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Ronald L.M. Goldman, Esq. (State Bar No. 33422)

rgoldman@baumhedlundlaw.com

Diane Marger Moore, Esq. (Pro Hac Vice)

dmargermoore@baumhedlundlaw.com

BAUM HEDLUND ARISTEI & GOLDMAN, PC

10940 Wilshire Boulevard, 17th Floor

Los Angeles, California 90024

Telephone: (310) 207-3233

Facsimile: (310) 820-7444

Attorneys for Creditors,

Majesti Mai Bagorio, et al.

UNITED STATES DISTRICT 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)

DECLARATION OF RONALD L.M. 

GOLDMAN IN SUPPORT OF NOTICE OF 

JOINDER IN MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. §§ 105(a) AND 501 

AND FED. R. BANKR. P. 3003(c) FOR 

ENTRY OF ORDER EXTENDING THE BAR 

DATE

Date: November 13, 2019

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

Place: United States Bankruptcy Court

 Courtroom 17, 16th Floor

 San Francisco, CA 94102

Objection Deadline: November 6, 2019

Case: 19-30088 Doc# 4331-1 Filed: 10/21/19 Entered: 10/21/19 10:51:05 Page 1

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DECLARATION OF RONALD L.M. GOLDMAN

I, Ronald L.M. Goldman. pursuant to 28 U.S.C. § 1746, declare:

1. I am a senior shareholder at Baum Hedlund Aristei Goldman, attorneys of record 

for creditors Majesti Mai Bagorio, et al herein. I have personal knowledge of the following facts, 

and if called as a witness, I could and would testify competently thereto, under oath.

2. I make this declaration in support of the notice of joinder by creditors Majesti Mai 

Bagorio, et al., in the motion of the Official Committee Of Tort Claimants pursuant to 11 U.S.C. 

§§ 105(a) and 501 and Fed. R. Bankr. p. 3003(c) for entry of order extending the bar date

[Docket #4292].

3. In addition to the grounds urged by the Official Committee Of Tort Claimants for 

extending the bar date to January 31, 2020 for fire victims to file proofs of claim, it is my 

experience that people are still trying to cope with claims and claims adjusters, and coming to us 

as late as today. They had no clear warning about the deadlines since they were not represented. 

We have clients who were surprised to learn that they had little time left to file. The magnitude 

of the tragedy and the total displacement of people and their lives - many having lost their home 

and virtually everything they owned and cherished, some having been rendered homeless by loss 

of job in addition to loss of home -- has placed them at a disadvantage when it comes to trying to 

put their lives back together, on the one hand, and taking steps to protect their rights on the other.

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and corrected. Executed this 21st day of October, 2019 at Los Angeles, California.

/S/ Ronald L.M. Goldman

_______________________________________

Ronald L.M. Goldman

Case: 19-30088 Doc# 4331-1 Filed: 10/21/19 Entered: 10/21/19 10:51:05 Page 2

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PROOF OF SERVICE

I am over the age of 18 years and not a party to the within cause. My business address is 

Baum Hedlund Aristei Goldman, 10940 Wilshire Boulevard, 17th Floor, Los Angeles, California 

90024. On this day, October 19, 2019, I served the following document(s) in the manner described 

below:

DECLARATION OF RONALD L.M. GOLDMAN IN SUPPORT OF NOTICE OF 

JOINDER IN MOTION OF THE OFFICIAL COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. §§ 105(a) AND 501 AND FED. R. BANKR. P. 3003(c) FOR 

ENTRY OF ORDER EXTENDING THE BAR DATE

✘ VIA ECF: I caused the aforementioned documents to be filed via the Electronic Case 

Filing (ECF) system in the United States Bankruptcy Court for the Northern District of 

California, on all parties registered for e-filing in Case Number Case No. 19-30088 (DM). 

Counsel of record are required by the Court to be registered e-filers, and as such are 

automatically e-served with a copy of the documents upon confirmation of e-filing.

I declare under penalty of perjury, under the laws of the United States of America, that the 

foregoing is true and correct. Executed on October 21, 2019.

Diane Marger Moore _

DIANE MARGER MOORE

Case: 19-30088 Doc# 4331-1 Filed: 10/21/19 Entered: 10/21/19 10:51:05 Page 3

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