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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO 

Robert A. Julian (SBN 99469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8875 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC 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) 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS’ REQUEST FOR 

JUDICIAL NOTICE IN OPPOSITION 

TO THE CORRECTED MOTION OF 

DEBTORS PURSUANT TO 11 U.S.C. 

§§ 105(a), 363, AND 503(c) FOR 

ENTRY OF AN ORDER (I) APPROVING 

SHORT-TERM INCENTIVE PLAN AND 

(II) GRANTING RELATED RELIEF 

(Dkt. No. 806) 

Date: April 23, 2019 

Time: 1:30 p.m. (Pacific Time) 

Place: United States Bankruptcy Court

Courtroom 17, 16 Floor 

San Francisco, CA 94102

Case: 19-30088 Doc# 1636 Filed: 04/23/19 Entered: 04/23/19 17:38:34 Page 1 of

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BAKER 

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ATTORNEYS AT LAW SAN FRANCISCO

 - 2 - 

TO THE HONORABLE COURT AND TO ALL PARTIES AND THEIR 

COUNSEL OF RECORD: 

The Official Committee of Tort Claimants (hereafter, the “TCC”), by and through its 

counsel of record, respectfully requests that the Court take judicial notice of the following 

documents pursuant to Federal Rule of Evidence 201: 

1. The webpage from PG&E, entitled “Learn about our vegetation safety work in 

high fire-threat areas” located from the following website: 

https://www.pge.com/en_US/safety/emergency-preparedness/naturaldisaster/wildfires/vegetation-management.page (last visited April 23, 2019), a true and correct 

copy of which is attached hereto as Exhibit A and incorporated herein by reference.

2. The Supplemental Response of the California Department of Forestry and Fire 

Protection Following January 30, 2019, Hearing on Order to Show Cause filed on February 6, 

2019 in U.S. v. Pacific Gas and Electric Co., Case No. 3:14-cr-00175 (WHA) (N.D. Cal.), Dkt. 

No. 1012, a true and correct copy of which is attached hereto as Exhibit B and incorporated 

herein by reference. 

It is appropriate for the Court to take judicial notice of the foregoing documents. A court 

may take judicial notice upon the request of a party. Fed. R. Evid. 201. A court may take judicial 

notice of a fact that “can be accurately and readily determine from sources whose accuracy cannot 

reasonably be questioned.” Fed. R. Evid. 201(b)(2). The authenticity or source of the document 

the TCC requests the Court take judicial notice of cannot be reasonably questioned—Exhibit A is 

a page from the Debtors’ own website (see Pollstar v. Gigmania Ltd., 170 F. Supp. 2d 974, 978 

(E.D. Cal. 2000) (judicial notice of information obtained from a website is proper when neither 

party questions the authenticity of the site)), and Exhibit B is a publically available filing in U.S. 

v. Pacific Gas and Electric Co., Case No. 3:14-cr-00175 (WHA) (N.D. Cal.), Dkt. No. 1012 that 

Judge Alsup incorporated by reference in his Order Adopting New Conditions of Probation, Apr. 

3, 2019), Dkt. No. 1040, ¶ 1. This Court previously granted the TCC’s Application to 

Supplement the Record to include this Order. See Dkt. No. 1282. 

Case: 19-30088 Doc# 1636 Filed: 04/23/19 Entered: 04/23/19 17:38:34 Page 2 of

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO

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Accordingly, the TCC respectfully requests that the Court take judicial notice of the 

document identified above and attached hereto as Exhibits A and B. 

Dated: April 23, 2019 Respectfully submitted, 

BAKER & HOSTETLER LLP

By: /s/ Robert A. Julian

Robert A. Julian

Attorneys for Official Committee of Tort Claimants

Case: 19-30088 Doc# 1636 Filed: 04/23/19 Entered: 04/23/19 17:38:34 Page 3 of

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