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William B. Abrams

end2endconsulting@gmail.com

2041 Stagecoach Rd.

Santa Rosa, CA, 95404

Tel: 707 397 5727

Pro Se Fire Victim Claimant and Party to related proceedings before the California Public Utilities 

Commission and the California Office of Energy Infrastructure Safety

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC GAS AND ELECTRIC

COMPANY,

Debtors.

* All papers shall be filed in the lead case, 

No. 19-30088 (DM) 

Bankr. Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administrated)

WILLIAM B. ABRAMS MOTION 

FOR RECONSIDERATION AND 

RELIEF FROM THE ORDER 

REGARDING HEARING ON MAY 24, 

2023 [Dkt. No. 13736] 

Relates To: [Dkt. 13685, 13714, 13736]

Hearing Date: May 24, 2023

Time: 10:00am (Pacific Time)

Case: 19-30088 Doc# 13755 Filed: 05/19/23 Entered: 05/19/23 10:25:22 Page 1

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PRELIMINARY STATEMENT AND BACKGROUND 

William B. Abrams (“Abrams”) as a PG&E fire victim claimant and Northern California 

resident, respectfully submits this “William B. Abrams Motion for Reconsideration and Relief from 

the Order Regarding Hearing on May 24, 2023” (the “Motion for Reconsideration”) and provides 

the following background for the Courts’ consideration: 

1) On April 26, 2023 The Debtors filed the “Reorganized Debtors’ Omnibus Motion to 

Enforce the Discharge and Injunction Provisions of Plan and Confirmation Order Against Certain 

Pending Actions” (the “Motion”) [Dkt. 13685]. Within this Motion the Debtors stated their intent to 

enforce the channeling injunction on “all holders of claims” indicating an objection deadline of May 

10, 2023 with a hearing on the Motion scheduled for May 24, 2023. On May 10, 2024, and in 

keeping with this schedule and the procedures of the Court, Abrams filed the “William B. Abrams 

Objection to the Reorganized Debtors’ Omnibus Motion to Enforce the Discharge and Injunction 

Provisions of Plan and Confirmation Order Against Certain Pending Actions” (the “Abrams 

Objection”) [Dkt. 13714]. Within this Objection Abrams presented arguments and outlined the 

following facts which he had planned to further evidence at hearing: 

• “the Debtors and other core parties NEVER provided notice or identified a process 

or procedure for victims to timely object to the waiver of their legal rights and 

remedies.” 

• “nowhere within these orders or any other Court orders did it identify how a fire 

victim could retain access to judicial review or object to an unknown waiver of their 

rights to further legal actions like those represented with the Motion.” 

• “if there is any timely notice anywhere and in any form that was provided to 

individual victim claimants informing them of the process or procedure to retain their 

rights to appeal or any Court order indicating when or how to retain their rights to 

judicial review more broadly, the Debtors or any other party should produce it.” 

 

2) On May 10, 2023 and following the Abrams Objection, certain plaintiffs filed the 

“Objections of Plaintiffs and Claimants Liza Sims, Individually and on Behalf of Thomas and 

Jaydene Gardner Pursuant to PG&E Motion to Obtain Coverage of Channeling Injunction to Defeat 

Plaintiffs Various Claims for Punitive Damages Pursuant to LR 9014-1” (the “Sims and Gardner 

Objection”) [Dkt. 13710]. Within this objection it was stated among other assertions that these 

plaintiffs “refused to participate in any fire-victim Plaintiff’s cartel that purported to ‘vote’ for 

PG&E’s plan of reorganization.” 

Case: 19-30088 Doc# 13755 Filed: 05/19/23 Entered: 05/19/23 10:25:22 Page 2

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3) On May 10, 2023 and following the Sims and Gardner Objection, certain plaintiffs 

filed the “Efron Robinson, Et Al.’s Objection to the Reorganized Debtors’ Omnibus Motion to 

Enforce the Discharge and Injunction Provisions of Plan and Confirmation Order Against Certain 

Pending Actions” (the “Robinson Objection”) [Dkt. 13721]. Within this objection, the plaintiffs 

correctly reiterated Abrams’ arguments by stating “The Debtors are well aware that these plaintiffs 

along with the vast majority of individual fire victim claimants were never informed of any Court 

process or schedule where they could retain their rights to an appeal. The post-facto removal of fire 

victim rights that was pursued by the Debtors in close collaboration and consultation with certain 

victim attorneys does not in any way satisfy Federal Rules of Bankruptcy Procedure 9019 or Rule 

2002... Here, within this Case there was (1) NO notice to victims regarding their “opportunity to 

object” to the waiver of their legal rights (2) NO information provided to victims that would allow 

them to make an “informed decision” about waiving judicial review and (3) NO information about 

how they could retain their “rights to appeal.” Indeed, there was no notice provided within the 

context of this case that would provide a schedule, a process or a procedure for upholding and/or 

retaining their rights to appeal or to pursue the types of legal action the Debtors’ now seem intent on 

directing to the FVT through this Motion. Given these facts, it is not surprising that these plaintiffs 

and many others filed actions against the Debtors. They were simply never noticed regarding an 

opportunity to retain these legal rights prior to bankruptcy plan confirmation and the execution of 

the channeling injunction.”

4) On May 16, 2023 and following these three timely filed objections, the Court issued 

the “Order Regarding Hearing on May 24, 2023.” (the “Order”). Within this Order, the Court set a 

schedule and stated that “the court will hear first from each of the named respondents” and then 

“followed by the Reorganized Debtors” as the moving party. After defining a process where the 

movant would present after the objecting parties, the Order went further to clarify that “the court has 

read and considered the filing (Dkts. 13714 and 13715) by Mr. William B. Abrams in response to the 

Motion. The court concludes that Mr. Abrams lacks standing, and therefore, he will not be 

permitted to argue” (emphasis added). 

Case: 19-30088 Doc# 13755 Filed: 05/19/23 Entered: 05/19/23 10:25:22 Page 3

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ARGUMENT 

 On December 4, 1770 John Adams famously stated “facts are stubborn things; and whatever 

may be our wishes, our inclinations, or the dictates of our passions, they cannot alter the state of 

facts or evidence.” The Court should consider that Adams characterized “facts” in this way because 

he understood that the facts and arguments put forward by ordinary citizens within the courtroom 

were critical to ensure justice. Abrams, not unlike the citizens that presented to the court in 1770, is 

an ordinary person trying to shed light and make arguments within this case to ensure the rights of 

victims are not further trampled upon by Pacific Gas and Electric Company or undermined by certain 

parties that would prefer to game the bankruptcy processes and procedures to advance their own 

financial interests at the expense victims’ due process rights. Abrams respectfully argues within this 

Motion for Reconsideration that neither Chief Justice Benjamin Lynde, Jr. in 1770 nor the Honorable 

Dennis Montali in 2023, regardless of their profound wisdom, would be able to “bend the arc of the 

moral universe towards justice”1 if they excluded citizen voices within the courtroom that would bear 

witness and present facts relevant to matters before the court. Here, Abrams has facts, evidence and 

arguments that are materially and directly relevant to the Debtors’ Motion and respectfully asks the 

Court to reconsider and allow Abrams to present these facts at the hearing scheduled for May 24, 

2023. 

In response to Abrams prior filed papers, the Court has rightly highlighted how US 

Bankruptcy laws and court procedures are different from other courts like the district courts where 

the named plaintiffs filed lawsuits. Despite these differences, I ask the Court to consider if the 

bankruptcy court is so different in terms of an orientation towards justice as to exclude those 

individuals that timely file objections and are able to share first-hand accounts of the facts within this 

case? Are the rights of pro se litigants like Abrams valued by the Court when the proper procedures 

and laws are followed? If there is any doubt that Abrams has the case background and knowledge of 

the facts to contribute to the evidentiary record relative to this Motion, I would remind the Court of 

the last hearing where Abrams was also prevented from speaking in support of his own motion. 

Within the hearing On March 24, 2023, the Court stated the following when preventing Abrams from 

speaking in support of his own motion: 

 

1

 Dr. Martin Luther King Jr. “Remaining Awake Through a Great Revolution” Speech given at the National Cathedral, 

March 31, 1968 

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“I’m not critical of Mr. Abrams. I’m simply saying that he brings the history, tremendous 

familiarity with that he probably knows more about this case than any of us in terms of the 

events.”2

Respectfully, Abrams requests that the Court consider this statement within the context of the 

Debtors’ Motion and the related objections filed in response. Among the three parties that timely 

filed objections, Abrams is the only objector that has actively engaged at the significant turning 

points within the case that are central to the Debtors’ Motion. The Court is aware that Abrams 

actively engaged in the disclosure statement hearings, confirmation hearings and within other 

hearings where there were material misrepresentations by the Debtors relative to their Motion and the 

enforcement of the channeling injunction. These experiences allow Abrams to provide first-hand 

accounts and refute the misguided and unjust arguments made by the Debtors. These facts are not to 

take away from the rights of the other victims and plaintiffs’ counsel that notably and effectively 

objected to the Debtors’ Motion but to add context and provide a stronger basis in support of their 

rights and remedies. 

Abrams, if permitted to do so by the Court, is able to present evidence that certain parties, 

unlawfully and without providing victims with sufficient due process, designed dead-end unnoticed 

and unidentified processes to strategically prevent “judicial review.” These efforts to avoid the 

equitable application of judicial review directly led to the dead-end channeling injunction that 

the Debtors now enforce to prevent the plaintiffs identified within the Debtors’ Motion and 

other victims from seeking punitive damages. These strategic efforts to game bankruptcy 

processes and to trample upon the due process rights of victims are inextricably linked. When 

victims are unable to seek compensatory damages for their injuries, they naturally seek the types of 

punitive damages sought by the named plaintiffs within the Motion. Of course, the Debtors would 

like to pretend that the lack of due process and lack of notice relative to judicial review is 

unrelated to the types of litigation unlawfully blocked by the channeling injunction. However, 

this is simply false. 

 In support of this Motion for Reconsideration, Abrams requests that the Court consider the 

following additional facts that were not considered with the prior Order that excluded Abrams from 

participating in the hearing: 

 

2

 See Hearing Transcript [Dkt. 13641, 13645], US Bankruptcy Court, Case#19-30088(DM), March 24, 2023 

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1. Trustee and TOC Request for Support – Given that the Debtors have argued within their 

Motion that the damages asserted by the plaintiffs should be redirected and asserted against 

the Fire Victim Trust, Abrams sent an email to Trustee counsel imploring both the Trustee 

and the Trust Oversight Committee to file an objection to the Debtors’ Motion. This May 10, 

2023, correspondence from Abrams stated the following: 

“I am hoping that the Trustee and members of the TOC will weigh-in and similarly 

file an objection to PG&E’s latest efforts to enforce the channeling injunction and 

direct these actions against the Fire Victim Trust. I am very concerned that these 

latest moves by PG&E will further dilute the Trust’s assets and limit the Trustee’s 

ability to get victims paid in full. Additionally, I am very concerned that PG&E is 

leveraging the channeling injunction to strip victims of their legal rights. Through my 

objection, I focus on the lack of due process and lack of notice relative to the 

perceived waiver of judicial review, right to an appeal and to seek remedies outside 

the confines of the bankruptcy court. No other parties would allow this type of 

circumvention of their legal rights and it would be horrible precedent to set that 

victims legal rights can be strategically trampled upon without sufficient notice 

regarding the process and procedures to retain their rights. I hope you agree that 

this maneuver to seemingly provide "retroactive due process" by informing victims 

after-the-fact that they missed an opportunity to “object to trust documents” as a 

pathway and retain their rights should not be tolerated. Assuming that this “objection 

to trust documents” was the standard for retaining judicial review, there was no 

notice or court order anywhere that provides victims with this information to preserve 

their rights. This is what the Trustee and members of the TOC consider “due 

process?” (emphasis added). 

This email was sent with the recognition that the Trustee and members of the Trust Oversight 

Committee had the legal expertise and the responsibility to file an objection to the Debtors’ 

Motion but inexplicably remained silent. Given that these parties which are paid quite 

substantially to represent the interests of victims continued to sit on the sidelines, Abrams was 

compelled to file an objection and this Motion for Reconsideration. The Court recognized the 

lack of notice and lack of adequate victim representation in the hearing on May 15, 2020 by 

stating “Is there anything in the plan or the disclosure statement that tells the thousands and 

thousands of people that were solicited, by the way, it doesn’t matter what you do, we’re 

going to stick this down your throat under 9019(b)?” The TCC answer to that question was 

inadequate in 2020 and it is inadequate now given that the attorneys representing the 

“thousands and thousands of people” are bound by similar unjust provisions that keep them 

from adequately defending the rights of the victims. 

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2. Debtors’ Continued Pattern of Material Misstatements, Omissions and Nondisclosures – 

On May 2, 2023 and just days after the Debtors filed their Motion to Enforce the Channeling 

Injunction, the California Public Utilities Commission released the Second “PG&E 

Independent Safety Monitor Status Update Report... In conjunction with California Public 

Utilities Commission (CPUC) Decision 20-05-053, the Bankruptcy Plan of Reorganization 

for Pacific Gas and Electric Company (PG&E) and the findings included in the Kirkland & 

Ellis LLP Federal Monitorship Final Report dated November 19, 2021 (Federal Monitorship 

Report).” Within this report it stated that “In meetings attended by the ISM, concern was 

expressed by PG&E leadership that the magnitude of capital needed for asset replacement 

programs was far in excess of the amount of capital believed to be available... Due to the 

combination of reduced spending on reliability related capital programs in order to shift 

spending more towards wildfire mitigation programs (as was noted earlier in this report) and 

the introduction of EPSS, PG&E’s average unplanned distribution SAIDI has more than 

doubled over the last five years, placing PG&E in the fourth quartile for reliability in 

comparison to other U.S. based electric utilities.” These and other findings of fact by the 

Independent Safety Monitor once again demonstrate a continued pattern of misrepresentations 

by the Debtors within and outside this case. While the findings of the monitor related to 

PG&E’s misrepresented safety performance, misrepresented capital expenditures and 

misrepresented focus on reliability may not be directly relevant to this Motion, the pattern of 

falsehoods and misrepresentations by the Debtors is absolutely relevant to the degree to 

which statements by the Debtor can be trusted by the Court. Specifically, the Court 

should have the reasonable expectation that the Debtors’ pattern of false statements will 

continue if left unchecked. Abrams through his objection and this Motion for 

Reconsideration is requesting that the Court allow him to provide arguments that refute the 

Debtors’ statements to date and those that will undoubtedly arise again during the May 24, 

2023 hearing on the Debtors’ Motion. 

/// 

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CONCLUSION 

 Abrams reassures the Court that he will continue to adhere to courtroom decorum and to 

follow the proper processes and procedures to the best of his ability as a pro se claimant and victim. 

That said, there are inconvenient facts that Abrams intends to bring to light at the May 24, 2023 

hearing if permitted to do so by the Court. These facts are material and central to the Court’s 

reasonable consideration of the Motion and the Debtors’ stated intent to enforce the channeling 

injunction on “all holders of claims” including Abrams. Given the Debtors’ position, Abrams timely 

filed objection and the additional facts provided herein, Abrams respectfully requests that the Court 

approve this Motion for Reconsideration and allow Abrams to present his arguments at the hearing on 

May 24, 2023. 

Dated: May 19, 2023 

Respectfully submitted, 

William B. Abrams 

Pro Se Claimant 

Case: 19-30088 Doc# 13755 Filed: 05/19/23 Entered: 05/19/23 10:25:22 Page 8

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