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CLASS REPRESENTATIVE’S MOTION TO EXTEND APPLICATION OF FEDERAL RULE OF CIVIL 

PROCEDURE 23 TO CLASS PROOFS OF CLAIM

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John E. Lattin (State Bar No. 167876)

 jlattin@ostergar.com

OSTERGAR LAW GROUP P.C.

9110 Irvine Center Drive

Irvine, California 92618

Phone: (949) 357-2544 | Fax: (949) 305-4591

Attorneys for Creditor

DAVID ALONZO and all similarly situated

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFRONIA - SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION, 

and 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

Bankruptcy Case: 3:19-bk-30088 DM

Chapter 11

(Lead Case)

(Jointly Administered)

CLASS REPRESENTATIVE’S 

NOTICE OF MOTION TO EXTEND 

APPLICATION OF FEDERAL RULE 

OF CIVIL PROCEDURE 23 TO 

CLASS PROOFS OF CLAIM

DATE: November 19, 2019 

TIME: 10:00 a.m. 

DEPT: 17 

Case: 19-30088 Doc# 4371 Filed: 10/21/19 Entered: 10/21/19 23:29:17 Page 1 of

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CLASS REPRESENTATIVE’S MOTION TO EXTEND APPLICATION OF FEDERAL RULE OF CIVIL 

PROCEDURE 23 TO CLASS PROOFS OF CLAIM

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TO THE HONORABLE JUDGE DENNIS MONTALI, UNITED 

STATES BANKRUPTCY JUDGE, DEBBTORS AND STANDARD PARTIES:

PLEASE TAKE NOTICE that, on November 19, 2019, at 10:00 a.m., in the 

above-entitled courtroom, a hearing will be held to consider the Motion to Extend 

Application of Federal Rule of Civil Procedure 23 to Class Proofs of Claim 

(“Motion”), filed by David Alonzo, the Class Representative, on behalf of himself 

and on behalf of the putative Class. By the Motion, the David Alonzo seeks an order 

extending the application of the Federal Rule of Civil Procedure 23 to this matter. 

The Motion is made and based upon this Notice, the attached Memorandum of 

Points and Authorities, the Declaration of John E. Lattin filed concurrently herewith, 

the pleadings, papers and other documents on file in the Debtors’ Chapter 11 case, 

and any supplemental evidence, both oral and documentary, that may be submitted to 

this Court at or before the time of the hearing on this Motion. 

WHEREFORE, David Alonzo respectfully requests that this Court ender an 

order extending application of Federal Rule of Civil Procedure 23 to this matter and 

such other and further relief as the Court deems just and proper.

Dated: October 21, 2019 OSTERGAR LAW GROUP P.C.

By: 

John E. Lattin

Attorneys for Creditor,

DAVID ALONZO, and all similarly situated

Case: 19-30088 Doc# 4371 Filed: 10/21/19 Entered: 10/21/19 23:29:17 Page 2 of

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CLASS REPRESENTATIVE’S MOTION TO EXTEND APPLICATION OF FEDERAL RULE OF CIVIL 

PROCEDURE 23 TO CLASS PROOFS OF CLAIM

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CERTIFICATE OF SERVICE

United Stated District Court for the Northern District of California

Case No. 3:19-bk-30089 (DM)

CLASS REPRESENTATIVE’S NOTICE OF MOTION AND MOTION TO 

EXTEND APPLICATION OF FEDERAL RULE OF CIVIL PROCEDURE 23 

TO CLASS PROOFS OF CLAIM

I hereby certify that I caused the foregoing to be served and filed with the 

Clerk of the Court for the United States District Court for the Central District of 

California using the court’s CM/ECF system on October 21, 2019. 

I further certify that all participants in the case are registered CMF/ECF users 

and that service will be accomplished by the court’s CM/ECF system. 

 /s/ John E. Lattin 

 John E. Lattin

Case: 19-30088 Doc# 4371 Filed: 10/21/19 Entered: 10/21/19 23:29:17 Page 3 of

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