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 Minh and Gurdon Merchant

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

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

NOTICE OF APPEARANCE AND 

REQUEST FOR SPECIAL NOTICE 

BY MINH AND GURDON 

MERCHANT

 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# 526 Filed: 02/20/19 Entered: 02/20/19 21:20:13 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 Minh and Gurdon Merchant (“the Merchants”) 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 the Merchants’ 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 the Merchants 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) the Merchants’ 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) the 

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

district judge; (4) the Merchants’ right to trial by jury in any proceedings or trial, in any state or

federal court, so triable herein or in any case, controversy or proceeding relating hereto; and (5) 

the Merchants’ 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 

Case: 19-30088 Doc# 526 Filed: 02/20/19 Entered: 02/20/19 21:20:13 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

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submission of the Merchants to the jurisdiction of the Court concerning any claim or the waiver 

of any rights of the Merchants to pursue any claims against any person in any other forum, state 

or federal, including without limitation, the jurisdiction of the Court to adjudicate non-core 

matters, all of which rights are reserved without prejudice. 

Dated: February 20, 2019 GROSS & KLEIN LLP 

By: /s/ Stuart G. Gross 

STUART G. GROSS 

Attorneys for Minh and Gurdon Merchant 

Case: 19-30088 Doc# 526 Filed: 02/20/19 Entered: 02/20/19 21:20:13 Page 3 of 3