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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) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

EX PARTE APPLICATION OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS PURSUANT TO 

FEDERAL RULE OF BANKRUPTCY 

PROCEDURE 2004 FOR ORDERS 

AUTHORIZING PRODUCTION OF 

DOCUMENTS 

Date: 

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

Place: Robert Julian 

 Baker & Hostetler LLP 

 Levi’s Place 

 1160 Battery Street East, Ste. 100 

 San Francisco, CA 94111 

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

counsel, hereby submits this Ex Parte Application Pursuant to Bankruptcy Rule 2004 for Orders 

Authorizing Production of Documents (the “Application”) to secure orders requiring PG&E Corp. 

and Pacific Gas and Electric Company (collectively, the “Debtors” or “PG&E”) to produce 

documents as set forth in Appendix A, attached hereto.

The TCC represents the largest stakeholders in the case, the victims of the fires caused by 

the Debtors’ equipment and electrical system practices. The TCC contends that the Debtors’ 

third-party contractors are or may be liable to the Debtors and the fire victims for the fire victims’ 

losses and resulting claims against the Debtors, and that the Debtors are not pursuing such claims. 

The claims against the third-party contractors and recoveries from the contractors and their 

insurers may supplement the Debtors’ assets and serve as a source of payment of the fire claims. 

Bankruptcy Rule 2004 permits discovery of the acts, conduct, or property of the Debtors, 

or to any matter which may affect the administration of the estate, including the existence of 

potential claims for relief and sources of recovery against the Debtors’ third-party contractors 

who are or may be liable to the Debtors and the fire victims for their losses. By this 2004 

Application, the TCC seeks discovery of the identity of the third-party contractors who: (1) 

inspected, repaired, constructed, maintained and/or evaluated the electrical distribution lines or 

electrical transmission systems located at the area identified by Cal Fire as the origin of the Fire 

(as defined in Appendix A); (2) inspected, trimmed, removed, maintained, managed, and/or 

evaluated—or agreed to inspect, trim, remove, maintain, manage, and/or evaluate—the vegetation 

along the electrical distribution lines and electrical transmission systems at any area identified by 

Cal Fire as the area of origin for the Fires; and/or, (3) provided any Risk Assessment (as defined 

in Appendix A) with regard to any portion of the electrical distribution line or electrical 

distribution system, including towers, located at the area identified by Cal Fire as the origin of the 

Fires. The TCC also requests copies of any insurance policies that may provide coverage for 

claims arising from the work the third-party contractors performed. This discovery is proper and 

necessary for the TCC to fulfill its obligations to investigate and evaluate claims against the 

Debtors’ third-party contractors and the existence of their insurance policies that the Debtors may 

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use to pay fire claims in this case. During the Continued § 341 Meeting of Creditors in this case 

that occurred on April 29, 2019, the Debtors’ representative testified that the Debtors have not 

conducted any valuation of claims against third-parties arising out of the fires. Hence such an 

evaluation is necessary and the TCC is eager to evaluate and identify the claims against the third 

party contractors that will add value to the estate. 

TIME AND PLACE FOR PRODUCTION 

The requested date of the document production is fifteen (15) days from entry of an order 

granting the Application. Bankruptcy Rule 2004(d) provides as follows: 

(d) Time and Place of Examination of Debtor. The court may for 

cause shown and on terms as it may impose order the debtor to be 

examined under this rule at any time or place it designates, whether 

within or without the district wherein the case is pending. 

These dates are a reasonable time after the anticipated date of entry. 

NO PRIOR REQUEST FOR RELIEF 

No previous application for the relief sought herein has been made to this Court. The 

TCC reserves the right to conduct further depositions and other discovery, or otherwise, as 

appropriate. 

CONCLUSION 

On April 28, 2019, Counsel for the TCC held a pre-filing telephonic meet and confer with 

Debtors’ counsel on this Application. In subsequent email correspondence, Debtors’ counsel stated 

that the Debtors had no objection to Requests 1-24, inclusive of subparts, and Request 25(a), (b), 

and (f); and the Debtors objected to Request 25 (c), (d), (e), (g), and (h). 

Accordingly, this Application is properly made on an ex parte basis under Local Rule 2004-

1(a) and the TCC respectfully requests this Court immediately take notice of the Application and 

enter an order in substantially the form attached hereto as Appendix B, granting the relief requested 

herein, and such other and further relief as may be just. 

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Dated: April 30, 2019 

BAKER & HOSTETLER LLP 

By: /s/ Robert A. Julian

Robert Julian 

Attorneys for The Official Committee of Tort 

Claimants 

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APPENDIX A 

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Pursuant to Rules 2004 and the Northern District Bankruptcy Local Rules, the TCC requests 

that Debtors produce the following documents, electronically stored information, and tangible 

things in their possession, custody, or control for inspection within fifteen (15) days from entry of 

an order granting the Application, and copying undersigned counsel at the offices of Baker & 

Hostetler LLP, c/o Robert A. Julian, 1160 Battery Street East, Suite 100, San Francisco, CA 9411, 

using the Definitions and Instructions below. 

DEFINITIONS 

1. “And/Or” shall be construed either disjunctively or conjunctively as necessary to 

bring within the scope of the discovery request all responses that might otherwise be construed to 

be outside of its scope. 

2. The term “communication” means the transmittal of information (in the form of 

facts, ideas, inquiries, or otherwise). 

3. The term “concerning” means relating to, referring to, describing, evidencing, or 

constituting. 

4. The term “Debtors” means Debtor Pacific Gas & Electric Company, and also 

Debtor PG&E Corporation, both collectively, and individually as a single Debtor. 

5. The terms “Document,” “document,” “electronically stored information,” and 

“tangible things” are defined to be synonymous in meaning and equal in scope to the usage of 

these terms in Federal Rule of Civil Procedure 34(a), including, without limitation, electronic or 

computerized data compilations, and specifically including e-mails. A draft or non-identical copy 

is a separate document within the meaning of this term. 

6. The term “Electrical Services” means to have inspected, constructed, repaired, 

maintained, tested, removed, replaced, and/or designed any distribution and/or transmission line, 

specifically including the actual lines, the poles and/or towers and any equipment located on any 

pole and/or tower. 

7. The term “Fires” means the following fires, both collectively, and individually as a 

Fire: 

a. Abode Fire 

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b. Atlas Fire 

c. Blue Fire 

d. Camp Fire 

e. Cascade Fire 

f. Cherokee Fire 

g. Honey Fire 

h. LaPorte Fire 

i. Lobo Fire 

j. Maacama Fire 

k. McCourtney Fire 

l. Norrbom Fire 

m. Nuns Fire 

n. Oakmont Fire 

o. Partrick Fire 

p. Pocket Fire 

q. Point Fire 

r. Potter Valley Fire 

s. Pressley Fire 

t. Redwood Fire 

u. Sullivan Fire 

v. Sulphur Fire 

w. Tubbs Fire 

x. 37 Fire 

8. The term “Third-Party Contractor” means any individual (who is not an employee 

of the Debtors) or entity that, on behalf of the Debtors, or at the request of the Debtors: 

a. inspected, repaired, constructed, maintained and/or evaluated electrical 

distribution lines, specifically including, but not limited to the lines themselves 

and/or all poles and equipment located on the poles, or electrical transmission 

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lines , specifically including the lines themselves, the towers or poles, and all 

equipment located on the towers or poles, located within the area identified by 

Cal Fire as the origin of the relevant Fire(s); 

b. inspected, trimmed, removed, maintained, managed, and/or evaluated—or 

agreed to inspect, trim, remove, maintain, manage, and/or evaluate—the 

vegetation along the electrical distribution lines, specifically including, but not 

limited to the lines themselves and/or all poles and equipment located on the 

poles, or electrical transmission lines , specifically including the lines 

themselves, the towers or poles, and all equipment located on the towers or 

poles, located within the area identified by Cal Fire as the origin of the 

relevant Fire(s); and 

c. provided any Risk Assessment (as defined below) with regard to any portion of 

the electrical distribution lines, specifically including, but not limited to the 

lines themselves and/or all poles and equipment located on the poles, or 

electrical transmission lines, specifically including the lines themselves, the 

towers or poles, and all equipment located on the towers or poles, located 

within the area identified by Cal Fire as the origin of the relevant Fire(s). 

9. The term “Risk Assessment” means any opinions, information and studies used to 

prioritize any work, replacement, repair, maintenance, and construction with regard to PG&E 

facilities. 

10. The term “Vegetation Management Services” includes any pre-inspection, tree 

trimming, tree removal, quality assurance inspections, quality control inspections, and/or other 

work relating to the identification of any tree which posed a threat to any PG&E electrical line. 

INSTRUCTIONS FOR DOCUMENT PRODUCTION REQUESTS 

Federal Rules of Civil Procedure 26–37, made applicable to this proceeding pursuant to 

Bankruptcy Rules 7026–7037, are hereby incorporated by reference and apply to each of the 

following instructions: 

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1. All Documents shall be identified by the Request(s) to which they are primarily 

responsive or be produced as they are maintained in the usual course of business. 

2. Produce all Documents and all other materials described below in Your actual or 

constructive possession, custody, or control, including in the possession, custody, or control of a 

current or former employees, officers, directors, agents, agents’ representatives, consultants, 

contractors, vendors, or any fiduciary or other third parties, wherever those Documents and 

materials are maintained, including on personal computers, PDAs, wireless devices, or web-based 

email systems such as Gmail, Yahoo, etc. 

3. You must produce all Documents in Your possession, custody, or control, whether 

maintained in electronic or paper form and whether located on hardware owned and maintained by 

You or hardware owned and/or maintained by a third-party that stores data on Your behalf. You 

must produce all such Documents even if they were deleted or in draft form. Without limitation, 

hardware where such data may be stored includes: servers; desktop, laptop, or tablet computers; 

cell and smart phones; PDA devices; scanners, fax machines, and copying machines; and mobile 

storage devices, such as thumb or external hard drives. Electronically stored Documents include 

any computerized data or content stored on electromagnetic media. Without limitation, types of 

electronically stored Documents include email, voicemail, instant messages, intranet and internet 

system data, telephone and cellular telephone calling records, data compilations, spreadsheets, 

word processing Documents, images, databases, digital photocopier memory, and any other 

information stored in memory storage devices. 

4. Produce the original or duplicate, as such terms are defined by Rule 1001 of the 

Federal Rules of Evidence, of each Document requested together with all non-identical copies and 

drafts of that Document. If a duplicate is produced, it should be legible and bound or stapled in the 

same manner as the original. 

5. Documents not otherwise responsive to these Requests should be produced: (i) if 

such Documents mention, discuss, refer to, explain, or concern one or more Documents that are 

called for by these Requests; (ii) if such Documents are attached to, enclosed with, or accompany 

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Documents called for by these Requests; or (iii) if such Documents constitute routing slips, 

transmittal memoranda or letters, comments, evaluations, or similar materials. 

6. Documents attached to each other should not be separated; separate Documents 

should not be attached to each other. 

7. Documents should include all exhibits, appendices, linked Documents, or otherwise 

appended Documents that are referenced in, attached to, included with, or are a part of the requested 

Documents. 

8. If any Document, or any part thereof, is not produced based on a claim of attorneyclient privilege, work-product protection, or any other privilege, then in answer to such Request or 

part thereof, for each such Document, You must: 

(a) Identify the type, title and subject matter of the Document; 

(b) State the place, date, and manner of preparation of the Document; 

(c) Identify all authors, addressees, and recipients of the Document, including 

information about such Persons to assess the privilege asserted; and 

(d) Identify the legal privilege(s) and the factual basis for the claim. 

9. Documents should not contain redactions unless such redactions are made to protect 

information subject to the attorney-client privilege and/or work-product doctrine. In the event any 

Documents are produced with redactions, a log setting forth the information requested in Instruction 

8 above must be provided. 

10. To the extent a Document sought herein was at one time, but is no longer, in your 

actual or constructive possession, custody, or control, state whether it: (i) is missing or lost; (ii) has 

been destroyed; (iii) has been transferred to others; and/or (iv) has been otherwise disposed of. In 

each instance, Identify the Document, state the time period during which it was maintained, state 

the circumstance and date surrounding authorization for such disposition, Identify each Person 

having knowledge of the circumstances of the disposition, and Identify each Person who had 

possession, custody, or control of the Document. Documents prepared prior to, but which relate or 

refer to, the time period covered by these Requests are to be identified and produced. 

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MANNER OF PRODUCTION 

All Documents produced to the Trustee shall be provided in either native file (“native”) or 

single-page 300 dpi-resolution group IV TIF format (“tiff”) format as specified below, along with 

appropriately formatted industry-standard database load files, and accompanied by true and correct 

copies or representations of unaltered attendant metadata. Where Documents are produced in tiff 

format, each Document shall be produced along with a multi-page, Document-level searchable text 

file (“searchable text”) as rendered by an industry-standard text extraction program in the case of 

electronic originals, or by an industry-standard Optical Character Recognition (“ocr”) program in 

the case of scanned paper Documents. Searchable text of Documents shall not be produced as 

fielded data within the “.dat file” as described below. 

1. Database load files and production media structure: Database load files shall consist 

of: (i) a comma-delimited values (“.dat”) file containing: production Document identifier 

information, data designed to preserve “parent and child” relationships within Document 

“families,” reasonably accessible and properly preserved metadata (or bibliographic coding in the 

case of paper Documents), custodian or Document source information; and (ii) an Opticon (“.opt”) 

file to facilitate the loading of tiff images. Load files should be provided in a root-level folder 

named “Data,” images shall be provided within a root level “Images” folder containing reasonably 

structured subfolders, and searchable text files shall be provided in a single root-level “Text” folder. 

If any of the Documents produced in response to these Requests are designated as confidential 

pursuant to the Litigation Protective Order, in addition to marking the Documents with the brand 

“CONFIDENTIAL” or branding the media with the word “CONFIDENTIAL,” also include a 

confidential field within the load file, with a “yes” or “no” indicating whether the Document has 

been designated as confidential, as well as native file loading/linking information (where 

applicable). 

2. Electronic Documents and data, generally: Documents and other responsive data or 

materials created, stored, or displayed on electronic or electro-magnetic media shall be produced 

in the order in which the Documents are or were stored in the ordinary course of business, including 

all reasonably accessible metadata, custodian or Document source information, and searchable text 

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as to allow the Trustee, through a reasonable and modest effort, to fairly, accurately, and completely 

access, search, display, comprehend, and assess the Documents’ true and original content. 

3. Emails and attachments, and other email account-related Documents: All 

Documents and accompanying metadata created and/or stored in the ordinary course of business 

within commercial, off-the-shelf email systems including but not limited to Microsoft ExchangeTM, 

Lotus NotesTM, or Novell GroupwiseTM shall be produced in tiff format, accompanying metadata, 

and searchable text files or, alternately, in a format that fairly, accurately, and completely represents 

each Document in such a manner as to make the Document(s) reasonably useable, manageable, and 

comprehendible by the Trustee. 

4. Documents and data created or stored in or by structured electronic databases: With 

the exclusion of email and email account-related Documents and data, all Documents and 

accompanying metadata created and/or stored in structured electronic databases or files shall be 

produced in a format that enables the Trustee to reasonably manage and import those Documents 

into a useable, coherent database. Documents must be accompanied by reasonably detailed 

documentation explaining the Documents’ content and format including but not limited to data 

dictionaries and diagrams. Some acceptable formats, if and only if provided with definitive file(s), 

table(s), and field level schemas include: 

(a) XML format file(s); 

(b) Microsoft SQL database(s); 

(c) Access database(s); and/or 

(d) fixed or variable length ASCII delimited files. 

5. Spreadsheets, multimedia, and non-standard file types: All Documents generated 

or stored in software such as Microsoft Excel or other commercially available spreadsheet 

programs, as well as any multimedia files such as audio or video, shall be produced in their native 

format, along with an accompanying placeholder image in tiff format indicating a native file has 

been produced. A “Nativelink” entry shall be included in the .dat load file indicating the relative 

file path to each native file on the production media. To the extent You have other file types that 

do not readily or easily and accurately convert to tiff and searchable text, You may elect to produce 

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those files in native format subject to the other requirements listed herein. Native files may be 

produced within a separate root-level folder structure on deliverable media entitled “Natives.” 

6. “Other” electronic Documents: All other Documents and accompanying metadata 

and embedded data created or stored in unstructured files generated by commercially available 

software systems (excluding emails, structured electronic databases, spreadsheets, or multimedia) 

such as, but not limited to, word processing files (such as Microsoft Word), image files (such as 

Adobe .pdf files and other formats), and text files shall be produced in tiff and searchable text 

format in the order the files are or were stored in the ordinary course of business. 

7. Paper Documents: Documents originally created or stored on paper shall be 

produced in tiff format. Relationships between Documents shall be identified within the Relativity 

.dat file utilizing document identifier numbers to express parent Document/child attachment 

boundaries, folder boundaries, and other groupings. In addition, the searchable text of each 

Document shall be provided as a multi-page text file as provided for by these Requests. 

LIST OF DOCUMENT REQUESTED FOR PRODUCTION

1. For the Abode Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Abode Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Abode Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

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2. For the Atlas Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Atlas Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Atlas Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

3. For the Blue Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Blue Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Blue Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

4. For the Camp Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

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area which includes the area identified by Cal Fire as the area of origin of 

the Camp Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Camp Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

5. For the Cascade Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Cascade Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Cascade Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

6. For the Cherokee Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Cherokee Fire. 

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b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Cherokee Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

7. For the Honey Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Honey Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Honey Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

8. For the LaPorte Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the LaPorte Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the LaPorte Fire. 

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c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

9. For the Lobo Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Lobo Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Lobo Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

10. For the Maacama Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Maacama Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Maacama Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

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11. For the McCourtney Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the McCourtney Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the McCourtney Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

12. For the Norrbom Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Norrbom Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Norrbom Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

13. For the Nuns Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

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area which includes the area identified by Cal Fire as the area of origin of 

the Nuns Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Nuns Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

14. For the Oakmont Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Oakmont Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Oakmont Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

15. For the Partrick Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Partrick Fire. 

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b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Partrick Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

16. For the Pocket Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Pocket Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Pocket Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

17. For the Point Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Point Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Point Fire. 

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c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

18. For the Potter Valley Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Potter Valley Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Potter Valley Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

19. For the Pressley Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Pressley Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Pressley Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

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20. For the Redwood Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Redwood Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Redwood Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

21. For the Sullivan Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Sullivan Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Sullivan Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

22. For the Sulphur Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

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area which includes the area identified by Cal Fire as the area of origin of 

the Sulphur Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Sulphur Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

23. For the Tubbs Fire, and for each year beginning in 2014 and ending in 2019, 

separately label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the Tubbs Fire. 

b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the Tubbs Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

24. For the 37 Fire, and for each year beginning in 2014 and ending in 2019, separately 

label and produce: 

a) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Vegetation Management Services in an 

area which includes the area identified by Cal Fire as the area of origin of 

the 37 Fire. 

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b) Each and every written agreement between PG&E and any third person or 

entity for the performance of any Electrical Service in an area which includes 

the area identified by Cal Fire as the area of origin of the 37 Fire. 

c) Each insurance policy, issued to any such third person or entity identified in 

subparts (a) and (b) of the above Request, which names any debtor as an 

insured. 

25. For each Third-Party Contractor who performed work on any portion of the 

Caribou-Palermo Line, which included Tower 22/227 from 2009 through 2019, 

separately label, by Third-Party Contractor, and produce: 

a) All agreements and contracts between the Debtor(s) and each Third-Party 

Contractor, including without limitation, any agreement or contract relating 

to indemnity, insurance, or liability. 

b) Each agreement between any Debtor and any Third-Party Contractor which 

required the inspection of the C-Hook on Tower 22/227, which the Debtors 

have identified as having failed on November 8, 2018; 

c) To the extent not set forth in the documents responsive to Request 2(a), all 

documents that describe the scope of services the Third-Party Contractor 

agreed to provide to the Debtor(s); 

d) To the extent not set forth in the documents responsive to Request 2(a) or 

2(b), all documents that describe the work performed by the Third-Party 

Contractor; 

e) All documents that contain the analyses, findings, summaries, impressions, 

recommendations, and/or other work-product of each of the Third-Party 

Contractors, including without limitation any Risk Assessments. 

f) All insurance policies that may provide coverage for claims arising from the 

work of each of the Third-Party Contractors. 

g) Each writing which documents any inspection performed of Tower 22/227 

at anytime from January 1, 2009 to and including April 24, 2019. 

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h) Each writing which sets forth the result of any inspection performed on 

Tower 22/227 at anytime from January 1, 2009 to and including April 24, 

2019. 

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APPENDIX B 

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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) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

ORDER GRANTING THE EX PARTE 

APPLICATION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO FEDERAL RULE OF 

BANKRUPTCY PROCEDURE 2004 FOR 

ORDERS AUTHORIZING 

PRODUCTION OF DOCUMENTS 

The Court, having reviewed the Ex Parte Application of the Official Committee of Tort 

Claimants Pursuant to Bankruptcy Rule 2004 for Orders Authorizing Production of Documents 

filed on April 30, 2019, and after due deliberation and sufficient cause appearing therefor, 

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IT IS HEREBY ORDERED THAT: 

1. The Application is granted, as provided herein. 

2. The Debtors are directed to produce to the TCC the documents and information 

described in Appendix A to the Application, without service of a subpoena, fifteen (15) days from 

entry of this Order, in accordance with the Instructions set forth therein. 

**END OF ORDER** 

 

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