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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO 

Robert A. Julian (SBN 99469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8875 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official 

Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors 

□ Affects PG& E Corporation 

□ Affects Pacific Gas and Electric Company 

■ Affects both Debtors 

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM) 

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered) 

MOTION OF OFFICIAL COMMITTEE 

OF TORT CLAIMANTS PURSUANT TO 

BANKRUPTCY SECTIONS 105(a) AND 

107(b) AND BANKRUPTCY RULE 9018 

FOR ENTRY OF AN ORDER 

AUTHORIZING THE FILING UNDER 

SEAL OF THE UNREDACTED 

DECLARATION OF BRENT C. 

WILLIAMS (Related to Dkt. No. 1777) 

Date: May 22, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 2023 Filed: 05/15/19 Entered: 05/15/19 16:14:13 Page 1 of

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The Official Committee of Tort Claimants (the “TCC”) hereby submits this motion (the 

“Motion”) pursuant to sections 105(a) and 107(b) of title 11 of the United States Code (the 

“Bankruptcy Code”), Rule 9018 of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”), Rule 1001-2(a) of the Bankruptcy Local Rules for the United States 

District Court for the Northern District of California (the “Bankruptcy Local Rules”) and the 

New District Wide Procedures for Electronically Filing Sealed and Redacted Documents adopted 

by the United States Bankruptcy Court for the Northern District of California (the “Local 

Procedures”) for entry of an order (i) authorizing the TCC to file under seal the unredacted 

Declaration (“Unredacted Declaration”) of Brent C. Williams in support of the TCC’s Limited 

Joinder, Objection and Counter Motion (“Joinder”) to the Wildfire Assistance Program Motion 

(Dkt. No. 1777) (“Wildfire Assistance Program Motion”) filed by PG&E Corp. and Pacific Gas 

and Electric Company (collectively, the “Debtors,”); (ii) directing that the Unredacted 

Declaration shall remain under seal and confidential and not be made available to anyone without 

the consent of the TCC and the Debtors or further order from the Court. The TCC proposes 

providing the Unredacted Declaration to the Office of the United States Trustee for the Northern 

District of California (the “U.S. Trustee”) on a highly confidential basis and to counsel and 

financial advisors to the Debtors and the Official Committee of Unsecured Creditors on a “Highly 

Confidential – Professionals’ Eyes Only” basis. 

In support of this Motion, the TCC submits the Declaration of Brendan J. Murphy (the 

“Murphy Declaration”) filed contemporaneously herewith. A proposed form of order granting 

the relief requested herein is annexed hereto as Exhibit A (the “Proposed Order”). 

MEMORANDUM AND POINTS OF AUTHORITIES 

I. JURISDICTION 

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

Venue is proper under 28 U.S.C. §§ 1408 and 1409. This Motion is a core proceeding under 28 

U.S.C. § 157(b)(2). 

Case: 19-30088 Doc# 2023 Filed: 05/15/19 Entered: 05/15/19 16:14:13 Page 2 of

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II. BACKGROUND 

On May 1, 2019, the Debtors filed the Wildfire Assistance Program Motion (Dkt. No. 

1777). Contemporaneously herewith, the TCC filed its Joinder to the Wildfire Assistance 

Program Motion. In support of the Joinder, the TCC is submitting, inter alia, the declaration of 

Brent C. Williams, which has three exhibits. The declaration is based on the Debtors’ responses 

(“Debtors’ Responses”) to the TCC’s request for information regarding the Wildfire Assistance 

Program Motion. Murphy Declaration at ¶ 6. The Debtors marked the Debtors’ Responses as 

“Highly Confidential – Professionals’ Eyes Only.” Id. at ¶ 5. 

III. BASIS FOR RELIEF REQUESTED 

Section 105(a) of the Bankruptcy Code allows a court to “issue any order . . . that is 

necessary or appropriate to carry out the provisions of this title.” 11 U.S.C. § 105(a). Section 

107(b) further provides that a court may “protect any entity with respect to a trade secret or 

confidential research, development, or commercial information.” 11 U.S.C. § 107(b). To seek 

protection under section 107(b), a party only needs to show “that the information it [seeks] to seal 

[is] ‘confidential’ and ‘commercial’ in nature.” Video Software Dealers Ass’n v. Orion Pictures 

Corp., 21 F.3d 24, 27 (2d Cir. 1994). 

The Bankruptcy Rules similarly authorize the Court to “make any order which justice 

requires (1) to protect the estate or any entity in respect of a trade secret or other confidential 

research, development, or commercial information.” Bankruptcy Rule 9018. 

Finally, Local Procedures require that a request for seal is narrowly tailored to sealable 

materials. New District Wide Procedures For Electronically Filing Sealed and Redacted 

Documents. 

The Unredacted Declaration is based on the Debtors’ Responses, attached as Exhibit C to 

the Unredacted Declaration. Murphy Declaration at ¶ 5. The Debtors marked the Debtors’ 

Responses as “Highly Confidential – Professionals’ Eyes Only.” Id. at ¶ 5. The TCC redacted 

only the information in the Unredacted Declaration and Exhibit C to the Unredacted Declaration 

that was based on the Debtors’ Reponses. Id. at ¶ 6. Because the Unredacted Declaration 

Case: 19-30088 Doc# 2023 Filed: 05/15/19 Entered: 05/15/19 16:14:13 Page 3 of

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contains highly confidential information, according to the Debtors, the Unredacted Declaration 

falls within the scope of section 107(b), and this Court should grant the TCC’s request. 

IV. NOTICE 

Notice of this Motion will be provided to (i) the Debtors, c/o PG&E Corporation and 

Pacific Gas and Electric Company, PO Box 770000, 77 Beale Street, San Francisco, CA 94105 

(Attn: Janet Loduca, Esq.); (ii) Weil, Gotshal & Manges LLP, 767 Fifth Avenue, New York, New 

York 10153 (Attn: Stephen Karotkin, Esq., Jessica Liou, Esq., and Matthew Goren, Esq.), 

proposed attorneys for the Debtors; (iii) Keller & Benvenutti LLP, 650 California Street, Suite 

1900, San Francisco, CA 94108 (Attn: Tobias Keller, Esq. and Jane Kim, Esq.), proposed 

attorneys for the Debtors; (iv) Stroock & Stroock & Lavan LLP, 180 Maiden Lane, New York, 

NY 10038-4982 (Attn: Kristopher M. Hansen, Esq., Erez E. Gilad, Esq., and Matthew G. 

Garofalo, Esq.) and 2029 Century Park East, Los Angeles, CA 90067-3086 (Attn: Frank A. 

Merola, Esq.), as counsel for the administrative agent under the Debtors’ debtor-in-possession 

financing facility; (v) Davis Polk & Wardwell LLP, 450 Lexington Avenue, New York, NY 

10017 (Attn: Eli J. Vonnegut, Esq., David Schiff, Esq., and Timothy Graulich, Esq.), as counsel 

for the collateral agent under the Debtors’ debtor-in-possession financing facility; (vi) Paul, 

Weiss, Rifkind, Wharton & Garrison LLP, 1285 Avenue of the Americas, New York, NY 10019-

6064 (Attn: Alan W. Kornberg, Esq., Brian S. Hermann, Esq., Walter R. Rieman, Esq., Sean A. 

Mitchell, Esq., and Neal P. Donnelly, Esq.), as counsel to the California Public Utilities 

Commission; (vii) the Office of the United States Trustee for Region 17, 450 Golden Gate 

Avenue, 5th Floor, Suite #05-0153, San Francisco, CA 94102 (Attn: James L. Snyder, Esq. and 

Timothy Laffredi, Esq.); (viii) U.S. Nuclear Regulatory Commission, Washington, DC 20555-

0001 (Attn: General Counsel); (ix) U.S. Department of Justice, 1100 L Street, NW, Room 7106, 

Washington DC 20005 (Attn: Danielle A. Pham, Esq.,) as counsel for United States on behalf of 

the Federal Energy Regulatory Commission; (x) Milbank LLP, 55 Hudson Yards, New York, NY 

10001-2163 (Attn: Dennis F. Dunne, Esq. and Sam A. Khalil, Esq.) and 2029 Century Park East, 

33rd Floor, Los Angeles, CA 90067 (Attn: Paul S. Aronzon, Esq., Gregory A. Bray, Esq., and 

Thomas R. Kreller, Esq.), as counsel for the Official Committee of Unsecured Creditors; and (xi) 

Case: 19-30088 Doc# 2023 Filed: 05/15/19 Entered: 05/15/19 16:14:13 Page 4 of

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those persons who have formally appeared in these Chapter 11 Cases and requested service 

pursuant to Bankruptcy Rule 2002. The TCC respectfully submits that no further notice is 

required. 

No previous request for the relief sought herein has been made by the Debtors to this or 

any other court 

WHEREFORE, the TCC respectfully requests entry of an order(i) authorizing the TCC 

to file under seal the Unredacted Declaration; and (ii) directing that the Unredacted Declaration 

shall remain under seal and confidential and not be made available to anyone without the consent 

of the TCC and the Debtors or further order from the Court 

Dated: May 15, 2019 Respectfully submitted, 

BAKER & HOSTETLER LLP

By: /s/ Robert A. Julian

Robert A. Julian

Counsel for Official Committee of Tort Claimants

Case: 19-30088 Doc# 2023 Filed: 05/15/19 Entered: 05/15/19 16:14:13 Page 5 of

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