GROSS 

&

KLEIN LLP 

THE 

EMBARCADERO

PIER 9, SUITE 100 

SAN FRANCISCO, CA 94111

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NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE; Case Nos. 19-30088, 19-30089

1

STUART G. GROSS (#251019) 

sgross@grosskleinlaw.com 

GROSS & KLEIN LLP 

The Embarcadero 

Pier 9, Suite 100 

San Francisco, CA 94111 

t (415) 671-4628 

f (415) 480-6688 

Attorneys for Dan Clarke

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, et al. 

 Debtors. 

In re: 

PACIFIC GAS & ELECTRIC COMPANY, et al. 

 Debtors.

Case No. 19-30088

Chapter 11 

Case No. 19-30089 

Chapter 11 

NOTICE OF APPEARANCE AND 

REQUEST FOR SPECIAL NOTICE 

BY DAN CLARKE

 

Case: 19-30088 Doc# 427 Filed: 02/13/19 Entered: 02/13/19 14:22:33 Page 1 of 3
GROSS 

&

KLEIN LLP 

THE 

EMBARCADERO

PIER 9, SUITE 100 

SAN FRANCISCO, CA 94111

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NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE; Case Nos. 19-30088, 19-30089

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PLEASE TAKE NOTICE that Dan Clarke (“Clarke”) hereby requests, pursuant to Rules 

2002, 3017, 9007, and 9010 of the Federal Rules of Bankruptcy Procedure, or pursuant to any 

other applicable rule or statute, that notice of all matters which may come before the Court be 

given to Clarke’s counsel of record: 

 GROSS & KLEIN LLP 

 Stuart G. Gross 

The Embarcadero 

Pier 9, Suite 100 

San Francisco, CA 94111 

Telephone: (415) 671-4628 

Facsimile: (415) 480-6688 

E-mail: sgross@grosskleinlaw.com 

The foregoing request includes, without limitation all notices, papers, and disclosure 

statements referred to in Rules 2002, 3017, and 9007 of the Federal Rules of Bankruptcy 

Procedure, and also includes notice of any orders, applications, complaints, demands, hearings, 

motions, petitions, pleadings or requests, and any other documents brought before the Court in 

this case, as well as anything concerning which Clarke may be heard under Section 1109 of the 

Bankruptcy Code, whether formal or informal, whether written or oral, and whether transmitted 

or conveyed by electronic mail, mail, hand delivery, telephone, telegraph, facsimile, or otherwise. 

This notice of appearance and request for special notice, as well as any subsequent 

appearance, pleading, claim or suit, are without prejudice to and do not waive and expressly 

reserves: (1) Clarke’s rights, remedies, claims, actions, defenses, setoffs, or recoupments, in law 

or in equity, against the above-captioned debtor and any other person either in this case or in any 

other action; (2) any objection which may be made to the jurisdiction of the Court; (3) Clarke’s 

right to have final orders in non-core matters entered only after de novo review by a district 

judge; (4) Clarke’s right to trial by jury in any proceedings or trial, in any state of federal court, so 

triable herein or in any case, controversy or proceeding relating hereto; and (5) Clarke’s right to 

have and reference withdrawn in any matter subject to mandatory or discretionary withdrawal. 

This notice of appearance and request for special notice, as well as any subsequent appearance, 

pleading, claim or suit, are not, shall not be deemed or construed as, a submission of Clarke to the 

jurisdiction of the Court concerning any claim or the waiver of any rights of Clarke to pursue any 

Case: 19-30088 Doc# 427 Filed: 02/13/19 Entered: 02/13/19 14:22:33 Page 2 of 3
GROSS 

&

KLEIN LLP 

THE 

EMBARCADERO

PIER 9, SUITE 100 

SAN FRANCISCO, CA 94111

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NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE; Case Nos. 19-30088, 19-30089

2

claims against any person in any other forum, state of federal, including without limitation, the 

jurisdiction of the Court to adjudicate non-core matters, all of which rights are reserved without 

prejudice. 

Dated: February 13, 2019 GROSS & KLEIN LLP 

By: /s/ Stuart G. Gross 

STUART G. GROSS 

Attorneys for Dan Clarke 

Case: 19-30088 Doc# 427 Filed: 02/13/19 Entered: 02/13/19 14:22:33 Page 3 of 3