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ESTELA O. PINO, SBN 112975

PINO & ASSOCIATES

1520 Eureka Rd., Suite 101

Roseville, CA 95661

Telephone: (916) 641-2288

Attorneys for the Plaintiffs’ Executive Committee appointed by the Superior Court of the State

of California, in and for the County of Alameda, in Case No. RG16843631 and related cases.

THE UNITED STATES BANKRUPTCY COURT

IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION, 

-andIn re:

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 Nos. 19-30088 (DM) 

Chapter 11

 THE PLAINTIFFS’ EXECUTIVE

COMMITTEE’S, APPOINTED BY THE

SUPERIOR COURT OF THE STATE OF

CALIFORNIA, IN AND FOR THE

COUNTY OF ALAMEDA, IN CASE NO.

RG16843631 AND RELATED CASES,

JOINDER IN AND SUPPORT FOR THE

JOINT MOTION OF THE OFFICIAL

COMMITTEE OF TORT CLAIMANTS

AND AD HOC COMMITTEE OF SENIOR

UNSECURED NOTEHOLDERS TO

TERMINATE THE DEBTORS’

EXCLUSIVE PERIODS PURSUANT TO

SECTION 1121(d)(1) OF THE

BANKRUPTCY CODE

DATE: October 7, 2019 

TIME: 10:00 A.M.

PLACE: Courtroom 17

450 Golden Gate Avenue, 

16th Fl.

San Francisco, California

JUDGE: Hon. Dennis Montali

RELATED DOCKET NO.: 3940

The Plaintiffs’ Executive Committee appointed by the Superior Court of the State of

California, in and for the County of Alameda, in Case No. RG16843631 and related cases

(“hereinafter referred to as the “Ghost Ship Warehouse Plaintiffs’ Executive Committee”), 

Case: 19-30088 Doc# 4118 Filed: 10/04/19 Entered: 10/04/19 11:54:32 Page 1 of

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1 A Third Amended Complaint was filed on April 24, 2019, to amend the allegations against the

 City of Oakland, another Defendant. Due to the Automatic Stay, the Third Amended Complaint has not 

 been served on the Debtors.

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party in interest in the above-referenced Chapter 11 cases, by and through its attorneys of

record, hereby joins in and supports the Joint Motion of the Official Committee of Tort

Claimants and Ad Hoc Committee of Senior Unsecured Noteholders to Terminate the

Debtors’ Exclusive Periods Pursuant to Section 1121(d)(1) of the Bankruptcy Code

(hereinafter referred to as the “Exclusivity Termination Motion”) (Docket No. 3940).

INTRODUCTION

The Ghost Ship Warehouse Plaintiffs’ Executive Committee was appointed by the

Superior Court of the State of California, in and for the County of Alameda (hereinafter

referred to as the “Superior Court”) in Case No. RG16843631 and related cases, which is

based on claims arising out of the catastrophic fire that took place on December 2, 2016,

(hereinafter referred to as the “Ghost Ship Plaintiff Cases”). On December 2, 2016, a fire

broke out at the building located in City of Oakland, County of Alameda, State of California,

bearing Assessor’s Parcel Numbers 25-690-10 and 25-690-11, commonly known as the

“Ghost Ship Warehouse.” The fire at the Ghost Ship Warehouse resulted in thirty-six (36)

deaths, the youngest individual to die was seventeen (17) years old, and many others

suffered personal injuries and incurred other damages. 

There are numerous civil actions pending in the Superior Court, which are being

maintained via a “Master Complaint” pending scheme before Honorable Brad Seligman. 

The plaintiffs in the Ghost Ship Plaintiff Cases (hereinafter referred to as the “Ghost Ship

Plaintiffs”) have adopted the Second Amended Master Complaint, which is operative

against the Debtors1, and was filed with the Superior Court on January 19, 2018. 

In many ways, the tragedy at the Ghost Ship Warehouse has been over shadowed

by the subsequent catastrophic wildfires, which occurred in 2017 and 2018. It must be

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realized; however, that the Ghost Ship Plaintiffs are numerous and have significant claims

against these Debtors.

JOINDER AND STATEMENT

The Ghost Ship Warehouse Plaintiffs’ Executive Committee believes that the

Exclusivity Termination Motion will foster competition, which will benefit all creditors. While

nothing herein should be considered as support for the Term Sheet, proposed jointly by the

Official Committee of Tort Claimants (hereinafter referred to as the “TCC”) and Ad Hoc

Committee of Senior Unsecured Noteholders (hereinafter referred to as the “Bondholders”);

however, the Ghost Ship Warehouse Plaintiffs’ Executive Committee joins in and supports

the Exclusivity Termination Motion.

The Ghost Ship Warehouse Plaintiffs’ Executive Committee does hereby reserves

the right to join in and support any additional pleadings filed by TCC, Bondholders,

creditors, and other parties in interest with regards to the Exclusivity Termination Motion.

CONCLUSION

Based upon the instant Joinder and the arguments to be presented during the

hearing on October 7, 2019, the Ghost Ship Warehouse Plaintiffs’ Executive Committee

respectfully requests that the Exclusivity Termination Motion be granted. 

Dated: October 4, 2019 Respectfully submitted,

PINO & ASSOCIATES

By: /s/ Estela O. Pino 

Estela O. Pino, Attorneys for the Ghost Ship

Warehouse Plaintiffs’ Executive Committee

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