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WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF BENJAMIN P.D. SCHRAG 

IN SUPPORT OF MOTION OF DEBTORS 

PURSUANT TO 11 U.S.C. §§ 502(b)(9) AND 105(a), 

FED. R. BANKR. P. 2002, 3003(c)(3), 5005, AND 

9007, AND L.B.R. 3003-1 FOR ORDER (I) 

ESTABLISHING DEADLINE FOR FILING 

PROOFS OF CLAIM, (II) ESTABLISHING THE 

FORM AND MANNER OF NOTICE THEREOF, 

AND (III) APPROVING PROCEDURES FOR 

PROVIDING NOTICE OF BAR DATE AND 

OTHER INFORMATION TO ALL CREDITORS 

AND POTENTIAL CREDITORS 

Date: May 22, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

San Francisco, CA 94102

Debtors.

 Affects PG&E Corporation 

Affects Pacific Gas and Electric 

Company 

 Affects both Debtors 

* All papers shall be filed in the Lead 

Case, No. 19-30088 (DM). 

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Pursuant to 28 U.S.C. § 1746, I, Benjamin P.D. Schrag, hereby declare as follows under penalty 

of perjury: 

I am the Chief Business Development Officer of Prime Clerk LLC (“Prime Clerk”), a chapter 

11 administrative services firm whose headquarters are located at 830 3rd Avenue, 9th Floor, New 

York, New York 10022. Prime Clerk is comprised of leading industry professionals with significant 

experience in both the legal and administrative aspects of large, complex chapter 11 cases. Prime 

Clerk’s professionals have experience in noticing, claims administration, solicitation, balloting and 

facilitating other administrative aspects of chapter 11 cases and experience in matters of the size and 

complexity of these Chapter 11 Cases. Prime Clerk’s professionals have acted as administrative agent 

or official claims and/or noticing agent in a large bankruptcy case in this District and in other districts 

nationwide. Prime Clerk’s active and former cases include: NewZoom, Inc., No. 15-31141 (HB) 

(Bankr. N.D. Cal.); Channel Technologies Group, LLC, No. 16-11912 (DS) (Bankr. C.D. Cal.); 

Checkout Holding Corp., No. 18-12794 (KG) (Bankr. D. Del.); Fairway Energy, LP, No. 18-12684 

(LSS) (Bankr. D. Del.); Dixie Electric, LLC, No. 18-12477 (KG) (Bankr. D. Del.); New MACH Gen 

GP, LLC, No. 18-11369 (MFW) (Bankr. D. Del.); Gibson Brands, Inc., No. 18-11028 (CSS) (Bankr. 

D. Del.); Bertucci’s Holdings, Inc., No.18-10894 (MFW) (Bankr. D. Del.); EV Energy Partners, L.P., 

No. 18-10814 (CSS) (Bankr. D. Del.); Claire’s Stores, Inc., No. 18-10584 (MFW) (Bankr. D. Del.); 

The Bon-Ton Stores, Inc., No. 18-10248 (MFW) (Bankr. D. Del.); Orchard Acquisition Company, 

LLC, No. 17-12914 (KG) (Bankr. D. Del.); Rentech WP U.S., Inc., No. 17-12958 (CSS) (Bankr. D. 

Del.); Appvion, Inc., No. 17-12082 (KJC) (Bankr. D. Del.); Global Brokerage, Inc., No. 17-13532 

(MEW) (Bankr. S.D.N.Y.); Global A&T Electronics Ltd., No. 17-23931 (RDD) (Bankr. S.D.N.Y.); 

Pacific Drilling S.A., No. 17-13193 (MEW) (Bankr. S.D.N.Y.); Walter Investment Management 

Corporation, No. 17-13446 (JLG) (Bankr. S.D.N.Y.); Castex Energy Partners, L.P., No. 17-35835 

(MI) (Bankr. S.D. Tex.); Toys “R” Us, Inc., No. 17-34665 (KLP) (Bankr. E.D. Va.); TK Holdings 

Inc., No. 17-11375 (BLS) (Bankr. D. Del.); Ultrapetrol (Bahamas) Limited, No. 17-22168 (RDD) 

(Bankr. S.D.N.Y.); and General Wireless Operations Inc. dba RadioShack, No. 17-10506 (BLS) 

(Bankr. D. Del.). 

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 I submit this declaration (the “Declaration”) in support of the Motion of Debtors Pursuant to 

11 U.S.C. §§ 502(b)(9) and 105(a), Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 

3003-1 for Order (i) Establishing Deadline for Filing Proofs of Claim, (ii) Establishing the Form and 

Manner of Notice Thereof, and (iii) Approving Procedures for Providing Notice of Bar Date and Other 

Information to all Creditors and Potential Creditors filed with the Court by PG&E Corporation 

(“PG&E Corp.”) and Pacific Gas and Electric Company (the “Utility”), as debtors and debtors in 

possession (collectively, “PG&E” or the “Debtors”) on the date hereof (together with any exhibits 

and schedules thereto, the “Bar Date Motion”).1

 Except as otherwise indicated herein, the facts set forth in this Declaration are based upon my 

personal knowledge, my review of relevant documents, and information provided to me by the Debtors 

and their other professionals, including professionals at Weil, Gotshal & Manges LLP (“Weil”), 

Cravath, Swaine & Moore LLP, and AlixPartners LLP, and other members of the Prime Clerk team. 

If called upon to testify, I would testify competently to the facts set forth in this Declaration. I am 

authorized to submit this Declaration on behalf of the Debtors. 

I. PRIME CLERK’S ENGAGEMENT BY THE DEBTORS 

 The Debtors engaged Prime Clerk in January 2019 to perform a variety of tasks relating to the 

Debtors’ restructuring. On February 1, 2019, the Court entered an order approving the Debtors’ 

retention of Prime Clerk as official claims and noticing agent [Docket No. 245]. In addition, by order 

dated April 9, 2019, the Court approved the Debtors’ application to employ Prime Clerk as 

administrative advisor in these Chapter 11 Cases [Docket No. 1300]. 

II. FORMULATION OF THE NOTICE PROCEDURES 

 As set forth in the Bar Date Motion, the Debtors are seeking to establish a Bar Date and 

procedures for providing notice thereof (the “Notice Procedures”) to all known and unknown 

creditors, including Wildfire Claimants, Wildfire Subrogation Claimants, and Customers (each as 

defined below). For purposes of the Bar Date Motion and this Declaration, and all matters related 

thereto (a) any claim (as such term is defined in section 101(5) of the Bankruptcy Code) related to or 

 

1

 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such 

terms in the Bar Date Motion. 

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in any way arising from the Northern California Wildfires2 (including any claim of a Wildfire 

Subrogation Claimant) is referred to herein as a “Wildfire Claim”; (b) any person or entity, including 

any Governmental Unit, holding a Wildfire Claim (other than a Wildfire Subrogation Claimant) is 

referred to herein as a “Wildfire Claimant”; and (c) any insurance carrier having made payments to 

their insureds for any damages arising out of or relating to a Wildfire Claim, or any other party who 

has acquired by assignment or otherwise obtained an interest in a claim arising out or related to such 

payments, is referred to herein as a “Wildfire Subrogation Claimant”. 

 With the exception of Wildfire Claimants, Wildfire Subrogation Claimants, and Customers 

(which are each discussed in detail below), it is my understanding that pursuant to the Bar Date 

Motion, the Debtors are proposing standard procedures for providing notice of the Bar Date to all 

creditors and parties in interest that are entitled to receive such notice in these Chapter 11 Cases, which 

includes parties such as the Debtors’ prepetition lenders, bondholders, other financial creditors, trade 

creditors, parties to pending or threatened litigation (other than Wildfire Claimants and Wildfire 

Subrogation Claimants), current and former employees, contract and lease counterparties, and other 

traditional creditors and parties in interest in these Chapter 11 Cases. The Debtors also propose to 

extend the deadline for Governmental Units to file Proofs of Claim beyond the standard 180 days after 

the Petition Date required under section 502(b)(9) of the Bankruptcy Code. 

 Due to the unique nature of these Chapter 11 Cases, including the number of potential 

individual claimants and the destruction of structures to which notices of a Bar Date would customarily 

be sent, the Debtors are proposing special procedures to facilitate the submission and evaluation of 

Wildfire Claims, including, a simplified Wildfire Claim Bar Date Notice (as defined below) and 

customized Proof of Claim Forms for both Wildfire Claimants and Wildfire Subrogation Claimants, 

which seek to identify critical information with respect to each potential Wildfire Claim, including, 

without limitation, the relevant wildfire, the type of loss or injury, the type of damages asserted, and 

(if applicable) whether the claim is covered by insurance and relevant coverage information. The 

 

2

 The Northern California Wildfires include, but are not limited to, the following fires: 37, Adobe, 

Atlas, Blue, Butte, Camp, Cascade, Cherokee, Honey, La Porte, Lobo, Maacama, McCourtney, 

Norrbom, Nuns, Partrick, Pocket, Point, Pressley, Pythian (a.k.a. Oakmont), Redwood, Sulphur and 

Tubbs. 

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Debtors are also proposing special procedures for providing notice of the Bar Date to their 16 million 

customers (each, a “Customer”), including a simplified Customer Bar Date Notice (as defined below), 

which makes clear that Customers are not required to file proofs of claim for ordinary and customary 

refunds, overpayments, billing credits, deposits, or similar billing items. 

 In addition to serving the Bar Date Notices, the Debtors intend to provide supplemental notice 

of the Bar Date (the “Supplemental Notice Plan”) to unknown creditors, including Unknown 

Wildfire Claimants (as defined below). As set forth below, the Supplemental Notice Plan is broad, 

multi-faceted, and is designed to reach its target audiences in a variety of different ways, including: 

(i) multiple newspaper publication notices, (ii) dedicated website and toll-free phone numbers, (iii) 

digital advertising, including social media and other paid internet search listings, (iv) television and 

radio advertising, (v) email notice, and (vi) dedicated claim service centers. 

 It is my understanding that, since being retained by the Debtors in January 2019, Prime Clerk 

has assisted the Debtors and their advisors in developing the Notice Procedures (including the 

Supplemental Notice Plan). It is my understanding that Prime Clerk collaborated with the Debtors in 

preparing the Debtors’ recommended noticing strategy by researching the costs and efficiencies of 

various noticing strategies and alternatives. Prime Clerk also used its knowledge of past noticing 

experiences to present various ideas for cost savings. 

III. ESTIMATED COSTS OF THE NOTICE PROCEDURES 

 As set forth in further detail below, the Debtors estimate the total cost of the Notice Procedures, 

including the Supplemental Notice Plan, to be approximately $19 million - $22 million depending on 

the final number of noticing parties (estimated to be 16.3 million to 16.5 million parties) and assuming 

eligibility for volume postage discounts obtained, which may be broken down as follows: (i) 

approximately $18 million - $20 million for expenses relating to service and mailing of physical Bar 

Date Notices; (ii) approximately $400,000 for publication of the Bar Date Notices; and (iii) $1.0 

million - $1.5 million for other costs and expenses associated with the Supplemental Notice Plan, 

including costs and expenses relating to digital, television, and radio advertising and the costs and 

expenses of staffing the Claim Service Centers. Each of the parties to be noticed and the cost 

components of the Notice Procedures is discussed in further detail below. 

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A. Costs of Mailing the Standard Bar Date Notice 

 Traditional creditors, which include, without limitation, the Debtors’ prepetition lenders, 

bondholders, other financial creditors, trade creditors, parties to pending or threatened litigation (other 

than Wildfire Claimants and Subrogation Claimants), current and former employees, contract and 

lease counterparties, and other customary parties of interest in these Chapter 11 Cases will receive a 

traditional notice of the Bar Date (the “Standard Bar Date Notice”) with a standard proof of claim 

form attached (the “Standard Proof of Claim Form”). The Standard Bar Date Notice (i) sets forth 

the Bar Date; (ii) advises creditors under what circumstances they must file a Standard Proof of Claim; 

(iii) alerts creditors to the consequences of failing to timely file a Standard Proof of Claim; (iv) sets 

forth the address to which Standard Proofs of Claim must be sent for filing; and (v) notifies creditors 

that (a) Standard Proofs of Claim must be filed with original signatures and (b) facsimile, telecopy, or 

electronic mail transmission of Standard Proofs of Claim (other than Proofs of Claim filed 

electronically through the Electronic Filing System) are not acceptable and are not valid for any 

purpose. The Debtors propose to mail the Standard Bar Date Notice via first class mail to all of the 

Debtors’ known creditors other than the Wildfire Claimants, Subrogation Claimants, and Customers. 

Prime Clerk estimates the cost of mailing the Standard Bar Date Notice to the Debtors’ traditional 

notice parties (approximately 300,000 parties) to be approximately $500,000. 

B. Costs of Mailing the Wildfire Claim Bar Date Notice 

As set forth above, due to the unique nature of these Chapter 11 Cases, including the number 

of potential individual claimants and the destruction of structures to which notices of a Bar Date would 

customarily be sent, the Debtors are proposing special procedures with respect to Wildfire Claims. 

These procedures address (a) holders of Wildfire Claims that, as of the Petition Date, already had 

commenced actions against the Debtors or had provided actual notice to the Debtors of their intention 

to commence actions against the Debtors (“Known Wildfire Claimants”), and (b) holders of Wildfire 

Claims that, as of the Petition Date, had not commenced actions against the Debtors or provided actual 

notice to the Debtors of their intention to commence actions against the Debtors (“Unknown Wildfire 

Claimants”). The Debtors propose to serve all Known Wildfire Claimants via first-class mail (i) a 

simplified 5 page Bar Date Notice (the “Wildfire Claim Bar Date Notice”), and (ii) a proof of claim 

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form that requests specific information designed to facilitate the evaluation and estimation of Wildfire 

Claims of Wildfire Claimants (the “Wildfire Claimant Proof of Claim Form”) and Wildfire 

Subrogation Claimants (the “Wildfire Subrogation Claimant Proof of Claim Form” and, together 

with the Wildfire Claimant Proof of Claim Form, the “Wildfire Proof of Claim Forms”). Further, 

the Debtors will post the Wildfire Claimant Proof of Claim Form, the Wildfire Subrogation Claimant 

Proof of Claim Form, and the Wildfire Claim Bar Date Notice on the Case Website. The Debtors 

propose to mail the Wildfire Claim Bar Date Notice and the applicable Wildfire Proof of Claim Form 

to each Known Wildfire Claimant at the address for the attorney of record set forth in the complaint 

initiating the prepetition action (or other document or correspondence notifying the Debtors of an 

intention to commence a prepetition action) and to (i) Willkie Farr & Gallagher LLP, as attorneys for 

the Ad Hoc Committee of Wildfire Subrogation Claimants, and (ii) Stutzman, Bromberg, Esserman 

& Plifka, P.C., as attorneys for the Ad Hoc Committee of Public Entity Wildfire Claimants. Similar 

notice will be sent by first class mail to any holder of a Wildfire Claim that has filed a Proof of Claim 

on or prior to the entry of a Proposed Order at the address listed in such Proof of Claim.3 I understand 

that, to supplement the foregoing, the Debtors are proposing to make efforts to send by first class mail 

the foregoing notice to property owners of destroyed homes within the areas affected by the 2017 

Northern California Wildfires using proprietary data maintained by Geographical Information 

Systems (“GIS”) satellite experts retained by Debtors in connection with the prepetition litigation. In 

addition, I further understand that the Debtors intend to request that certain third parties who may be 

in possession of contact information for additional potential Wildfire Claimants provide such 

information for the Debtors’ use in identifying such claimants. I understand that such information 

includes: (i) contact information stored in a database maintained by BrownGreer PLC, which lists 

 

3

 It is my understanding that the list of Known Wildfire Claimants set forth in the Debtors’ Schedule 

E/F (filed on March 14, 2019) was compiled from a review of all complaints related to the North 

Bay, Camp and Butte wildfires filed as of the Petition Date, as well as a list of individuals who may 

have contacted or corresponded with the Debtors through their claims management process 

regarding potential Wildfire Claims but who had not yet commenced formal litigation at the time of 

correspondence. I further understand that the list of Wildfire Claims set forth in Schedule E/F 

reflects approximately 13,700 individual Known Wildfire Claimants. Taking into account additional 

related notice parties identified in the Schedules, the total number of parties to receive the Wildfire 

Claim Bar Date Notice is estimated to be approximately 38,400. 

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persons or entities that have Wildfire Claims in connection with the State court litigation related to the 

2017 Northern California Wildfires; and (ii) contact information maintained by the subrogation 

insurance carriers for persons or entities that have filed insurance claims or have received payment 

under any insurance policy for any damages arising out of or relating to a Wildfire Claim. To the 

extent such information is provided to the Debtors reasonably in advance of the entry of the Proposed 

Order, the Debtors will send the foregoing notice by first class mail to any potential Wildfire Claimants 

identified in such sources at the addresses listed for them in those sources. 

The Debtors designed the Wildfire Proof of Claim Forms with the assistance of Prime 

Clerk and the Debtors’ attorneys and other professionals to request certain information relating to the 

asserted Wildfire Claims, including information to identify the relevant wildfire, the type of loss or 

injury, the type of damages asserted, and (if applicable) whether the claim is covered by insurance and 

relevant coverage information. The Wildfire Claim Bar Date Notice (i) sets forth the Bar Date; (ii) 

advises Wildfire Claimants and Wildfire Subrogation Claimants under what circumstances they must 

file a Wildfire Proof of Claim Form; (iii) alerts the Wildfire Claimants and Wildfire Subrogation 

Claimants to the consequences of failing to file a timely Wildfire Proof of Claim Form; and (iv) sets 

forth the address to which Wildfire Proof of Claim Forms must be sent for filing. Prime Clerk 

estimates the cost of mailing the Wildfire Claim Bar Date Notice to all Known Wildfire Claimants 

and related notice parties (approximately 38,400 parties) to be approximately $100,000.

C. Costs of Mailing the Customer Bar Date Notice 

 Customers will receive a simplified 2-page Bar Date Notice (the “Customer Bar Date 

Notice”), but with a Standard Proof of Claim Form attached. The Customer Bar Date Notice (i) sets 

forth the Bar Date; (ii) advises Customers under what circumstances they must file a Standard Proof 

of Claim; (iii) makes clear that Customers are not required to file proofs of claim for refunds, 

overpayments, billing credits, or deposits that the Debtors have been authorized by the Court to pay 

or honor in the ordinary course of business, (iv) alerts Customers to the consequences of failing to file 

a timely Standard Proof of Claim; and (iv) sets forth the address to which Standard Proofs of Claim 

must be sent for filing. In addition, the Customer Bar Date Notice includes bold and conspicuous 

language alerting Customers that may potentially have Wildfire Claims of their obligation to file the 

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applicable Wildfire Proof of Claim Form by the Bar Date (which is available for download or 

submission on the Case Website) – thereby providing notice of the procedures for filing Wildfire Proof 

of Claim Forms to any Unknown Wildfire Claimants that are Customers of the Debtors or have 

otherwise provided the Debtors with a forwarding address. The Customer Bar Date Notice will also 

direct Customers to the Case Website where such parties may register an email address and request 

electronic notice for the duration of these Chapter 11 Cases. I believe that the Customer Bar Date 

Notice provides the required notice of Bar Date and will result in substantial cost-savings to the estates. 

Prime Clerk estimates that providing the Standard Bar Date Notice to the Debtors’ 16 million 

customers will cost approximately $17 million - $20 million depending on total number of notices of 

Customer Bar Date Notices to be sent and final postage costs. Prime Clerk estimates that if it were 

instead to provide hard-copies of the Standard Bar Date Notice to the Debtors’ customers, such notice 

would increase the cost of preparing and mailing the Bar Date Notice to the Debtors’ 16 million 

customers by approximately $14 - $21 million as compared to the cost of preparing and mailing the 

Customer Bar Date Notice. 

D. Costs of the Supplemental Notice Plan 

 The Supplemental Notice Plan aims to reach individuals impacted by the Wildfires in Napa, 

Lake, Sonoma, Mendocino, Nevada, Butte, and Humboldt counties, all of the counties impacted by 

the Northern California Wildfires. I believe the Supplemental Noticing Plan will maximize notice of 

the Bar Date to adults in the impacted areas and those who may have moved within or out of the 

affected counties in the past two years. The Supplemental Notice Plan is a media-based plan that 

utilizes numerous media formats including widespread dissemination of publication notices, internet 

banner advertisements, social media posts, informational releases, a dedicated website, a call center, 

and in-person claims service centers to reach potential claimants. In my opinion, the Supplemental 

Notice Plan is reasonably calculated to provide notice to all unknown creditors, including all Unknown 

Wildfire Claimants, and parties in interest. The Supplemental Notice Plan is estimated to cost 

approximately $1.5 million - $2.0 million. The primary components and associated costs of the 

Supplemental Notice Plan are summarized as follows: 

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(a) Publication of the Bar Date Notice. 

(i) Multiple Newspaper Publications. The information set forth in the Standard 

Bar Date Notice will be published three times in each of the Wall Street 

Journal, USA Today, the Los Angeles Times, San Francisco Chronicle, The 

Bakersfield Californian, The Fresno Bee, The Modesto Bee, The Sacramento 

Bee, The Santa Rosa Press Democrat, The San Jose Mercury News, The East 

Bay Times, The Stockton Record, the Paradise Post, and the Chico 

Enterprise-Record. These are the same publications in which the Notice of 

Commencement was previously published. Additionally, each of the 

Standard Bar Date Notice, the Wildfire Claim Bar Date Notice, and the 

Customer Bar Date Notice will be posted on the Case Website. The cost of 

publishing the Standard Bar Date Notice as set forth above is estimated to be 

approximately $400,000. 

(b) Dedicated Website(s) and Toll-Free Numbers. 

(i) The Debtors, through Prime Clerk, have established a dedicated Case 

Website and toll-free number. The Case Website and toll-free numbers will 

be prominently displayed in all printed notice documents and other paid 

advertising and will provide notice of the Bar Date and all requirements to 

comply therewith, and other relevant information relating to the Chapter 11 

Cases. Included within the Case Website will be a page specifically tailored 

to, and designed for, the holders of Wildfire Claims, which will, among other 

things, inform them of certain key dates and deadlines, allow them to view 

certain key documents in the Chapter 11 Cases free of charge, and allow 

holders of Wildfire Claims and other creditors to register their email 

addresses and consent to e-mail service of certain notices required to be sent 

during the Chapter 11 Cases. In addition, Spanish, Mandarin, Tagolog, 

Vietnamese, and Korean language translations of the Customer Bar Date 

Notice will be available for download on the Case Website. Prime Clerk 

does not anticipate additional material costs and expenses to be incurred in 

connection with maintaining the Case Website and toll-free numbers as set 

forth herein. 

(c) Digital Advertising. 

(i) As soon as practicable following entry of the Proposed Order, the Debtors, 

through Prime Clerk, will implement both (1) a broad-based geographic 

effort to provide notice to a large majority of online adults in the six affected 

counties using available data related to adult online usage, and (2) digital 

matching to precisely target a known universe of individuals who have 

moved within or out of the affected counties in the past year. 

(ii) This digital effort is estimated to reach approximately 750,000 individuals, 

or approximately 70% of the adult population estimated to be approximately 

1 million individuals, in the six affected counties through a combination of 

Facebook, Google Display NetworkTM, and targeted news website ads. 

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(iii) In order to target individuals who have moved within or out of the affected 

counties, Prime Clerk will utilize U.S. Postal Service data and private 

databases. Prime Clerk will then match those names to digital advertising 

targets (e.g., using phone numbers to match to Facebook profiles) and target 

digital ads to that list. 

(iv) The initial running of all digital advertising, as well as the radio and 

television advertisements discussed below, is estimated to cost 

approximately $525,000 - $600,000. In the event the Debtors decide to run 

additional advertisements, additional charges may be incurred. 

(d) Television and Radio. 

(i) All of the affected counties are within four designated market areas in 

California, which render television and radio advertising fairly cost efficient 

and effective. The Debtors, through Prime Clerk, will utilize such methods to 

reach some of the more rural affected areas and audiences that may not be 

otherwise exposed to online noticing. The estimated costs and expenses of 

the television and radio advertising – in both English and Spanish – are 

included in the estimate for digital advertising set forth above. 

(ii) The Supplemental Notice Plan’s television and radio advertisements will 

deliver approximately 150 gross rating points (GRPs) or rough equivalent 

each on English television, Spanish television, English radio, and Spanish 

radio. GRPs are a standard measure of delivery in advertising. In this 

instance, the Supplemental Notice Plan’s advertisements will be seen by an 

average adult 1.5 times on television and heard 1.5 times on radio, although 

many individuals will see the advertisements numerous times and some may 

not see it at all. 

(e) Email Notice. 

(i) The Debtors have email information for approximately 40% of their 

Customers. Accordingly, to supplement the hard-copy notice to Customers 

described above, the Debtors intend to send the Customer Bar Date Notice to 

such parties via email as well, with a link to the online proof of claim 

submission portal. Prime Clerk does not anticipate material costs or 

expenses to be incurred in connection with providing email notice as set 

forth herein. 

(f) Claim Service Centers. 

(i) The Debtors intend to utilize certain of their existing customer billing service 

centers as claims service centers (“Claim Service Centers”). Prime Clerk 

staff will supplement existing staff at the Debtors’ Chico, Marysville, 

Oroville, Redding, Santa Rosa, and Napa billing center locations where 

members of the affected communities may go to ask general questions about 

the claims process. Additionally, Customers will be able to hand deliver 

Proofs of Claim to the Claim Service Centers during normal business hours 

and receive a date-stamped receipt. The individuals staffing the Claim 

Case: 19-30088 Doc# 1787 Filed: 05/01/19 Entered: 05/01/19 15:38:46 Page 11

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Service Centers will make clear that that no legal advice would be provided. 

In addition, the Bar Date Notices will be posted in each of the Debtors’ 

approximately seventy-five (75) billing service center locations. Prime Clerk 

estimates the cost of staffing Claims Service Centers to be $500,000 - 

$750,000 depending on staffing levels. 

 

[Signature page on next page]

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

 Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing statements 

are true and correct. 

Dated: May 1, 2019 

 

 

/s/ Benjamin P.D. Schrag

By: Benjamin P.D. Schrag 

Title: Chief Business Development Officer 

Prime Clerk LLC 

830 3rd Avenue, 9th Floor 

New York, New York 10022 

Case: 19-30088 Doc# 1787 Filed: 05/01/19 Entered: 05/01/19 15:38:46 Page 13

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