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Lillian G. Stenfeldt (Cal Bar No. 104929) 

Phillip K. Wang (Cal Bar No. 186712) 

RIMON, P.C. 

One Embarcadero Center, Suite 400 

San Francisco, California 94111 

Telephone: (415) 915-5192 

Facsimile: (415) 683-5472 

Email: lillian.stenfeldt@rimonlaw.com 

 phillip.wang@rimonlaw.com 

 

Attorneys for Retiree Claimants 

Holding Claims Under Certain Supplemental 

Retirement Plans 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

and 

PACIFIC GAS AND ELECTRIC COMPANY 

Debtor(s). 

 Case No. 19-30088 (DM) 

(Lead Case) 

Chapter 11 

(Jointly Administered) 

VERIFIED STATEMENT OF RETIREE 

CLAIMANTS HOLDING CLAIMS 

UNDER CERTAIN SUPPLEMENTAL 

RETIREMENT PLANS PURSUANT TO 

BANKRUPTCY RULE 2019 

☐ 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).

 

Without conceding the applicability of Rule 2019 of the Federal Rules of Bankruptcy 

Procedure (the "Bankruptcy Rules"), the Rimon Retiree Claimants Group (the “Retiree Claimants”), 

Case: 19-30088 Doc# 2765 Filed: 06/26/19 Entered: 06/26/19 11:15:48 Page 1 of

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consisting of individuals, who hold claims against one or both Debtors, by and through its 

undersigned counsel, hereby submit this verified statement (the "Statement"), and in support 

thereof, states what they believe to be true on information and belief, as follows: 

1. The Retiree Claimants are a group of just over 100 retired individuals who were

employed by PG&E Corporation and/or Pacific Gas and Electric Company (collectively, “PG&E”) 

and who now have claims under one or more of the following three non-qualified retirement plans: 

(i) the Supplemental Executive Retirement Plan (the “SERP”), (ii) the Defined Contribution

Executive Supplemental Retirement Plan (the “DC-ESRP”), and/or (iii) the Supplemental

Retirement Savings Plan (the “SRSP”) (each a "Retirement Plan" and collectively, the “Retirement

Plans”). There are also two hybrid retirement plans and for the purposes of this Statement, any

hybrid plans are also included in the definition of the Retirement Plan(s). Two individuals of the

Retiree Claimants each are beneficiaries under one of the hybrid plans. The distributions to the

Retiree Claimants under the Retirement Plans were suspended, and in the case of SRSP,

withdrawals from the Retirement Plans have been denied, as of the filing date of the Debtors’

chapter 11 cases.

2. (While the Retirement Plans incorporate various distribution systems and cover

active/inactive members who are/were PG&E employees, the Retiree Claimants represented by 

Rimon, P.C. (“Rimon”) only include inactive, retired employees and some surviving spouses who 

were designated as retirement beneficiaries under one or more of the Retirement Plans. Many of the 

Retiree Claimants are elderly (having retired on average 12 years ago and in some cases decades 

ago) and either they or their widows/widowers rely on the income from the Retirement Plans. The 

average years of service to PG&E by the Retiree Claimants was 24 years. Many of the individual 

Retiree Claimants devoted their entire working careers to PG&E. The Retirement Plans provided 

funds for the daily support of the retirees and some spouses before the payments were suspended by 

the filing of the Debtors’ chapter 11 cases. Each of the standard three Retirement Plans is more 

fully described below. Both hybrid plans that we are aware of are similar to the SERP plan. 

3. The SERP was established in 1985 to provide a supplemental annuity above PG&E’s

qualified pension plan to eligible employees and the SERP was available to all eligible participants 

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who retired prior to 2005. The 1985 SERP did not specify that it applied only to employees who 

retired prior to January 1, 2005. In 2004, an amendment to the then-existing SERP froze the 

benefits as of the end of 2004 for those who retired prior to January 1, 2005. The successor SERP 

was adopted to supersede the SERP across all PG&E entities. The SERP participants receive 

monthly annuity benefits for the remainder of their lives after ceasing employment with PG&E and 

after reaching a specific age; they could choose to receive the annuity with or without survivor 

benefits that continue a portion of their monthly annuity over the life of their surviving spouse. The 

amount of the SERP monthly annuity payment was determined based on their final years of 

compensation while employed with PG&E, the years of service they provided at PG&E, the age at 

which they were to start receiving benefits, and if the survivors option was chosen. 

4. The DC-ESRP was first established in 2013. Unlike SERP, which was based on a

formula that considered the number of years of service and level of compensation, DC-ESRP was a 

non-qualified defined contribution plan, which allowed the eligible employees to receive certain 

lump sum payments within a specified time after leaving PG&E. The DC-ESRP also provided 

certain benefits to designated surviving beneficiaries if the plan participant died before the DCESRP payments were made. The DC-ESRP is still in effect with regard to the current eligible 

PG&E employees, as well as the Retiree Claimants qualified under the plan. 

5. The SRSP was a deferred compensation plan established at PG&E in 2000. The

SRSP funds earned were distributed as one or more lump sum payment(s) made within specified 

timeframes. As with the other Retirement Plans, the SRSP funds could be allocated to designated 

beneficiaries if the plan participant passed away before receiving the benefit. The SRSP was nearly 

entirely funded by eligible employee contributions. 

6. Each of the Retiree Claimants listed in Exhibit “A” has individually retained Rimon

to represent him or her only in connection with their individual claims under their applicable 

Retirement Plans in the chapter 11 cases of the Debtors. The first retention was in or about 

February of 2019 and new clients continue to engage Rimon. As of the date of this Statement, 

Rimon does not represent or purport to represent any other entities in connection with the Debtors' 

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chapter 11 cases, except as disclosed in this Statement.1 

7. Rimon does not represent or purport to represent the Retiree Claimants as a 

“committee,” as that term is defined in the Bankruptcy Code and the Bankruptcy Rules, and does 

not undertake to represent the interests of, and are not fiduciaries for, any creditor, party in interest, 

or other entity that has not signed an engagement agreement with Rimon. In addition, the Retiree 

Claimants do not represent or purport to represent any other persons or entities in connection with 

the Debtors' chapter 11 cases. 

8. The Retiree Claimants either hold claims or manage accounts that hold claims 

pursuant to their individual Retirement Plans against the Debtors' estates. The total amounts of the 

Retiree Claimants’ claims are not ascertainable at this point. Further, the majority of claim amounts 

depend on a formula that is based on the retired employee’s life span, as well as the elections that 

he/she had made under the provisions of each applicable Retirement Plan. The Retiree Claimants 

may also individually hold some shares of stock in one or both debtors; Rimon currently does not 

have that information. The names of the Retiree Claimants as of June 26, 2019, are set forth in 

Exhibit A. More specific information about the individual claims of the Retiree Claimants, 

including the addresses and claim amount information (to the extent available), will be set forth by 

the Retiree Claimants in their individual Proof of Claim forms filed pursuant to this Court’s claim 

procedures. 

9. The information provided in this statement regarding the description of the 

Retirement Plans is based on information provided by certain retiree claimants and is based on their 

best information and belief and is intended only to comply with Bankruptcy Rule 2019 and is not 

intended for any other purpose. 

10. The information set forth herein and in Exhibit A is intended only to comply with 

Bankruptcy Rule 2019 (without conceding its applicability to the Retiree Claimants represented by 

Rimon) and is not intended for any other purpose. Rimon does not make any representation 

 1

 Rimon also represents creditors Pivot Interiors, Inc., Trayer Engineering Company and 

Cedar Glade Capital, LLC, which are other creditors in these cases unrelated to Retiree Claimants. 

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regarding the validity, amount, allowance, or priority of such claims and reserves all rights with 

respect thereto. 

11. Nothing contained in this Statement (or Exhibit A) should be construed as a 

limitation upon, or waiver of, any rights of any Retiree Claimant to assert, file and/or amend his or 

her claim in accordance with applicable law and any orders entered in these chapter 11 cases. 

12. Rimon reserves the right to amend and/or supplement this Statement in accordance 

with the requirements set forth in Bankruptcy Rule 2019. 

DATED: June 26, 2019 

 RIMON, P.C. 

 By: 

 Lillian G. Stenfeldt 

Attorneys for Retiree Claimants Holding 

Claims Under Certain Supplemental 

Retirement Plans

Case: 19-30088 Doc# 2765 Filed: 06/26/19 Entered: 06/26/19 11:15:48 Page 5 of

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EXHIBIT A 

LIST OF RETIREE CLAIMANTS 

1. Agerter, Linda

2. Alexander, Beverly

3. Anderson, Barry David

4. Angalakutai, Mallikarjun

5. Austin, Karen

6. Baker, Chris

7. Bar-Lev, Joshua

8. Basgal, Ophelia

9. Becker, James Richard

10. Bedwell, Ed

11. Bhattacharya, Shankar (Shan)

12. Boren, Thomas Garner

13. Bottorff, Thomas Edward

14. Brennan, Jean Frances

15. Burt, Helen

16. Butler, Jeff

17. Callaway III, Lee

18. Campbell, Walter Lee

19. Carter, Glen E.

20. Clare, David

21. Clark, John

22. Clifton, George F. Jr.

23. Conway, John T.

24. Corippo, Peter

25. Crossley, Shawn

26. Cunningham, Russell H.

27. Dasso, Kevin John

28. Draeger, Anita Loree

29. Earley, Anthony F. Jr.

30. Everett, Leslie Hart

31. Fitzpatrick, Tim

32. Flynn, Roger James

33. Fong, Katheryn M.

34. Fujimoto, Warren H.

35. Garcia, Ronald Craig

36. Gibson, Daniel Eugene

37. Golden, Patrick G.

38. Golub, Howard V.

39. Hapner, DeAnn (go by Dede)

40. Harper, William H. III

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41. Harris, Robert L.

42. Hartman, Sanford L.

43. Harvey, Jeanne Walker

44. Harvey, Kent Michael

45. Hayes, Kathleen

46. Hayes, William D.

47. Higa, Patricia

48. Hinds, Jacqueline Rene

49. Howard, Robert T.

50. Howe, James

51. Jackson, Russell M. (Russ)

52. Janis, Megan Smith

53. Jenkins-Stark, John

54. Jeung, Garrett (Gary)

55. Johnson, Manly Kirk

56. Johnson, Mark S.

57. Jonas, Junona A.

58. Katz, Michael

59. Keenan, John S.

60. Kennady, Donald L.

61. Keyser, John Charles

62. King, Thomas B.

63. Klimczak, Rickard L.

64. Kline, Steven L.

65. Knapp, Kevin

66. LaRue, R Jack Jr.

67. Lee, Evelyn Ching

68. Lipscomb, Robert Cyrus

69. Lipson, Merek Evan

70. Livingston, Randal S

71. Long, Thomas C.

72. Macias, Edward (Jim) James

73. Martinez, Placido J.

74. Mayekawa, Douglas W.

75. Meko, Michael D.

76. Moller, David W.

77. Morrow, William Thomas

78. Oatley, David Herbert

79. Peters , Roger James

80. Pope, James Henry

81. Pruett, Greg S.

82. Randolph, James Kay

83. Rayburn, Stephen

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84. Regan, Frank

85. Risser, Roland Jonathan

86. Rueger, Gregory Michael

87. Salas, Edward A.

88. Shiffer, Esther

89. Shiffer, Margaret

90. Skinner, Stanley T.

91. Smith, Gordon Ray

92. Stanley, Brent

93. Stavropoulos, Nickolas

94. Steel, Brian

95. Togneri, Gabe

96. Torres, Albert Frank

97. Townsend, Martha J.

98. Wallace, William Henry

99. Whelan, Steven

100.Williams, Joseph T.

101.Willrich, Mason

102.Womack, Lawrence

103.Worthington, Bruce Robert

104.Yura, Jane K.

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CERTIFICATE OF SERVICE 

PG&E Corporation and Pacific Gas and Electric Company 

U.S.B.C., Northern District of California, Case No. 19-30088 (DM) 

I am employed in the City of Menlo Park, County of San Mateo, State of California. I am 

over the age of 18 and not a party to the within action; my business address is: Rimon, P.C. 800 

Oak Grove Avenue, Suite 250, Menlo Park, CA 94025. 

On June 26, 2019, I electronically filed the following document: 

 VERIFIED STATEMENT OF RETIREE CLAIMANTS HOLDING 

UNSECURED CLAIMS UNDER CERTAIN SUPPLEMENTAL 

RETIREMENT PLANS PURSUANT TO BANKRUPTCY RULE 2019 

by electronically filing it with the Court Clerk of the Court using the CM/ECF system which 

transmits a notification of electronic filing (NEF) of such filing to email addresses on file with the 

Court’s ECF System. 

 Executed on June 26, 2019 at Menlo Park, California. 

 I declare under penalty of perjury under the laws of the United States of America that the 

above is true and correct. 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. 

 _______ 

 Ashley N. Frisch 

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