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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

Robert A. Julian (SBN 88469) 

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 

 Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

□ 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) 

AMENDED MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR RELIEF FROM AUTOMATIC STAY 

TO PERMIT STATE COURT JURY 

TRIAL OF 2017 TUBBS WILDFIRE 

CLAIMS [Dkt. No. 2842] 

 

Date: July 24, 2019 

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

Place: United States Bankruptcy Court 

Courtroom 17, 16 Floor 

San Francisco, CA 94102 

Objection Deadline: July 19, 2019 at 4:00 p.m. 

Case: 19-30088 Doc# 2904 Filed: 07/09/19 Entered: 07/09/19 12:59:18 Page 1 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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Purpose of the Amendment 

In the Motion of the Official Committee of Tort Claimants (the “TCC”) for Relief from 

Automatic Stay to Permit State Court Jury Trial of 2017 Tubbs Wildfire Claims (“Motion”) [Dkt. 

No. 2842], the TCC moved for an order terminating the automatic stay to permit the individuals 

listed on Exhibit A (the “Tubbs Preference Plaintiffs”) to proceed to a jury trial on their 

personal injury and related property damage claims against the Debtors (as set forth in Exhibits B 

and C), as may be amended. The TCC amends its Motion as set forth below, to request relief 

from stay with respect to five additional plaintiffs and their personal injury, wrongful death and 

related property damage claims against the Debtors as set forth in Amended Exhibits A, B and C 

hereto. Accordingly, all references in the TCC’s memorandum of points and authorities to the 

Tubbs Preference Plaintiffs’ personal injury claims, as amended [Dkt. No. 2855] shall refer to the 

amended Tubbs Preference Plaintiffs’ personal injury and wrongful death claims. 

The Amended Motion 

The TCC, in the above-captioned chapter 11 cases (the “Chapter 11 Cases”) of PG&E 

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

hereby submits this Motion (the “Amended Motion”), pursuant to section 362(d)(1) of title 11 of 

the United States Code (the “Bankruptcy Code”), sections 1334(c) and 1452(b) of title 28, Rules 

4001 and 5011(b) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and 

Rule 4004-1 of the Bankruptcy Local Rules for the United States District Court for the Northern 

District of California (the “Bankruptcy Local Rules”) for entry of an order terminating the 

automatic stay to permit the individuals listed on Amended Exhibit A hereto to proceed to a jury 

trial on their personal injury, wrongful death and related property damage claims against the 

Debtors arising from the 2017 Tubbs Fire as set forth in the Complaints against the Debtors 

(attached as Amended Exhibits B and C hereto), as may be amended, and to request the Court in 

the California North Bay Fire Cases, JCCP 4955, to order the Tubbs Preference Plaintiffs’ claims 

to trial with preference pursuant to Code of Civil Procedure section 36. Should the Debtors, in 

response to this Motion, request the Court to permit any additional litigation to go forward in the 

California Superior Court, the TCC requests the Court to terminate the automatic stay with 

Case: 19-30088 Doc# 2904 Filed: 07/09/19 Entered: 07/09/19 12:59:18 Page 2 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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respect to the additional litigation. In support of the Motion, the TCC submitted the Amended 

Memorandum of Points and Authorities [Dkt. No. 2855], the declaration of Steven M. Campora 

(“Campora Decl.”) [Dkt. No. 2845], the declaration of Robert A. Julian (“Julian Decl.”) [Dkt. 

No. 2844], the declaration of Michael A. Kelly (“Kelly Decl.”) [Dkt. No. 2847] and the 

declaration of Brent C. Williams (“Williams Decl.”) [Dkt. No. 2846]. Contemporaneously 

herewith, the TCC is filing an amended declaration of Michael A. Kelly. A proposed form of 

order granting the relief requested herein is attached hereto as Exhibit D. 

The Motion was noticed and scheduled pursuant to the Second Amended Order 

Implementing Certain Notice and Case Management Procedures entered on May 14, 2019 [Dkt. 

No. 1996]. 

Dated: July 9, 2019 BAKER & HOSTETLER LLP 

By: /s/ Robert A. Julian Robert A. Julian 

Counsel for The Official Committee of Tort 

Claimants 

Case: 19-30088 Doc# 2904 Filed: 07/09/19 Entered: 07/09/19 12:59:18 Page 3 of

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