DECLARATION OF MANUEL CORRALES, JR., IN SUPPORT OF MOTION FOR RELIEF FROM 

AUTOMATIC STAY AND ABSTENTION 

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Manuel Corrales, Jr. SBN 117647

ATTORNEY AT LAW

17140 Bernardo Center Drive, Suite 358

San Diego, CA 92128

Tel: (858) 521-0634/Fax: (858) 521-0633

Email: mannycorrales@yahoo.com

Attorney for Creditors BARBARA JEAN ZELMER 

and ROBERT THOMAS ZELMER

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In Re

PG&E CORPORATION

and

PACIFIC GAS AND ELECTRIC 

COMPANY,

 Debtors.

Bankruptcy Cases

19-30088-DM (Lead Case)

19-30089-DM

(Jointly Administered)

DECLARATION OF MANUEL CORRALES, 

JR., IN SUPPORT OF MOTION FOR 

RELIEF FROM AUTOMATIC STAY AND 

ABSTENTION

Date: June 25, 2019

Time: 9:30 a.m. (PT)

Ctrm: Hon. Dennis Montali 

450 Golden Gate Avenue 

16th Floor, Courtroom 17 

San Francisco, CA 94102

o Affects PG&E Corporation

o Affects Pacific Gas and 

Electric Corporation

Ä Affects both Debtors

**All papers shall be filed in 

the Lead Case No. 19-30088 DM

I, Manuel Corrales, Jr., declare that if called as a 

witness in this case I could and would testify as follows:

1. I am an attorney at law duly licensed to practice law 

in the State of California, the State of New Mexico, and the 

State of Utah, and I am the attorney of record for Creditors 

Barbara Zelmer and Robert Zelmer herein. I have personal 

knowledge concerning the facts set forth herein.

2. On September 9, 2015, an electrical power line 

constructed, owned, operated, managed and maintained by PG&E 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 1 of

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DECLARATION OF MANUEL CORRALES, JR., IN SUPPORT OF MOTION FOR RELIEF FROM 

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CORPORATION and PACIFIC GAS AND ELECTRIC COMPANY (collectively 

“PG&E”), came in contact with adjacent native vegetation that 

had not been properly trimmed and maintained in violation of 

fire safety practices. As a result, an electrical arc ignited a 

fire, known as the Butte Fire, that spread and burned over 

70,000 acres, destroyed over 570 homes, 368 buildings, killed 

two people, injured others, and damaged about 44 structures. 

The fire was not fully contained until October 1, 2015.

3. The Zelmers are the owners of property located at 8749 

Maranatha Lane, San Andreas, California 95246, and were not 

insured at the time of the fire. Their home and all of its 

contents were destroyed by the Butte Fire. On December 4, 2017, 

the Zelmers filed suit in the Sacramento County Superior Court 

in the Butte Fire Coordinated Proceeding, styled Barbara Jean 

Zelmer and Robert Thomas Zelmer v. PG&E, Case No. CGC-17-561107, 

and incorporated the Master Complaint therein (Butte Fire Cases, 

No. JCCP 4853, Hon. Allen H. Sumner, Dept. 42). The Zelmers sued 

PG&E for, inter alia, negligence, trespass, and inverse 

condemnation.

4. The Zelmers sought damages for rebuilding their home, 

for personal property loss, tree loss, landscaping, erosion, 

lost wages, evacuation costs, alternative living expenses, cost 

of cleaning and repair of the property due to smoke, soot and 

ash damage, and damage to other structures. They also sought 

compensation for mental anguish, annoyance, inconvenience, 

disturbance, and loss of the quiet enjoyment of their property 

stemming from the damage caused by the fire.

5. During the course of litigation, Defendants PG&E 

disclosed that it had liability insurance that covered the 

Zelmers’ claims. Although PG&E claims its carrier has paid out 

the entirety of its policy, PG&E remains an additional insured 

under two policies from its contractors who were supposed to 

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DECLARATION OF MANUEL CORRALES, JR., IN SUPPORT OF MOTION FOR RELIEF FROM 

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maintain proper vegetation control around the electrical line 

that sparked the fire, with limits in excess of $75 million. 

The Zelmers only seek recovery of insurance proceeds.

6. On June 22, 2017, the trial court ruled on cross 

motions on whether PG&E is or should be liable for damages 

caused by the fire under the doctrine of inverse condemnation. 

It concluded that PG&E is liable for inverse condemnation, and 

found: (1) PG&E may be held liable for inverse condemnation 

under California law even though it is a privately-owned public 

entity, and (2) the Butte Fire was caused by a public 

improvement as deliberately designed and constructed by PG&E.

7. PG&E reached a settlement with the Zelmers whereby 

PG&E would pay the Zelmers a sum certain up front, and then 

another sum, should PG&E succeed in reversing the trial court’s 

ruling on inverse condemnation. To this end, on September 4, 

2018, the Zelmers and PG&E entered into a stipulated judgment 

that allowed PG&E to appeal that ruling. The trial court 

approved the stipulated judgment on November 29, 2018. If the 

Bankruptcy Court lift the automatic stay and allow PG&E and the 

Zelmers to pursue the appeal of the Stipulated Judgment, and 

should PG&E not prevail on the appeal, the Zelmers would only be 

looking to the available insurance to satisfy the Stipulated 

Judgment.

8. On December 12, 2018, PG&E filed a Notice of Appeal of 

the Stipulated Judgment.

9. To the Zelmers knowledge, there are no other parties 

in the Butte Fire litigation who have entered into a stipulated 

judgment as the Zelmers and PG&E did.

10. On January 29, 2019, PG&E filed for Chapter 11 

bankruptcy protection.

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DECLARATION OF MANUEL CORRALES, JR., IN SUPPORT OF MOTION FOR RELIEF FROM 

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11. Attached herewith and marked as Exhibit “1” is a true 

and correct copy of an Order Granting Motion for Entry of 

Stipulated Judgment, dated November 29, 2018.

12. Attached herewith and marked as Exhibit “2” is a true 

and correct copy of a Notice of Filing Notice of Appeal, dated 

December 13, 2018.

13. Attached herewith and marked as Exhibit “3” is a true 

and correct copy of a Notice of Filing of Notice of Appeal, 

dated December 11, 2018.

14. Attached herewith and marked as Exhibit “4” is a true 

and correct copy of Defendant Pacific Gas and Electric Company’s 

Response to Plaintiffs’ Form Interrogatories, Set One, dated May 

23, 2016, wherein it discloses the existence of insurance 

policies covering the Zelmers’ claims.

15. Attached herewith and marked as Exhibit “5” is a true 

and correct copy of Defendant Pacific Gas and Electric Company’s 

Response to Plaintiffs’ Requests for Production of Documents and 

Things, Set One, dated May 23, 2016, wherein it discloses the 

existence of insurance policies covering the Zelmers’ claims.

I declare under penalty of perjury under the laws of the 

State of California that the foregoing is true and correct.

Executed this 3 May 2019 at San Diego, California.

___________________________

MANUEL CORRALES, JR.

DATED: May 3, 2019

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DECLARATION OF MANUEL CORRALES, JR., IN SUPPORT OF MOTION FOR RELIEF FROM 

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s/ Manuel Corrales, Jr.

Manuel Corrales, Jr., Esq.

Attorney for Creditors

BARBARA ZELMER and ROBERT 

ZELMER

17140 Bernardo Center Dr.

Suite 358

San Diego, CA 92128

T: (858) 521-0634

E: mannycorrales@yahoo.com

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 5 of

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EXHIBIT “1”

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SUPERIOR COURT OF CALIFORNIA, COUNTY OF SACRAMENTO 

Gordon D Schaber Courthouse 

720 Ninth STREET 

Sacramento, CA 95814-1311 

SHORT TITLE: Unifund CCR Partners vs. Lor 

CLERK'S CERTIFICATE OF SERVICE BY MAIL CASE NUMBER: 

34-2008-00004853-CL-CL-GDS 

I certify that I am not a party to this cause. I certify that a true copy of Stipulated Judgment filed November 29, 

2018 was mailed following standard court practices in a sealed envelope with postage fully prepaid, addressed 

as indicated below. The mailing and this certification occurred at Sacramento, California, on 11/30/2018. 

Clerk of the Court, by: /s/ 'B. (OriEJa ----------------,Deputy 

MANUEL CORRALES, JR 

17140 BERNARDO CENTER DRIVE# 370 

SAN DIEGO, CA 92128 US 

KENNETH R CHIATE 

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

865 S FIGUEROA STREET# 10TH FLR 

LOS ANGELES, CA 90017 US 

CLERK'S CERTIFICATE OF SERVICE BY MAIL 

Page: 1 

V31013a (June 2004) Code of Civil Procedure,§ CCP1013(a) Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 7 of

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SUPERIOR COURT OF THE STATE OF CALIFORNIA 

COUNTY OF SACRAMENTO 

Coordination Proceeding Special Title 

(CRC 3.550) 

BUTIE FIRE CASES 

Case No. JCCP 4853 

[PIE J fl Jl!IJ] ORDER GRANTING 

MOTION FOR ENTRY OF 

STIPULATED JUDGMENT 

The joint motion of Defendants Pacific Gas and Electric Company and PG&E Corporation 

(collectively, "PG&E") and Plaintiffs Barbara Jean Zelmer and Robert Thomas Zelmer 

(collectively, "Zelmers") for an order entering judgment in accordance with the terms of the 

Stipulated Judgment entered between the Zelmers and PG&E came on for hearing in Department 

4 OtOUJOJJA L.. '2t Z9 ZO/,d' . 42 of this Court on ~-:"' ..,....,,... I 

Having read the motion and the proposed Stipulated Judgment, and having heard argument 

by counsel, the Court hereby grants PG&E' s Motion for Entry of Stipulated Judgment 

THEREFORE, IT IS ORDERED THAT the joint motion is G~ED, and that final 

judgmentl;;:;z.re;u;~ to the Stipulated Jud ~between PGf 1 and the Zelmers. 

DATED: ~r_,2018 ) 

Judge of the Superior Court 

NOV 2 9 2018 

By B. Loriga, Deputy Clerk 

-i- Case No. JCCP 4853 

[PROPOSED] ORDER GRANTING MOTION FOR ENTRY OF STIPULATED JUDGMENT Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 8 of

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Christopher Tayback (SBN 145532) 

Kenneth R. Chiate (SBN 39554) 

Kristen Bird (SBN 192863) 

Jeffrey N. Boozell (SBN 199507) 

FIL 

NOV 2 9 2018 

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

865 South Figueroa Street, 10th Floor 

By B. Loriga, Deputy Clerk 

Los Angeles, CA 9001 7 

Telephone: (213) 443-3000 

christayback@quinnemanuel.com 

kenchiate@quinnemanuel.com 

kristenbird uinnemanuel. com · eftboozell uinnemanuel. com 

Counsel for Defendants Pacific Gas and 

Electric Company and PG&E Corporation 

Manuel Corrales, Jr. (SBN 117647) 

ATTORNEY AT LAW 

17140 Bernardo Center Drive, Ste. 358 

San Diego, CA 92128 

Telephone: (858) 521-0634 

mannycorrales@yahoo.com 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

FOR THE COUNTY OF SACRAMENTO 

Coordination Proceeding 

Special Title (CRC 3.550) 

BUTTE FIRE CASES 

This Document Relates to: 

BARBARAZELJ\.1ER,ROBERT 

ZELJ\.1ER, 

Plaintiffs, 

vs. 

PACIFIC GAS & ELECTRIC COMP ANY, 

et al., 

Defendants. 

Assigned to the Honorable Allen H. Sumner 

Department No. 42 

CASE NO. JCCP 4853 

STIPULATED JUDGMENT 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 9 of

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The Parties hereby stipulate and consent to final judgment resolving the entire case as 

follows: 

WHEREAS, Plaintiffs Barbara Jean Zelmer and Robert Thomas Zelmer ("the 

Zelmers") filed complaints against Defendant Pacific Gas & Electric Company 

("PG&E") asserting claims for inverse condemnation, negligence, trespass, public 

nuisance, private nuisance, negligence per se, premises liability, violation of California 

Public Utilities Code § 2106, and violation of California Health and Safety Code 

§ 13007, and alleging damage to their home in Calaveras County, California and other 

property damage as a result of the 2015 Butte Fire; 

WHEREAS, the Zelmers have requested dismissal with prejudice of their causes 

of action against PG&E for negligence, trespass, public nuisance, private nuisance, 

negligence per se, premises liability, viOlation of' California Public Utilities Code § 2106, 

and violation of California Health and Safety Code § 13007, leaving inverse 

condemnation as their sole cause of action; 

WHEREAS, PG&E denies any liability for the damages claimed by the Zelmers; 

WHEREAS, PG&E believes this Court's June 22, 2017 and May 1, 2018 orders 

holding PG&E liable for inverse condemnation damages to be prejudicially erroneous 

and subject to reversal on appeal, but that the expense of trial, both to the court system 

and the litigants, is unwarranted given the standard for liability under inverse 

condemnation that was adopted by this Court, including the Court's rejection of legal 

arguments made in PG&E's May 5, 2017 motion and January 4, 2018 Renewed Motion; 

WHEREAS, the Parties wish to enter into a stipulated judgment that is final but 

reserves the right of PG&E to appeal from the June 22, 2017 and May 1, 2018 orders 

holding PG&E liable in inverse condemnation for damages arising out the Butte Fire; 

THEREFORE, the Parties agree that the Court should enter a final judgment 

03 765-00001/10433300.1 2 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 10

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resolving all of Plaintiffs' claims and the entire case consisting of the terms set forth 

below for the purpose of facilitating PG&E' s appeal of the Court's June 22, 2017 and 

May 1, 2018 orders: 

1. Plaintiffs shall take nothing on their claims against Defendant PG&E for 

negligence, trespass, public nuisance, private nuisance, negligence per se, premises 

liability, violation of California Public Utilities Code § 2106, and violation of California 

Health and Safety Code § 130, which have been dismissed; 

2. On Plaintiffs' First Cause of Action for Inverse Condemnation in their 

Complaint and Fourth Cause of Action for Inverse Condemnation in their Adoption 

Complaint, judgment shall be entered in favor of Plaintiffs and against Defendant PG&E 

in the amount of $850,000, inclusive of fees and costs; 

3. This stipulated final judgment resolving all of the claims in this case is 

without prejudice to the rights of PG&E to appeal this final judgment, including the 

Court's June 22, 2017 order denying PG&E's Motion for a Legal Determination of 

Inverse Condemnation Liability and its May 1, 2018 order denying PG&E's Renewed 

Motion for a Legal Determination of Inverse Condemnation Liability; 

4. Plaintiffs hereby waive, pursuant to Code of Civil Procedure § 995.230, 

any requirement that Defendant post an undertaking, bond or security deposit to stay, and 

they agree not to enforce the Judgment pending appeal from this Judgment. 

Ill 

I II 

I II 

II I 

I II 

03 765--00001/l 0433300.1 3 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 11

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IT IS SO STIPULATED 

DATED: October 1 , 2018 

tt('/} 0 DATED: 7 , 2018 --+------

IT IS SO ORDERED. 

QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

By 

Jeffrey 

Kenneth/~~at 

N. 

~ Boozell 

Kristen Bird 

Attorney for Defendants 

Pacific Gas and Electric Company 

and PG&E Corporation 

Attorney for the Zelmers 

~\,~ 

Dated this z:q day of_, 2018. 

By __ -H-''<-->'-=->..:~---------- HON. ,rH _ _,.lJ.lJ 

Judge of the Superior Court 

03765.()0001/10433300.1 4 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 12

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EXHIBIT “2”

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SUPERIOR COURT OF CALIFORNIA 

County of Sacramento 

720 Ninth Street, Appeals Unit Room 102 

Sacramento, CA 95814-1380 

(916) 874-3701-Website www.saccourt.ca.gov 

BARBARA ZELMER, ROBERT ZELMER 

Plaintiff/Respondent 

SUPERIOR COURT 

NUMBER: JCCP 4853 

vs. 

PACIFIC GAS & ELECTRIC COMP ANY et al 

Defendant/ A ellant 

NOTICE OF FILING 

NOTICE OF APPEAL 

Please be advised that on December 12, 2018 a NOTICE OF APPEAL was filed in the 

above entitled cause. 

SUPERIOR COURT OF CALIFORNIA 

COUNTY OF SACRAMENTO 

DATED:: December 12, 2018 

SUPERIOR COURT OF CALIFORNIA) 

COUNTY OF SACRAMENTO ) 

KevinM. 

By: Deputy Clerk 

DECLARATION OF MAILING 

As Deputy Clerk of the Superior Court of California, County of Sacramento, I hereby 

declare under penalty of perjury, that I have this day mailed, by first class mail, postage fully 

prepaid, a true and correct copy of the above notice to each of the persons hereinafter set 

forth, addressed as follows: 

MANUEL CORRALES #117647 

17140 BERNARDO CENTER DR., STE 358 

SAN DIEGO, CA 92128 

858-521-0634 

Representing: Plaintiff/Respondent 

COURT OF APPEAL 

THIRD APPELLATE DISTRICT 

914 CAPITOL MALL 4TH FLOOR 

SACRAMENTO, CA 95814 

CHRISTOPHER TAYBACK#192863 

QUINN EMANUEL URQUHART & SULLIVAN LLP 

865 S. FIGUEROA STREET, 1 OTH FL 

LOS ANGELES, CA 90017 

213-443-3000 

Representing: DefendanUAppellant 

Executed at Sacramento, California, on December 13, 2018 

KevinM. 

DEPUTY CLERK 

Notice of Filing Notice of Appeal 

CV\E-SU-23 Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 14 (Rev 9.1.2006) Page 1of1 

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EXHIBIT “3”

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Case No. JCCP 4853

PG&E’s Notice of Filing of Notice of Appeal

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

 Christopher Tayback (Bar No. 145532) 

 christayback@quinnemanuel.com 

 Kristen Bird (Bar No. 192863) 

 kristenbird@quinnemanuel.com 

 Jeffrey N. Boozell (Bar No. 199507) 

 jeffboozell@quinnemanuel.com 

865 South Figueroa Street, 10th Floor 

Los Angeles, California 90017-2543 

Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 

Attorneys for Defendants 

PACIFIC GAS AND ELECTRIC COMPANY and 

PG&E CORPORATION 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

COUNTY OF SACRAMENTO

Coordination Proceeding

Special Title (CRC 3.550) 

BUTTE FIRE CASES

Case No. JCCP 4853

NOTICE OF FILING OF NOTICE OF 

APPEAL 

Hon. Allen H. Sumner 

Dept.: 42 

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Case No. JCCP 4853

PG&E’s Notice of Filing of Notice of Appeal

PLEASE TAKE NOTICE that Defendants and Appellants Pacific Gas and Electric 

Company and PG&E Corporation have filed the attached Notice of Appeal in Zelmer v. PG&E, 

San Francisco County Superior Court, Case No. CGC-17-561107. For the reasons set forth in the 

Court’s November 29, 2018 order, this notice is provided for information purposes only. 

DATED: December 11, 2018 QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

By

Christopher Tayback 

Kristen Bird 

Jeffrey N. Boozell 

ATTORNEYS FOR DEFENDANTS 

PACIFIC GAS AND ELECTRIC COMPANY 

AND PG&E CORPORATION 

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03765-00001/10571948.3 Case No. JCCP 4853

PG&E’s Notice of Appeal

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

 Christopher Tayback (Bar No. 145532) 

 christayback@quinnemanuel.com 

 Kristen Bird (Bar No. 192863) 

 kristenbird@quinnemanuel.com 

 Jeffrey N. Boozell (Bar No. 199507) 

 jeffboozell@quinnemanuel.com 

865 South Figueroa Street, 10th Floor 

Los Angeles, California 90017-2543 

Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 

Attorneys for Defendants 

PACIFIC GAS AND ELECTRIC COMPANY and 

PG&E CORPORATION 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

COUNTY OF SACRAMENTO

Coordination Proceeding

Special Title (CRC 3.550) 

BUTTE FIRE CASES

This Document Relates to: 

BARBARA ZELMER, ROBERT ZELMER, 

 Plaintiffs, 

vs. 

PACIFIC GAS & ELECTRIC COMPANY, et 

al., 

 Defendants.

Case No. JCCP 4853

San Francisco County Superior Court 

Case No. CGC-17-561107 (Joses) 

NOTICE OF APPEAL 

Hon. Allen H. Sumner 

Dept.: 42 

Action Filed: September 1, 2017 

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03765-00001/10571948.3 Case No. JCCP 4853

PG&E’s Notice of Appeal

PLEASE TAKE NOTICE that Defendants and Appellants Pacific Gas and Electric 

Company and PG&E Corporation hereby appeal from the stipulated judgment entered on 

November 29, 2018 and each and every part of that judgment. 

DATED: December 11, 2018 QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

By

Christopher Tayback 

Kristen Bird 

Jeffrey N. Boozell 

ATTORNEYS FOR DEFENDANTS 

PACIFIC GAS AND ELECTRIC COMPANY 

AND PG&E CORPORATION 

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03765-00001/10571948.3 -i- Case No. JCCP 4853

PG&E’s Notice of Appeal

PROOF OF SERVICE 

I am employed in the County of Los Angeles, State of California. I am over the age of 

eighteen years and not a party to the within action; my business address is 865 South Figueroa 

Street, 10th Floor, Los Angeles, California 90017-2543. 

 On December 11, 2018, I served a true copy of the following document(s) described as 

on the interested parties in this action pursuant to the most recent Service List. 

 BY HAND DELIVERY: In addition, I caused the above-described documents to be hand 

delivered via messenger at the addresses noted below: 

Manuel Corrales, Jr. 

17140 Bernardo Center Drive, Ste. 358 

San Diego, CA 92128 

 I declare under penalty of perjury under the laws of the State of California that the 

foregoing is true and correct. 

Executed on December 11, 2018, at Los Angeles, California. 

Omar Galicia

NOTICE OF APPEAL 

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-i- Case No. JCCP 4853

Proof of Service

PROOF OF SERVICE 

I am employed in the County of Los Angeles, State of California. I am over the age of 

eighteen years and not a party to the within action; my business address is 865 South Figueroa 

Street, 10th Floor, Los Angeles, California 90017-2543. 

 On December 11, 2018, I served a true copy of the following document(s) described as 

on the interested parties in this action pursuant to the most recent Service List. 

 BY ELECTRONIC FILING SERVICE: Pursuant to C.C.P. §1010.6, Cal. R. Ct. Rule 

2.260, and the parties’ agreement to accept service by e-mail or electronic transmission, I caused 

the document(s) to be sent to the person(s) at the e-mail address listed by submitting a PDF format 

copy of such document via file transfer protocol (FTP) to CaseHomePage through the upload 

feature at www.casehomepage.com on December 11, 2018. The document(s) was transmitted by 

file transfer protocol (FTP) without error. 

I declare under penalty of perjury under the laws of the State of California that the 

foregoing is true and correct. 

Executed on December 11, 2018, at Los Angeles, California. 

Omar Galicia

NOTICE OF FILING OF NOTICE OF APPEAL

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 21

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EXHIBIT “4”

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP 

KENNETH R. CHIATE (SBN 39554) 

2 kenchiate@quinnemanuel.com 

JEFFREY N. BOO ZELL (SBN 199507) 

3 jefjboozell@quinnemanuel.com 

SARAH J. COLE (SBN 222719) 

4 sarahco/e@quinnemanuel.com 

865 South Figueroa Street, 10th Floor 

5 Los Angeles, CA 90017 

Telephone: (213) 443-3000 

6 Facsimile: (213) 443-3100 

7 GOUGH & HANCOCK LLP 

GAYLE L. GOUGH (SBN 154398) 

8 gay/e.gough@ghcounsel.com 

649 Mission Street, Suite 460 

9 San Francisco, CA 94105 

Telephone: ( 415) 848-8900 

10 Facsimile: (415) 974-6745 

11 Attorneys for Defendants 

PACIFIC GAS AND ELECTRIC COMPANY 

12 and PG&E CORPORATION 

13 

14 

15 

16 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

COUNTY OF SACRAMENTO 

17 Coordination Proceeding 

18 Special Title (CRC 3.550) 

JCCP 4853 

DEFENDANT PACIFIC GAS AND 

ELECTRIC COMPANY'S RESPONSE TO 

PLAINTIFFS' FORM 

INTERROGATORIES, SET ONE 

19 

20 

21 

22 

23 

24 

25 

26 

BUTTE FIRE CASES 

PROPOUNDING PARTY: All Plaintiffs 

RESPONDING PARTY: Defendant Pacific Gas and Electric Company 

SETNO.: One 

Defendant Pacific Gas and Electric Company ("PG&E"), pursuant to Code of Civil 

27 Procedure sections 2030.010 through 2030.410, responds to Plaintiffs' First Set of Form 

28 Interrogatories as follows: 

-1-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 FORMINTERROGATORYN0.1.1: 

2 State the name, ADDRESS, telephone number and relationship to you of each PERSON 

3 who prepared or assisted in the preparation of the responses to these interrogatories. (Do not 

4 identify anyone who simply typed or reproduced the responses.) 

5 RESPONSE TO FORM INTERROGATORY NO. 1.1: 

6 PG&E's attorneys of record prepared and/or assisted in the preparation of these responses. 

7 FORMINTERROGATORYN0.3.1: 

8 Are you a corporation? If so, state: 

9 (a) The name stated in the current articles of incorporation; 

10 (b) All other names used by the corporation during the past 10 years and the dates each 

11 was used; 

12 (c) The date and place of incorporation; 

13 (d) The ADDRESS of the principal place of business; and 

14 ( e) Whether you are qualified to do business in California. 

15 RESPONSE TO FORM INTERROGATORY NO. 3.1: 

16 Yes. 

17 

18 

19 

20 

21 

(a) 

(b) 

(c) 

(d) 

(e) 

Pacific Gas and Electric Company; 

None; 

October 10, 1905, San Francisco, California; 

77 Beale Street, San Francisco, California 94105; 

Yes 

22 FORM INTERROGATORY NO. 4.1: 

23 At the time of the INCIDENT, was there in effect any policy of insurance through which 

24 you were or might be insured in any manner (for example, primary, pro-rata, or excess liability 

25 coverage or medical expense coverage) for the damages, claims, or actions that have arisen out of 

26 the INCIDENT? If so, for each policy state: 

27 (a) The kind of coverage; 

28 

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DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 (b) The name and ADDRESS of the insurance company; 

2 ( c) The name, ADDRESS, and telephone number of each named insured; 

3 ( d) The policy number; 

4 ( e) The limits of coverage for each type of coverage contained in the policy; 

5 ( t) Whether any reservation of rights or controversy or coverage dispute exists between 

6 you and the insurance company; and 

7 (g) The name, ADDRESS, and telephone number of the custodian of the policy. 

8 RESPONSE TO FORM INTERROGATORY NO. 4.1: 

9 PG&E has insurance coverage for third party claims. PG&E's insurers for 2015-2016 are 

10 identified in the chart produced in response to request for production no. 20. PG&E and its 

11 insurers are custodians of these policies. In addition, PG&E has coverage through policies 

12 obtained by Trees, Inc. and ACRT, including policies that include PG&E as an additional insured. 

13 FORM INTERROGATORY NO. 4.2: 

14 Are you self-insured under any statute for the damages, claims or actions that have arisen 

15 out of the INCIDENT? If so, specify the statute. 

16 RESPONSE TO FORM INTERROGATORY NO. 4.2: 

17 Not applicable. PG&E is insured as stated in response to Interrogatory No. 4.1. 

18 FORMINTERROGATORYN0.12.1: 

19 State the name, ADDRESS, and telephone number of each individual: 

20 (a) Who witnessed the INCIDENT or the events occurring immediately before or after the 

21 INCIDENT; 

22 (b) Who made any statement at the scene of the INCIDENT; 

23 (c) Who heard any statements made about the INCIDENT by any individual at the scene; 

24 and 

25 (d) Who YOU OR ANYONE ACTING ON YOUR BEHALF claim has knowledge of the 

26 INCIDENT (except for expert witnesses covered by Code of Civil Procedure section 

27 2034). 

28 

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DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 RESPONSETOFORMINTERROGATORYN0.12.1: 

2 (a)-(c) PG&E understands that INCIDENT in this request means the start of the Butte 

3 Fire on September 9, 2015, on the Caufield Ranch, in Amador County. PG&E objects to the 

4 extent the request is vague and ambiguous. Pursuant to Code of Civil Procedure section 2030.230, 

5 PG&E refers Plaintiffs to the Cal Fire Investigation Report, including the witness statements of 

6 Jamie Affonso, Jack and Diane Caufield, Louie Podesta Jr., and Louie Podesta Sr., and the aerial 

7 photographs taken by Michael Lombart, a subcontracted pilot of P J Helicopters. 

8 ( d) Cal Fire contacted PG&E representatives on September 11, 2015 to go to the area of 

9 origin. PG&E employees Robert Cupp, Jason Regan, Mark Rasmussen, Barry Anderson, Richard 

10 Yarnell, Micah Brosnan, Niel Fischer, Eric Back, Becky Johnson, and Kamran Rasheed went to 

11 the area of origin on September 11 and 12, 2015. These individuals can be contacted through 

12 counsel for PG&E. Thereafter, the area of origin was visited on numerous occasions by the 

13 parties. PG&E objects to this interrogatory to the extent that it is overbroad, vague, and seeks the 

14 work product of PG&E's attorneys or expert witnesses covered by Code of Civil Procedure 

15 sections 2034.210-2034.310. 

16 FORM INTERROGATORY NO. 12.2: 

17 Have YOU OR ANYONE ACTING ON YOUR BEHALF interviewed any individual 

18 concerning the INCIDENT? If so, for each individual state: 

19 (a) The name, ADDRESS, and telephone number of the individual interviewed; 

20 (b) The date of the interview; and 

21 (c) The name, ADDRESS, and telephone number of the PERSON who conducted the 

22 interview. 

23 RESPONSE TO FORM INTERROGATORY NO. 12.2: 

24 PG&E understands that INCIDENT in this request means the start of the Butte Fire on 

25 September 9, 2015, on the Caufield Ranch, in Amador County. PG&E objects to the extent the 

26 request is vague and ambiguous. PG&E cooperated with Cal Fire's investigation of the incident. 

27 PG&E objects to this interrogatory to the extent that it seeks attorney work product or attorney28 

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DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 client privileged communications. Subject to and without waiving these objections, PG&E 

2 responds as follows: Jason Burke, who may be contacted through PG&E's counsel; Susan 

3 Vinciguerra; Walt Ballard; and Michael Lombart. 

4 FORMINTERROGATORYNO. 12.3: 

5 Have YOU OR ANYONE ACTING ON YOUR BEHALF obtained a written or recorded 

6 statement from any individual concerning the INCIDENT? If so, for each statement state: 

7 (a) The name, ADDRESS, and telephone number of the individual from whom the 

8 statement was obtained; 

9 (b) The name, ADDRESS, and telephone number of the individual who obtained the 

10 statement; 

11 ( c) The date the statement was obtained; and 

12 (d) The name, ADDRESS, and telephone number of each PERSON who has the original 

13 statement or a copy. 

14 RESPONSE TO FORM INTERROGATORY NO. 12.3: 

15 PG&E understands that INCIDENT in this request means the start of the Butte Fire on 

16 September 9, 2015, on the Caufield Ranch, in Amador County. PG&E objects to the extent the 

17 request is vague and ambiguous and seeks attorney work product or attorney-client privileged 

18 communications. Subject to and without waiving these objection and pursuant to Code of Civil 

19 Procedure section 2030.230, PG&E refers Plaintiffs to the Cal Fire Investigation Report, including 

20 the witness statements of Jamie Affonso, Jack and Diane Caufield, Louie Podesta Jr., and Louie 

21 Podesta Sr. PG&E has not otherwise obtained written or recorded witness statements. 

22 FORM INTERROGATORY NO. 12.4: 

23 Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any photographs, films, 

24 or videotapes depicting any places, object, or individual concerning the INCIDENT or plaintiff's 

25 injuries? If so, state: 

26 (a) The number of photographs or feet of film or videotape; 

27 (b) The places, objects, or persons photographed, filmed, or videotaped; 

28 

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DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 ( c) The date the photographs, films, or videotapes were taken; 

2 (d) The name, ADDRESS, and telephone number of the individual taking the photographs, 

3 films, or videotapes; and 

4 ( e) The name, ADDRESS, and telephone number of each PERSON who has the original 

5 or a copy of the photographs, films, or videotapes. 

6 RESPONSE TO FORM INTERROGATORY NO. 12.4: 

7 PG&E understands that INCIDENT in this request means the start of the Butte Fire on 

8 September 9, 2015, on the Caufield Ranch, in Amador County. PG&E objects to the extent the 

9 request is vague and ambiguous. Pursuant to Code of Civil Procedure section 2030.230, PG&E 

10 refers Plaintiffs to the Cal Fire Investigation Report, including aerial photographs taken by 

11 Michael Lombart and the photographs provided by PG&E to Cal Fire (published at 

12 www.fire.ca.gov/fire protection/fire protection firereports); and the photographs produced to the 

13 California Public Utilities Commission, which are produced in response to Plaintiffs' request for 

14 production of documents. PG&E objects to this request to the extent that it seeks the work 

15 product of PG&E's attorneys or expert witnesses covered by Code of Civil Procedure sections 

16 2034.210-2034.310. PG&E further objects to the extent the request is overbroad and burdensome. 

17 Subject to and without waiving this objection, PG&E responds that it is also aware that 

18 photographs were taken by the parties at inspections in the area of origin and evidence inspections 

19 allowed by Cal Fire that were attended by the parties. 

20 FORMINTERROGATORYN0.12.5: 

21 Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any diagram, 

22 reproduction, or model or any place or thing (except for items developed by expert witnesses 

23 covered by Code of Civil Procedure sections 2034.210-2034.310) concerning the INCIDENT? If 

24 so, for each item state: 

25 (a) The type (i.e., diagram, reproduction, or model); 

26 (b) The subject matter; and 

27 ( c) The name, ADDRESS, and telephone number of each PERSON who has it. 

28 

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DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 RESPONSE TO FORM INTERROGATORY NO. 12.5: 

2 PG&E understands that INCIDENT in this request means the start of the Butte Fire on 

3 September 9, 2015, on the Caufield Ranch, in Amador County. PG&E objects to the extent the 

4 request is vague and ambiguous. Pursuant to Code of Civil Procedure section 2030.230, PG&E 

5 refers Plaintiffs to the Cal Fire Investigation Report and a drawing by Mark Rasmussen 

6 identifying the location where a section of the conductor was removed at the request of Cal Fire. 

7 The drawing is produced in response to Plaintiffs' request for production of documents. PG&E 

8 objects to this request to the extent that it seeks the work product of PG&E's attorneys or expert 

9 witnesses covered by Code of Civil Procedure sections 2034.210-2034.310. PG&E further objects 

10 to the extent it is overbroad and burdensome. 

11 FORMINTERROGATORYN0.12.6: 

12 Was a report made by any PERSON concerning the INCIDENT? If so, state: 

13 (a) The name, title, identification number, and employer of the PERSON who made the 

14 report; 

15 (b) The date and type of report made; 

16 ( c) The name, ADDRESS, and telephone number of the PERSON for whom the report 

17 was made; and 

18 (d) The name, ADDRESS, and telephone number of each PERSON who has the original 

19 or a copy of the report. 

20 RESPONSE TO FORM INTERROGATORY NO. 12.6: 

21 PG&E understands that INCIDENT in this request means the start of the Butte Fire on 

22 September 9, 2015, on the Caufield Ranch, in Amador County. PG&E objects to the extent the 

23 request is vague and ambiguous. Pursuant to Code of Civil Procedure section 2030.230, PG&E 

24 refers Plaintiffs to the Cal Fire Investigation Report, PG&E's Electric Safety Incident Report to 

25 the California Public Utilities Commission, and the 2015 Fire Patrol Recap for 9/7 to 9/13. These 

26 last two reports will be produced in response to Plaintiffs' request for production of documents. 

27 PG&E objects to this request to the extent that it seeks the work product of PG&E's attorneys or 

28 

-7-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 expert witnesses covered by Code of Civil Procedure sections 2034.210-2034.310. PG&E further 

2 objects to the extent it is vague, ambiguous, and overbroad. 

3 FORM INTERROGATORY NO. 12.7: 

4 Have YOU OR ANYONE ACTING ON YOUR BEHALF inspected the scene of the 

5 INCIDENT? If so, for each inspection state: 

6 (a) The name, ADDRESS, and telephone number of the individual making the inspection 

7 (except for expert witnesses covered by Code of Civil Procedure sections 2034.210-

8 2034.31 O); and 

9 (b) The date of the inspection. 

10 RESPONSE TO FORM INTERROGATORY NO. 12.7: 

11 PG&E understands that INCIDENT in this request means the start of the Butte Fire on 

12 September 9, 2015, on the Caufield Ranch, in Amador County. PG&E objects to the extent the 

13 request is vague and ambiguous. Pursuant to Code of Civil Procedure section 2030.230, PG&E 

14 refers Plaintiffs to the Cal Fire Investigation Report. Cal Fire contacted PG&E representatives on 

15 September 11, 2015 to go to the area of origin. PG&E employees Robert Cupp, Jason Regan, 

16 Mark Rasmussen, Barry Anderson, Richard Yarnell, Micah Brosnan, Niel Fischer, Eric Back, 

17 Becky Johnson, and Kamran Rasheed went to the area of origin on September 11 and 12, 2015. 

18 These individuals can be contacted through counsel for PG&E. Thereafter, the area of origin was 

19 visited on numerous occasions by the parties. PG&E objects to this interrogatory to the extent that 

20 it seeks the work product of PG&E's attorneys or expert witnesses covered by Code of Civil 

21 Procedure sections 2034.210-2034.310. PG&E further objects to the extent it is vague, 

22 ambiguous, and overbroad. 

23 FORMINTERROGATORYN0.17.1: 

24 Is your response to each request for admission served with these interrogatories an 

25 unqualified admission? If not, for each response that is not an unqualified admission: 

26 (a) State the number of the request; 

27 (b) State all facts upon which you base your response; 

28 

-8-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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1 ( c) State the names, ADDRESSES, and telephone numbers of all PERSONS who have 

2 knowledge of those facts; and 

3 ( d) Identify all DOCUMENTS and other tangible things that support your response and 

4 state the name, ADDRESS, and telephone number of the PERSON who has each 

5 DOCUMENT or thing. 

6 RESPONSETOFORMINTERROGATORYN0.17.1: 

7 PG&E incorporates herein by reference each and every response and objection stated in the 

8 responses to requests for admissions, set one. As to requests 20 through 23, PG&E responds as 

9 follows: 

10 Request no. 20 

11 PG&E objects to this request as vague and ambiguous. PG&E objects to the extent this 

12 request seeks the work product of attorneys or expert witnesses covered by Code of Civil 

13 Procedure sections 2034.210-2034.310. Subject to and without waiving the objection, PG&E 

14 states that it does not have sufficient information to respond to this request. Cal Fire's recent 

15 report related to the Butte Fire referred to additional evidence that has not yet been produced. 

16 Discovery and investigation are continuing at this time. 

17 Request no. 21 

18 PG&E objects to this request as vague and ambiguous. PG&E objects to the extent this 

19 request seeks the work product of attorneys or expert witnesses covered by Code of Civil 

20 Procedure sections 2034.210-2034.310. Subject to and without waiving the objection, PG&E 

21 states that it does not have sufficient information to respond to this request. Cal Fire's recent 

22 report related to the Butte Fire ref erred to additional evidence that has not yet been produced. 

23 Discovery and investigation are continuing at this time. 

24 Request no. 22 

25 PG&E objects to this request as vague and ambiguous. PG&E objects to the extent this 

26 request seeks the work product of attorneys or expert witnesses covered by Code of Civil 

27 Procedure sections 2034.210-2034.310. Subject to and without waiving the objection, PG&E 

28 

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DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM INTERROGATORIES, SET ONE 

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states that it does not have sufficient info rmation to respond to this request. Cal Fire's recent 

2 report related to the Butte Fire referred to additional evidence that has not yet been produced. 

3 Discovery and investigation are continuing at this time. 

4 Request no. 23 

5 PG&E objects to this request as vague and ambiguous. PG&E objects to the extent this 

6 request seeks the work product of attorneys or expert witnesses covered by Code of Civil 

7 Procedure sections 2034.210-2034.310. Subj ect to and without waiving the objection, PG&E 

8 states that it does not have sufficient information to respond to this request. Cal Fire's recent 

9 report related to the Butte Fire referred to additional evidence that has not yet been produced. 

I 0 Discovery and investigation are continuing at this time. 

11 DATED: ~ )3, 2..0\lp 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

By: _))~j~ Kenneth R. Chiate 

Jeffrey N. Boozell 

Sarah J. Cole 

QUINN EMANUEL URQUHART & SULLIVAN, 

LLP 

Gayle L. Gough 

GOUGH & HANCOCK LLP 

Attorneys for Defendants 

PACIFIC GAS AND ELECTRIC COMPANY 

and PG&E CORPORATION 

-I 0-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' FORM fNTERROGATORJES, SET ONE 

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2 

.... 

.) 

RE: Butte Fire Cases 

JCCP 4853 

4 VERIFICATION 

5 I, the undersigned. say: 

6 l am an offi cer, lo wit, Assislanl Corporate Secretary of PACIFIC GAS AN D ELECTRIC 

7 COMPANY, a corporation. and am authorized, pursuant to Code of Civil Procedure Section 

8 446(a), to make this verification for and on behalf of said corporation. and I make this 

9 verification fo r that reason: I have read the foregoing document. DEFEN DANT PACIFIC GAS 

10 ANO ELECTRIC COMPANY'S RESPONSE TO PLAINTIFFS' FORM 

11 INTERROGATO RI ES, SET O NE, and I am informed and believe the mallers therein are true 

11 and on that ground I allege that the matters stated therein are true. 

13 I declare under penalty of perjury that the foregoing i true and correct. 

14 Executed on May 2 . 20 16, at San f-'rancisco. Californ ia. 

15 

16 

17 

18 

19 

20 

21 

22 

24 

r _ .) 

26 

27 

28 

Eil een Chan 

VERIFICATI0 1 Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 33

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EXHIBIT “5”

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QUINN EMANUEL URQUHART & SULLIVAN, LLP 

KENNETH R. CHIATE (SBN 39554) 

2 kenchiate@quinnemanuel.com 

JEFFREY N. BOOZELL (SBN 199507) 

3 jefjboozell@quinnemanuel.com 

SARAH J. COLE (SBN 222719) 

4 sarahcole@quinnemanuel.com 

865 South Figueroa Street, 10th Floor 

5 Los Angeles, CA 90017 

Telephone: (213) 443-3000 

6 Facsimile: (213) 443-3100 

7 GOUGH & HANCOCK LLP 

GAYLE L. GOUGH (SBN 154398) 

8 gayle.gough@ghcounsel.com 

649 Mission Street, Suite 460 

9 San Francisco, CA 94105 

Telephone: ( 415) 848-8900 

10 Facsimile: (415) 974-6745 

11 Attorneys for Defendants 

PACIFIC GAS AND ELECTRIC COMPANY 

12 and PG&E CORPORATION 

13 

14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 

15 

16 

l 7 Coordination Proceeding 

18 Special Title (CRC 3.550) 

19 

20 

21 

BUTTE FIRE CASES 

COUNTY OF SACRAMENTO 

JCCP 4853 

DEFENDANT PACIFIC GAS AND 

ELECTRIC COMPANY'S RESPONSE TO 

PLAINTIFFS' REQUESTS FOR 

PRODUCTION OF DOCUMENTS AND 

THINGS, SET ONE 

22 PROPOUNDING PARTY: All Plaintiffs 

23 RESPONDING PARTY: Defendant Pacific Gas and Electric Company 

24 SET NO.: One 

25 

26 Pursuant to Code of Civil Procedure sections 2031.010-2031.510, Defendant Pacific Gas 

27 and Electric Company ("PG&E") hereby responds to plaintiffs' Request for Production of 

28 

-1-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

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Documents, Set One, as follows: 

2 REQUEST NO. 1: 

3 Any and all DOCUMENTS THAT RELATE TO the statements made on Page 36 of the 

4 Quarterly Report Pursuant to Section 15 or 15( d) of the Securities Exchange Act of 1934 filed by 

5 PG&E on or about September 30, 2015, which statements are as follows: 

6 "Investigation oftlze Butte Fire 

7 In September 2015, a wildfire (known as the "Butte Fire") ignited and spread in 

8 Amador and Calaveras Counties in Northern California. The California Department of 

9 Forestry and Fire Protection ("Cal Fire") is investigating the source of the fire including 

10 whether a live tree may have contacted a power line owned and operated by the Utility, in 

11 the vicinity of the ignition point. The Utility also is conducting an investigation. Cal Fire 

12 has reported that as a result of the fire there were two deaths and 965 structures, including 

13 571 houses, were damaged or destroyed. 

14 Although the cause of the fire has not yet been determined, PG&E Corporation and 

15 the Utility believe that it is reasonably possible that the Utility will incur a material amount 

16 of losses associated with third-party claims for property damage, fire suppression costs, 

17 personal injury, or other claims. PG&E Corporation and the Utility are unable to 

18 reasonably estimate the amount of possible losses (or range amounts) given the 

19 preliminary stages of the investigation into the cause of the fire and uncertainty about the 

20 extent and value of real and personal property damaged by the fire which spread over 

21 70,000 acres much of which is remote and rugged terrain. The Utility has insurance 

22 coverage for these types of claims. If the amount of insurance is insufficient to cover the 

23 Utility's liability resulting from the Butte fire, or if insurance is otherwise available, PG&E 

24 Corporation's and the Utility's financial condition or results or operations could be 

25 materially affected." 

26 RESPONSE TO REQUEST NO. 1: 

27 PG&E responds that the Cal Fire information and evidence available to PG&E has been 

28 

-2-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

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1 made equally available to Plaintiffs. Subject to and without waiving objections based on attorney2 client privilege, the work product doctrine, and Code of Civil Procedure sections 2034.010 et seq. 

3 regarding expert witnesses, PG&E will produce the information referred to in form interrogatory 

4 responses regarding available insurance and the information produced to the CPUC and Cal Fire. 

5 PG&E objects to the extent this request is vague, ambiguous, overbroad, and burdensome. PG&E 

6 is willing to meet and confer with Plaintiffs regarding this request. 

7 REQUEST NO. 2: 

8 Any and all DOCUMENTS THAT RELATE TO PG&E's compliance during the five9 year period immediately preceding the BUTTE FIRE with the requirements stated in Public 

10 Utilities Code§ 451 with respect to the POWER POLES and POWER LINES located on the 

11 CAUFIELD RANCH. 

12 RESPONSE TO REQUEST NO. 2: 

13 Procedures, contracts, inspections, and work records for five years preceding the Butte fire 

14 that relate to the Electra 1101 circuit that crosses the property identified as the Caufield Ranch are 

15 responsive to this request. The Electra 1101 circuit is also identified in vegetation management 

16 records by the prior name of "Martell 1102." Subject to and without waiving objections on the 

17 grounds of attorney-client privilege, the work product doctrine, and expert witness discovery 

18 provided by Code of Civil Procedure sections 2034.010, and pursuant to an appropriate protective 

19 order, PG&E will produce non-privileged responsive documents identified above. PG&E objects 

20 to the extent the request is vague, ambiguous, overbroad and burdensome. 

21 REQUEST NO. 3: 

22 Any and all DOCUMENTS THAT RELATE TO PG&E's compliance during the five-year 

23 period immediately preceding the BUTTE FIRE with the requirements stated in Public Resources 

24 Code§ 4292 with respect to the POWER POLES and POWER LINES located on the CAUFIELD 

25 RANCH. 

26 RESPONSE TO REQUEST NO. 3: 

27 Procedures, contracts, inspections, and work records for five years preceding the Butte fire 

28 

-3-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

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that relate to the Electra 1101 circuit that crosses the property identified as the Caufield Ranch are 

2 responsive to this request. The Electra 1101 circuit is also identified in vegetation management 

3 records by the prior name of "Martell 1102." Subject to and without waiving objections on the 

4 grounds of attorney-client privilege, the work product doctrine, and expert witness discovery 

5 provided by Code of Civil Procedure sections 2034.010, and pursuant to an appropriate protective 

6 order, PG&E will produce the non-privileged responsive documents identified above. PG&E 

7 objects to the extent the request is vague, ambiguous, overbroad and burdensome. 

8 REQUEST NO. 4: 

9 Any and all DOCUMENTS THAT RELATE TO PG&E's compliance during the five-year 

10 period immediately preceding the BUTTE FIRE with the requirements stated in Public Resources 

11 Code§ 4293 with respect to the POWER POLES and POWER LINES located on the CAUFIELD 

12 RANCH. 

13 RESPONSE TO REQUEST NO. 4: 

14 Procedures, contracts, inspections, and work records for five years preceding the Butte fire 

15 that relate to the Electra 1101 circuit that crosses the property identified as the Caufield Ranch are 

16 responsiv.e to this request. The Electra 1101 circuit is also identified in vegetation management 

17 records by the prior name of "Martell 1102." Subject to and without waiving objections on the 

18 grounds of attorney-client privilege, the work product doctrine, and expert witness discovery 

19 provided by Code of Civil Procedure sections 2034.010, and pursuant to an appropriate protective 

20 order, PG&E will produce the non-privileged responsive documents identified above. PG&E 

21 objects to the extent the request is vague, ambiguous, overbroad and burdensome. 

22 REQUEST NO. 5: 

23 Any and all DOCUMENTS THAT RELATE TO PG&E's compliance during the five-year 

24 period immediately preceding the BUTTE FIRE with the requirements stated in Public Utility 

25 Commission General Order 95, including, but not limited to, Rules 33.1and35 of that Order, with 

26 respect to the POWER POLES and POWER LINES located on the CAUFIELD RANCH. 

27 RESPONSE TO REQUEST NO. 5: 

28 

-4-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 38

of 49
1 Procedures, contracts, inspections, and work records for five years preceding the Butte fire 

2 that relate to the Electra 1101 circuit that crosses the property identified as the Caufield Ranch are 

3 responsive to this request. The Electra 1101 circuit is also identified in vegetation management 

4 records by the prior name of "Martell 1102." Subject to and without waiving objections on the 

5 grounds of attorney-client privilege, the work product doctrine, and expert witness discovery 

6 provided by Code of Civil Procedure sections 2034.010, and pursuant to an appropriate protective 

7 order, PG&E will produce the non-privileged responsive documents identified above. PG&E 

8 objects to the extent the request is vague, ambiguous, overbroad and burdensome. 

9 REQUEST NO. 6: 

10 Any and all DOCUMENTS THAT RELATE TO PG&E's compliance during the five-year 

11 period immediately preceding the BUTTE FIRE with the requirements stated in Public Utility 

12 Commission General Order 165 with respect to the POWER POLES and POWER LINES located 

13 on the CAUFIELD RANCH. 

14 RESPONSE TO REQUEST NO. 6: 

15 Procedures, contracts, inspections, and work records for five years preceding the Butte fire 

16 that relate to the Electra 1101 circuit that crosses the property identified as the Caufield Ranch are 

17 responsive to this request. The Electra 1101 circuit is also identified in vegetation management 

18 records by the prior name of "Martell 1102." Subject to and without waiving objections on the 

19 grounds of attorney-client privilege, the work product doctrine, and expert witness discovery 

20 provided by Code of Civil Procedure sections 2034.010, and pursuant to an appropriate protective 

21 order, PG&E will produce the non-privileged responsive documents identified above. PG&E 

22 objects to the extent the request is vague, ambiguous, overbroad and burdensome. 

23 REQUEST NO. 7: 

24 Any and all DOCUMENTS THAT RELATE TO PG&E's compliance with the 

25 requirements stated in North American Electric Reliability Council (NERC) Standard F AC-003-1 

26 with respect to the POWER POLES and POWER LINES located on the CAUFIELD RANCH. 

27 RESPONSE TO REQUEST NO. 7: 

28 

-5-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 39

of 49
1 The North American Electric Reliability Council (NERC) Standard FAC-003-1 pertains to 

2 transmission lines, and the electric lines that cross the property identified as the Caufield Ranch 

3 are distribution lines. The NERC Standard F AC-003-01 is not relevant. Subject to and without 

4 waiving objections on the grounds of attorney-client privilege, the work product doctrine, and 

5 expert witness discovery provided by Code of Civil Procedure sections 2034.010, and pursuant to 

6 an appropriate protective order, PG&E will produce the documents responsive to request numbers 

7 2 through 6, identified above, that show compliance with regulatory requirements. 

8 REQUEST NO. 8: 

9 Any and all DOCUMENTS THAT RELATE TO any report YOU made to any 

10 governmental agency, including, but not limited to the CPUC and the California Department of 

11 Forestry and Fire Protection, regarding the BUTTE FIRE. 

12 RESPONSE TO REQUEST NO. 8: 

13 PG&E provided documents to the CPUC and Cal Fire regarding the Butte Fire. Subject to 

14 and without waiving objections on the grounds of attorney-client privilege, the work product 

15 doctrine, and expert witness discovery provided by Code of Civil Procedure sections 2034.010, 

16 and pursuant to an appropriate protective order, PG&E will produce the non-privileged responsive 

17 documents identified above. PG&E objects to the extent the request is vague, ambiguous, 

18 overbroad and burdensome. 

19 REQUEST NO. 9: 

20 Any and all DOCUMENTS THAT RELATE TO any COMMUNICATIONS that YOU 

21 had with any governmental agency, including, but not limited to the CPUC and the California 

22 Department of Forestry and Fire Protection, regarding the BUTTE FIRE. 

23 RESPONSE TO REQUEST NO. 9: 

24 Documents provided to the CPUC and Cal Fire regarding the Butte Fire and 

25 communications with FEMA are responsive to this request. Subject to and without waiving 

26 objections on the grounds of attorney-client privilege, the work product doctrine, and expert 

27 witness discovery provided by Code of Civil Procedure sections 2034.0 I 0, and pursuant to an 

28 

-6-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 40

of 49
1 appropriate protective order, PG&E will produce non-privileged responsive documents identified 

2 above. PG&E objects to the extent the request is vague, ambiguous, overbroad and burdensome. 

3 REQUEST NO. 10: 

4 Any and all DOCUMENTS that identify any individual or entity, including, but not limited 

5 to, PG&E, who investigated the cause of the BUTTE FIRE. 

6 RESPONSE TO REQUEST NO. 10: 

7 PG&E cooperated with and provided documents to the CPUC and Cal Fire. The Cal Fire 

8 Investigation Report and evidence is equally available to Plaintiffs. Subject to and without 

9 waiving objections on the grounds of attorney-client privilege, the work product doctrine, and 

10 expert witness discovery provided by Code of Civil Procedure sections 2034.010, and pursuant to 

11 an appropriate protective order, PG&E is producing the documents provided to the CPUC and Cal 

12 Fire. PG&E objects to the extent the request is vague, ambiguous, and overbroad. 

13 REQUEST NO. 11: 

14 Any and all any electronic audio recordings relating to the BUTTE FIRE. 

15 RESPONSE TO REQUEST NO. 11: 

16 Cal Fire audio recordings regarding fire suppression operations are equally available to 

1 7 Plaintiffs. PG&E objects to the extent the request is vague, ambiguous, overbroad and 

18 burdensome. Subject to and waiving the objections, PG&E will meet and confer to determine the 

19 documents responsive to this request. 

20 REQUESTNO. 12: 

21 Any and all still and video ground photographs taken within the perimeter of the BUTTE 

22 FIRE. 

23 RESPONSE TO REQUEST NO. 12: 

24 Ground photographs taken by PG&E employees on the property identified by Plaintiffs as 

25 the Caufield Ranch after PG&E was contacted by Cal Fire are responsive to this request. Subject 

26 to and without waiving objections on the grounds of attorney-client privilege, the work product 

27 doctrine, and expert witness discovery provided by Code of Civil Procedure sections 2034.010, 

28 

-7-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 41

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PG&E will produce responsive documents identified above. PG&E objects to the extent the 

2 request is vague, ambiguous, and overbroad. 

3 REQUEST NO. 13: 

4 Any and all any still and video aerial photographs taken of lands within the perimeter of 

5 the BUTTE FIRE. 

6 RESPONSE TO REQUEST NO. 13: 

7 Aerial photographs that were taken of the area where the fire started on September 9, 2015 

8 are responsive. Subject to and without waiving objections on the grounds of attorney-client 

9 privilege, the work product doctrine, and expert witness discovery provided by Code of Civil 

10 Procedure sections 2034.010, PG&E will produce the non-privileged responsive documents 

11 identified above. PG&E objects to the extent the request is vague. ambiguous, and overbroad. 

12 REQUEST NO. 14: 

13 Any and all LIDAR images oflands within the perimeter of the BUTTE FIRE. 

14 RESPONSE TO REQUEST NO. 14: 

15 LiDAR data before the fire is responsive to this request. Cal Fire evidence is equally 

16 available to Plaintiffs. Subject to and without waiving objections on the grounds of attorney-client 

17 privilege, the work product doctrine, and expert witness discovery provided by Code of Civil 

18 Procedure sections 2034.010, PG&E will produce the non-privileged responsive data identified 

19 above. PG&E objects to the extent the request is vague and ambiguous. 

20 REQUESTNO. 15: 

21 Any and all DOCUMENTS THAT RELATE TO any COMMUNICATIONS that YOU 

22 had with any emergency services or authorities at any time concerning the BUTTE FIRE. 

23 RESPONSE TO REQUEST NO. 15: 

24 PG&E objects that this request is overbroad, vague, and ambiguous and includes extensive 

25 documents regarding response to the fire and restoration of services. Subject to and without 

26 waiving objections on the grounds of attorney-client privilege, the work product doctrine, and 

27 expert witness discovery provided by Code of Civil Procedure sections 2034.010, and pursuant to 

28 

-8-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 42

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1 an appropriate protective order, PG&E will produce the responsive documents after meeting and 

2 conferring with Plaintiffs regarding the scope of this demand. 

3 REOUESTNO. 16: 

4 Any and all DOCUMENTS THAT RELATE TO any contracts or agreements that YOU 

5 had with ACRT regarding the maintenance of vegetation located on the CAUFIELD RANCH, 

6 including final contracts or agreements, drafts, bids, and COMMUNICATIONS concerning 

7 negotiations as to terms. 

8 RESPONSE TO REQUEST NO. 16: 

9 Contracts for the five years preceding the Butte Fire are responsive to this request. Subject 

10 to and without waiving objections on the grounds of attorney-client privilege, the work product 

11 doctrine, and expert witness discovery provided by Code of Civil Procedure sections 2034.010, 

12 and pursuant to an appropriate protective order, PG&E will produce the responsive non-privileged 

13 documents identified above. PG&E objects to the extent the request is vague, ambiguous, and 

14 overbroad. 

15 REQUEST NO. 17: 

16 Any and all DOCUMENTS THAT RELATE TO any contracts or agreements that YOU 

17 had with TREES regarding the maintenance of vegetation located on the CAUFIELD RANCH, 

18 including final contracts or agreements, drafts, bids, and COMMUNICATIONS concerning 

19 negotiations as to terms. 

20 RESPONSE TO REQUEST NO. 17: 

21 Contracts for the five years preceding the Butte Fire are responsive to this request. Subject 

22 to and without waiving objections on the grounds of attorney-client privilege, the work product 

23 doctrine, and expert witness discovery provided by Code of Civil Procedure sections 2034.010, 

24 and pursuant to an appropriate protective order, PG&E will produce the responsive non-privileged 

25 documents identified above. PG&E objects to the extent the request is vague, ambiguous, and 

26 overbroad. 

27 REOUESTNO. 18: 

28 

-9-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 43

of 49
1 Any and all DOCUMENTS THAT RELATE TO contracts or agreements between PG&E 

2 and ACRT in force between January 1, 2010, and December 31, 2015, including final contracts or 

3 agreements, drafts, bids, and COMMUNICATIONS concerning negotiations as to terms. 

4 RESPONSE TO REQUEST NO. 18: 

5 Contracts for the five years preceding the Butte Fire that relate to vegetation located on the 

6 property identified as the Caufield Ranch are responsive to this request. Subject to and without 

7 waiving objections on the grounds of attorney-client privilege, the work product doctrine, and 

8 expert witness discovery provided by Code of Civil Procedure sections 2034.010, and pursuant to 

9 an appropriate protective order, PG&E will produce the non-privileged responsive documents 

10 identified above. PG&E objects to the extent the request is vague, ambiguous, and overbroad. 

11 REQUEST NO. 19: 

12 Any and all DOCUMENTS THAT RELATE TO contracts or agreements between PG&E 

13 and TREES in force between January 1, 2010 and December 31, 2015, including final contracts or 

14 agreements, drafts, bids, and COMMUNICATIONS concerning negotiations as to terms. 

15 RESPONSE TO REQUEST NO. 19: 

16 Contracts for the five years preceding the Butte Fire that relate to vegetation located on the 

17 property identified as the Caufield Ranch are responsive to this request. Subject to and without 

18 waiving objections on the grounds of attorney-client privilege, the work product doctrine, and 

19 expert witness discovery provided by Code of Civil Procedure sections 2034.010, and pursuant to 

20 an appropriate protective order, PG&E will produce the non-privileged responsive documents 

21 identified above. PG&E objects to the extent the request is vague, ambiguous, and overbroad. 

22 REQUEST NO. 20: 

23 Any and all DOCUMENTS THAT RELATE TO policies of insurance that YOU contend 

24 provide coverage for any DAMAGES caused by the BUTTE FIRE, including but not limited to 

25 policies, demand letters, and other COMMUNICATIONS between YOU and YOUR insurers. 

26 RESPONSE TO REQUEST NO. 20: 

27 Subject to and without waiving objections based on attorney-client privilege, the work 

28 

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DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 44

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1 product doctrine, and Code of Civil Procedure sections 2034.010 et seq. regarding expert 

2 witnesses, PG&E will produce the document identifying insurance information referred to in 

3 response to form interrogatory 4.1. In addition, PG&E has coverage through policies obtained by 

4 Trees, Inc. and ACRT, including policies that include PG&E as an additional insured. 

5 REQUEST NO. 21: 

6 Any and all DOCUMENTS THAT RELATE TO COMMUNICATIONS between PG&E 

7 and ACRT about maintenance work near POWER POLES or POWER LINES on the CAUFIELD 

8 RANCH, including, but not limited to, all documents showing when PG&E asked for or 

9 authorized any work to be done and all bids for such work. 

10 RESPONSE TO REQUEST NO. 21: 

11 Procedures, contracts, inspections, and work records for five years preceding the Butte fire 

12 that relate to the Electra 1101 circuit that crosses the property identified as the Caufield Ranch are 

13 responsive to this request. The Electra 1101 circuit is also identified in vegetation management 

14 records by the prior name of"Martell 1102." Subject to and without waiving objections on the 

15 grounds of attorney-client privilege, the work product doctrine, and expert witness discovery 

16 provided by Code of Civil Procedure sections 2034.010, and pursuant to an appropriate protective 

17 order, PG&E will produce non-privileged responsive documents identified above. PG&E objects 

18 to the extent the request is vague, ambiguous, and overbroad. 

19 REQUEST NO. 22: 

20 Any and all DOCUMENTS THAT RELATE TO COMMUNICATIONS between PG&E 

21 and TREES about maintenance work near POWER POLES or POWER LINES on the 

22 CAUFIELD RANCH, including, but not limited to, all documents showing when PG&E asked for 

23 or authorized any work to be done and all bids for such work. 

24 RESPONSE TO REQUEST NO. 22: 

25 Procedures, contracts, inspections, and work records for five years preceding the Butte fire 

26 that relate to the Electra 1101 circuit that crosses the property identified as the Caufield Ranch are 

27 responsive to this request. The Electra 1101 circuit is also identified in vegetation management 

28 

-11-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 45

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records by the prior name of "Martell 1102." Subject to and without waiving objections on the 

2 grounds of attorney-client privilege, the work product doctrine, and expert witness discovery 

3 provided by Code of Civil Procedure sections 2034.010, and pursuant to an appropriate protective 

4 order, PG&E will produce privileged responsive documents identified above. PG&E objects to 

5 the extent the request is vague, ambiguous, and overbroad. 

6 REQUEST NO. 23: 

7 Any and all DOCUMENTS THAT RELATE TO PG&E' s budgets for vegetation 

8 maintenance for the period from January 1, 2010 and December 31, 2015, including, but not 

9 limited to, preliminary and final budgets. 

10 RESPONSE TO REQUEST NO. 23: 

11 This request is overbroad, vague, ambiguous, burdensome, and seeks documents that are 

12 not relevant. PG&E vegetation management budgets are included in PG&E's General Rate Case 

13 submitted to the CPUC. PG&E will meet and confer with Plaintiffs regarding the scope of this 

14 request. PG&E further objects to this request on grounds of attorney-client privilege, the work 

15 product doctrine, and expert witness discovery provided by Code of Civil Procedure sections 

16 2034.010. 

17 REQUEST NO. 24: 

18 Any and all DOCUMENTS THAT RELATE TO meetings ofPG&E's Board of Directors 

19 between January 1, 2010 and December 31, 2015, of PG&E's Board of Directors where vegetation 

20 maintenance was on the agenda or discussed, including, but not limited to, agenda, notes, minutes, 

21 and recordings of meetings of PG&E's full Board of Directors and any committee comprised of 

22 members of PG&E's Board of Directors. 

23 RESPONSE TO REQUEST NO. 24: 

24 This request is overbroad, vague, ambiguous, burdensome, and seeks documents that are 

25 not relevant. PG&E will meet and confer with Plaintiffs regarding the scope of this request. 

26 PG&E further objects to this request on grounds of attorney-client privilege, the work product 

27 doctrine, and expert witness discovery provided by Code of Civil Procedure sections 2034.010. 

28 

-12-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 46

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1 REQUEST NO. 25: 

2 Any and all DOCUMENTS sufficient to identify the names, employers, business addresses 

3 and business telephone numbers of all Supervising Program Managers, Vegetation Program 

4 Managers, and Utility Foresters whose responsibilities during the five-year period immediately 

5 preceding the BUTTE FIRE were to oversee and manage the contractor staff who inspected, 

6 pruned, and removed vegetation growing into and near POWER LINES in PG&E's Vegetation 

7 Management Area that included Calaveras County. 

8 RESPONSE TO REQUEST NO. 25: 

9 Subject to and without waiving objections on the grounds of attorney-client privilege, the 

10 work product doctrine, and expert witness discovery provided by Code of Civil Procedure sections 

11 2034.010, and pursuant to an appropriate protective order, PG&E will produce a document 

12 sufficient to identify vegetation management personnel. PG&E objects to the extent this request is 

13 vague, ambiguous, overbroad, and burdensome. 

14 REQUEST NO. 26: 

15 Any and all DOCUMENTS sufficient to identify the names, employers, business addresses 

16 and business telephone numbers of all inspection contractors with whom PG&E contracted during 

17 the five-year period immediately preceding the BUTTE FIRE to inspect the vegetation adjacent to 

18 the POWER LINES in PG&E's Vegetation Management Area that included Calaveras County. 

19 RESPONSE TO REQUEST NO. 26: 

20 Contracts for the five years preceding the Butte Fire that relate to vegetation located on the 

21 property identified as the Caufield Ranch are responsive to this request. Subject to and without 

22 waiving objections on the grounds of attorney-client privilege, the work product doctrine, and 

23 expert witness discovery provided by Code of Civil Procedure sections 2034.010, and pursuant to 

24 an appropriate protective order, PG&E will produce the non-privileged responsive documents 

25 identified above. PG&E objects to the extent the request is vague, ambiguous, and overbroad. 

26 REQUEST NO. 27: 

27 Any and all DOCUMENTS sufficient to identify the names, employers, business addresses 

28 

-13-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 47

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and business telephone numbers of all tree trimmers with whom PG&E contracted during the five2 year period immediately preceding the BUTTE FIRE to prune and remove vegetation growing 

3 into and near POWER LINES in PG&E's Vegetation Management Area that included Calaveras 

4 County. 

5 RESPONSE TO REQUEST NO. 27: 

6 Contracts for the five years preceding the Butte Fire that relate to vegetation located on the 

7 property identified as the Caufield Ranch are responsive to this request. Subject to and without 

8 waiving objections on the grounds of attorney-client privilege, the work product doctrine, and 

9 expert witness discovery provided by Code of Civil Procedure sections 2034.0 I 0, and pursuant to 

10 an appropriate protecti ve order, PG&E wi ll produce the non-privileged responsive documents 

11 identified above. PG&E objects to the extent the request is vague, ambiguous. and overbroad. 

:: DATED ~~3 '1oll., By .2\ ~ )j+= l! 

Kenneth fii te 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Jeffrey N. Boozell 

Sarah J. Cole 

QUINN EMANUEL URQUHART & SULLIVAN, 

LLP 

Gayle L. Gough 

GOUGH & HANCOCK LLP 

Attorneys for Defendants 

PACIFIC GAS AND ELECTRIC COMPANY 

and PG&E CORPORATION 

- 14-

DEFENDANT PG&E'S RESPONSE TO PLAINTIFFS' REQUESTS FOR PRODUCTION OF 

DOCUMENTS AND THINGS, SET ONE 

Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 48

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2 

3 

RE: Butte Fire Cases 

JCCP 4853 

.+ VERIFICATION 

5 I, the undersigned. say: 

6 I am an offi cer. to wi t. Assistant Corporate Secretary of PACIFIC GAS AND ELECTRIC 

7 COMP A Y, a corporation. and am authori zed. pursuant to Code of Civil Procedure Section 

8 446(a), to make this verification for and on behalf of said corporation, and I make this 

9 verification for that reason; I have read the forego ing document. DEFENDANT PACIFIC GAS 

10 AND ELECTRJ C COM PANY'S RESPONSE TO PLAINTIFFS' REQUESTS FOR 

11 PRODUCTlON OF DOCUMENTS AND THINGS, SET ONE, and I am informed and 

12 believe the matters therein arc true and on that ground I allege that the matters stated therein arc 

13 true. 

14 I declare under penalty of perj ury that the foregoing is true and correct. 

I 5 Executed on May 20 I 6, at San Francisco, California. 

16 

17 

18 

19 

20 

21 

22 

24 

r _) 

26 

28 

Eil een Chan 

YERIFICATI01 Case: 19-30088 Doc# 2184 Filed: 05/22/19 Entered: 05/22/19 11:38:07 Page 49

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