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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

Sander L. Esserman (Admitted Pro Hac Vice)

Cliff I. Taylor (Admitted Pro Hac Vice)

STUTZMAN, BROMBERG, ESSERMAN & PLIFKA, P.C. 

2323 Bryan Street, Suite 2200 

Dallas, TX 75201-2689 

Telephone: 214-969-4900 

Email: esserman@sbep-law.com

Scott Summy 

John Fiske (CSBN 249256) 

BARON & BUDD, P.C. 

3102 Oak Lawn Avenue #1100 

Dallas, TX 75219 

Telephone: 214-521-3605 

Email: ssummy@baronbudd.com 

Christopher H. Hart (CSBN 184117) 

Kimberly S. Fineman (CSBN 184433) 

NUTI HART LLP 

411 30TH Street, Suite 408 

Oakland, CA 94609-3311 

Telephone: 510-506-7152 

Email: kfineman@nutihart.com 

Attorneys for the Association of California Water Agencies 

Joint Powers Insurance Authority 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

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. 

 Case No. 19-30088-DM 

Chapter 11 

Lead Case, Jointly Administered 

MOTION PURSUANT TO FED. R. 

BANKR. P. 9006(b)(1) TO ENLARGE 

THE TIME FOR ACWA/JPIA TO FILE 

PROOF OF CLAIM 

Date: February 26, 2020 

Time: 10:00 a.m. 

Place: 450 Golden Gate Avenue, Ctrm 17 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

Objection Deadline: February 19, 2020 

 4:00 p.m. (Pacific Time)

Case: 19-30088 Doc# 5215 Filed: 12/27/19 Entered: 12/27/19 14:38:16 Page 1 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

2 

Pursuant to Rule 9006(b)(1) of the Federal Rules of Bankruptcy Procedure, by this 

motion (“Motion”) the Association of California Water Agencies Joint Powers Insurance 

Authority (“ACWA/JPIA” or “Movant”) seeks an order expanding the time for it to file its proof 

of claim in these cases, a true copy of which is attached hereto as Exhibit 1. Movant is causing 

a true copy of Exhibit 1 hereto to be filed in Debtors’ claims register contemporaneously with 

the filing of this Motion. This Motion is based upon the points and authorities set forth herein 

and the concurrently filed notice of hearing, declaration of Jennifer Nogosek (“Nogosek Decl.”) 

in support of the Motion, and any evidence or oral argument presented at the time of any hearing 

on this matter. In support thereof, the ACWA/JPIA, by an through its undersigned counsel, 

respectfully represents as follows: 

Summary of Argument 

The general bar date in these cases was October 21, 2019 (“Original Bar Date”). The 

process for submission of timely claims has continued after the Original Bar Date. Pursuant to 

the Stipulation Between Debtors and Official Committee of Tort Claimants to Extend Bar Date 

for Fire Claimants and for Appointment of Claims Representative (Dkt# 4651), the Original Bar 

Date was extended for the benefit of Unfiled Fire Claimants to December 31, 2019 at 5:00 p.m. 

(Prevailing Pacific Time). 

This Motion concerns a subrogation claim in the amount of $350,000 that, although not 

technically a “fire claim,” is assuredly fire related. Plaintiff, a risk-sharing pool for its member 

water utilities, has a $350,000 retention claim for damages sustained by its member, the Paradise 

Irrigation District, as a result of the Camp Fire in November 2018. 

Application of the so-called Pioneer factors shows that Movant’s late filing is the result 

of excusable neglect and therefore permissible under Rule 9006(b)(1). As to the first such factor, 

Plaintiff’s late filing will cause no prejudice to Debtors, inasmuch as their reorganizations are 

solvent, timely claims are still being received, and their reorganizations are at an early stage (no 

confirmed plan, no disclosure statement on file, no voting deadlines, no distribution schedule, 

etc.). As to the second Pioneer factor, Movant’s delay in asserting its claim and the potential 

impact on these proceedings are exceedingly modest and immaterial for the same reasons that 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

3 

Debtors will not be prejudiced. As to the third Pioneer factor, the reason for the delay and 

whether it was in Movant’s reasonable control, no notice of the bar date appears to have been 

sent to Movant’s offices.1 As evidenced by the Declaration of Jennifer Nogosek, the person at 

AWCA/JPIA responsible for administering the underlying claim does not recall ever seeing or 

receiving any notice regarding the Original Bar Date or any other bar date. These circumstances 

effectively remove the resulting delay in filing the proof of claim from Movant’s reasonable 

control. Although generally unfamiliar with bankruptcy practices and procedures and having 

never before been involved in the filing of a proof of claim in bankruptcy, Ms. Nogosek promptly 

made inquiries upon seeing a news report during the first half of December 2019 suggesting the 

possibility of a deadline for asserting a claim against Debtors. These inquiries demonstrate 

Movant’s good faith, satisfying the fourth Pioneer factor. Because consideration of the Pioneer

factors points overwhelmingly to Movant’s neglect having been excusable, late filing of the 

proof of claim should be permitted. 

Jurisdiction and Venue 

The Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 1334, 

the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24 

(N.D. Cal.), and Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District 

Court for the Northern District of California. This is a core proceeding pursuant to 28 U.S.C. 

§ 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. The

statutory predicate for the relief requested herein is Rule 9006(b)(1) of the Federal Rules of 

Bankruptcy Procedure. 

Background 

As set forth in the Declaration of Jennifer Nogosek filed contemporaneously herewith, 

ACWA/JPIA is a risk sharing cooperative owned and governed by its member agencies, all 

California water utilities. ACWA/JPIA was first formed by certain California water agencies in 

1

 This potentially implicates a fifth factor some courts have considered as part of the Pioneer analysis, 

the adequacy or sufficiency of notice. 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

4 

1979 to provide, among other things, risk-sharing pools. Like its members, ACWA/JPIA is a 

special district subject to the California Government Code. 

 Infrastructure losses are among the most frequent and significant casualty-related losses 

sustained by ACWA/JPIA’s member agencies. The Paradise Irrigation District—water utility to 

the Town of Paradise devastated by the deadly Camp Fire—is an ACWA/JPIA member agency. 

As a result of the Camp Fire, the Paradise Irrigation District sustained sizeable losses, mostly in 

the nature of damage and destruction to its infrastructure. As a risk-sharing cooperative, 

ACWA/JPIA effectively insures fire-related claims of the Paradise Irrigation District arising 

from the Camp Fire to the extent of ACWA/JPIA’s $350,000 insured retention. Various 

excess carriers are responsible for the loss to the extent it exceeds $350,000 retention. 

Basis for Relief Requested

Bankruptcy Rule 9006(b)(1) allows the enlargement of time for “an act . . . required or 

allowed to be done at or within a specified period . . .by order of court.” Rule 9006(b)(1) further 

provides: 

[T]he court for cause shown may at any time in its discretion (1) with or without

motion or notice order the period enlarged if the request therefor is made before

the expiration of the period originally prescribed or as extended by a previous

order or (2) on motion made after the expiration of the specified period permit

the act to be done where the failure to act was the result of excusable neglect.

Bankruptcy Rule 9006(b)(1). “Excusable neglect” under Bankruptcy Rule 9006(b)(1) is a 

flexible concept and caselaw has identified a four non-exclusive factors to be considered: 

With regard to determining whether a party's neglect of a deadline is excusable 

. . . we conclude that the determination is at bottom an equitable one, taking 

account of all relevant circumstances surrounding the party's omission. These 

include . . . [1] the danger of prejudice to the [nonmovant], [2] the length of the 

delay and its potential impact on judicial proceedings, [3] the reason for the 

delay, including whether it was within the reasonable control of the movant, and 

[4] whether the movant acted in good faith.

Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. Partnership, 507 U.S. 380, 395, 113 S.Ct. 

1489, 1498 (1993) (citations omitted); see also In re Orthopedic Bone Screw Prods. Liability 

Litig., 246 F.3d 315, 323 (3d Cir. 2001) (citing Pioneer, 507 U.S. at 395). Rule 9006(b)(1) 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

5 

allows “late filings caused by inadvertence, mistake, or carelessness, not just those caused by 

intervening circumstances beyond the party's control.” Pioneer, 507 U.S. at 381. 

In Pioneer, a creditor represented by experienced bankruptcy counsel missed the proof 

of claim deadline because his lawyer overlooked the filing date in the bankruptcy court’s notice. 

The Supreme Court affirmed the Sixth Circuit’s finding of excusable neglect and endorsed a 

balancing test, the hallmark of which is consideration of various factors to aid in determining 

whether a movant’s neglect of a bar date was excusable, thereby justifying a late proof of claim 

filing. This equitable determination is to “tak[e] account of all relevant circumstances 

surrounding the party’s omission.” Id. at 395, 113 S. Ct. at 1498; see also Corning v. Corning 

(In re Zilog, Inc.), 450 F.3d 996 (9th Cir. 2006) (noting Pioneer’s non-exhaustive list of relevant 

factors). Consideration of all four Pioneer factors—as well as a fifth engrafted onto the Pioneer

analysis by some courts--supports the conclusion that ACWA/JPIA’s failure to file its proof of 

claim in connection with its $350,000 retention prior to the general bar date was excusable. 

Because in this case there is no danger of prejudice to the Debtors, the first Pioneer factor 

weighs overwhelmingly in Movant’s favor. Debtors estates are solvent, and all creditors stand 

to be paid. See, e.g., In re Best Payphones, Inc., 523 B.R. 54, 75-6 (Bankr. S.D.N.Y. 2015) 

(citing Scott I. Davidson & Jennifer A. Bender, Late-Filed Claims are not Always Excluded from 

the Distribution Party, AM. BANKR. INST. J. 16, 62 (Jan. 2014)) (where unsecured creditors 

will be made whole, “the debtor will not be able to object to a proof of claim solely on the 

grounds that the proof of claim was filed after the bar date.”) and In re Sheehan Mem’l Hosp., 

507 B.R. 802, 803 (Bankr. W.D.N.Y. 2014) (where the chapter 11 estate is solvent, “the proper 

remedy for a late filing is not the expungement of a claim, but its allowance as a tardily filed 

claim only.). The tininess of ACWA/JPIA’s claim relative to Debtors’ estates speaks to the 

absence of prejudice even if the estates were not solvent (which they are). See, e.g., In re Keene 

Corp., 188 B.R. 903, 910 (Bankr. S.D.N.Y. 1995) (size of the late claim in relation to the estate 

is a consideration in determining prejudice). 

Beyond the Debtors’ solvency, any prospect of disruptive prejudice seems especially 

unlikely here because Debtors’ reorganizations are at an early stage. Although prospective plans 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

6 

are on file, claims are still coming in. Fire claimants’ proofs of claim are not due until December 

31, 2019. No disclosure statement has yet been approved or even filed. No voting deadline has 

been established. Distributions have not been made, nor are any set to be made. See In re 50-

Off Stores, Inc., 220 B.R. 897, 902 (Bankr. W.D. Tex. 1998) (in assessing prejudice, court 

distinguished between situations in which a reorganization plan is formulated, negotiated, and 

consummated after receipt and notice of the late-filed claim and where, as here, all of that is yet 

to occur). 

Consideration of the second Pioneer factor, the length of the delay and its potential 

impact on these proceedings, also strongly favors Movant. Here, ACWP/JPIA missed the 

applicable bar date by barely two months and, in any event, filed its proof of claim before the 

deadline applicable to Debtors’ almost innumerable fire claimants. See In re Lyondell Chemical 

Co., 543 B.R. 400, 410 (Bankr. S.D.N.Y. 2016) (length of delay is only given meaning by its 

effect on the administration of the case). ACWA/JPIA’s late filing, if permitted by the Court, 

would have little to no appreciable impact on these proceedings. 

As to the third Pioneer factor, the reason for the delay and whether it was in Movant’s 

reasonable control, does not move the Pioneer needle in the direction of inexcusability. Movant 

acknowledges this Court’s observation, in 2004, that “[o]n balance, ... the authorities construing 

Pioneer weigh the reasons for the delay factor most heavily.” In re Pacific Gas & Electric, Co., 

311 B.R. 84, 91 (Bankr. N.D. Cal. 2004) (citing Graphic Communications Int’l Union, Local 

12-N v. Quebecor Printing Providence, Inc., 270 F.3d 1 (1st Cir. 2001)).2

 A “satisfactory

explanation for the late filing” is required. Graphic Communications at 5. In Pincay v. Andrews,

2 That said, the Fifth and Eleventh Circuits and courts in at least two other circuits (the Third and the 

Eighth) have identified the danger of prejudice is the most important of the Pioneer factors. See 

Greyhound Lines, Inc. v. Rogers (In re Eagle Bus Mfg., Inc.), 62 F.3d 730, 737 (5th Cir. 1995) 

(“Under Pioneer, the central inquiry is whether the debtor will be prejudiced.”); Advanced Estimating 

System, Inc. v. Riney, 77 F.3d 1322, 1325 (11th Cir. 1996) (“Primary importance should be accorded 

to the absence of prejudice to the nonmoving party and to the interest of efficient judicial 

administration.); In re Cable & Wireless USA, Inc., 338 B.R. 609, 614 (Bankr. D. Del. 2006) (quoting 

In re Tannen Towers Acquisition Corp., 235 B.R. 748, 755 (D.N.J. 1999) (“In applying the Pioneer

test, courts place the greatest weight on whether any prejudice to the other parties will occur by 

allowing a late claim.”); Matter of Papp Intern., Inc., 189 B.R. 939, 944 (Bankr. D. Neb. 1995) (citing 

In re Sacred Heart Hos. of Norristown, 186 B.R. 891 as suggesting “the most significant [Pioneer] 

factor ... is that of prejudice to the debtor.”). 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

7 

389 F.3d 853, 855-56 (9th Cir. 2004) (en banc), cert. denied, 544 U.S. 961, 125 S.Ct. 1726, 161 

L.Ed.2d 602 (2005), the Ninth Circuit applied Pioneer to hold that a district court did not abuse

its discretion in finding excusable neglect when a sophisticated law firm missed a notice of 

appeal deadline because a paralegal has mistakenly calendared the 60-day deadline applicable to 

government parties instead of the correct 30-day deadline. In In re Zilog, which also involved a 

late proof of claim, a panel of the Ninth Circuit found excusable neglect based on an ambiguous 

email from debtor’s general counsel to three unrepresented employees that the court found “was 

not calculated to inform the women that they needed to file their wage claims with the bankruptcy 

court.” 450 F.3d at 1003. 

In her accompanying declaration, Ms. Nogosek’s identifies herself, in her capacity as a 

Liability and Property Claims Manager at ACWA/JPIA, as the person generally responsible for 

administering the claim for losses sustained by the Paradise Irrigation District in the Camp Fire 

to the extent of Movant’s $350,000 retention. She does not recall ever seeing or receiving a 

notice of any claims bar date in these cases, and the record contains no indication to the contrary. 

Prior to seeing a report on the news during the first or second week of December 2019 that 

prompted her to make inquiries on her own, Ms. Nogosek avers that she had no knowledge of any 

deadline or bar date for filing a claim in Debtors’ bankruptcy cases apart from the applicable 

California statute of limitations. Ms. Nogosek, in her declaration, also acknowledges 

her general unfamiliarity with bankruptcy practices and procedures and notes that she has not 

been involved in the filing of any proof of claim in any bankruptcy case previously and has never 

before pursued a subrogation claim that involved bankruptcy. Nogosek Decl., ¶ 8. The Ninth 

Circuit’s comment in In re Zilog resonates here: “It would be very strange indeed to find the 

neglect in our case inexcusable, when the neglect in Pioneer and Pincay was found excusable.” 

450 F.3d at 1006. 

A few courts have recognized the adequacy or sufficiency of notice to a creditor of the 

claims bar date as an additional factor to be considered in the Pioneer balancing test. See, e.g., 

In re R.H. Macy & Co., Inc., 166 B.R. 799, 801 (S.D.N.Y. 1994). Debtors did list Movant on 

their schedules of unsecured creditors filed March 14, 2019, p. 479 of Dkt.# 906-7 noting 

“Wildfire Litigation” as the basis for unspecified claim(s). It appears from these schedules, 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

8 

however, that Debtor provided no notice to Movant at its Roseville, California, office address; 

the only addresses appearing on the schedules are those of Movant’s various lawyers, including 

Baron & Budd’s San Diego office and that of its co-counsel, the Dixon Diab & Chambers firm 

in San Diego. This is unremarkable because these firms were counsel to Movant with respect to 

a pending lawsuit asserting claims against Debtors stemming from 2017’s North Bay wildfires 

and damages sustained by another ACWA/JPIA member, the Circle Oaks County Water District 

in Napa County. While Movant’s counsel of record in that pending lawsuit did file a proof of 

claim on Movant’s behalf with respect to that litigation claim,3 neither firm had been retained by 

Movant with respect to the $350,000 retention claim at issue in this motion.4

There is no litigation with respect to Movant’s $350,000 retention claim, as to which 

ACWA/JPIA was, as yet, working with adjusters, not counsel, until mid-December 2019. 

Nogosek Decl., ¶ 9. As reflected in her declaration, although Ms. Nogosek was the person at 

ACWA/JPIS dealing with the Paradise Irrigation District claim resulting from the Camp Fire, 

she was not the person at ACWA/JPIA responsible for the administration of any claims related 

to 2017’s North Bay wildfires or with respect to damages sustained at Circle Oaks. Nogosek 

Decl., ¶ 9. 

Finally, as to the fourth Pioneer factor, no reasonable suggestion can be made that 

ACWA/JPIA failed to act in good faith, particularly inasmuch Ms. Nogosek acted responsibly 

and with expedition upon being alerted to the possibility of a claims deadline by an early 

December 2019 newscast, which culminated in a proof of claim being filed prior to December 

31, 2019 deadline applicable to fire claimants. 

Conclusion 

 For the reasons set forth above, Movant respectfully requests that this Court enter an 

order pursuant to Bankruptcy Rule 9006(b)(1) as follows: 

1. Granting this Motion; 

3

 Claim # 56573. 

4

 Nor had Movant retained the Jang & Associates law firm in Walnut Creek, which is also listed on 

Debtors’ schedules, with respect to the retention claim at issue. 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

9 

2. Directing that Exhibit 1 hereto be deemed timely filed; 

 

3. Directing that Movant shall have until 30 days from the date of the filing of this 

Motion to submit “Attachment 1” to Prime Clerk as referenced on Exhibit 1 

hereto. 

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

Dated: December 27, 2019 STUTZMAN, BROMBERG, ESSERMAN & 

PLIFKA, P.C. 

 By: /s/ Sander L. Esserman 

 Sander L. Esserman

Attorneys for the Association of California Water 

Agencies Joint Powers Insurance Authority 

Dated: December 27, 2019 BARON & BUDD, P.C. 

 By: /s/ Scott Summy

 Scott Summy

Attorneys for the Association of California Water 

Agencies Joint Powers Insurance Authority 

Dated: December 27, 2019 NUTI HART LLP 

 By: /s/ Kimberly S. Fineman 

 Kimberly S. Fineman

Attorneys for the Association of California Water 

Agencies Joint Powers Insurance Authority 

 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

10 

EXHIBIT 1 

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