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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO 

EXHIBIT A

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61766260

Mar 06 2018 

03:18PM

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SUPERIOR COURT OF CALIFORNIA 

COUNTY OF SAN FRANCISCO 

COORDINATION PROCEEDING 

SPECIAL TITLE [RULE 3.550] 

California North Bay Fire Cases 

Judicial Council Coordination 

Proceeding No.: 4955 

CASE MANAGEMENT ORDER NO. 1 

I conducted a case management conference (CMC) February 27, 2018.1 

There are five groups in this litigation: 1) Individual Plaintiffs, which include cases 

brought on behalf of persons and business entities; 2) Public Entity Plaintiffs; 3) Class Action 

Plaintiffs (together with the Individual Plaintiffs and the Public Entity Plaintiffs the "Direct 

Action Plaintiffs''); 4) Subrogation Plaintiffs; and 5) Defendants. 

ORGANIZATION OF PLAINTIFFS' COUNSEL 

A. Individual Plaintiffs 

1. Lead Counsel for Individual Plaintiffs 

The Court appoints the following lawyers as Individual Plaintiffs' Lead Counsel for those 

cases: 

Michael A. Kelly 

Walkup, Melodia, Kelly & Schoenberger 

650 California Street, 26th Floor 

San Francisco, CA 94108 

Tel: (415) 98t-7210 

1 The Department's User Manual may be found at <http://sfsuperiorcourtorg/divisions/civil/litigation> 

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mkelly@walkuplawoffice.com 

Frank Pitre 

Cotchett, Pitre & McCarthy, LLP 

840 Malcolm Road, Suite 200 

Burlingame, CA 940 I 0 

Tel: (650) 697-6000 

fuitre@cpmlegal.com 

Bill Robins, III 

Robins Cloud LLP . 808 Wilshire Boulevard, Suite 450 

Santa Monica, CA 90401 

Tel.: (310) 929-4200 

robins@robinscloud.com 

I 0 Lead Counsel for Individual Plaintiffs shall be members of, as wen· as authorize and 

11 direct the work of the Plaintiffs' Executive Committee and Individual Plaintiffs' Steering 

12 Committee for cases involving Individual Plaintiffs. Individual Plaintiffs' Lead Counsel shall 

13 also be responsible for coordinating the activities of the Direct Action Plaintiffs during pretrial 

14 proceedings, and in consultation and with the assistance of the Plaintiffs' Executive Committee, 

15 shall: 

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a 

b. 

Appear before the Court and present the position of Individual Plaintiffs at 

all Case Management Conferences, Status Conferences, or other court 

ordered hearings; 

Direct and coordinate the briefing and argument of all motions directed at 

or brought by Direct Action Plaintiffs generally; 

c. Direct and coordinate the filing of opposing briefs and argue motions in 

proceedings initiated by other parties against pirect Action Plaintiffs' 

interests (except as to matters directed to.., specific individual plaintiffs and 

their counsel or a specific Plaintiff group); 

d. Initiate and coordinate. all discovery proceedings on behalf of Direct 

Action Plaintiffs, including propounded general liability written discovery, 

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e. 

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document production discovery and the taldng of oral depositions;2 

Manage the selection of all cases for trial setting; 

Coordinate the initiation of, and conduct discovery on behalf of Direct 

Action Plaintiffs consistent with the requirements of the California Code 

of Civil Procedure and Rules of Court or any order of this Court; 

Assign work for the investigation and discovery of common liability and 

damages matters for all Direct Action Plaintiffs' counsel, and delegate 

specific tasks to other Direct Action Plaintiffs' counsel, in a manner to· 

ensure that pretrial preparation for Individual Plaintiffs is conducted 

effectively, efficiently and economically; 

Enter into stipulations, on behalf of Direct Action Plaintiffs, with opposing 

counsel as necessary for the conduct of the litigation; 

Prepare and distribute to other Individual Plaintiffs' counsel periodic 

status reports; 

j. Perform such other duties as may be necessary to the representation of 

Individual Plaintiffs, proper coordination of Individual Plaintiffs' activities 

or authorized by order of the Court; and 

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2. 

Submit, if appropriate, additional Individual Plaintiffs' committees and 

counsel for designation by the Court. 

Individual Plaintiffs' Liaison Counsel 

The Court appoints the following lawyers as Individual Plaintiffs' Liaison Counsel: 

Khaldoun A. Baghdadi 

Walkup, Melodia, Kelly & Schoenberger 

650 California Street, 26th Floor 

San Francisco, CA 94108 

Tel: (415) 981-7210 

kbaghdadi@walkuplawoffice.com 

2 Discovery initiated by Defendants directed to specific individual plaintiffs shall be handled by the attorney for 

those specific individuals. 

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Amy Eskin 

Levin Simes LLP 

44 Montgomery Street, Floor 32 

San Francisco, CA 94104 

Tel: (415) 426-3000 

aeskin@levinsimes.com 

Steven J. Skikos 

Skikos, Crawford, Skikos & Joseph, LLP 

One Sansome Street, Suite 2830 

San Francisco, CA 94104 

Tel: (415) 546-7300 

sskikos@skikos.com 

Liaison Counsel shall be members of the Plaintiffs' Executive Committee and have the 

following responsibilities: 

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b. 

c. 

d. 

e. 

Upon the designation of Individual Plaintiffs' Lead Counsel, appear before 

the Court and present the position of Individual Plaintiffs at all Case 

Management Conferences, Status Conferences, or other court ordered 

hearings; 

To make available to the Court, to counsel for Individual Plaintiffs, and to 

counsel for Defendants an up-to-date comprehensive Service List of all 

Individual Plaintiffs' counsel (including the date of the most recent 

revision); 

To receive and distribute to Individual Plaintiffs' counsel as appropriate, 

orders, notices and correspondence from the Court; 

To maintain and make available to other Individual Plaintiffs, on 

reasonable notice and at reasonable times, a complete set of all filed 

pleadings and orders filed and/or served in these coordinated proceedings; 

and 

To coordinate the filing of notices and papers by any Individual Plaintiff, 

including the designation of responsibilities to encourage the filing of a 

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single set of papers by the Individual Plaintiffs in situations where the 

Individual Plaintiffs have a common position. 

3.· Individual Plaintiffs' Executive Committee 

6 The Court appoints the lawyers and firms identified in Addendum A to the Individual 

7 Plaintiffs' Executive Committee. Individual Plaintiffs' Executive Committee shall have the 

8 following responsibilities with respect to matters of common concern to all Individual Plaintiffs: 

9 a. Coordination of Individual Plaintiffs' pretrial activities and work 

10 performed by the Individual Plaintiffs' lead counsel and liaison counsel; 

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b. 

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Calling meetings of Individual Plaintiffs' counsel when appropriate and to 

consult with Individual Plaintiffs' counsel on matters of common concern; 

Designating additional Individual Plaintiffs' subcommittees to perform 

services on behalf of Individual Plaintiffs and designate additional 

Individual Plaintiffs' counsel to serve on such subcommittees; and 

When appropriate, chairing and organizing Individual Plaintiffs' sub~ . 

committees as necessary to address specific issues of concern to claims of 

Individual Plaintiffs, Subrogation Plaintiffs, Government Plaintiffs and 

Class Plaintiffs. 

4. Individual Plaintiffs' Steering Committee 

The Court appoints the lawyers and firms identified in Addendum B to the Individual 

Plaintiffs' Steering Committee. The Individual Plaintiffs' Steering Committee shall have the 

following responsibilities with respect to matters of common concern to all Individual Plaintiffs: 

a. To mee~ strategize, and provide guidance to Individual Plaintiffs' Lead 

Counsel, Liaison Counsel, and Executive Committee with respect to the 

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direction of Individual Plaintiffs' pretrial activities and overall litigation 

strategy; 

To provide recommendations concerning the execution of Individual 

Plaintiffs' pretrial activities and work performed by the Individual 

Plaintiffs' lead counsel and liaison counsel, including the drafting of 

motions and opposing briefs and taking of depositions; 

To call meetings of Individual Plaintiffs' counsel when appropriate and to 

consult with Individual Plaintiffs' counsel on matters of common concern; 

and 

Serve on additional Individual Plaintiffs' subcommittees to perform 

services on behalf of Individual Plaintiffs and designate additional 

·Individual Plaintiffs' counsel to serve on such subcommittees. 

Public Entity Plaintiffs 

. The Court appoints the following lawyer as Lead Counsel: 

Scott Summy 

Baron & Budd, P.C. 

3102 Oak Lawn Ave #1100 

Dallas, TX 75219 

Tel: (214) 521-3605 

ssummy@baronbudd.com 

Public Entities' Lead Counsel shall be responsible for responding to discovery, briefing, 

and argument of issues that are specific to the Public Entity cases. Public Entities' Lead Counsel 

shall maintain a current listing of all filed Public Entity cases and identify same for the Executive 

Plaintiffs Committee, Defendants and the Court. Counsel in any Public Entity cases shall 

cooperate with the Lead Counsel for Individual Plaintiffs, Public Entities' Lead Counsel and the 

Court in the production of information necessary to prepare for any status conference or in the 

27 · scheduling of any discovery, or hearing. 

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below: 

C. Class Action Plaintiffs 

The Class Action committee will be formed and the Committee Chairs are identified 

Elizabeth Cabraser 

LexiHazam 

Lieff Cabraser Heimann & Bernstein, LLP 

275 Battery Street, 29th Floor 

San Francisco, CA 94111-3339 

Tel:. (415) 956"'-1000 

ecabraser@lchb.com 

lhazam@lchb.com 

The Committee shall be responsible for the prosecution and management of the class 

actions, including discovery, briefing, and argument of issues that are specific to the class cases. 

The Committee shall maintain a current listing of all filed class action cases and identify same 

for Lead Counsel for Individual Plaintiffs, Defendants and the Court. Counsel in any Class 

Action case shall cooperate with the Committee, Lead Counsel for Individual Plaintiffs and the 

Court in the production of information necessary to prepare for any status conference or in the 

scheduliJi'g of any discovery, or hearing. The Committee should evaluate consolidated 

17 · complaints arid certification hearings, and report in the next CMC statement its views on the . 

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timing of these. While there is no stay of class related discovery, the Committee expects that the 

liability discovery described below will be used for certification briefing. 

D. Subrogation Plaintiffs 

22 The Court appoints the following lawyers as Lead Counsel and Liaison Counsel for the 

23 Subrogation Plaintiffs and the Executive Committee for Subrogation Plaintiffs. They have the 

24 same duties/responsibilities within/to the Subrogation Plaintiffs group as the lawyers serving as 

25 Lead Counsel and Liaison Counsel and the Executive Committee for the Individual Plaintiffs: 

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1. Lead Counsel for Subrogation Plaintiffs3 

Shawn Caine 

The Law Offices of S_hawn E, Caine 

1221 Camino Del Mar 

Del Mar, CA 92014 

Tel: (619) 838-1365 

scaine@cainelaw.com 

Mark Grotefeld 

Grotefeld Hoffinann 

Shepard Mountain Plaza 

6034 West Courtyard Drive, Suite 200 

Austin, TX 78730 

Tel: (737) 226-5310 

mgrotefeld@ghlaw-llp.com 

Howard Maycon 

Cozen O'Connor 

601 S. Figueroa Street, Suite 3700 

Los Angeles, CA 90017 

Tel: (213) 892-7900 

hmaycon@cozen.com 

Maura Walsh Ochoa 

Grotefeld Hoffinann 

700 Larkspur Landing Circle, Suite 280 

Larkspur, California 94939 

Tel: (415) 344-9670 

mochoa@ghlaw-llp.com 

Craig Simon 

Berger Kahn, A Law Corporation 

1 Park Plaza, Suite 340 

Irvine, CA 92614 

Tel: (949) 748-4444 

csimon@bergerkahn.com 

21 Lead Counsel for Subrogation Plaintiffs shall be responsible for discovery, briefing, and 

22 argument of issues that are specific to the Subrogation cases. Lead Counsel for the Subrogation 

23 Plaintiffs shall maintain a current listing of all filed Subrogation cases and identify same for 

24 Lead Counsel for Indiv~dual Plaintiffs, Defendants and the Court. Counsel in any Subrogation 

25 cases shall cooperate with Lead Counsel for the Subrogation Plaintiffs, Subrogation Plaintiffs' 

26 Executive Committee and the Court in the production ofinformation necessary to prepare for 

27 3 The rights and obligations of Lead Counsel for Subrogation Plaintiffs mirror the rights and obligations of Lead 

Counsel for Individual Plaintiffs. 

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any status conference or in the scheduling of any discovery, or hearing. 

2. Liaison Counsel for Subrogation Plaintiffs 

Alan Jang 

Jang & Associates 

1766 Lacassie A venue, Suite 200 

Walnut Creek, CA 94596 

Tel: (925) 937-1400 

ajang@janglit.com 

Scott Loewe 

Bauman Loewe Witt & Maxwell, PLLC 

8765 East Bell Road, Suite 210 

Scottsdale, Arizona 85260 

Tel: ( 480) 502-4664 

sloewe@blwmlawfum.com 

Waylon Pickett 

Grotefeld Hoffinann 

0324 SW Abernethy Street 

Portland, Oregon 97239 

Tel: (503) 384-2772 

yypickett@ghlaw-llp.com 

3. Subrogation Plaintiffs' Executive Committee 

Mark Bauman 

Bauman Loewe Witt & Maxwell, PLLC 

8765 East Bell Road, Suite 210 

Scottsdale, Arizona 85260 

Tel: (480) 502-4664 

mbauman@blwmlawfirm.com 

Kevin Bush 

Cozen O'Connor 

601 S. Figueroa Street, Suite 3700 

Los Angeles, CA 90017 

Tel: (213) 892-7900 

kbush@cozen.com 

Tim Cary 

StutmanLaw 

1260 Corona Pointe Ct., Suite 306 

Corona, CA 92879 

Tel: (951) 963-1298 

carvt@stutmanlaw.com 

Eric Schroeder 

Schroeder Loscotoff 

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7410 Greenhaven Dr., Ste. 200 

Sacramento, CA 95831 

Tel: (916) 438-8306 

emschroeder@calsubro.com 

DEFENDANTS' COUNSEL 

Defendants are represented by Cravath, Swaine & Moore LLP, Wilson Sonsini Goodrich 

& Rosati and Clarence Dyer & Cohen LLP. 

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Evan R. Chesler, 

Timothy G. Cameron 

Kevin J. Orsini 

Damaris Hernandez 

Cravath, Swaine & Moore LLP 

Worldwide Plaza 

825 8th A venue 

New York, New York 10019 

Tel: (212) 474-1000 

echesler@cravath.com 

tcameron@cravath.com 

korsini@cravath.com 

dhemandez@cravath.com 

Keith E. Eggleton 

John P. Flynn 

Rodney G. Strickland 

Colleen Bal 

Wilson Sonsini Goodrich & Rosati 

650 Page Mill Road 

Palo Alto, California 94304, and 

One Market Plaza, Suite 3300 

San Francisco, CA 94105 

Tel: (650) 493-9300 

Tel: (415) 947-2000 

keggleton@wsgr.com 

jflynn@wsgr.com 

rstrickland@wsgr.com 

cbal@wsgr.com 

Kate Dyer 

Clarence Dyer & Cohen LLP 

899 Ellis Street 

San Francisco, California 94109 

Tel: (415) 749-1800 

kdyer@clarencedyer.com 

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1 JURISDICTION AND WAIVER OF SERVICE OF PROCESS 

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The parties agree that this court has jurisdiction over the parties and that there are no 

challenges to personal or subject matter jurisdiction. The parties have met and conferred and 

Defendants have agreed to waive service of process in cases filed in JCCP No. 4955 in which 

they are named. For such cases, Plaintiffs shall send the Notice of Adoption of Short Form 

Complaint and Short Form Complaint by email to the following individuals, Kevin J. Orsini 

(korsini@cravath.com). Brittany L. Sukiennik, (bsukennik@cravath.com), Keith E. Eggleton 

(keggleton@wsgr.com), and Rodney Strickland (rstrickland@wsgr.com) or by U.S. Mail to: 

Kevin J. Orsini 

Brittany L. Sukiennik 

Cravath, Swaine & Moore LLP 

Worldwide Plaza · 

825 8th A venue 

New York, New York 10019-7475 

Keith E. Eggleton 

Rodney G. Strickland 

Wilson Sonsini Goodrich & Rosati, EC 

650 Page Mill Road 

Palo Alto, California 94304 

The parties agree that complying with these provisions shall constitute personal service of 

process under the California Code of Civil Procedure. 

A. Master Pleadings 

The parties agree that a Master Complaint for Individual Plaintiffs, a Master Complaint 

for Subrogation Plaintiffs and a Master Complaint for the Public Entity Plaintiffs shall be lodged 

with the Court. Corresponding Master Answers for Defendants in response to each of the three 

Master Complaints shall govern the pleadings for those actions.4 Drafts of the applicable Master 

Complaints for the Individual Plaintiffs, Public Entity Plaintiffs and Subrogation Plaintiffs are 

being exchanged and will be presented to the Court. 

4 Subsections B, C and D do not apply to the Class Action Plaintiffs. 

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B. Challenges to Master Pleadings 

The parties anticipate a single challenge to the Master Complaints concerning the 

applicability of inverse condemnation to a private utility. 

Defendants will file that challenge on March 16, 2018. The Individual Plaintiffs' Lead 

Counsel (on behalf of the Direct Action Plaintiffs) and the Subrogation Plaintiffs' Lead Counsel 

shall each file their opposition no later than April 16, 2018. Defendants will file a single reply to 

both oppositions, which shall not exceed 20 pages, by April 30, 2018. The hearing is set for May 

18, 2018 at 9:00 a.m. 

c. Notice of Adoption of Master Complaint and Master Answer 

12 The parties will meet and confer regarding the Notice of Adoption of Master Complaint, 

13 and Notice of Potential Add-On Cases and Request for Coordination. Plaintiffs will provide 

14 Defendants the applicable documents for review and submission to the Court. The Master 

15 Complaints shall be filed no later than March 12, 2018. The Master Ariswers shall be filed no 

· 16 later than March 16, 2018. The Master Complaints and the Master Answers will not be verified. 

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1. Notice of Adoption of Master Complaint 

Each Direct Action Plaintiff or Subrogation Plaintiff with a case already on file in JCCP 

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No. 4955 shall serve on their respective Lead Counsel a Notice of Adoption of Master Complaint 

within 30 days of the date the Master Complaint is filed. The Notice of Adoption shall contain 

the following information: 1) the name and address of each plaintiff; 2) the fire( s) by which each 

plaintiff was. allegedly harmed;5 3) the causes of action each plaintiff is joining and against 

which defendant(s) they are pled; and 4) the categories of damages allegedly incurred by each 

plaintiff and for which that plaintiff is seeking recovery and from which defendant( s ). 

For existing Individual Plaintiffs, the filing of a Notice of Adoption of Master Complaint 

5 Counsel are to agree on a naming convention for the fires. 

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shall not require the payment of an additional filing fee or a new case number. Each Notice of 

Adoption shall constitute an amended complaint for all purposes. Upon filing the Notice of 

Adoption, the Master Complaint, as amended by the Plaintiff's Notice of Adoption, sruul be the 

operative pleading. The date on which the Master Complaint is filed shall have no bearing on 

whether any Plaintiff has satisfied the applicable statute of limitations. Rather, the date on which 

an individual Plaintiff's properly filed original complaint initiating his or her action was filed· 

shall be the operative date for statute of limitations purposes. 

For cases naming more than one Plaintiff, except those naming a derivative Plaintiff(e.g., 

an heir asserting a wrongful death claim) each Plaintiff must file an individual Notice of 

Adoption.6 

2. Notice of Adoption of Master Answer 

14 The Defendants' Notice of Adoption of Master Answer must be filed within 30 days of 

15 the filing of Plaintiffs' Notice of Adoption of Master Complaint. All responses pied in PG&E's 

16 Master Answer will be deemed pled in any previously filed Complaint and Responsive Pleading 

17 now pending in this JCCP proceeding, and in any Notice of Adoption filed thereafter. 

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3. Cases to Be Filed 

Plaintiffs who have not yet filed an action will initiate an action by Filing a Short Form 

Complaint and Notice of Adoption of Master Complaint, in a proper venue in California As 

indicated above, the Notice of Adoption shall contain the following information: 1) the name and 

address of each plaintiff; 2) the fire( s) by which each plaintiff was allegedly harmed; 3) the 

causes of action each plaintiff is joining and against which defendant(s) they are pied; and 4) the 

categories of damages allegedly incurred by each plaintiff and for which that plaintiff is seeking 

recovery and from which defendant(s). 

6 Members of a single household need only file one notice of adoption. 

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Upon that filing, the Master Complaint, as Amended by the Notice of Adoption, shall be 

the operative pleading. The date on which the Master Complaint is filed shall have no bearing on 

whether any Plaintiff has satisfied any applicable statute of limitations. Rather, the later date on 

which an individual Plaintiff properly filed the Short Form Complaint or Notice of Adoption 

initiating his or her action shall be the operative date for statute oflimitations purposes. For any 

future case filed, the Plaintiff must include a civil cover sheet identifying this JCCP (California 

North Bay Fire Cases, JCCP No. 4955). 

D. Adding Cases into These Coordinated Proceedings 

Add-on cases may be handled by stipulation of all parties or by petition of Defendants 

consistent with the procedures and requirements ofCRC 3.531 and C.C.P. § 404.4. 

. E. Cross-Complaints 

The parties agree that Defendants may or may not file cross-complaints as they choose. 

However, if a cross-complaint is not filed at the time Defendants file the Master Answers, 

but instead is filed by an existing Defendant at a later date, by whatever means or procedure, 

such later filing will not, absent good cause or as otherwise provided by the Code of Civil 

Procedure, constitute cause for delay of any then-existing trial date or trial. 

Discovery Phases 

The parties have agreed to stage discovery. Stage One relates to: 1) liability discovery; 

and 2) damages discovery from Individual Plaintiffs, Public Entity Plaintiffs and Subrogation 

Plaintiffs. Stage Two relates to expert discovery on issues of both liability and damages and will 

be subject to further order of this "court. 

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Stage One: Liability Discovery 

1. By Direct Action and Subrogation Plaintiffs. 

. Liability discovery shall be conducted as directed by Lead Counsel for the Individual 

Plaintiffs and Lead Counsel for Subrogation Plaintiffs. Lead Counsel for Individual Plaintiffs 

have informed counsel for PG&E regarding the initial round of liability discovery that includes: 

a set of initial Requests for Admission to elicit whether PG&E is contesting causation on the 

origin of each of the North Bay Fires;· a Deposition notice for the person most qualified at PG&E 

on the general topics of how the company stores, accesses, exchanges and retrieves data on 

vegetation management and electrical infrastructure; and a request for inspection and/or 

production of photographs or recordings of any item of physical evidence related to PG&E 

equipment or vegetation inspected as a potential cause of a fire included in these proceedings. 

Direct Action Plaintiffs and Subrogation Plaintiffs may seeJ_\: liability discovery concerning the 

origin and cause of each of the North Bay Fires:, such as vegetation management, electrical 

infrastructure and wildfire risk management. 

Prior to serving Defendants with liability discovery, Direct Action Plaintiffs and 

Subrogation Plaintiffs have agreed to cooperate in good faith to coordinate such discovery. 

Either the Individual Plaintiffs' Lead Counsel (on behalf of Direct Action Plaintiffs) or the 

Subrogation Plaintiffs' Lead Counsel may serve discovery on Defendants. After liability . 

discovery is served on Defendants, regardless of which Plaintiff group was the serving party, the 

Individual Plaintiffs' Lead Counsel (on behalf of Direct Action Plaintiffs) and the Subrogation 

Plaintiffs' Lead Counsel shall collectively meet and confer with Defendants concerning 

Defendants' discovery responses. Plaintiffs shall not serve duplicative or cumulative discovery 

on Defendants. 

Should any Plaintiff or law firm after consultation with the Individual Plaintiffs' Lead 

Counsel and the Subrogation Plaintiffs' Lead Colinsel believe that they need to propound 

liability discovery that has not been or will not be propounded by the Individual Plaintiffs' Lead 

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Counsel or the Subrogation Plaintiffs' Lead Counsel, such Plaintiff or law firm may seek an 

order from the Court allowing such discovery to be propounded. Otherwise, no Plaintiff may 

serve separate liability discovery. 

2. By Defendants 

7 Defendants will serve any liability discovery directed to any specific individual Plaintiff 

8 or the Subrogation Plaintiffs on Individual Plaintiffs' Lead Counsel, Subrogation Plaintiffs' Lead 

9 Counsel and. counsel of record for the specific individual plaintiff( s ). Where appropriate, the 

1 o Direct Action Plaintiffs or Subrogation Plaintiffs will serve Defendants with a Master Response. 

11 To the extent such discovery relates to a specific Plaintiffs' group, Defendants may serve such 

12 discovery requests on Lead Counsel for each applicable Plaintiffs' group or, in the case of the 

13 Class Action Plaintiffs, the Committee, Lead Counsel or Committee shall similarly serve 

14 Defendants with a Master Response for such group. 

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Stage One: Damages Discovery 

3. Subrogation Plaintiffs 

Damages discovery may be propounded to all Subrogation Plaintiffs in a Master Request 

to All Subrogation Plaintiffs. The Subrogation Plaintiffs will serve a Master Response to the 

Master Request to All Subrogation Plaintiffs, and each Subrogation Plaintiff will then serve an 

Adoption of the Master Response in Full or in Part. If the response adopts "in Part", the 

responding Subrogation Plaintiff will set forth any answers that are different from the Master 

Response in the Adoption. These Adoptions will be verified by each responding Subrogation 

Plaintiff. 

The Subrogation Plaintiffs will set forth a list of claims for which they are seeking 

reimbursement. The Subrogation Plaintiffs will provide to Defendants an updated list of the 

names, addresses, dates of loss, claim numbers, the amounts paid by Subrogation Plaintiffs and 

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open reserves (as that information is available) as to each of the subrogated claims for which 

they are seeking reimbursement (hereinafter the "List of Claims") not later than June 30, 2018. 

The Subrogation Plaintiffs will provide an updated List of Claims at least on a quarterly ba'sis, or 

more frequently as necessary to advise Defendants of additional payments made on any claims, 

and/or as reasonably requested by the Defendants. In any event, Subrogation Plaintiffs will 

provide a final List of Claims to Defendants on or before October 31, 2020 (prior to the statute of 

limitations), which will constitute the final list of claims to be included in the litigation. 7 The 

original and/or any amended adoption complaint filed by the Subrogation Plaintiffs will be 

deemed to set forth all of the information in the List of Claims provided to Defendants pursuant 

to this order. Any claims not disclosed by the Subrogating Plaintiffs on or before October 31, 

2020, will be barred by statute. 

The parties agree that the Lists of Claims provided by the Subrogation Plaintiffs will not 

be admissible in evidence unless the Defendants later reach an agreement with the Subrogation 

Plaintiff that prepared the List of Claims that the List of Claims is admissible. 

The Subrogation Plaintiffs will produce claim files on a rolling basis. The parties will 

meet and confer regarding a schedule and protective order to govern the production of claim files 

and will report back to the Court on thjs issue in the next joint CMC statement. The Subrogation 

Plaintiffs will continue to produce on a rolling basis any supplements to the claim files as 

required to update Defendants on any additional payments made on the claims following the 

production of the claim files. Defendants will also be notified of additional payments on any of 

the claims by the Subrogating Plaintiffs by the periodic production of an updated List of Claims. 

Claim files may be requested sooner for any Plaintiff claiming a preference or on a case-by-case 

basis, and Subrogation Plaintiffs will make every effort to .produce such claim files within 15 

days of a request. 

7 This is not an implication that trials be delayed until after this date; 

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4. Individual Plaintiffs 

Each individual plaintiff shall complete the Notice of Adoption of Master Complaint 

which contains specific facts regarding the case. All other damages case specific discovery is 

stayed including any written discovery, contention discovery, or deposition discovery until 

further order of the court and as contemplated by sections below relating to bellwether trial 

settings and preference trial settings. 

Privileged Communications 

1 o Pursuant to the parties' agreement, the communication, transmission, or dissemination of 

11 information of common interest among Plaintiffs' counsel or among Defendants' counsel shall 

12 be protected by the attorney-client privilege, the protections afforded by the attorney work 

13 product doctrine, the protections afforded to material prepared for litigation or any other 

14 privilege to which a party may otherwise be entitled. Further, cooperative efforts shall not in any 

15 way be used against any of the parties, be cited as purported evidence of conspiracy, wrongful 

16 action or wrongful conduct, and shall not be communicated to any jury. 

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Trial 

Preferential Trial Settings: The Plaintiffs anticipate that it may be appropriate to file 

motions for preferential trial settings per C.C.P. § 36. 

Bellwether Process: The parties have agreed to meet and confer on the scope and 

procedlire relating to any J?Otential bellwether process, including a bellwether case selection 

process, case specific ·discovery and law and motion practice in bellwether and non-bellwether 

cases, if any, and the conduct of bellwether trials. The parties contemplate that if they agree upon 

a bellwether process, an order of this Court relating to the bellwether process will include: trial 

settings and the bellwether selection process, discovery and motion practice appropriate for 

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bellwether selected cases, and whether or not motion practice may be appropriate to cases 

outside of those selected as bellwethers. 

Jury or Non-Jury: Plaintiffs demand jury trials. 

Trial Date: Trial dates and length, and close of discovery dates will be set in future case 

management conferences. 

Place of Trial: Complaints in this matter have been filed in the Superior Court of Napa, 

Sonoma, and San Francisco. Locations of trials are reserved for future consideration. 

Pro Hae Vice Admissions: 

A number of counsel have been admitted pro hac vice in the underlying cases now 

coordinated in this JCCP. Such counsel are deemed admitted for all purposes in this JCCP and 

all current and future actions coordinated in this JCCP. Counsel not yet been admitted pro hac 

vice shall file his or her pro hac vice application with this Court. 

Protective Order: The parties are expected to present a proposed stipulated protective 

order within 30 days. I ask the parties to review the Department's User Manual especially on 

sealing issues, and to resist the urge to over-designate under the protective order. 

Next Case Management Conference 

A date will be selected for the next CMC at the May 18, 2018 hearing. In addition to 

issues noted above, the parties are invited to advise on (1) the status of a discovery plan, 

including discovery focused on e.g., (i) PG&E policies and actions and (ii) causes and 

circumstances of ignitions; (2) whether a cut-off date for the addition of new parties should be 

set (which could be avoided on a showing that new information supported leave of court to add 

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the party); a general description of the discovery required for meaningful settlement discussions, 

and the likely time needed to acquire it. 

Dated: March 6, 2018 

Curtis E.A. Karnow 

Judge Of The Superior Court 

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1 Addendum A -Individual Plaintiffs, Executive Committee 

2 Individual Plaintiffs request that the Court appoint the following attorneys and firms to the 

3 Executive Committee: 

4 Mary Alexander 

Mary Alexander & Associates, P.C. 

5 44 Montgomery Street, Suite 1303 

San Francisco, CA 9410 I 

6 Tel: (415) 433-4440 

malexander@maryalexanderlaw.com 

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Thomas Brandi 

8 The Brandi Law Firm 

354 Pine St. Floor, 3rd floor 

9 San Francisco, CA 94104-3231 

Tel (415) 989-1800 

10 tjb@brandilaw.com 

11 Elizabeth Cabraser 

LexiHazam 

12 Lieff Cabraser Heimann & Bernstein, LLP 

275 Battery Street, 29th Floor 

13 .San Francisco, CA 94111-3339 

Tel: (415) 956-1000 

14 ecabraser@khb.com 

lhazam@lchb.com 

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Steven M. Campora 

16 Dreyer Babich Buccola Wood Campora LLP 

20 Bicentennial Circle 

17 Sacramento, CA 95826 

Tel: (916) 379-3500 

18 scampora@dbbwc.com 

19 Ahmed S. Diab 

Dixon Diab & Chambers LLP 

20 501 W. Broadway, Suite 800 

San Diego, CA 92101 

21 Tel: (619) 354-2662 

diab@theddcfirm.com 

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Amy Eskin (Co.-Liaison) 

23 Levin Simes LLP 

44 Montgomery Street, Floor 32 

24 San Francisco, CA 94104 

Tel: (415) 426-3000 

25 aeskin@levmsimes.com 

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Dario de Ghetaldi 

Corey, Luzaich, de Ghetaldi & Riddle LLP 

700 El Camino Real 

Millbrae, CA 94030 

Tel: (650) 871-5666 

deg@coreylaw.com 

Michael A. Kelly (Co-Lea .. ) 

Khaldoun A. Baghdadi (Co-Liaison) 

Walkup, Melodia, Kelly & Schoenberger . 650 California Street, 26th Floor 

San Francisco, CA 94108 

Tel: (415) 981-7210 

mkelly@walkuplawoffice.com 

kbaghdadi@walkuplawoffice.com 

Brendan M. Kunkle 

Michael Green 

Abbey, Weitzenberg, Warren & Emery 

100 Stony Point Rd, Suite 200 

Santa Ros~ CA 95401 

Tel: (707) 542-5050 

bkunkle@abbeylaw.com 

mgreen@abbeylaw~com 

Brian Panish 

Rahu1 Ravipudi 

Panish Shea & Boyle, LLP 

11111 Santa Monica Blvd. #700 

Los Angeles, CA 90025 

Tel: (310)477-1700 

panish@psblaw.com 

ravipudi@psblaw.com 

Frank Pitre (Co .. Lead) 

Cotchett, Pitre & McCarthy, LLP 

840 Malcolm Road, Suite 200 

Burlingame, CA 94010 

Tel: (650) 697-6000 

fuitre@cpmlegal.com 

Bill Robins III (Co-Lead) 

Robins Cloud, LLP 

808 Wilshire Bou1evard, Suite 450 

Santa Monica, CA 90401 

Tel: (310) 929-4200 

robins@robinscloud.com 

ADDENDUM A - PLAINTIFFS' EXECUTNE COMMITIBE - JCCP No. 4955 

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1 Mark Robinson 

Robinson Caicagnie, Inc. 

2 19 Corporate Plaza Dr. 

Ne-wport Beach, CA 92660 

3 Tel: (949) 720-1288 

mrobinson@robinsonfirm.com 

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Steve Skikos (Co-Liaison) 

5 Greg Skikos 

Matt Skikos 

6 Skikos, Crawford, Skikos & Joseph, LLP 

One Sansome Stree4 Suite 2830 

7 San Francisco, CA 94104 

Tel: (415) 546-7300 

8 sskikos@skikos.com 

gskikos@skikos.com 

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Scott Summy (Lead for Public Entities) 

Baron&Budd 

N 7000 Mopac Service Road #200 

Austin, TX 78731 

Tel: (214) 521-3605 

ssummy@baronbudd.com 

ADDENDUM A - PLAINTIFFS' EXECUTIVE COMMITTEE - JCCP No. 4955 

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1 Addendum B - Individual Plaintiffi' Steering Committee 

2 Individual Plaintiffs request that the Court create and name the following individuals to a 

3 Steering Committee: 

4 Elliot Adler 

Adler Law Group, APLC 

5 402 W. Broadway, Suite 860 

San Diego, CA 92101 

6 Tel: (619) 531-8700 

eadler@theadlerfirm.com 

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Michael Caddell · 8 Cynthia Chapman 

Caddell & Chapman 

9 628 E. 9th Street 

Houston, TX 77077 

10 Tel: (713) 751-0400 . 

mac@caddellchapman.com 

11 cbc@caddellchapman.com 

12 DonEdgar 

Edgar Law Firm 

13 408 College A venue 

s·anta Rosa, CA 95401 

14 Tel: (707) 799-4090 

don@classattomeys.com 

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Dave Fox 

16 Fox Law, APC 

Plaza Building 

17 225 West Plaza Street, Suite 102 

Solana Beach, CA 92075 

18 Tel: (858) 256-7616 

dave@foxlawapc.com 

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Sean Higgins 

20 Andrews & Thornton 

2 Corporate Park, Suite 110 

21 Irvine, California 92606 

Tel: (949) 748-1000 

22 shigcins@andrewsthomton.com 

23 John F. McGuire 

Thorsnes Bartolotta McGuire, LLP 

24 2550 Fifth A venue, 11th Floor' 

San Diego, CA 92103 

25 Tel: (619) 236-9363 

mcguire@tbmlawvers.com 

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Patrick McNicholas 

McNicholas & McNicholas, LLP 

10866 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90024 

Tel: (310) 474-1582 

pmc@mcnicholaslaw.com 

Francis 0. Scarpulla 

Law Offices of Francis 0. Scarpulla 

456 Montgomery Street, 17th Floor 

San Francisco, CA 94104 

Tel: (415) 788-7210 

fos@scai:pullalaw.com 

Christopher Sieglock 

Sieglock Law, APC 

1221 Camino Del Mar 

Del Mar, CA 92014 

Tel: (858) 793-0380 

chris@sieglocklaw.com 

Gerald Singleton 

Singleton Law Firm 

115 Plaza St 

Solana Beach, CA 92075 

Tel: (760) 697-1330 

gerald@slffirm.com 

Terry L. Singleton 

Terry Singleton, APC 

1950 5th A venue, Suite 200 

San Diego, CA 92101-2344 

Tel: (619) 239-3225 

terrv@terrvsingleton.com 

Tom Tosdal 

777 South Highway 101, Suite 215 

Solana Beach, CA 92075 

Tel: (858) 704-4709 

tom@tosdallaw.com 

Mikal C. Watts 

Guy Watts 

Watts Guerra LLP 

5726 W. Hausman Rd, Suite 119 

San Antonio, Texas 

Tel: (210) 527-0500 

mcwatts@wattsguerra.com 

gwatts@wattsguerra.com 

ADDENDUM B - PLAINTIFFS' STEERING COMMITTEE..: JCCP No. 4955 

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Ben Wilson 

2 Morgan & Morgan, PLLC 

4450 Old Canton Rd. SUite 200 

3 Jackson, MS 39211 

Tel: (601) 949-3388 

4 BWilson@ForThePeople.com 

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ADDENDUM B - PLAINTIFFS' STEERING COMMITTEE - JCCP No. 4955 

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CERTIFICATE OF ELECTRONIC SERVICE 

(CCP 1010.6(6) & CRC 2.260(g)) 

I, DANIAL LEMIRE, a Deputy Clerk of the Superior Court of the County of San 

Francisco, certify that I am not a party to the within action. 

On MAR 6- 2.018 , I electronically served THE ATTACHED DOCUMENT via 

File & ServeXpress on the recipients designated on the Transaction Receipt located on the File & 

ServeXpress website. 

Dated: 

MAR 6- 2018 ~~'-, ' 

T.. ichael Yuen, Clerk 

By: 

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