OF RECORD

 PLEASE TAKE NOTICE that Plaintiffs Efren Robinson, et al. hereby oppose the Order to 

Show Cause regarding dismissal and request a continuance of this matter for 120 days and

hereby files this Case Management Statement with respect to the pending PG&E bankruptcy 

cases.

I. INTRODUCTION

 Plaintiffs’ filed suit against PG&E arising from the 2018 Camp Fire which PG&E admittedly 

caused. They filed bankruptcy as a result of causing numerous wildfires in Northern California, 

including the subject Camp Fire giving rise to this litigation. On January 29, 2019, PG&E filed 

bankruptcy and soon thereafter, settled with invidual fire victims, including all Plaintiffs to this 

action, for $13.5Billion Dollars. However, to date, fire victims have only received 60% of their 

settlement proceeds. Because they have only received 60% of their settlement proceeds, mainly 

because half of the $13.5Billion settlement was in stock, Plaintiffs’ respectfully request a 

continuance of this matter for approximately 120 days as the Trustee for the fire victims and 

Plaintiffs, the Fire Victim Trust, continues to sell stock to compensate Plaintiffs. Because of this 

uncertainty as to whether or not Plaintiffs will be made whole or not, Plaintiffs request a

continuance of this matter until the bankruptcy has resolved.

II. ARGUMENT

1. Pending Bankruptcy Proceedings

As the Court is aware, Defendant Pacific Gas & Electric Company ("PG&E") is currently 

undergoing bankruptcy proceedings, which resulted in a settlement agreement with the fire 

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victims, including the Plaintiffs. These bankruptcy proceedings have necessitated a stay of this 

civil litigation.

2. Partial Settlement Payment

The bankruptcy settlement stipulated payment of $13.5 billion to the fire victims. 

However, Plaintiffs have only received 60% of their due settlement proceeds, largely due to the 

fact that half of the settlement was in the form of stock. The Fire Victim Trust is in the process of 

selling stock to compensate the Plaintiffs fully.

3. Continuance is Justified

In accordance with case law such as In re Whitaker, 514 F.2d 922 (10th Cir. 1975), 

Matter of Texas Extrusion Corp., 844 F.2d 1142 (5th Cir. 1988), and In re Collins, 173 F.3d 924 

(4th Cir. 1999), a continuance of this civil case is not only justified due to the ongoing 

bankruptcy proceedings, but it is also in line with principles of judicial economy and fairness.

4. Risk of Inconsistent Judgments

Dismissing this case could lead to inconsistent judgments and might prevent Plaintiffs 

from receiving the full compensation to which they are entitled under the settlement. A stay or 

continuance would avoid this risk.

5. The Interest of Justice

In City of Fresno v. Superior Court (2007) 153 Cal.App.4th 590, the court noted that the 

interest of justice is a paramount concern in determining whether a continuance should be 

granted. Here, the interest of justice is served by ensuring that the Plaintiffs have sufficient time 

to be made whole, and to determine the full extent of their damages before proceeding to trial.

/ / / /

/ / / /

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For these reasons, Plaintiffs respectfully request that the Court deny the Order to Show 

Cause regarding dismissal and grant a continuance of 120 days to allow for the resolution of the 

bankruptcy proceedings and the receipt of the full settlement compensation.

Additionally, a key case is In re Whitaker, 514 F.2d 922 (10th Cir. 1975), where the court 

stated that "although a bankruptcy filing imposes an automatic stay on the commencement or 

continuation of judicial proceedings against the debtor, a bankruptcy court may exercise its 

discretion to stay proceedings that are not subject to the automatic stay." Moreover, in Matter of 

Texas Extrusion Corp., 844 F.2d 1142 (5th Cir. 1988), the court ruled that a bankruptcy court has 

the power to issue any order, process, or judgment that is necessary or appropriate to carry out 

the provisions of the bankruptcy laws. This has been interpreted to include the power to stay civil 

litigation pending in other forums. Furthermore, the case of In re Collins, 173 F.3d 924 (4th Cir. 

1999) is also relevant. Here, the court held that it could impose a stay of civil litigation where 

"unique circumstances" suggested that a stay would be in the interest of justice. The ongoing 

bankruptcy proceedings and the delay in the full payment of the settlement in the present case 

could be considered such "unique circumstances."

In the interest of justice and fairness, the court should consider granting a continuance in 

this case due to the unfortunate circumstance of attorney illness. It is well established that an 

attorney's physical or mental incapacity to proceed with scheduled legal proceedings can 

constitute "good cause" for a continuance. Courts, in exercising their discretion, often grant 

continuances when a party's attorney is seriously ill, recognizing the fundamental importance of 

competent representation to the integrity of the legal process. See, e.g., Smith v. Ayer (1985) 101 

Cal.App.3d 1003, 1009. Indeed, forcing a party to proceed without their chosen counsel due to 

circumstances beyond their control could significantly prejudice their case, infringe upon their 

Case: 19-30088 Doc# 13742-1 Filed: 05/17/23 Entered: 05/17/23 15:14:49 Page

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right to counsel of choice, and potentially deny them a fair opportunity to present their case. 

Therefore, given the gravity of the illness faced by the attorney in this case, a continuance would 

allow for their recovery and ensure that the Plaintiff receives the effective and vigorous 

representation that they are entitled to under the law.

Given these precedents, a continuance of the civil case due to PG&E's ongoing 

bankruptcy proceedings is not only reasonable but also aligns with principles of judicial 

economy and fairness to the parties involved.

III. REQUEST FOR CONTINUANCE

 The bankruptcy case is still pending and ongoing. All fire victims have only received .60 

cents to the dollar for their settlement with PG&E thus far and have not been made whole. 

Therefore, Plaintiffs’ respectfully request a continuance for approximately 120 days to allow for 

the Fire Victim Trust to continue to process claims and pay victims. This will allow more time 

for the Trustee to sell the remaining PG&E stock and for Plaintiffs to evaluate their claims as 

well, as they have only been paid 60% of their settlements.

Dated: May 1, 2023 RICHARDS WILLIS PC 

 By: ____ _________

JOHN T. RICHARDS, ESQ.

EVAN WILLIS, ESQ.

Attorneys for Plaintiffs

RICHARDS WILLIS PC

750 B Street, Suite 1760

San Diego, California 92101

T: (619) 237-9800 

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PROOF OF SERVICE

STATE OF CALIFORNIA

SUPERIOR COURT OF CALIFORNIA – COUNTY OF SAN FRANCISCO

Efren Robinson, et al. v. PG&E Corporation, et al.

CASE NO. CGC-19-580073

I am employed in the County of San Diego, State of California. I am over the age of 18 

and am not a party to the within action; my business address is 750 B Street, Suite 1760, San 

Diego, California 92101. 

On May 1, 2023, I served the foregoing documents, described as:

PLAINTIFFS’ CASE MANAGEMENT STATEMENT REGARDING BANKRUPTCY 

STATUS; REQUEST FOR CONTINUANCE

on all interested parties in this action by placing a true and correct copy thereof into the mail to:

_____ (By Mail) As follows:

_____ I placed such envelope with postage thereon prepaid in the United States mail at San 

Diego, California.

_____ I am readily familiar with the firm’s practice of collecting and processing

correspondence for mailing. Under that practice it would be deposited with the U.S. 

Postal Service on that same day with the postage thereon fully prepaid at San Diego, 

California, in the ordinary course of business. I am aware that on motion of the party 

served, service is presumed invalid if postal cancellation or postage meter date is 

more than one day after the date of deposit for mailing in affidavit.

__XX__ (By ELECTRONIC MAIL) I sent such document via electronic mail to:

_____ (STATE) I declare under penalty of perjury under the laws of the State of California 

that the above is true and correct.

_____ (FEDERAL) I declare that I am employed in the office of a member of the bar of this 

court at whose direction the service was made.

Dated: May 1, 2023, San Diego California. ___/s/ Connie Magat __________

Connie Magat

Keith Eggleton, Esq.

Wilson Sonsini Goodrich & Rosati, PC

650 Page Mill Road

Palo Alto, CA 94304

Case: 19-30088 Doc# 13742-1 Filed: 05/17/23 Entered: 05/17/23 15:14:49 Page

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