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COLETTE F. STONE, ESQ. (SBN: 129773)

RONALD F. BERESTKA, JR. ESQ. (SBN: 155707)

LYDIA V. KO, ESQ. (SBN: 272588)

STONE & ASSOCIATES

A Professional Corporation

2125 Ygnacio Valley Road, Suite 101

Walnut Creek, CA 94598

Telephone: (925) 938-1555

Facsimile: (925) 938-2937

Email: cstone@stonelawoffice.com

rberestka@stonelawoffice.com

Attorneys for

GEORGE M. VLAZAKIS; MARIA BARBIS; JOHN BARBIS; 

and ATHANASIA V. VLAZAKIS

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In Re:

PG&E CORPORATION, 

And

PACIFIC GAS AND ELECTRIC COMPANY,

Debtors,

 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)

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CASE NO. 19-30088 (DM)

Chapter 11

NOTICE OF HEARING ON MOTION 

AS TO INAPPLICABILITY OF 

AUTOMATIC STAY, AND IN THE 

ALTERNATIVE FOR RELIEF FROM 

STAY

Date: December 17, 2019

Time: 10:00 a.m.

Dept.: 17

450 Golden Gate Ave

San Francisco, CA 94102

Judge: Dennis Montali

Objection Deadline: December 12, 2019

Time: 4:00 p.m. (Pacific Time)

TO DEBTORS, THE UNITED STATES TRUSTEE, AND OTHER INTERESTED PARTIES:

PLEASE TAKE NOTICE that a hearing on the Motion as to Inapplicability of Stay, and in 

the Alternative for Relief from Stay filed by George M. Vlazakis, Maria Barbis, John Barbis, and 

Athanasia V. Vlazakis (“Vlazakis Defendants:”) will be heard by the Honorable Dennis Montali

on December 17, 2019 at 10:00 a.m. in the United States Bankruptcy Court for the Northern 

District of California located at 450 Golden Gate Avenue, 16th Floor, San Francisco, California in 

Courtroom 17. Vlazakis Defendants are requesting through the Motion that the Bankruptcy Court

Case: 19-30088 Doc# 4847 Filed: 11/22/19 Entered: 11/22/19 13:50:57 Page 1 of

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issue an order that the automatic stay does not apply to the state court action filed by PG &E 

entitled Pacific Gas & Electric Company v. Athanasia V. Vlazakis, et al, California Superior 

Court, County of Alameda, Case number RG19021463, or in the alternative, for an order lifting 

the bankruptcy stay for “cause” as to the state court action filed by PG &E entitled Pacific Gas & 

Electric Company v. Athanasia V. Vlazakis, et al, California Superior Court, County of Alameda, 

Case number RG19021463, in order that the Vlazakis defendants can assert a cross-complaint

against PG & E and otherwise litigate the case without any restrictions caused by the Debtor filing

for relief under the Bankruptcy Code.

The Motion is brought per 11 USC Section 362(a)(1) and 362(d)(1), and for cause. The 

Motion is based on this Notice, the Motion, the Declarations of Ronald F. Berestka and Maria 

Barbis, and any exhibits attached thereto, all filed in support of the Motion and upon all other 

pleadings and papers on file herein and such oral and documentary evidence as may be presented 

at the hearing on the Motion.

PLEASE TAKE FURTHER NOTICE that the Debtor is advised to appear personally or by 

counsel at the preliminary hearing as provided in Local Rule 4001-1(a) and that failure to so 

appear may result in the Court granting the relief requested without further hearing, including the a

determination that the automatic stay does not apply to the above-referenced state court action, or 

the lifting of the automatic state to allow the Vlazakis defendants to pursue its proposed crosscomplaint and the resolution of the state court lawsuit without any restrictions from the automatic 

stay. Respondent may but will not be required to file responsive pleadings, points and authorities,

and declarations in response to the Motion as provided in Bankruptcy Local Rule for the Northern 

District of California 4001-1(f).

PLEASE TAKE FURTHER NOTICE that any opposition or response to the Motion must 

be in writing, filed with the Bankruptcy Court, and served on the counsel for Vlazakis Defendants 

at the above-referenced address so as to be received by no later than 4:00 p.m. (Pacific Time) on 

December 12, 2019. Any opposition or response must be filed and served on all “Standard 

Parties” as defined the Second Amended Order Implementing Certain Notice and Case 

Management Procedures entered by the Court on May 13, 2019 (“Case Management Order”). Any 

Case: 19-30088 Doc# 4847 Filed: 11/22/19 Entered: 11/22/19 13:50:57 Page 2 of

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relief required in the Motion may be granted without a hearing if no opposition is filed and served

in accordance with the Case Management Order. In Deciding the Motion, the Court may consider 

any other document filed in these Chapter 11 Cases and Related Adversary Proceedings. 

PLEASE TAKE FURTHER NOTICE that copies of the Motion and its supporting papers 

can be viewed and/or obtained: (i) by accessing the Court’s website at 

http://www.canb.uscourts.gov, (ii) by contacting the Office of the Clerk of the Court at 450 Golden 

Gate Ave, San Francisco, CA 94102, or (iii) from the Debtor’s notice and claims agent, Prime 

Clerk LLC, at https://restructuring.primeclerk.com/pge or by calling (844) 339-4217 for U.S. 

based parties or +1 (929) 333-8977 for international parties or by email at 

pgeinfo@primeclerk.com. Note that a PACER password is needed to access documents on the 

Bankruptcy Court’s website. 

DATED: November 22, 2019 STONE & ASSOCIATES

By 

COLETTE F. STONE

RONALD F. BERESTKA, JR.

LYDIA V. KO

Attorneys for Defendants

GEORGE M. VLAZAKIS; MARIA A. BARBIS;

JOHN A. BARBIS; and ATHANASIA V. 

VLAZAKIS

Case: 19-30088 Doc# 4847 Filed: 11/22/19 Entered: 11/22/19 13:50:57 Page 3 of

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