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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

Sander L. Esserman (Admitted Pro Hac Vice)

Cliff I. Taylor (Admitted Pro Hac Vice)

STUTZMAN, BROMBERG, ESSERMAN & PLIFKA, P.C. 

2323 Bryan Street, Suite 2200 

Dallas, TX 75201-2689 

Telephone: 214-969-4900 

Email: esserman@sbep-law.com

Scott Summy 

John Fiske (CSBN 249256) 

BARON & BUDD, P.C. 

3102 Oak Lawn Avenue #1100 

Dallas, TX 75219 

Telephone: 214-521-3605 

Email: ssummy@baronbudd.com 

Christopher H. Hart (CSBN 184117) 

Kimberly S. Fineman (CSBN 184433) 

NUTI HART LLP 

411 30TH Street, Suite 408 

Oakland, CA 94609-3311 

Telephone: 510-506-7152 

Email: kfineman@nutihart.com 

Attorneys for Public Entities Impacted by the Wildfires 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

In re 

PG&E CORPORATION, 

and 

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. 

 Case No. 19-30088-DM 

Chapter 11 

Lead Case, Jointly Administered 

LIMITED OBJECTION OF PUBLIC 

ENTITIES IMPACTED BY THE 

WILDFIRES TO MOTION OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS PURSUANT TO 11 U.S.C. §§ 

105(a), 501 AND FED. R. BANKR. P. 3001(a), 

3003(c), 5005 AND 9007 FOR ENTRY OF AN 

ORDER (I) ESTABLISHING A BAR DATE 

FOR FILING FIRE CLAIMS, (II) 

APPROVING THE FORM AND 

PROCEDURES FOR NOTICE OF THE BAR 

DATE FOR FIRE CLAIMS, AND (III) 

APPROVING SUPPLEMENTAL 

PROCEDURES FOR NOTICE OF THE BAR 

DATE TO FIRE CLAIMANTS 

Date: June 26, 2019 

Time: 9:30 a.m. (prevailing Pacific time) 

Place: 450 Golden Gate Avenue, Ctrm 17 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

Case: 19-30088 Doc# 2654 Filed: 06/19/19 Entered: 06/19/19 15:49:12 Page 1 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

2 

The Public Entities Impacted by the Wildfires (the “Public Entities”)1 hereby submit this 

limited objection to the Motion of the Official Committee of Tort Claimants Pursuant to 11 

U.S.C. §§ 105(a), 501 and Fed. R. Bankr. P. 3001(a), 3003(c), 5005 and 9007 for Entry of an 

Order (I) Establishing a Bar Date for Filing Fire Claims, (II) Approving the Form and 

Procedures for Notice of the Bar Date for Fire Claims, and (III) Approving Supplemental 

Procedures for Notice of the Bar Date to Fire Claimants [Docket No. 2297] (the “TCC’s Bar 

Date Motion”). In support hereof, the Public Entities, by and through their undersigned counsel, 

respectfully represent as follows: 

BACKGROUND 

 On January 29, 2019, the Debtors commenced voluntary cases under chapter 11 of the 

Bankruptcy Code. 

 On May 1, 2019, the Debtors file their Motion of Debtors Pursuant to 11 U.S.C. §§ 

502(b)(9) and 105(a), Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 

for Order (I) Establishing Deadline for Filing Proofs of Claim, (II) Establishing the Form and 

Manner of Notice Thereof, and (III) Approving Procedures for Providing Notice of Bar Date and 

Other Information to All Creditors and Potential Creditors [Docket No. 1784] (the “Debtors’ 

Bar Date Motion”). In the Debtors’ Bar Date Motion, the Debtors request that this Court enter 

an order, inter alia, (a) establishing the last day to file proofs of claim in these bankruptcy cases 

for Wildfire Claims as October 21, 20192

 (the “Debtors’ Proposed Wildfire Bar Date”), and (b) 

approving the Debtors’ proposed proof of claim forms. The Debtors proposed a discrete proof 

of claim form for Wildfire Claims. 

 1

 The Public Entities consist of the following California public entities: (a) Calaveras County Water 

District, (b) Napa County, (c) City of Napa, (d) Mendocino County, (e) Lake County, (f) City of 

Clearlake, (g) Nevada County, (h) Yuba County, (i) City of Santa Rosa, (j) Sonoma County, (k) Sonoma 

County Agricultural Preservation and Open Space District, (l) Sonoma County Community Development 

Commission, (m) Sonoma County Water Agency, (n) Sonoma County Sanitation District, (o) Town of 

Paradise, and (p) Butte County.

2

 The Debtors’ Bar Date Motion initially requested September 16, 2019 as the bar date. This 

requested date was updated to October 21, 2019 by the Debtors’ Corrected Omnibus (I) Reply 

in Support of the Debtors’ Bar Date Motion, and (II) Objection to the TCC’s Bar Date Motion 

[Docket No. 2646] filed June 19, 2019. 

Case: 19-30088 Doc# 2654 Filed: 06/19/19 Entered: 06/19/19 15:49:12 Page 2 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

3 

 On May 3, 2019, the Official Committee of Tort Claimants (the “TCC”) filed its Motion 

of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. §§ 105(a) and 501 and Fed. 

R. Bankr. P. 3001(a) for Entry of an Order Approving Proposed Model Proof of Claim Form for 

Fire Claims and Related Procedures (the “Tort Committee POC Motion”), seeking approval of 

its own proposed model proof of claim form for Wildfire Claims. [See Docket Nos. 1824 and 

1825]. 

 On May 28, 2019, the Public Entities filed their Objection of Public Entities Impacted by 

the Wildfires to Motion of Debtors Pursuant to 11 U.S.C. §§ 502(b)(9) and 105(a), Fed. R. Bankr. 

P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 for Order (I) Establishing Deadline for 

Filing Proofs of Claim, (II) Establishing the Form and Manner of Notice Thereof, and (III) 

Approving Procedures for Providing Notice of Bar Date and Other Information to All Creditors 

and Potential Creditors And Statement In Support of Motion of the Official Committee of Tort 

Claimants Pursuant to 11 U.S.C. §§ 105(a) and 501 and Fed. R. Bankr. P. 3001(a) for Entry of 

an Order Approving Proposed Model Proof of Claim Form for Fire Claims and Related 

Procedures [Docket No. 2239] (“PE’s Objection to Debtors’ POC and Statement in Support of 

TCC POC”), wherein the Public Entities objected to the Debtors’ proposed proof of claim form 

for Wildfire Victims and supported the TCC’s proposed proof of claim form for Wildfire 

Victims. 

 On May 31, 2019, the TCC filed the TCC Bar Date Motion and accompanying 

Memorandum of points and Authorities in Support of Motion of the Official Committee of Tort 

Claimants for Entry of an Order (I) Establishing a Bar Date for Filing Fire Claims, (II) Approving 

the Form and Procedures for Notice of the Bar Date for Fire Claims, and (III) Approving 

Supplemental Procedures for Notice of the Bar Date to Fire Claimants [Docket No. 2297], 

seeking, inter alia, an order establishing the last day to file proofs of claim for Wildfire Claims 

in these bankruptcy cases as January 31, 2020 (the “TCC Proposed Wildfire Bar Date”). 

Case: 19-30088 Doc# 2654 Filed: 06/19/19 Entered: 06/19/19 15:49:12 Page 3 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

4 

LIMITED OBJECTION TO TCC BAR DATE MOTION AND STATEMENT IN 

SUPPORT OF DEBTORS’ PROPOSED WILDFIRE BAR DATE

 The Public Entities continue to support an order by this Court approving the TCC’s 

proposed model proof of claim form for Wildfire Claims as proposed in the Tort Committee 

POC Motion. The Public Entities file this objection solely with respect to the TCC Proposed 

Wildfire Bar Date of January 31, 2020, which the Public Entities assert could cause undue delay 

in these bankruptcy cases and could delay resolution of Wildfire Claims to the detriment of the 

Public Entities and the other Wildfire Claimants. The Public Entities believe that the Debtors’ 

Proposed Wildfire Bar Date of October 21, 2019 is reasonable under the circumstances and 

support a October 21, 2019 bar date for Wildfire Claims or such other bar date as this Court may 

determine to be reasonable and encourage prompt confirmation of a plan of reorganization in 

these bankruptcy cases. In the event this Court enters an order approving the model proof of 

claim form for Wildfire Claims as proposed in the Tort Committee POC Motion—which this 

Court should enter—an October 21, 2019 bar date for Wildfire Claims should provide sufficient 

time for Wildfire Claimants to submit their claims to this Court. 

CONCLUSION 

WHEREFORE, the Public Entities respectfully request that (a) their limited objection 

be granted, (b) the TCC Proposed Wildfire Bar Date of January 31, 2020 not be approved by 

this Court, (c) the Debtors’ Proposed Wildfire Bar Date of October 21, 2019 be approved by 

this Court or this Court otherwise approve such other bar date as it may determine to be 

reasonable and encourage prompt confirmation of a plan of reorganization in these bankruptcy 

cases, and (d) the Public Entities be granted such other and further relief as the Court deems 

just and proper. 

Dated: June 19, 2019 STUTZMAN, BROMBERG, ESSERMAN & 

PLIFKA, P.C. 

 By: /s/ Sander L. Esserman 

 Sander L. Esserman 

Attorneys for Public Entities Impacted by the Wildfires 

Case: 19-30088 Doc# 2654 Filed: 06/19/19 Entered: 06/19/19 15:49:12 Page 4 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

5 

Dated: June 19, 2019 BARON & BUDD, P.C. 

 By: /s/ Scott Summy

 Scott Summy

Attorneys for Public Entities Impacted by the Wildfires 

Dated: June 19, 2019 NUTI HART LLP 

 By: /s/ Kimberly S. Fineman 

 Kimberly S. Fineman 

Attorneys for Public Entities Impacted by the Wildfires 

 

Case: 19-30088 Doc# 2654 Filed: 06/19/19 Entered: 06/19/19 15:49:12 Page 5 of

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