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XAVIER BECERRA, SBN 118517

Attorney General of California 

MARGARITA PADILLA, SBN 99966 

Supervising Deputy Attorney General 

JAMES POTTER, SBN 166992 

Deputy Attorney General 

1515 Clay Street, 20th Floor 

P.O. Box 70550 

Oakland, CA 94612-0550 

Telephone: (510) 879-0815 

Fax: (510) 622-2270 

Margarita.Padilla@doj.ca.gov 

James.Potter@doj.ca.gov 

STEVEN H. FELDERSTEIN, SBN 059678 

PAUL J. PASCUZZI, SBN 148810 

FELDERSTEIN FITZGERALD 

WILLOUGHBY & PASCUZZI LLP 

400 Capitol Mall, Suite 1750 

Sacramento, CA 95814 

Telephone: (916) 329-7400 

Fax: (916) 329-7435 

sfelderstein@ffwplaw.com 

ppascuzzi@ffwplaw.com 

Attorneys for 35th District Agricultural 

Association

XAVIER BECERRA, SBN 118517

Attorney General of California 

DANETTE VALDEZ, SBN 141780 

ANNADEL ALMENDRAS, SBN 

192064 

Supervising Deputy Attorneys General 

455 Golden Gate Avenue, Suite 11000 

San Francisco, CA 94102-7004 

Telephone: (415) 510-3367 

Fax: (415) 703-5480 

Danette.Valdez@doj.ca.gov 

Annadel.Almendras@doj.ca.gov 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

- and – 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors.

Bankruptcy Case

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

 Affects PG&E Corporation 

 Affects Pacific Gas and 

Electric Company 

 Affects both Debtors 

Date: N/A

Time: 

Ctrm: 17 

Judge: Dennis Montali 

35TH DISTRICT AGRICULTURAL ASSOCIATION OBJECTION TO TRANSFER OF

CLAIM OTHER THAN FOR SECURITY [DKT NO. 1671] 

The 35th District Agricultural Association, an institution of the State of California (“35th

DAA”) hereby files this objection to the Transfer of Claim Other Than for Security filed by 

Case: 19-30088 Doc# 2039 Filed: 05/16/19 Entered: 05/16/19 11:08:55 Page 1 of

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Vendor Recovery Fund IV, LLC (“VRF”) filed at Docket No. 1671 (“Transfer of Claim”) 

pursuant to Federal Rule of Bankruptcy Procedure 3001(e), and asserts the following: 

1. In or about April 2019, VRF solicited the 35th DAA for the purchase of any claims 

the 35th DAA may have against the Debtors. 

2. On or about April 19, 2019, an employee of the 35th DAA executed an Assignment 

of Claim purportedly assigning a claim for $850 to VRF. A copy of the Assignment of Claim is 

attached to the Transfer of Claim. A copy of the Transfer of Claim is attached hereto. 

3. The Assignment of Claim is void, because the employee at 35th DAA that signed 

the Assignment of Claim did not have the authority to enter into the agreement. Any valid 

assignment of a claim must be signed by the Chief Executive Officer of the 35th DAA. In 

addition, as an entity of the State of California, California Food and Agriculture Code section 

4051 requires that any agreement by the 35th DAA must be approved by the 35th DAA’s Board of 

Directors and the California Department of General Services. These approvals were not obtained 

when the assignment was executed, rendering the assignment not legally binding. 

4. The 35th DAA sent a letter to VRF on or about May 10, 2019, informing it that the 

assignment was void, demanding that the Transfer of Claim be withdrawn, and indicating that the 

35th DAA would return the consideration for the purchase of the claim. No response was 

received from VRF, necessitating this filing. 

5. The 35th DAA reserves all rights and remedies, including the right to request a 

hearing on this objection. 

6. Neither this objection nor any subsequent appearance, pleading, proof of claim, 

claim or suit is intended or shall be deemed or construed as: 

a. consent by the 35th DAA to the jurisdiction of this Court or any other court 

with respect to proceedings, if any, commenced in any case against or otherwise involving the 

35th DAA; 

b. waiver of any right of the 35th DAA to (i) have an Article III judge 

adjudicate in the first instance any case, proceeding, matter or controversy as to which a 

Bankruptcy Judge may not enter a final order or judgment consistent with Article III of the 

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United States Constitution, (ii) have final orders in non-core matters entered only after de novo 

review by a District Court Judge, (iii) trial by jury in any proceeding so triable in the Chapter 11 

Cases or in any case, controversy, or proceeding related to the Chapter 11 Cases, (iv) have the 

United States District Court withdraw the reference in any matter subject to mandatory or 

discretionary withdrawal, (v) any and all rights, claims, actions, defenses, setoffs, recoupments or 

remedies to which the 35th DAA is or may be entitled under agreements, in law or in equity, all of 

which rights, claims, actions, defenses, setoffs and recoupments are expressly reserved hereby, 

(vi) the requirements for service of process under Federal Rules of Bankruptcy Procedure 7004 

and 9014, or (vii) the requirements for service of an objection to claim under Federal Rule of 

Bankruptcy Procedure 3007, all of which rights, claims, actions, defenses, setoffs, and 

recoupments the 35th DAA expressly reserves; or 

c. waiver of any objections or defenses that the State of California, the 35th

DAA or any other agency, unit or entity of the State of California may have to this Court’s 

jurisdiction over the State of California, the 35th DAA or such other agency, unit or entity based 

upon the Eleventh Amendment to the United States Constitution or related principles of sovereign 

immunity or otherwise, all of which objections and defenses are hereby reserved. 

Dated: May 16, 2019 Respectfully submitted, 

XAVIER BECERRA 

Attorney General of California 

MARGARITA PADILLA 

Supervising Deputy Attorney General 

By:/s/ Paul J. Pascuzzi_________________ STEVEN H. FELDERSTEIN 

PAUL J. PASCUZZI 

FELDERSTEIN FITZGERALD 

WILLOUGHBY & PASCUZZI LLP 

Attorneys for California 

35th District Agricultural Association 

Case: 19-30088 Doc# 2039 Filed: 05/16/19 Entered: 05/16/19 11:08:55 Page 3 of

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PROOF OF SERVICE 

I, Lori N. Lasley, declare: 

I am a resident of the State of California and over the age of eighteen years, and not a 

party to the within action; my business address is 400 Capitol Mall, Suite 1750, Sacramento, CA 

95814. On May 16, 2019, I served the within documents: 

35th DISTRICT AGRICULTURAL ASSOCIATION OBJECTION TO 

TRANSFER OF CLAIM OTHER THAN FOR SECURITY [DKT NO. 1671] 

By Electronic Service via CM/ECF. 

And 

By Electronic Service on 

Edwin Camson, Claims Administrator, Drum Capital Management – camson@drumcapital.com

And 

By First Class Mail on 

Edwin Camson, Claims Administrator 

Drum Capital Management 

P.O. Box 669 

Smithtown, NY 11787 

Vendor Recovery Fund IV, LLC 

Attention: Officer, Director, or Managing Agent 

P.O. Box 669 

Smithtown, NY 11787 

I am readily familiar with the firm’s practice of collection and processing correspondence 

for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same 

day with postage thereon fully prepaid in the ordinary course of business. I am aware that on 

motion of the party served, service is presumed invalid if postal cancellation date or postage 

meter date is more than one day after date of deposit for mailing in affidavit. 

I am employed in the office of a member of the bar of this court at whose direction the 

service was made. I declare under penalty of perjury that the foregoing is true and correct. 

Executed on May 16, 2019, at Sacramento, California. 

/s/ Lori N. Lasley

Lori N. Lasley 

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