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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO 

Robert A. Julian (SBN 99469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8875 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors 

□ Affects PG&E Corporation 

□ Affects Pacific Gas and Electric Company 

■ Affects both Debtors 

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM)

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered) 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS’ REQUEST FOR 

JUDICIAL NOTICE IN OPPOSITION TO 

CORRECTED MOTION OF DEBTORS 

PURSUANT TO 11 U.S.C. § 1121(d) TO 

EXTEND EXCLUSIVITY PERIODS 

(DKT. NO. 1797) 

Date: May 22, 2019 

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor 

San Francisco, CA 94102 

Objections Due: 

May 15, 2019 at 4:00 p.m. (Pacific Time) 

TO THE HONORABLE COURT AND TO ALL PARTIES AND THEIR COUNSEL 

OF RECORD: 

Case: 19-30088 Doc# 2028 Filed: 05/15/19 Entered: 05/15/19 16:58:06 Page 1 of

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO

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The Official Committee of Tort Claimants (hereafter, the “TCC”), by and through its 

counsel of record, respectfully requests that the Court take judicial notice of the following 

documents pursuant to Federal Rule of Evidence 201: 

1. Portions of the unofficial Transcript of Meeting of Creditors on April 29, 2019.1 

True and correct copies of the portions of the transcript are attached hereto as Exhibit A and 

incorporated herein by reference. 

2. National Transportation Safety Board, Pacific Gas and Electric Company, Natural 

Gas Transmission Pipeline Rupture and Fire, San Bruno CA, Sept. 9, 2010, Pipeline Accident 

Report NTSB/PAR-11/01. A true and correct copy of the accident report is attached hereto as 

Exhibit B. 

3. April 1, 2014 Indictment handed up in United States of America v. Pacific Gas and 

Electric Company, Case No. 3:14-cr-00175 (WHA) (N.D. Cal.), Dkt. No. 1. A true and correct 

copy of the Indictment is attached hereto as Exhibit C. 

4. August 9, 2016 Verdict Form handed up in United States of America v. Pacific Gas 

and Electric Company, Case No. 3:14-cr-00175 (WHA) (N.D. Cal.), Dkt. No. 884. A true and 

correct copy of the Verdict Form is attached hereto as Exhibit D. 

5. December 21, 2018 Assigned Commissioner’s Scoping Memo and Ruling issued 

from the Public Utilities Commission of the State of California. A true and correct copy of the 

Scoping Memo and Ruling is attached hereto as Exhibit E. 

6. Form 8-K report of PG&E Corporation and Pacific Gas and Electric Company filed 

with the Securities and Exchange Commission on February 28, 2019. A true and correct copy of 

the Form 8-K is attached hereto as Exhibit F.

7. Transcript of Proceedings before the Honorable William Alsup on May 7, 2019 in 

United States of America v. Pacific Gas and Electric Company, Case No. 3:14-cr-00175 (WHA) 

(N.D. Cal.). A true and correct copy of the transcript is attached hereto as Exhibit G. 

 

1

 The TCC will submit the entire transcript upon request. 

Case: 19-30088 Doc# 2028 Filed: 05/15/19 Entered: 05/15/19 16:58:06 Page 2 of

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HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO

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8. Order Adopting New Conditions of Probation, entered on May 14, 2019 in United 

States of America v. Pacific Gas and Electric Company, Case No. 3:14-cr-00175 (WHA) (N.D. 

Cal.), Dkt. No. 1071. A true and correct copy of the order is attached hereto as Exhibit H. 

9. The online “Notice of Proposed Violation and Proposed Compliance Order,” dated 

October 12, 2007, and sent to Ms. Cheryl F. Campbell in her capacity as President of WestGas 

Interstate, Inc. (“WestGas”), a subsidiary of Xcel Energy, Inc. (“Xcel”), by the Department of 

Transportation’s Pipeline and Hazardous Materials Safety Administration, CPF 5-2017-1012 

(“Notice”). A true and correct copy of the Notice is attached hereto as Exhibit I. 

10. The “Final Order” pertaining to Case No. CPF 5-2017-1012 against WestGas, which 

was entered into on March 8, 2019 by the Department of Transportation’s Pipeline and Hazardous 

Materials Safety Administration, Office of Pipeline Safety. A true and correct copy of the Final 

Order is attached hereto as Exhibit J. 

It is appropriate for the Court to take judicial notice of the foregoing documents. A court 

may take judicial notice upon the request of a party. Fed. R. Evid. 201. A court may take judicial 

notice of a fact that “can be accurately and readily determined from sources whose accuracy cannot 

reasonably be questioned.” Fed. R. Evid. 201(b)(2). The authenticity or source of the documents 

the TCC requests the Court take judicial notice of cannot be reasonably questioned—Exhibit A is 

portions of the Debtors’ sworn testimony. Exhibits C, D, G, and H are publicly available filings in 

U.S. v. Pacific Gas and Electric Co., Case No. 3:14-cr-00175 (WHA) (N.D. Cal.). Exhibits B, E,F, 

I and J are also matters of public record and are not reasonably subject to dispute. The Court may 

also take judicial notice of specific facts within the judicially noticed document if not in dispute. 

 

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ATTORNEYS AT LAW SAN FRANCISCO

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Accordingly, the TCC respectfully requests that the Court take judicial notice of the 

documents identified above and attached hereto as Exhibits A, B, C, D, E, F, G, H, I and J. 

Dated: May 15, 2019 Respectfully submitted, 

BAKER & HOSTETLER LLP

By: /s/ Cecily A. Dumas 

Cecily A. Dumas

Attorneys for Official Committee of Tort Claimants

Case: 19-30088 Doc# 2028 Filed: 05/15/19 Entered: 05/15/19 16:58:06 Page 4 of

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