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KELLER BENVENUTTI KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Dara L. Silveira (#274923) 

(dsilveira@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized Debtors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

NOTICE OF HEARING ON REORGANIZED 

DEBTORS’ ONE HUNDRED TWENTIETH 

OMNIBUS OBJECTION TO CLAIMS (NO 

LIABILITY CLAIMS) 

Response Deadline: 

May 10, 2023, 4:00 p.m. (PT) 

Hearing Information If Timely Response Made: 

Date: May 24, 2023 

Time: 10:00 a.m. (Pacific Time) 

Place: (Tele/Videoconference Appearances Only) 

 United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102

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). 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 1

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PLEASE TAKE NOTICE that on January 29, 2019 (the “Petition Date”), PG&E Corporation 

and Pacific Gas and Electric Company, as debtors and reorganized debtors (the “Debtors,” or as 

reorganized pursuant to the Plan, the “Reorganized Debtors”) in the above-captioned chapter 11 cases 

(the “Chapter 11 Cases”), each filed a voluntary petition for relief under chapter 11 of title 11 of the 

United States Code (the “Bankruptcy Code”) with the United States Bankruptcy Court for the 

Northern District of California (San Francisco Division) (the “Bankruptcy Court”). 

PLEASE TAKE FURTHER NOTICE that the Bankruptcy Court will hold a hearing on May 

24, 2023, at 10:00 a.m. (Pacific Time) (the “Omnibus Hearing”) before the Honorable Dennis 

Montali, United States Bankruptcy Judge. Pursuant to the Bankruptcy Court’s Eighth Amended

General Order No. 38 In re: Coronavirus Disease Public Health Emergency, effective December 1, 

2021 and until otherwise ordered, all hearings shall be conducted by video or teleconference. The 

Courtroom will be closed. All interested parties should consult the Bankruptcy Court’s website at 

www.canb.uscourts.gov for information about court operations during the COVID-19 pandemic. The 

Bankruptcy Court’s website provides information regarding how to arrange a telephonic or video 

appearance. If you have any questions regarding how to appear at a court hearing, you may contact the 

Bankruptcy Court by calling 888-821-7606 or by using the Live Chat feature on the Bankruptcy 

Court’s website.

PLEASE TAKE FURTHER NOTICE that, in addition to any other matters to be heard at the 

Omnibus Hearing, the Bankruptcy Court is scheduled to hear the Reorganized Debtors’ One Hundred 

Twentieth Omnibus Objection to Claims (No Liability Claims), filed on April 14, 2023 

[Dkt. No. 13670] (the “Omnibus Objection”). 

PLEASE TAKE FURTHER NOTICE that any oppositions or responses to the Omnibus 

Objection must be in writing, filed with the Bankruptcy Court, and served on counsel for the 

Reorganized Debtors at the above-referenced address or by email at PGEclaims@kbkllp.com so as to 

be received by no later than 4:00 p.m. (Pacific Time) on May 10, 2023. Any oppositions or responses 

must be filed and served as described in the Order Approving (A) Procedures for Filing Omnibus 

Objections to Claims and (B) the Form and Manner of the Notice of Omnibus Objections, entered on 

July 1, 2020 [Dkt No. 8228] (the “Omnibus Objections Procedures Order”). Any relief requested 

in the Omnibus Objection may be granted without a hearing if no opposition is timely filed and 

served in accordance with the Omnibus Objections Procedures Order. In deciding the Omnibus 

Objection, the Court may consider any other document filed in these Chapter 11 Cases and related 

Adversary Proceedings. 

PLEASE TAKE FURTHER NOTICE that a customized One Hundred Twentieth Omnibus 

Claim Objection Notice in substantially the form attached hereto as Exhibit A has been sent to each of 

the parties to whose Proof(s) of Claim the Reorganized Debtors objected in the Omnibus Objection. 

PLEASE TAKE FURTHER NOTICE that copies of the Omnibus Objection and its 

supporting documents can be viewed and/or obtained: (i) by accessing the Court’s website at 

http://www.canb.uscourts.gov, (ii) by contacting the Office of the Clerk of the Court at 450 Golden 

Gate Avenue, San Francisco, CA 94102, or (iii) from the Debtors’ notice and claims agent, Kroll 

Restructuring Administration LLC (formerly known as Prime Clerk), at 

https://restructuring.ra.kroll.com/pge or by calling (844) 339-4217 (toll free) for U.S.-based parties; or 

+1 (929) 333-8977 for International parties or by e-mail at: pgeinfo@ra.kroll.com. Note that a PACER 

password is needed to access documents on the Bankruptcy Court’s website. 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 2

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Dated: April 14, 2023 KELLER BENVENUTTI KIM LLP 

/s/ Dara L. Silveira 

Dara L. Silveira 

Attorneys for Debtors and Reorganized Debtors 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 3

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Exhibit A 

One Hundred Twentieth Omnibus Claim Objection Notice 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 4

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KELLER BENVENUTTI KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Dara L. Silveira (#274923) 

(dsilveira@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized Debtors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

NOTICE OF THE REORGANIZED 

DEBTORS’ ONE HUNDRED TWENTIETH 

OMNIBUS OBJECTION TO CLAIMS (NO 

LIABILITY CLAIMS) 

Response Deadline: 

May 10, 2023, 4:00 p.m. (PT) 

Hearing Information If Timely Response Made: 

Date: May 24, 2023 

Time: 10:00 a.m. (Pacific Time) 

Place: (Tele/Videoconference Appearances Only) 

 United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

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). 

THE OBJECTION DESCRIBED IN 

THIS NOTICE ASKS THE COURT TO 

DISALLOW AND EXPUNGE YOUR 

CLAIM(S) IDENTIFIED AS 

“OBJECTED-TO” ON THE 

FOLLOWING PAGE OF THIS 

NOTICE. 

 

CLAIMANTS RECEIVING THIS 

NOTICE SHOULD READ THIS 

NOTICE CAREFULLY BECAUSE THE 

OBJECTION MAY AFFECT YOUR 

RIGHT TO RECEIVE A 

DISTRIBUTION ON YOUR CLAIM IN 

THIS CASE. 

IF YOU HAVE QUESTIONS, PLEASE 

CONTACT KROLL RESTRUCTURING 

ADMINISTRATION LLC, AT (844) 339-

4217 

THE LAST PARAGRAPH OF THIS 

NOTICE EXPLAINS HOW YOU CAN 

OBTAIN A COMPLETE COPY OF THE 

OBJECTION, AT NO COST TO YOU. 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 5

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[Claimant Name] 

Objected-To Claim(s) Basis for Objection 

Date Claim # Debtor Classification Amount 

 

On April 14, 2023, PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

reorganized debtors (collectively, the “Debtors,” or as reorganized pursuant to the Plan, the 

“Reorganized Debtors”) in the above-captioned chapter 11 cases (the “Chapter 11 Cases”), filed 

their Reorganized Debtors’ One Hundred Twentieth Omnibus Objection to Claims (No Liability 

Claims) (the “Omnibus Objection”) with the United States Bankruptcy Court for the Northern 

District of California (San Francisco Division) (the “Bankruptcy Court”). A full copy of the 

Omnibus Objection may be obtained at no cost, as provided below.

Any Response (as defined below) to the Omnibus Objection must be filed and 

served upon the Reorganized Debtors’ Counsel by May 10, 2023 (the “Response 

Deadline”); 

Any Response must be accompanied by any declarations or memoranda of law any 

responding party wishes to present in support of its position; 

If there is no timely Response, the Bankruptcy Court may enter an order granting 

the Omnibus Objection to your Proof(s) of Claim by default. 

If you file a timely Response, the Hearing will be held at the date and time shown 

below. If factual disputes are presented by the Objection and the Response, the 

Hearing will proceed as a status conference; factual disputes will not be decided at 

the Hearing, but at a future evidentiary hearing that may be set at the Hearing. 

Issues of a purely legal nature, where facts are not in dispute, may be decided at 

the Hearing. See Bankruptcy Local Rule 3007-1. 

If you file and serve a timely Response, the date, location and time of the Hearing 

are: 

May 24, 2023, at 10:00 a.m. (Pacific Time) 

Courtroom 17, 16th Floor, 450 Golden Gate Ave., San Francisco, CA 

 The Hearing will be held before the Honorable Dennis Montali, United States Bankruptcy 

Judge. Pursuant to the Bankruptcy Court’s Eighth Amended General Order No. 38 In re: Coronavirus 

Disease Public Health Emergency, effective December 1, 2021 and until otherwise ordered, all 

hearings shall be conducted by video or teleconference. The Courtroom will be closed. All 

interested parties should consult the Bankruptcy Court’s website at www.canb.uscourts.gov for 

information about court operations during the COVID-19 pandemic. The Bankruptcy Court’s website 

provides information regarding how to arrange a telephonic or video appearance. If you have any 

questions regarding how to appear at a court hearing, you may contact the Bankruptcy Court by calling 

888-821-7606 or by using the Live Chat feature on the Bankruptcy Court’s website. 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 6

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These Omnibus Claims Objection Procedures DO NOT APPLY to any proofs of claim 

with respect to (a) FIRE VICTIM CLAIMS or (b) SUBROGATION WILDFIRE CLAIMS. 

 BASIS FOR OBJECTION TO YOUR PROOF(S) OF CLAIM: By the Omnibus 

Objection, the Reorganized Debtors seek to disallow and/or expunge one or more of your Proof(s) of 

Claim (as defined therein) listed above as “Objected-To Claim(s)” on the grounds that the designated 

Proof(s) of Claim seek recovery of amounts for which the Debtors are not liable. 

 If you do NOT oppose the disallowance and/or expungement of your Objected-To Proof(s) of 

Claim listed above, then you do NOT need to file a written Response to this Omnibus Objection and 

you do NOT need to appear at the Hearing. If you do nothing, the Objected-To Claim(s) will be 

disallowed and/or expunged. 

FILING AND SERVICE OF RESPONSE: If you DO oppose the disallowance and/or 

expungement of your Objected-To Proof(s) of Claim listed above, then you MUST file a response (a 

“Response”), in writing, with the Bankruptcy Court, and serve it on the counsel for the Reorganized 

Debtors at PGEclaims@kbkllp.com so as to be received by no later than 4:00 p.m. (Pacific Time) on 

May 10, 2023 (the “Response Deadline”): You must file the Response through the Court’s electronic 

case filing (“ECF”) system if you have access to the ECF system; service on the Reorganized Debtors’ 

Counsel will occur automatically upon ECF filing; and no separate service of your Response is 

required. If you do NOT have access to the ECF system, service must be made by electronic mail to 

the Reorganized Debtors’ counsel at PGEclaims@kbkllp.com, and you must arrange for the Response 

to be filed with the Court within two business days thereafter. If you do not have the ability to serve a 

Response electronically, the Response must be served by mail, express or some other means so either 

(a) it is actually received by the Reorganized Debtors’ Counsel by the Response Deadline, or (b) it is 

dispatched not later that the Response Deadline through a postal or commercial express service that 

will make actual delivery not more than two business days after the Response Deadline, and in that 

case the Claimant must inform the Reorganized Debtors’ counsel by email, telephone or facsimile 

before the Response Deadline of the Claimant’s name and phone number, the number of the Omnibus 

Objection, and the fact that a paper Response is being delivered by express. 

CONTENTS OF RESPONSE The Response must, at a minimum, include the following: 

(i) a caption setting forth the name of the Bankruptcy Court, the name of the Reorganized Debtor, the 

case number and title of the Omnibus Objection to which the Response is directed; (ii) your name, the 

assigned number(s) of your Proof(s) of Claim, and an explanation for the amount of the Proof(s) of 

Claim; (iii) a concise statement setting forth the reasons why the Bankruptcy Court should not sustain 

the Omnibus Objection; (iv) a declaration under penalty of perjury of a person with personal 

knowledge of the relevant facts that support the Response; (v) your name, address, telephone number, 

and/or the name, address, and telephone number of your attorney and/or designated representative to 

whom counsel for the Reorganized Debtors should serve a reply to the Response, if any; and (vi) the 

name, address, telephone number, and email address of the party with authority to reconcile, settle, or 

otherwise resolve the Omnibus Objection on your behalf, if any. 

If the Bankruptcy Court does not disallow and/or expunge your Objected-To Proof(s) of Claim 

listed above, then the Reorganized Debtors have the right to object on other grounds to your Proof(s) 

of Claim at a later date. You will receive a separate notice of any such objection. 

TO GET COPIES OF THE COMPLETE OBJECTION: Copies of the complete Omnibus 

Objection and the other pleadings and documents identified herein can be viewed and/or obtained: 

(i) by accessing the Bankruptcy Court’s website at http://www.canb.uscourts.gov [PACER account 

required], (ii) for free by downloading on the Reorganized Debtors’ approved notice and claim agent’s 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 7

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website at https://restructuring.ra.kroll.com/pge, or (iii) by mail, for free, by calling by calling (844) 

339-4217 (toll free) for U.S.-based parties; or +1 (929) 333-8977 for International parties or by e-mail 

at: pgeinfo@ra.kroll.com. 

Dated: April 14, 2023 KELLER BENVENUTTI KIM LLP 

/s/ Dara L. Silveira 

Dara L. Silveira 

Attorneys for Debtors and Reorganized Debtors 

Case: 19-30088 Doc# 13672 Filed: 04/14/23 Entered: 04/14/23 09:26:22 Page 8

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