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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 Boulevard 

Suite 1400 

Los Angeles, CA 90025 

Telephone: 310.820.8800 

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) 

MEMORANDUM OF POINTS AND 

AUTHORITIES IN SUPPORT OF 

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ENTRY OF AN ORDER 

(I) ESTABLISHING A BAR DATE FOR 

FILING FIRE CLAIMS, 

(II) APPROVING THE FORM AND 

PROCEDURES FOR NOTICE OF THE 

BAR DATE FOR FIRE CLAIMS, AND 

(III) APPROVING SUPPLEMENTAL 

PROCEDURES FOR NOTICE OF THE 

BAR DATE TO FIRE CLAIMANTS 

Date: June 11, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: June 10, 2019

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TABLE OF CONTENTS 

I. JURISDICTION .................................................................................................................. 1

II. BACKGROUND ................................................................................................................ 1

III. INTRODUCTION .............................................................................................................. 2

IV. THE TCC’S PROPOSED PROCEDURES FOR FIRE CLAIMS ...................................... 3

A. The Fire Proof of Claim Form ................................................................................ 3

B. Fire Claimant Bar Date ........................................................................................... 3

C. Direct Notice Program ............................................................................................ 4

D. Proposed Procedures for Filing Fire Proofs of Claim ............................................. 4

V. TCC’S PROPOSED NOTICE PROGRAM AND PROCEDURES ................................... 8

A. Direct Notice Program ............................................................................................ 8

B. Supplemental Notice Program .............................................................................. 10

C. Cost of TCC’s Proposed Notice Program ............................................................. 12

VI. BASIS FOR RELIEF ........................................................................................................ 13

A. The Court Should Approve the TCC’s Bar Date and the Proposed Notice 

Program for Filing Proofs of Claim in the Chapter 11 Cases ............................... 13

B. The Proposed Notice Procedures Are Reasonable and Appropriate ..................... 14

VII. NOTICE ............................................................................................................................ 16

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TABLE OF AUTHORITIES 

Cases Page(s) 

Eisen v. Carlisle & Jacquelin, 

417 U.S. 156 (1974) ..................................................................................................................15 

Huntsinger v. The Shaw Group, Inc., 

268 Fed. Appx. 518 (9th Cir. Feb. 26, 2008) ............................................................................15 

In re Mansaray-Ruffin, 

530 F.3d 230 (3d Cir. 2008) ......................................................................................................15 

In re Maya Const. Co., 

78 F.3d 1395 (9th Cir. 1996) .....................................................................................................14 

Mullane v. Cent. Hanover Bank & Tr. Co., 

339 U.S. 306 (1950) ............................................................................................................14, 15 

PacifiCorp and Van Cott Bagley Cornwall & McCarthy v. W.R. Grace, 

No. 05-764, 2006 WL 2375371 (D. Del. Aug. 16, 2006) .........................................................15 

In re Reg’l Care Servs. Corp., 

No. 16-1213, 2017 WL 2871751 (B.A.P. 9th Cir. Jul. 5, 2017) ......................................... 14-15 

Tulsa Prof’l Collection Servs., Inc. v. Pope, 

485 U.S. 478 (1988) ..................................................................................................................15 

Statutes 

11 U.S.C. § 341 ...............................................................................................................................13 

28 U.S.C. § 157 .................................................................................................................................1 

28 U.S.C. § 1334 ...............................................................................................................................1 

28 U.S.C. § 1408 ...............................................................................................................................1 

28 U.S.C. § 1409 ...............................................................................................................................1 

Rules 

Fed. R. Bankr. P. 2002 ..............................................................................................................16, 18 

Fed. R. Bankr. P. 3003 ................................................................................................................7, 13 

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Other Authorities 

B.L.R. 3003-1 ..................................................................................................................................13 

B.L.R. 5011-1 ....................................................................................................................................1 

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I. JURISDICTION 

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

the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24 

(N.D. Cal.), and Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District Court 

for the Northern District of California (“Bankruptcy Local Rules”). This is a core proceeding 

pursuant to 28 U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 

and 1409. 

II. BACKGROUND 

On January 29, 2019 (the “Petition Date”), PG&E Corporation and Pacific Gas and Electric 

Company (the “Debtors” or “PG&E”) commenced with the Court voluntary cases (the “Chapter 

11 Cases”) under chapter 11 of the United States Code (“Bankruptcy Code”). PG&E’s chapter 11 

filings were necessitated by a confluence of factors resulting from catastrophic fires that occurred 

in Northern California prior to the Petition Date, and PG&E’s potential liabilities arising 

therefrom. See Amended Declaration of Jason P. Wells in Support of First Day Motions and 

Related Relief (Dkt. No. 263), at 3.

On the Petition Date, PG&E filed an application (Dkt. No. 14) for the appointment of Prime 

Clerk LLC (“Prime Clerk”) as claims and noticing agent. On February 1, 2019, the Court entered 

an order (Dkt. No. 245) authorizing Prime Clerk to (1) serve as the custodian of court records and 

the authorized repository for all proofs of claim filed in these Chapter 11 Cases; (2) perform 

noticing services and to receive, maintain, record and otherwise administer the proofs of claim filed 

in these Chapter 11 Cases; and (3) provide an electronic interface for filing proofs of claim. 

On May 1, 2019, PG&E filed a motion to set the bar date for claims, approve the claim 

form, and approve notice procedures (Dkt. No. 1784) (the “Bar Date Motion”). 

On May 3, 2019, the TCC filed a motion to approve the TCC’s model proof of claim form 

(Dkt. No. 1824) (“TCC Proof of Claim Motion”) and a memorandum of points and authorities in 

support thereof (Dkt. No. 1825) (the “TCC Proof of Claim Memorandum in Support”).1

 

1

 Capitalized terms used but not defined herein shall have the meanings given to them in the TCC Proof of Claim 

Memorandum in Support. 

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Contemporaneously herewith, the TCC is filing an objection to PG&E’s Bar Date Motion. 

The TCC’s Motion requests that the Court enter an order approving a separate bar date for Fire 

Claims (the “Fire Claim Bar Date”), the TCC’s notice of bar date to known and reasonably 

identifiable Fire Claimants (the “Direct Notice Program”), and the TCC’s supplemental notice 

plan to unknown Fire Claimants (the “Supplemental Notice Program” and together with the 

Direct Notice Program, the “Notice Program”), as detailed below. 

III. INTRODUCTION 

For these Chapter 11 Cases to be successful, it is the critical that all Fire Claimants file 

proofs of claim. The TCC has created a robust plan to ensure exactly that. Contemporaneously 

with the filing of its Motion, the TCC is filing an application to retain the renowned noticing firm 

Angeion Group, LLC (“Angeion”). 

As set forth in the Declaration of Steven Weisbrot, the experts at Angeion have extensive 

experience in creating and administering claims and notice programs designed to maximize 

claimant reach and participation and have designed a notice plan to meet applicable legal 

requirements given the unique circumstances presented by these cases. The Motion seeks 

authorization for Angeion (subject to the Court’s approval of its retention application) to perform 

all necessary noticing and related services to effectuate the TCC’s Notice Program. 

The TCC’s Notice Program utilizes a wide range of methods to reach potential claimants, 

including direct notice through mail and email, paid media in the form of television, radio, 

newspaper and magazine publication, billboards, and social media, as well as grassroots and 

experiential marketing. Again, it is critical that a robust plan be implemented, as many victims of 

the 2018 Camp Fire are still homeless and suffering trauma. 

If the TCC’s Motion is granted, Angeion will replace Prime Clerk for purposes of 

implementing the TCC’s Notice Program to Fire Claimants. Prime Clerk will continue to maintain 

the claims registry and implement PG&E’s notice plan for claimants other than Fire Claimants, but 

the Direct Notice Program and outreach to known Fire Claimants and the Supplemental Notice 

Program and outreach to unknown Fire Claimants would be handled by Angeion. 

The TCC is also requesting that the Court set a separate bar date for Fire Claims. The TCC, 

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in consultation with experts, believes that the Fire Claimants will need at least until early 2020 to 

file Fire Claims. Many of the Fire Claimants are still living in tents and trailers, focused on meeting 

basic survival needs. These Fire Claimants will need more time to file these critical Fire Claims. 

As set forth in the TCC’s objection to PG&E’s Bar Date Motion, PG&E’s proposed notice 

plan is constitutionally insufficient. PG&E does not plan to take steps to obtain updated address 

information beyond the forwarding information available from the U.S. Postal Service. PG&E 

proposes to spend a mere $1.5 million to $2 million on its supplemental notice program, as 

administered by Prime Clerk, to reach victims who will not receive direct notice – which includes 

those Fire Claimants whose homes and mailboxes have been incinerated. PG&E’s minimalist 

approach is improper in the context of these cases and ignores the fact that many victims of the 

2018 Camp Fire are still homeless and suffering trauma. The TCC cannot wait for PG&E to take 

appropriate actions. To advance these Chapter 11 Cases, the TCC comes before this Court and 

seeks approval of its Notice Program. 

IV. THE TCC’S PROPOSED PROCEDURES FOR FIRE CLAIMS 

A. The Fire Proof of Claim Form 

As a preliminary matter, the TCC has already sought approval of its model Fire Proof of 

Claim Form (the “Fire Proof of Claim Form”), attached hereto as Exhibit C. The TCC’s Fire 

Proof of Claim Form substantially conforms to Official Form 410. The modifications made by the 

TCC to the Official Form are intended to ensure that Fire Claimants provide information regarding 

the basis for their Fire Claims, the harm caused by the related fire, and the damages sought. The 

TCC’s form is designed to meet applicable legal requirements so that each Fire Claim is entitled to 

prima facie validity, while also making it as easy as possible for unrepresented victims to file claims 

so they are not excluded. For the reasons already set forth in the TCC Proof of Claim Memorandum 

in Support, the TCC’s Fire Proof of Claim Form should be approved. 

B. Fire Claim Bar Date 

The TCC anticipates that thousands of parties are likely to file claims in the Chapter 11 

Cases arising from or relating to the Fires that PG&E is alleged to have caused. As a result, the 

TCC is requesting a Fire Claim Bar Date that will allow sufficient time for Fire Claimants to 

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understand the claim requirements and complete the Fire Proof of Claim Form. 

To this end, the TCC consulted with Jeffrey Dion, the Executive Director of the National 

Compassion Fund, a non-profit organization dedicated to the collection and distribution of 

charitable donations to victims of mass casualty crimes. Mr. Dion has extensive experience in 

developing notice and outreach programs to contact and inform dispersed and displaced victims of 

mass disasters, including nearly a dozen mass shooting events around the country. Mr. Dion also 

conducted an outreach and awareness campaign to educate victims of the September 11, 2001 

terrorist attacks about their options to file a civil lawsuit against their airlines or a claim with the 

federal government’s September 11th Victim Compensation Program. 

Although fires have important categorical differences from mass shootings or terrorist 

attacks, they share common elements of trauma that have likely affected potential Fire Claimants 

here. Many victims feared for their lives, fled impending danger, and were uncertain as to whether 

they or their loved ones would make it out alive. Such experiences can cause deep, long-lasting 

psychological trauma, and it is critical to recognize this fact when designing a compensation 

program and selecting an appropriate claim-submission deadline. Based on this reality, the TCC 

requests the Fire Claim Bar Date be set no earlier than January 31, 2020, which assumes the Court’s 

adoption of the TCC’s Fire Proof of Claim Form and the TCC’s Notice Program. 

C. Direct Notice Program 

To facilitate the notice of the Fire Claim Bar Date, the TCC proposes to use a one-page Fire 

Claim Bar Date Notice in the form attached to the Motion as Exhibit A. The Fire Claim Bar Date 

Notice is a simplified one-page form designed to provide key information to Fire Claimants about 

the bar date to Fire Claimants. The Fire Claim Bar Date Notice includes all of the most relevant 

information, such as the bar date and the method for filing a Fire Proof of Claim, in a streamlined, 

understandable way. 

D. Proposed Procedures for Filing Fire Proofs of Claim 

The TCC proposes the following procedures for filing Fire Proofs of Claim by any person 

or entity that is a Fire Claimant: 

(a) The Fire Claim Bar Date shall be January 31, 2020 at 9:00 p.m. (Pacific Time). 

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(b) Fire Proof of Claim Forms must: 

(1) be written in the English language; 

(2) conform substantially to the Fire Proof of Claim Form or Official 

Form No. 410; and 

(3) be signed by the Fire Claimant or, if the Fire Claimant is not an 

individual, by an authorized agent of the Fire Claimant. 

(c) All timely filed Fire Proof of Claim Forms will be deemed filed against both Debtors 

(without prejudice to the Debtors’ right to assert that any such claim should be 

allowed only as to one of the Debtors). 

(d) All Fire Proof of Claim Forms must be filed either (i) electronically through Prime 

Clerk’s website using the interface available on the Case Website under the link 

entitled “Submit a Claim” (the “Electronic Filing System”) or (ii) by delivering the 

original Fire Proof of Claim Form by hand, or mailing the original Fire Proof of 

Claim Form so that is received on or before the Fire Claim Bar Date as follows: 

If by first class mail: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

Grand Central Station, PO Box 4850 

New York, NY 10163-4850 

If by overnight courier: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

850 Third Avenue, Suite 412 

Brooklyn, NY 11232 

If by hand delivery: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

850 Third Avenue, Suite 412 

Brooklyn, NY 11232 

-orAt one of the Debtors’ Claim Service Centers located at the following PG&E 

locations: 

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(i) 350 Salem Street, Chico, CA 95928; 

(ii) 231 “D” Street, Marysville, CA 95901; 

(iii) 1567 Huntoon Street, Oroville, CA 95965; 

(iv) 3600 Meadow View Road, Redding, CA 96002; 

(v) 111 Stony Circle, Santa Rosa, CA 95401; or 

(vi) 1850 Soscol Ave. Ste 105, Napa, CA 94559. 

(e) A Fire Proof of Claim Form shall be deemed timely filed only if it is actually 

received by Prime Clerk (i) at the addresses listed above in subparagraph (d), or 

(ii) electronically through the Electronic Filing System on or before the Fire Claim 

Bar Date. 

(f) Fire Proof of Claim Forms sent by facsimile, telecopy, or electronic mail 

transmission (other than Fire Proofs of Claim filed electronically through the 

Electronic Filing System) will not be accepted. 

(g) In the event that the Debtors amend or supplement their Schedules subsequent to the 

date of entry of the order setting the Fire Claim Bar Date, the Debtors shall give 

notice of any amendment or supplement to the holders of claims or interests affected 

thereby, and such holders shall have until the later of (i) the Fire Claim Bar Date or 

(ii) thirty (30) days from the date of such notice to file a Fire Proof of Claim or be 

barred from doing so and shall be given notice of such deadline. 

(h) The following persons or entities are not required to file a Fire Proof of Claim solely 

with respect to the claims described below: 

(i) any person or entity that is not a Fire Claimant; 

(ii) any Fire Claimant who has already filed a Fire Proof of Claim against 

any of the Debtors with respect to the claim being asserted, utilizing a 

claim form that substantially conforms to the Fire Proof of Claim Form 

or Official Form No. 410; provided, however, that any Fire Claimant 

who holds or asserts a claim other than a Fire Claim must file a general 

proof of claim prior to the general claims bar date set in the Chapter 11 

Cases; 

(iii) any Fire Claimant whose claim has been paid in full; 

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(iv) any Fire Claimant who holds a claim that heretofore has been allowed 

by Order of the Court entered on or before any applicable bar date set for 

Fire Claims in the Chapter 11 Cases; and 

(v) any Fire Claimant whose claim is listed on the Schedules; provided that 

(A) the claim is not listed on the Schedules as “disputed,” “contingent,” 

or “unliquidated,” (B) the Fire Claimant does not dispute the amount, 

nature, and priority of the claim as set forth in the Schedules, and (C) the 

Fire Claimant does not dispute that the claim is an obligation of the 

specific Debtor against which the claim is listed in the Schedules. 

(i) Pursuant to Bankruptcy Rule 3003(c)(2), all holders of Fire Claims, including Fire 

Claimants, that fail to comply with the Court’s Order by timely filing a Proof of 

Claim in the appropriate form shall (a) be forever barred, estopped and enjoined 

from asserting such claims against the Debtors, their property, or their estates (or 

submitting a Fire Proof of Claim with respect thereto) and (b) not be treated as a 

creditor with respect to such claim for the purposes of voting and distribution with 

respect to any Chapter 11 plan or plans of reorganization that may be filed in these 

Chapter 11 Cases. Notwithstanding the foregoing, late filings shall be permitted 

where the failure to act was the result of “excusable neglect” under the standard set 

forth in Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership, 

507 U.S. 380 (1993) or as otherwise permitted by the Court. 

(j) No party, including the Debtors, may object in whole or in part to any Fire Claim 

prior to the Fire Claim Bar Date. 

(k) Within five (5) days of entry of an order granting the Motion, the Debtors, Prime 

Clerk, and the TCC shall post the Fire Claim Bar Date Notice and Fire Proof of 

Claim Form on their websites, and the UCC shall include a link to both the TCC and 

Prime Clerk websites. 

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V. TCC’s PROPOSED NOTICE PROGRAM AND PROCEDURES 

Not only are there tens of thousands of Fire Claimants, but many have been displaced by 

the fires. Many have left California. Others are still living in temporary housing. Providing notice 

of the claims bar date for Fire Claimants will not be as simple as sending a notice to the last known 

address, particularly in instances where one of the Fires incinerated the Fire Claimant’s house and 

mailbox, or where the Fire Claimant has been displaced. The TCC’s Notice Program is robust, will 

ensure that updated contact information is obtained for displaced victims where possible, and will 

ensure that a first-class media campaign is implemented to reach unknown Fire Claimants. 

The Notice Program is based on objective data customarily used by advertising 

professionals and is designed to reach the greatest practicable number of Fire Claimants. Notice 

will be effectuated directly where possible, and via the use of a sophisticated, integrated, 

multimedia campaign, where no direct contact information exists or can be reasonably ascertained. 

Specifically, the Notice Program utilizes a combination of direct notice via U.S. mail and 

email (where both are available or can be derived from third-party data sources), coupled with 

robust paid and earned media campaigns. The integrated paid media campaign utilizes state-ofthe-art targeted internet banner advertisements, custom social media campaigns, a bespoke 

broadcast radio/television campaign, a network of digital and static billboards, a combination of 

local, regional, and national print publications, and a nationwide, yet geographically tailored, public 

relations campaign. Further, the Notice Program utilizes an earned media campaign designed to 

take advantage of the substantial news coverage the events have already garnered and to continue 

to drive media to cover the story at a local, regional and national level. Moreover, the TCC through 

its program will engage in a grassroots word-of-mouth campaign and experiential marketing. 

An overview of the TCC’s proposed Notice Program is provided below. 

A. Direct Notice Program 

The TCC’s Notice Program contemplates a robust Direct Notice Program, which 

incorporates sophisticated third-party data sources, known best practices, and advanced search 

techniques. The facts and circumstances of the Chapter 11 Cases demand that PG&E, in 

consultation with the TCC, undertake additional efforts to locate Fire Claimants, and obtain current 

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addresses for the same. In order to comport with Due Process, within fourteen (14) days following 

entry of the Order, PG&E shall provide Angeion with information sufficient to allow it to compile 

a Fire Claimant mailing list that will be designed to be as fulsome and over-inclusive as possible. 

Broadly, the categories of information that will ultimately provide name, address, and other 

pertinent contact information necessary to comprise this Fire Claimant list can be summarized as 

follows: 

a. Prepetition Litigation Records. The list will include all fire victims that filed 

prepetition suits. This includes the data gathered during the North Bay Fires 

litigation, which is stored in a centralized database run by BrownGreer PLC. 

Angeion, working with the TCC, will also locate previously filed complaints and 

obtain attorney contact information for the lawyers representing the plaintiffs, 

including the use of litigations service lists. 

b. PG&E Customer Data. Nearly all of the victims were PG&E customers and, thus, 

PG&E maintained current contact information up to and including the dates of the 

fires. The physical addresses in this database could, in some cases, be outdated, 

since many of the customer addresses would be for homes that were destroyed by 

the fires. Nevertheless, PG&E customers may have updated their records with 

PG&E, and even if they did not, Angeion, working with both the United States 

Postal Service (“USPS”) and reputable third-party data aggregation companies, can 

determine a significant number of current addresses for some of these individuals. 

c. Geographic Information Systems Data. PG&E has represented in its Bar Date 

Motion, at 22, that it has some “proprietary data maintained by Geographical 

Information Systems (“GIS”) satellite experts retained by Debtors in connection 

with the prepetition litigation.” 

d. Disaster Relief and Community Organizations. Several disaster relief organizations, 

including but not limited to the Red Cross, FEMA and myriad local agencies, have 

provided support to fire victims. The TCC believes it will be successful in garnering 

additional contact information through those organizations which can be utilized as 

part of the direct notice efforts. 

e. Records Garnered Pursuant to Subpoena. In other court-approved notice programs 

that Angeion has implemented, the court has authorized the use of third-party 

subpoenas to help identify and contact absentee audiences. In particular, as it relates 

to this case, the TCC could use subpoenas to procure information from insurance 

carriers, governmental organizations, and/or private repair/remediation companies 

to gather additional address information for Fire Claimants. 

f. First-Party Intelligence. Public records, third-party data sources, and community 

resources will be identified, culled and thoroughly searched to identify as many 

owners of destroyed properties as possible. Angeion will then use other sources of 

data to ascertain current mailing addresses, particularly in circumstances where 

properties were completely destroyed and notice can no longer be sent to former 

addresses. 

g. TCC Website. Angeion has been advised that the TCC is designing a dedicated 

website that will act as a hub of communication between the TCC and the fire 

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victims. Among other functions, the website will allow those affected by the fires 

to enter their own contact information as well as contact information for displaced 

friends and family members. 

h. Emergency Fund. Debtors shall cause Angeion to receive a list with contact 

information for all Fire Claimants who file applications for assistance from the 

Emergency Fund approved by this Court on May 24, 2019. See Dkt. No. 2223. 

Specifically, Angeion will cause the Fire Bar Date Notice and Fire Proof of Claim Form 

(collectively, the “Fire Claimant Notice Materials”) to be mailed via USPS first-class mail, 

postage prepaid. Prior to mailing, the mailing list will be processed via the USPS National Change 

of Address database to identify updated address information for individuals and businesses who 

have moved in the last four years and who filed a change of address card with the USPS. 

Similarly, in an effort to deliver notices to the intended recipients, the Notice Program 

provides for the following: (1) notices that are returned as undeliverable by the USPS and have a 

forwarding address will be re-mailed to that forwarding address; and (2) notices that are returned 

as undeliverable by the USPS without a forwarding address will be subject to address verification 

searches (“skip tracing”), utilizing a wide variety of data sources, including public records, real 

estate records, electronic directory assistance listings, and so on, to locate updated addresses. 

Notices will then be re-mailed to updated addresses located through skip tracing. 

The direct mail effort will be supplemented by sending notice to all Fire Claimants who 

have an email address or for whom an email address can be garnered via PG&E’s customer records 

and sophisticated third-party data aggregation services described infra. It is important to note that 

the email effort will be in addition to, not in lieu of, the mailed notice efforts described herein. 

B. Supplemental Notice Program 

To supplement the comprehensive Direct Notice Program and effectuate notice to the Fire 

Claimants, the Supplemental Notice Program contemplates a robust paid campaign that utilizes 

multiple forms of media—e.g., television, radio, magazines, newspapers, and social media—to 

enable PG&E to identify additional known Fire Claimants and to give constructive notice to 

unknown claimants. 

The Supplemental Notice Program is summarized below and described in more detail in the 

Weisbrot Declaration. 

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a. Video: Both traditional broadcast television and internet/streaming opportunities 

are high-reach media tactics that provide exposure to affected people regardless of 

where they reside (i.e., rural areas, urban areas, etc.). Thirty-second units will 

appear on local broadcast and cable television as appropriate in the 4 core designated 

market areas (San Francisco, Sacramento, Chico-Redding, and Eureka). 

b. Audio: Both terrestrial and streaming radio are high-frequency mediums, ideally 

suited for providing exposure to affected Fire Claimants where they reside (i.e., rural 

areas, urban areas, etc.). The Supplemental Notice Program contemplates 60-

second units over a 21 week schedule on selected radio stations in the Northern 

California markets. There are a total of 6 radio metro survey areas in the Northern 

California area: Chico, Redding, San Francisco, Sacramento, Stockton, and 

Modesto. There are an additional 3 counties that are not measured in radio metros 

and will be included in the consideration set. Those counties are Lake, Mendocino, 

and Humboldt. 

c. Programmatic Display and Video: Angeion utilizes advanced targeting, machine 

learning, and a known and verifiable target audience profile, to ensure that members 

of the target audience are reached online. Through this “programmatic” approach, 

Angeion’s focus will be on effectively reaching the prototypical Fire Claimant, 

rather than whitelisting specific websites. Purchasing display and video inventory 

programmatically provides the highest reach, allows for multiple targeting layers, 

and offers the most cost-efficient rates. The campaign will run across all devices 

including desktop, mobile, tablet, and other connected devices to ensure maximum 

reach. Further, the display campaign will include targeting around key word lists 

and IP addresses. Utilizing these types of lists, the program will target residents in 

Lake, Sonoma, Napa, Mendocino, Nevada, Butte, and Humboldt counties based on 

their IP addresses. In addition to residents, similar lists will be utilized to target 

employees or business owners in those areas. 

d. Magazines: Two print publications will be utilized to cover the western region of 

the United States: People and Sports Illustrated. These were chosen due to their 

reach against Adults 18+ and the balanced demographic readership that the 

publications provide when used together. In order to maximize efficiencies, the 

publication notice will be geo-targeted to the following states: California, Nevada, 

Oregon, and Washington. Over the course of the 7-month campaign timeframe, 

each publication will have 4 regional insertions. 

e. Newspapers: The Supplemental Notice Program includes newspapers targeted to 

two different geographic regions. A collection of 14 local newspapers targeted to 

the 4 key designated market areas (San Francisco, Sacramento, Chico-Redding, and 

Eureka) were chosen to provide a campaign-long print presence in this key market. 

Each publication will have 14 full-page insertions spread out over the 7 months. 

These will be included in the weekday publications of each paper. In addition to the 

local publications, newspapers covering the remainder of the state were all selected 

given the intense displacement of the affected parties. These include the LA Times, the Wall Street Journal (Northern CA & Southern CA Editions), and USA Today

(Los Angeles and San Francisco Editions). Each of these publications will include 

7 full-page insertions over the course of the 7-month campaign and will be in the 

weekday issues. 

f. Social Media: The Supplemental Notice Program also contemplates a robust multipronged approach to using social media to seed and disburse news of the bar date to 

the Fire Claimants. The paid social media component will include Facebook, 

Instagram, and Twitter. 

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g. Out-of-Home: The Supplemental Notice Program will include “out-of-home” or 

outdoor advertising in both the Northern California area and the entire state of 

California. Out-of-home is a very strong awareness tactic and efficiently drives 

significant reach. To focus in on the primary geography, a large portion of the outof-home advertising will be placed in the 4 designated market areas mentioned 

previously. Out-of-home will include a mix of digital and static units to maximize 

overall reach and efficiencies. This includes 54 digital units and 18 static units in 

the Northern California area for the first 3 months of the campaign. In addition to 

the local focus, there will be support in both Los Angeles and San Diego. In Los 

Angeles, 10 digital units are recommended to reach potential claimants. In San 

Diego, 29 digital transit shelters and 10 digital billboards are recommended to reach 

potential claimants. 

h. Earned Media: A critical component of the Supplemental Notice Program is a 

sustained media presence via earned media; this is effectuated using two unified 

public relations partners—one on the east coast and one in the Bay Area. The fires 

have proved to be the ultimate public interest story and have been covered by local, 

national and international press. The public relations portion of the campaign is 

designed to guarantee a continued lifecycle in the press concerning the importance 

and timeliness of the Fire Claim Bar Date. Using direct media outreach, press 

conferences, regular news releases, content development and official spokespeople, 

Angeion will generate substantial earned media. This includes personally 

contacting the media and leveraging standing relationships to open conversations 

and ultimately secure media coverage of the bar date. A list of target media outlets 

is attached as Exhibit D to the Weisbrot Declaration. 

i. Grassroots Outreach and Experiential Marketing: The Supplemental Notice 

Program will include both grassroots outreach and experiential marketing. It will 

utilize professional experiential marketers to hand-distribute notice forms for a total 

of 35 days across the 7 counties affected by the fires. The team will distribute flyers 

both to individuals and institutions that make sense in the various communities, 

including leaving flyers at high-traffic locations such as community centers, 

restaurants, and houses of worship. The Supplemental Notice Program also includes 

direct outreach to any remaining community centers and meeting places, notice 

through churches, social service agencies, support groups, online forums and other 

trusted community resources. 

C. Cost of TCC’s Proposed Notice Program 

The TCC is not proposing to spend more, but to spend funds in the right way. Of the $22 

million budgeted by PG&E for noticing, the TCC proposes to spend a total of $21.8 million, of 

which $12.8 is allocated to the Supplemental Notice Program. Prime Clerk estimates the cost of 

mailing bar date notices to be $18 million to $20 million. Bar Date Motion at 11. Angeion Group 

estimates that it can effectuate the same mailing for approximately $8 million to $9 million. 

By adopting the TCC’s Notice Program, the cost of mailings could be substantially reduced 

by approximately $9 million to $11 million, and the savings could be used to fund the Supplemental 

Notice Program without meaningfully increasing (and perhaps even decreasing) the overall cost of 

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the Notice Program. This would allow a substantially stronger and more effective Notice Program 

at a virtually identical price point. 

VI. BASIS FOR RELIEF 

A. The Court Should Approve the TCC’s Bar Date and the Proposed Notice 

Program for Filing Proofs of Claim in the Chapter 11 Cases 

Bankruptcy Rule 3003(c)(3) provides that the Court shall fix the time within which proofs 

of claim are filed. Local Bankruptcy Rule 3003-1 provides that unless otherwise ordered by the 

Court, proofs of claim in Chapter 11 cases shall be filed within 90 days after the first date set for 

the meeting of creditors called pursuant to 11 U.S.C. § 341(a). B.L.R. 3003-1. Bankruptcy 

Rule 3003(c)(2) provides that any creditor whose claim (a) is not scheduled in PG&E’s schedules 

of assets and liabilities and statements of financial affairs or (b) is scheduled as disputed, 

contingent, or unliquidated must file a proof of claim by the bar date fixed by the Court. Bankruptcy 

Rule 3003(c)(2) further provides that “any creditor who fails to do so shall not be treated as a 

creditor with respect to such claim for the purposes of voting and distribution.” Fed. R. Bankr. P. 

3003(c)(2). 

Here, PG&E scheduled thousands of Fire Claims in the Chapter 11 Cases in an 

“undetermined” amount as “disputed,” “contingent,” and “unliquidated,” thus necessitating the 

need for virtually all, if not all, Fire Claimants to file proofs of claim in the Chapter 11 Cases. See

Dkt. No. 906 at Schedule E/F. In addition, actual notice of any bar date set in the Chapter 11 Cases 

must be sent to all known creditors, including all known or reasonably identifiable Fire Claimants. 

The importance of this cannot be understated. This task will require not only considerable effort 

but also a level of cooperation between various parties in interest. Approving the TCC’s Notice 

Program will allow PG&E to gain visibility into the total Fire Claims against the estates and will 

create a process that is both efficient and less burdensome on Fire Claimants. 

The Notice Program described herein provides Fire Claimants with ample notice and 

opportunity and a clear process for filing Fire Proofs of Claim and achieving administrative and 

judicial efficiency. Indeed, the TCC’s Notice Program will provide comprehensive notice and clear 

instructions to Fire Claimants, on the one hand, and allow the Chapter 11 Cases to move forward 

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quickly with a minimum of administrative expense and delay, on the other hand. 

The TCC’s Notice Program provides clear instructions that will help avoid confusion or 

uncertainty among Fire Claimants that might lead them to file unnecessary protective proofs of 

claim or multiple proofs of claim that would cause expense and delay in the claims process for all 

parties. The TCC’s Notice Program is also designed to comply with the Bankruptcy Code while 

providing flexibility if supplemental information on the Fire Claims is required. 

B. The Proposed Notice Procedures Are Reasonable and Appropriate 

The TCC’s Notice Program provides for mailing the Fire Claimant Notice Materials to Fire 

Claimants who are known to PG&E, or whose identity can be reasonably ascertained. The Notice 

Program thus relies on publication and supplemental notice for unknown or unascertainable Fire 

Claimants. This procedure is consistent with applicable case law and practice in this District. 

See, e.g., Mullane v. Cent. Hanover Bank & Tr. Co., 339 U.S. 306, 317 (1950). 

Due process requires that known creditors receive actual written notice of a debtor’s 

bankruptcy filing and claims bar date. See In re Maya Const. Co., 78 F.3d 1395, 1399 (9th Cir. 

1996) (due process requires formal notice to known contingent creditors); In re Reg’l Care Servs. 

Corp., No. 16-1213, 2017 WL 2871751, at *6 (B.A.P. 9th Cir. Jul. 5, 2017) (“It is a fundamental 

principle of due process that known creditors of a debtor are entitled to actual notice of a claims 

bar date before their claims can be extinguished”) (citation omitted). 

A known creditor is one whose identity is either known or “reasonably ascertainable by the 

debtor.” Tulsa Prof’l Collection Servs., Inc. v. Pope, 485 U.S. 478, 490 (1988). Customers with 

whom a debtor has a direct relationship are generally considered known creditors. See PacifiCorp 

and Van Cott Bagley Cornwall & McCarthy v. W.R. Grace, No. 05-764, 2006 WL 2375371, at *4 

(D. Del. Aug. 16, 2006). For unknown creditors, constructive notice by publication typically 

satisfies the requirements of due process. See Huntsinger v. The Shaw Group, Inc., 268 Fed. Appx. 

518, 521 (9th Cir. Feb. 26, 2008) (notice by publication proper for unknown creditor’s claims) 

(citing Mullane v. Cent. Hanover Bank & Trust Co., 339 U.S. 306, 317 (1950)). 

When actual or constructive notice is required, a “process which is a mere gesture is not 

due process.” Mullane, 339 U.S. at 315. “[N]otice must be reasonably calculated, under all the 

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circumstances, to apprise interested parties of the pendency of the action and afford them an 

opportunity to present their objections.” Eisen v. Carlisle & Jacquelin, 417 U.S. 156, 174 (1974). 

The level of notice due to a party is “highly dependent on the context;” thus, a “process that may 

be constitutionally sufficient in one setting may be insufficient in another.” In re Mansaray-Ruffin, 

530 F.3d 230, 239 (3d Cir. 2008). 

The unique context of these Chapter 11 Cases is that PG&E’s tortious conduct creates 

noticing problems. Fire Claimants that are PG&E’s current or former customers, or those located 

within the region where PG&E supplied power and PG&E can determine their identities from a 

diligent investigation of its records and other sources, such as third-party subpoenas, are known 

creditors. This information can and should be provided to Angeion. Notice, however, cannot be 

delivered to a house that was destroyed. The mailbox is gone. Families were displaced. These 

problems apply especially to those Fire Claimants impacted by the 2018 Camp Fire. While the 

identity of some of the Fire Claimants may be known or can be determined, actions must be taken 

here to locate known creditors and identify their current address or contact information. Many Fire 

Claimants are suffering from trauma. A constitutionally sufficient notice program must take this 

into account. 

The TCC’s Notice Program addresses the unique context of these Chapter 11 Cases. The 

TCC’s Notice Program includes the use of GIS database records, third-party subpoenas to entities 

such as insurers, and record searches to identify contact information for all known Fire Claimants. 

See Weisbrot Decl. at 67. 

For those Fire Claimants who are unknown and whose identity is not reasonably 

ascertainable, the TCC proposes to use multiple forms of media—e.g., television, radio, magazines, 

newspapers, and social media. The TCC’s program achieves a much higher frequency than 

PG&E’s program. The TCC’s paid media plan is designed to ensure that 95% of adults in Northern 

California receive notice approximately 51.95 times. Id. at 83. The TCC’s proposed television 

advertising alone is estimated to reach over 74% of adults in Northern California market with an 

estimated frequency of 10 times each. Id. at 80. 

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The TCC further submits that the relief requested herein provides for clear notice of the Fire 

Claim Bar Date in satisfaction of the requirements of the Bankruptcy Rules and consistent with the 

underlying policies of the Bankruptcy Code. Specifically, to the extent the Fire Claim Bar Date is 

established, as proposed, as 9:00 p.m. (Pacific Time) on January 31, 2020, the TCC, through its 

noticing agent, Angeion, intends to: (a) cause the Fire Claimant Notice Materials to be mailed by 

by a date that is at least 120 days before the Fire Claim Bar Date; (b) cause the Publication Notice 

to be published by a date that is at least 120 days before the Fire Claim Bar Date; and (c) run a 

seven-month media campaign that is strategically timed to maximize participation by unknown Fire 

Claimants. 

Within five (5) days after entry of an order granting this Motion, PG&E and the TCC shall 

post the Fire Claimant Notice Materials on their respective websites, as well as the websites 

established by Prime Clerk for PG&E’s Chapter 11 Cases. 

Under the Notice Program, the Fire Claimant Notice Materials shall be served as soon as 

practicable after entry of the Order, but at least one hundred twenty (120) days prior to any Fire 

Claim Bar Date established by the Court. The TCC submits that the Fire Claim Bar Date Notice 

will provide Fire Claimants with sufficient information to file properly prepared and executed Fire 

Proof of Claim Forms in a timely manner. This time period is longer than the twenty-one (21) 

days’ notice required under Bankruptcy Rule 2002(a)(7) and is intended to provide Fire Claimants 

with additional time to file Fire Proofs of Claim. Accordingly, the TCC respectfully submits that 

the Fire Claim Bar Date, and the form and manner of providing notice thereof, are appropriate in 

light of the circumstances, inure to the benefit of all parties in interest and should be approved. 

VII. NOTICE 

Notice of the 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.), attorneys for the Debtors; (iv) Stroock 

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& 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) the U.S. Nuclear Regulatory Commission, 

Washington, DC 20555-0001 (Attn: General Counsel); (ix) the U.S. Department of Justice, 1100 L 

Street, NW, Room 7106, Washington DC 20005 (Attn: Danielle A. Pham, Esq.,) as counsel for the 

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) 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 TCC to this or any 

other court. 

WHEREFORE, the TCC respectfully requests entry of an order (i) setting a Fire Claim 

Bar Date for no earlier than January 31, 2020, (ii) approving the TCC’s Fire Claim Bar Date Notice, 

and (iii) implementing the TCC’s Notice Program, including its Supplemental Notice Program and 

the appointment of Angeion as the noticing agent. 

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Dated: May 31, 2019 Respectfully submitted, 

BAKER & HOSTETLER LLP 

By: /s/ Eric Goodman 

Counsel for The Official Committee of Tort 

Claimants 

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