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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

-oOoIn Re:

PG&E CORPORATION AND PACIFIC 

GAS AND ELECTRIC COMPANY

Debtors.

_____________________________

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Case No. 19-30088

Chapter 11

San Francisco, California

Wednesday, June 26, 2019

9:30 AM

MOTION OF DEBTORS PURSUANT TO 

11 U.S.C. SECTIONS 502(b)(9) 

AND 105(a), FED, R. BANKR. P. 

2002, 3003(c)(3), 5005, AND 

9007, AND L.B.R. 3003-1 FOR 

ORDER (I) ESTABLISHING 

DEADLINE FOR FILING PROOFS OF 

CLAIM, (II) ESTABLISHING THE 

FORM AND MANNER OF NOTICE 

THEREOF, AND (III) APPROVING 

PROCEDURES FOR PROVIDING 

NOTICE OF BAR DATE AND OTHER 

INFORMATION TO ALL CREDITORS 

AND POTENTIAL CREDITORS BY 

PG&E CORPORATION [1784]

MOTION OF THE AD HOC GROUP OF 

SUBROGATION CLAIM HOLDERS 

PURSUANT TO 11 U.S.C. 105(a), 

107(b), AND 501 AND FRBP 

3001(a) ABD 9018 FOR ENTRY OF 

AN ORDER APPROVING PROPOSED 

MODEL OMNIBUS INSURANCE 

SUBROGATION PROOF OF CLAIM 

FORM FOR SUBROGATION CLAIMS 

AND RELATED PROCEDURES FILED 

BY AD HOC GROUP OF 

SUBROGATION CLAIM HOLDERS

[2044]

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MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. SECTION 

105(a) AND 501 AND FED. R. 

BANKR. P. 3001(a) FOR ENTRY 

OF AN ORDER APPROVING 

PROPOSED MODEL POLICE OFFICER 

FORM FOR FIRE CLAIMS AND 

RELATED PROCEDURES FILED BY 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS [1824]

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. SECTION 

105(a) AND 501 AND FED. R. 

BANKR. P. 3001(a) FOR ENTRY 

OF AN ORDER (I) ESTABLISHING 

A BAR DATE FOR FILINGS FIRE 

CLAIMS, (II) APPROVING A FORM 

AND PROCEDURES FOR NOTICE OF 

THE BAR DATE FOR FILING FIRE 

CLAIMS, AND (III) APPROVING 

SUPPLEMENTAL PROCEDURES FOR 

NOTICE OF THE BAR DATE TO 

FIRE CLAIMANTS [2297]

APPLICATION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. SECTION 

1103 AND FED. R. BANKR. P 

2014 AND 5002 TO RETAIN AND 

EMPLOY ANGEION GROUP, LLC AS 

FIRE CLAIM BAR DATE NOTICING 

AGENT EFFECTIVE AS OF MAY 22, 

2019 [2303]

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ENTRY OF A PROTECTIVE 

ORDER [2419]

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APPLICATION PURSUANT TO 11 

U.S.C. SECTIONS 327 AND 328 

FOR AN ORDER AUTHORIZING 

EMPLOYMENT AND RETENTION OF 

DELOITTE & TOUCHE LLP AS 

INDEPENDENT AUDITOR AND 

ADVISOR TO THE DEBTORS NUNC 

PRO TUNC TO THE PETITION DATE

[2197]

MOTION FOR ENTRY OF 

PROTECTIVE ORDER PS TO FED. 

R. BANKR. P. 7026 AND 9014(c) 

AND 11 U.S.C. SECTION 105(a) 

GOVERNING DISCOVERY MATERIALS 

AND OTHER INFORMATION FILED 

BY PG&E CORPORATION [2459]

TRANSCRIPT OF PROCEEDINGS

BEFORE THE HONORABLE DENNIS MONTALI

UNITED STATES BANKRUPTCY JUDGE

APPEARANCES:

For the Debtors: STEPHEN KAROTKIN, ESQ.

MATTHEW GOREN, ESQ.

RICHARD W. SLACK, ESQ.

THEODORE TSEKERIDES, ESQ.

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153

TOBIAS S. KELLER

Keller & Benvenutti LLP

650 California Street

Suite 1900

San Francisco, CA 94108

For Official creditors' 

committee:

ANDREW M. LEBLANC, ESQ.

GREGORY BRAY, ESQ.

Millbank LLP

2029 Century Park East

33rd Floor

Los Angeles, CA 90067

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For California Public 

Utilities Commission:

ALAN W. KORNBERG

SEAN MITCHELL

Paul, Weiss, Rifkind, Wharton & 

Garrison LLP

1285 Avenue of the Americas

New York, NY 10019

For State Farm: ALLAN S. BRILLIANT

Dechert LLP

1095 Avenue of the Americas

New York, NY 10036

For Ad Hoc Bondholder 

Committee:

DAVID H. BOTTER

MICHAEL STAMER

Akin Gump Strauss Hauer & Feld LLP

One Bryany Park

New York, NY 10036

For Mia Nash: FRANK DAVID BLOKSBERG

142 E McKnight Way

Grass Valley, CA 95949

For NextEra Energy Inc., 

et al.:

SAMUEL MORGAN KIDDER

Klee Tuchin Bogdanoff & Stern LLP

1999 Avenue Of The Stars

Floor 39

Los Angeles, CA 90067

For Consolidated Edison 

Development, Inc.:

GABRIEL OZEL

Troutman Sanders LLP

11682 El Camino Real

Suite 400

San Diego, CA 92130

For Ad Hoc Group of 

Subrogation Claim Holders:

ALEXANDER JAMES DEMITRO LEWICKI

Diemer & Wei, LLP

100 W San Fernando Street

Suite 555

San Jose, CA 95113

For Calpine: MICHAEL P. ESSER

Kirkland & Ellis LLP

555 California Street

San Francisco, CA 94104

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For Interested Party: PAUL JOSEPH PASCUZZI

Felderstein et al. LLP

400 Capitol Mall

Suite 1750

Sacramento, CA 95814

For Interested Party: JOHN CARL LEMON

Law Offices of John C Lemon APC

1350 Columbia Street

Unit 600

San Diego, CA 92101

For Interested Party: LARS TERENCE FULLER

The Fuller Law Firm

60 North Keeble Avenue

San Jose, CA 95126

For Official Committee of 

Tort Claimants:

ERIC EVAN SAGERMAN

16060 Ventura Blvd

Suite 110-125

Encino, CA 91436

For Interested Party: DARIO D'GHATALI

Also Present: Jeanne Finegan

President and Chief Media Officer 

of HF Media, LLC

Shai Waisman

Chief Executive Office of Prime 

Clerk

Court Recorder: MONICA TARTAGLIA

 United States Bankruptcy

Court

450 Golden Gate Avenue, 16th Floor

San Francisco, CA 94102

Transcriber: JENNIFER HAMILTON

 eScribers, LLC

7227 N. 16th Street

Suite #207

Phoenix, AZ 85020

(973)406-2250

Proceedings recorded by electronic sound recording; 

transcript provided by transcription service.

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SAN FRANCISCO, CALIFORNIA, WEDNESDAY, JUNE 26, 2019, 9:54 AM

-oOo-

(Call to order of the Court.)

THE CLERK: Matter of PG&E Corporation.

THE COURT: Mr. Karotkin, good morning. Are you okay 

with the sequence that --

MR. KAROTKIN: Good morning, sir.

THE COURT: -- I asked that we follow today? Do you 

have any problem with that?

MR. KAROTKIN: No, sir.

THE COURT: Okay. All right, let's do it, then. Do 

you want -- do you want to make some opening comments? I mean, 

tell me how you want to.

MR. KAROTKIN: Yeah, if you don't mind, sir.

THE COURT: Yeah, sure.

MR. KAROTKIN: Stephen Karotkin, Weil, Gotshal & 

Manges, for the debtors.

We, of course, have out declarants here in court 

today. And if I could introduce them, we have Ms. Finegan, 

president and chief media officer of HF Media, a division of 

Heffler Claims Group.

If she would stand up?

THE COURT: Good morning. Thank you for coming.

MR. KAROTKIN: And Mr. Waisman, chief executive 

officer of Prime Clerk.

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THE COURT: Guardian, Mr. Waisman. Thank you.

MR. KAROTKIN: Your Honor, I'm more than happy to 

address the questions that you raised in your hearing order 

that you issued yesterday. And I think, in view of where 

things stand today, and I think, as you noted in that order, 

The issues before the Court today are fairly limited. I think 

that we have resolved most of the issues with respect to the 

bar date. With respect to the wildfire proof of claim form, 

there are only a couple of open items that I can go through 

with you --

THE COURT: Well, you know what might --

MR. KAROTKIN: -- in a few minutes.

THE COURT: -- be helpful? And whether I -- whether I 

make my comment through the order or the form, I mean, to some 

extent, the proposed order that you submitted mirrors much of 

the proof of claim form. And much like -- that I've done in 

other matters where I have to review something in advance, it's 

just helpful for me to jot down questions and then just present 

them to you. And some of them, you might say it's a nonissue 

or you've resolved it. Others, you might tell me that I'm 

crazy. And another one, you might say that's a good idea, 

we'll do it. So I mean, I can go through just a series of 

questions. And they're really to you, but they're also to the 

TCC counsel. And it doesn't -- you know, there are questions 

that are common to both versions of the proof of claim form. I 

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didn't even have time, with the flush -- flood of activities in 

the last few days, to even review the proposed order from the 

TCC. But again, the kind of comments I have are --

MR. KAROTKIN: Um-hum.

THE COURT: -- common to anywhere.

So for example, I have your proposed order with 

questions right down the line. And I'm more comfortable just 

running through that way if you're okay.

MR. KAROTKIN: I'm okay, but if I could just make a 

couple of remarks before --

THE COURT: Sure.

MR. KAROTKIN: -- before we get to that?

THE COURT: Sure.

MR. KAROTKIN: As we reference in our -- in our reply 

pleadings, we have reached an agreement with the subrogation 

claimants --

THE COURT: Right.

MR. KAROTKIN: -- and their proof of claim form. And 

to the extent that there are any objections, those have --

those have been resolved. And although I know you have 

questions with respect to the proposed order, we have filed a 

revised -- a revised order on the bar date. We believe that 

has resolved --

THE COURT: Is that another -- after the one you filed 

on the 19th?

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MR. KAROTKIN: No, no. No. No.

THE COURT: Okay, no, that's --

MR. KAROTKIN: The one --

THE COURT: -- the one I --

MR. KAROTKIN: The one that --

THE COURT: -- in the markup.

MR. KAROTKIN: -- you have before you. And I know you 

have questions.

THE COURT: Yeah.

MR. KAROTKIN: I think that, in our view, that has 

resolved the outstanding objections, particularly, Your Honor, 

in view of the comments you made in the order yesterday with 

respect to potential claims based on post-petition events. So 

I think that you have disposed of that issue by saying that 

you're not going to address this. So I think it's fair to say 

--

THE COURT: By the way, it's not like a huge can of 

worms to start speculating about the future.

MR. KAROTKIN: I think that your approach is 

absolutely correct.

THE COURT: Okay.

MR. KAROTKIN: So I think it's fair to say -- and 

we'll get to this -- that the only remaining issues relate to 

the extent and the adequacy of the supplemental notice. And 

again, as I'll explain further, we have agreed to further 

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supplement it since what we filed last week. And the second 

issue is what is the appropriate bar date?

THE COURT: Well, I'm kind of treating that as a -- as 

a discrete question that I want to hear from --

MR. KAROTKIN: Yes.

THE COURT: -- both sides and anyone else.

MR. KAROTKIN: Yeah, we --

THE COURT: But I think, again, going back to the way 

it helps me, some of my points on the form order are really 

almost nitpicks, but they're nitpicks in the sense that I'm 

afraid they might be creating confusion --

MR. KAROTKIN: Sure.

THE COURT: -- in the minds of people that aren't 

under -- familiar with this. And it -- and therefore, there 

are comments that are consistent for either or more, whatever 

we come to.

MR. KAROTKIN: Right, we have -- we understand that --

THE COURT: Okay.

MR. KAROTKIN: -- and, as I said, we're happy to go 

through that with you.

THE COURT: Okay. Should we do that now or do you 

want to make some more --

MR. KAROTKIN: I want to make a couple of more 

remarks.

THE COURT: Okay. Okay.

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MR. KAROTKIN: If you don't mind?

THE COURT: No, go ahead. Go ahead.

MR. KAROTKIN: You seem anxious to get to that order.

THE COURT: No. No.

MR. KAROTKIN: I want to make it clear, Your Honor, 

that the original notice that we proposed, in our view, more 

than satisfied due process. And we now, as you will see, have 

made two rounds of supplements to that in order to address some 

of the issues raised by the -- by the tort claimants committee. 

And I would like to reference, Your Honor, Ms. Finegan's 

declaration, again, which was filed after the first 

supplemental notice, which states, in paragraph 6, that the 

notice plan is one of the largest and most comprehensive notice 

and media campaigns recommended in bankruptcy history. And 

that statement, as I said, Your Honor, was made before the

additional modifications that I'll go through with you shortly.

As the debtors have stated clearly and consistently, 

Your Honor, since these cases were commenced, a principal goal 

is to move forward with the administration of these cases as 

expeditiously as possible so that distributions can be made to 

the holders of wildfire claims as soon as possible and, in 

fact, more quickly than distributions would be made in the tort 

system. Your Honor, we thought that the tort committee shared 

that goal. It has fiduciary duties to all claimants. We 

thought they shared that goal and that would be of paramount 

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interest to them. For reasons that completely mystify us, and 

I think mystify other parties who are here today, including the 

unsecured creditors committee, the tort committee apparently 

doesn't share the goal of moving this case forward --

THE COURT: Well, I -- you know, I --

MR. KAROTKIN: -- expeditiously.

THE COURT: -- what I'd -- what I'd like to do is 

focus on the issue. And I'll ask the tort committee if they're 

adamant about January 31st. If they say no, we want it to be 

February 28th, I might ask for further clarification.

But to me, as I tried to say, my decision points today 

are between October 21st and January 31st. I'm not going to --

I'm not going to go outside that range. So that's really --

I'd rather not talk about motive, but talk about reason, why 

one date is better than the other.

MR. KAROTKIN: And we'll get to that.

THE COURT: Okay.

MR. KAROTKIN: But I'd like to point out one other 

thing. That what actually concerned me the most, Your Honor, 

and perhaps I find most troubling is that why didn't the tort 

committee come to us after we filed our motion and say: we 

have issues with your noticing?

Instead, they waited three weeks and they filed their 

motion, and here we are today with additional motion practice, 

additional cost and expense, and frankly, if they wanted to 

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move constructive -- these cases forward constructively, they 

would have called us. But let me go through, Your Honor, the -

-

THE COURT: Yeah, again --

MR. KAROTKIN: -- changes that --

THE COURT: -- those are the kinds of questions that 

are fair to ask, but I'm not going to try to answer them, I'm 

not going to ask the other side to answer them.

MR. KAROTKIN: But I think it puts things in 

perspective, Your Honor --

THE COURT: I got the --

MR. KAROTKIN: -- as to --

THE COURT: I got the message.

MR. KAROTKIN: -- as to what's going on here today. 

So I -- if I could, I would like to go through, with you, the 

additional noticing that we are proposing, again, in addition 

to what we have --

THE COURT: Well, I mean, I've --

MR. KAROTKIN: -- already proposed --

THE COURT: -- read Ms. Finegan's papers and your --

everything else. I mean, I -- it's --

MR. KAROTKIN: And there's more --

THE COURT: -- it's overwhelming.

MR. KAROTKIN: But there --

THE COURT: If you want --

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MR. KAROTKIN: But there's --

THE COURT: -- to add more things --

MR. KAROTKIN: -- there's more --

THE COURT: Okay. 

MR. KAROTKIN: There is now more.

THE COURT: More -- more was --

MR. KAROTKIN: In order to address --

THE COURT: Okay. Go ahead.

MR. KAROTKIN: -- some additional concerns. And if I 

could approach?

THE COURT: Sure.

MR. KAROTKIN: Okay.

THE COURT: Do we -- is it something we can put on the 

screen for other people? Or --

MR. KAROTKIN: No, we have copies for them.

THE COURT: Well, we also have people in the other 

courtroom, as well. Okay.

MR. KAROTKIN: So if you -- if you look at this chart, 

Your Honor, this sets forth, with respect to the supplemental 

noticing program, our original plan and the debtor's current 

proposed notice plan, which now includes what we supplemented 

last week, in addition to what we've -- the additional 

provisions that we've made and added in the last day or so.

THE COURT: Okay.

MR. KAROTKIN: And it's relatively self-explanatory. 

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And if you -- if you look at the frequency and reach, you will 

see that the original -- the original proposal was estimated to 

reach approximately ninety-five percent of adults eighteen 

years an older in the four designated market areas. And those 

DMAs -- the designated market areas, Your Honor, are the four 

areas --

THE COURT: I know -- I know what they are. I read 

about them.

MR. KAROTKIN: -- in which the wildfires occurred. 

That covers six counties.

THE COURT: Um-hum.

MR. KAROTKIN: And if not -- if you now look at the 

comments on the right-hand side, you'll see that it has been 

increased from 5.8 times reach with, now, the reach increased 

and designed to cover 95 percent of the target audience an 

average of ten times. That means they would see it -- a notice 

ten times.

With respect to magazines and print, we have -- we 

have added national distribution in People Magazine, Sports 

Illustrated, and Sunset Magazine. I would note that the --

that the tort committee requested only that we use People 

Magazine and Sports Illustrated. We went beyond that.

With respect to the newspapers, we added fifteen 

additional newspapers in Northern California, as requested by 

the tort committee. And if you look at the right-hand side, 

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there are now twenty-nine total publications which will run 

print notices three times in each, other -- in each 

publication, other than the Wall Street Journal, which will be 

published once.

THE COURT: By the way, I saw this before about 

publication sequence. What you didn't say or I don't recall 

was intervals. Is there going to be an interval between each 

of the publications?

MR. KAROTKIN: There will be intervals.

THE COURT: But I mean, not like each day. Every week 

or something, a larger period of time?

MR. KAROTKIN: Yes, sir.

THE COURT: Okay. And --

MR. KAROTKIN: With the first ones starting --

THE COURT: That's okay. I don't need to go into the 

detail.

MR. KAROTKIN: Okay.

THE COURT: But we have timing as to when that will 

initially start.

With respect to television, there's some term called 

"TRPs", which I won't try to explain to you because that's 

beyond my capabilities. But we have increase TRPs to 1,300, 

and I will note that the tort committee, in its request, had 

only requested 500, so we've gone above and beyond that.

With respect to local radio -- with respect to radio, 

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that's been increased to add streaming radio. Again, I believe 

at the tort committee's request, we've added Pandora. And as 

noted in the comments on the right, there will be ads purchased 

in four English-speaking and two Spanish-speaking radio 

stations in each market for a total of thirty-four stations.

And then there is a whole host of online -- of online 

noticing with specific ability to target websites that people 

in the wildfire areas would frequent, with specific abilities 

to obtain addresses of people who lived in the area and the 

ability to track -- and don't ask me how this is done -- the 

websites that they visit, both in search ads -- both in news --

in news streaming types of facilities --

THE COURT: It's kind of scary, when you think about 

it.

MR. KAROTKIN: It is very scary.

THE COURT: Yeah.

MR. KAROTKIN: As well as people who have left the 

area, where they can track them and find sites they visit on 

YouTube, Facebook, Instagram, and assure that they get notice 

that way, as well.

And with those -- all of those modifications, we 

believe -- and our experts can confirm, and they are here 

today, Your Honor -- that this plan goes well above and beyond 

what is necessary and addresses any legitimate concerns that 

the tort committee could have. And Your Honor, I would refer 

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you -- refer you to Ms. Finegan's declaration -- again, 

prepared before we added this additional notice -- at paragraph 

98, where she says: building on the original supplemental 

notice plan, the revised supplemental notice plan now 

incorporates additional layers of notice through additional 

magazine coverage nationwide; an increase in the number of 

television commercials locally on broadcast, cable, and 

nationwide through cable television and OTT; more robust local 

radio coverage and streaming radio; increased impressions 

online; online video cross-platforms, such as YouTube; and 

importantly -- and I won't refer to Angeion -- the debtors are 

leveraging social influencers who have enormous followings and 

have had their lives affected by the fires.

She goes on to say, Your Honor, in paragraph 99, that 

the reach and frequency of the debtors' supplemental notice 

plan is estimated as follows. It will reach ninety-five 

percent of adults age eighteen years and older with an average 

frequency of eight times in the target four DMAs, the 

designated market areas, those six counties in which the fires 

occurred. It will reach over eighty-one percent of California 

residents eighteen years and older with an average frequency of 

five times. It will reach seventy-eight percent of adults over 

the age of eighteen nationwide who live outside of California 

and moved within the last four years with an average frequency 

of 2.3 times.

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And then she says: when that is combined with the 

other methods of notice not measured, such as community 

outreach, the overall effort, no doubt, will achieve -- will 

achieve greater results.

And if you want to hear from Ms. Finegan, she is in --

THE COURT: No, I don't.

MR. KAROTKIN: -- court today.

THE COURT: I read about her background and her 

explana -- her explanation --

MR. KAROTKIN: and I'll further --

THE COURT: -- and it's helped.

MR. KAROTKIN: -- note, Your Honor -- and again, Ms. 

Finegan will confirm -- that the typical notice in a class 

action case reaches only seventy to eighty percent -- seventy 

to eighty percent, not ninety-five percent -- of the target 

audience approximately two to three times with a very limited 

amount of online and other means of notice outreach that our 

plan includes. Our plan, Your Honor, goes well beyond what is 

done in any class action, well beyond, Your Honor, what's been 

done in any Chapter 11 case.

THE COURT: We have -- we have bankruptcy principles 

and we have Mullane, and its progeny, and we have reasonable 

efforts to give due process. It's not a certainty, it's not 

positively. And unlike a class action, if I'm not mistaken, 

if, despite all the efforts in a class action, someone never, 

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never, ever had notice, that person doesn't suffer a discharge. 

In bankruptcy, of course, there's the risk of discharge. 

Although even the case law says certain people don't get a 

discharge if they never had notice. So --

MR. KAROTKIN: Correct --

THE COURT: -- this really comes down to the 

bankruptcy principles of reasonable under the circumstances. 

It's a judgment call, right?

MR. KAROTKIN: Absolutely, and --

THE COURT: Okay.

MR. KAROTKIN: -- and what I'm saying to Your Honor is 

this goes beyond reasonable.

THE COURT: Yeah. I understand.

MR. KAROTKIN: This is the most robust plan that has 

ever been done.

THE COURT: It certainly seems to be that way. And 

I'll listen to TCC and anyone else who wants to say -- speak 

against it. But again, I am going to talk about my comments on 

the order at some point.

MR. KAROTKIN: Would you like to do that now or would 

you like to talk about it?

THE COURT: Well, no, and I'm not -- I'm not -- excuse 

me, I'm not making light of this. My point is that I read Ms. 

Finegan's declarations, I've read the reports, I was amazed at 

how complex it is. And this is not -- again, this is not 

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playing Ms. Finegan and Prime versus Angeion. This is new 

territory for a lot of us. And just the technology and the --

and the thought that goes into all these alternative plans is 

almost incomprehensible. But we start with the principle that 

I mentioned is that what the Mullane court taught us whatever 

hundreds of years ago was and everything since then. So I'm 

going to listen to anybody that wants to say why I should 

disapprove this or this proposal, but not now. I'll come back 

to that when we come to that.

MR. KAROTKIN: So --

THE COURT: Okay?

MR. KAROTKIN: -- would you --

THE COURT: Yeah.

MR. KAROTKIN: -- like me to address the October 21st 

date or would you like to --

THE COURT: No, I'd rather go --

MR. KAROTKIN: -- go through the order?

THE COURT: -- on the comments because this is -- I --

there may be some back-and-forth, as I said. Unless I'm 

missing something, it's a simple question of letting the 

lawyers tell me why I should pick one date or the other or 

something in between. I'm not going to go earlier than your 

date, I'm not going to go beyond their date. This is --

MR. KAROTKIN: Okay.

THE COURT: This is my call to figure out, well, 

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what's the right thing to do? But let's -- I mean -- I mean, 

as I said to you before, I -- in my little summary for today, 

that seems to be what I -- my choices are at the moment.

MR. KAROTKIN: Yes.

THE COURT: And well, you -- I'll tell you what. As 

long as you're there, give me what response to the question 

that I raised about is it really a ninety-five date when you 

think about it? Because --

MR. KAROTKIN: Yes.

THE COURT: -- I'm not going to be signing an order 

today, best case. You know I'm not. And the question is, so 

let's assume I assign something on your side on July 1. When 

do the first things start to happen --

MR. KAROTKIN: Okay.

THE COURT: -- versus when the most untechnical 

assisted claimant has to drop something in the mail in, you 

know, Paradise, California to go to New York city. It's --

MR. KAROTKIN: May --

THE COURT: Tt's a shorter number of days, right?

MR. KAROTKIN: It is. May I approach?

THE COURT: Yeah, of course.

MR. KAROTKIN: So what you have before you, sir, is, 

assuming you enter -- I think you mentioned in your order --

THE COURT: I just picked it. I mean, look, today's 

Wednesday, and --

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MR. KAROTKIN: Okay, so assume July 1.

THE COURT: -- it's going to take time to do it, yeah. 

Yeah.

MR. KAROTKIN: So if you assume July 1, the mailing to 

all known creditors other than customers, including the mailing 

to all known -- all known wildfire claimants will be completed 

by July 8th.

THE COURT: And if Prime is going to do it, they're 

the principal source of putting it all together, stuffing the 

envelopes, or however they do it --

MR. KAROTKIN: And --

THE COURT: -- and out they go?

MR. KAROTKIN: Exactly.

THE COURT: Okay.

MR. KAROTKIN: And moreover, Your Honor, these will be 

all customized --

THE COURT: Right.

MR. KAROTKIN: -- claim forms for creditors, wildfire 

claimants, with their names, addresses, to the extent they're 

scheduled, they'll be referenced to the schedules. Completely 

customized --

THE COURT: Okay,22

MR. KAROTKIN: -- to make it easy.

THE COURT: -- yeah, I mean, I've -- particularly if 

they're non -- they're nontort claimants.

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MR. KAROTKIN: Correct.

THE COURT: That's another question. But that's a 

different question.

MR. KAROTKIN: All right. The mailing to all 

customers, which is about seven million pieces, will be 

completed by July 16th. That leaves ninety-seven days.

THE COURT: Okay.

MR. KAROTKIN: Until October 21st.

THE COURT: Okay. But again, back to -- let's just 

stick with an individual, not represented by counsel, not techsavvy, so that they've seen it seventy-five times on their 

satellite radio. Somebody ideally will get it no earlier than 

around July 8th, and then there's a deadline if they drop it in 

the mail rather than going to one of the service centers. It 

will be mailed, and it has to get there by --

MR. KAROTKIN: October 21.

THE COURT: Well, it would have to get there by 

October 21st. So presumably it has to be mailed a few days 

prior. That's all.

MR. KAROTKIN: Okay. So that a hundred days. Let's 

say a hundred days.

THE COURT: So you're saying a hundred days, okay.

MR. KAROTKIN: Okay.

THE COURT: All right.

MR. KAROTKIN: The customers would all be completed by 

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July 16th. So ninety-seven days to October 21st. So if you 

wanted to say ninety-two days, that's fine. The first 

newspaper --

THE COURT: I think -- by the way, I think it is the 

tort victims who we're really focusing on the need to do this 

kind of notice, right? I mean, they are the ones who -- it's 

not to say that a contractual claimant isn't entitled to due 

process either, but contractual claimants typically are on 

schedules, maybe don't have to file claims at all, and there's 

a much less pressure in terms affording due process, right?

MR. KAROTKIN: Correct.

THE COURT: Okay.

MR. KAROTKIN: And again, I think that we took that 

into account.

THE COURT: Right.

MR. KAROTKIN: This is more than adequate time. And I 

think, Your Honor, you will know from the pleadings that other 

parties here representing tort claimants certainly are 

comfortable with the date we've selected.

THE COURT: Yes.

MR. KAROTKIN: I think, Your Honor, the tort committee 

is the lone wolf out there asking for an extended bar date. 

Newspaper publication recommends within seven days after entry 

of the order.

THE COURT: Again, when I asked you before about on 

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the newspapers, I asked you what the frequency was, and it's 

going to vary with publication, but it seemed to me there 

should be a publication no later than a date also because --

MR. KAROTKIN: Yes, yes.

THE COURT: -- if you publish something on October 20, 

that's not very helpful.

MR. KAROTKIN: No. It will be --

THE COURT: Right?

MR. KAROTKIN: Yeah. I think if it's not in the 

proposed order we will certainly include in the proposed order 

that publication shall be no later than a certain date the 

first time, the first publication.

THE COURT: Well, no, the last publication, also. I 

mean, again --

MR. KAROTKIN: Oh, yeah.

THE COURT: What good is a mailing on October 20th do?

MR. KAROTKIN: We can put in the sequencing of --

THE COURT: Okay.

MR. KAROTKIN: -- all of it if you'd like. The TV and 

radio spots we commence within two weeks of entry of the order, 

again assuming July 1st, that would be July 15th and --

THE COURT: Okay. I've got all the points right here.

MR. KAROTKIN: Okay. So again --

THE COURT: And --

MR. KAROTKIN: -- with that type of a timetable, we 

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believe that there is again --

THE COURT: And when is the drop centers -- when are 

they staffed and open for business, the four or five places?

MR. KAROTKIN: July 15th.

THE COURT: The 15th. So they will be physically 

manned by --

MR. KAROTKIN: Yes.

THE COURT: -- human beings during at least business 

hours?

MR. KAROTKIN: Yes.

THE COURT: Beginning on July 15th?

MR. KAROTKIN: Yes.

THE COURT: Okay.

MR. KAROTKIN: And again, Your Honor, we've agreed to 

a pretty simple claim form.

THE COURT: I know.

MR. KAROTKIN: Okay. So it's not burdensome for 

someone to complete the claim form.

THE COURT: Well, that's easy for you and me to know, 

but it might be really very burdensome for someone who is 

traumatized and intimidated by the legal system and doesn't 

understand what a bar date means, you know --

MR. KAROTKIN: And we've tried to make --

THE COURT: -- et cetera.

MR. KAROTKIN: -- abundantly clear.

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THE COURT: Okay.

MR. KAROTKIN: Okay.

THE COURT: All right.

MR. KAROTKIN: So I think that again with this 

timetable and the amount of notice we clearly believe we 

satisfied all the requirements of due process under Mullane, 

and I'm happy to go through the order if you'd like to do that.

THE COURT: Okay. If you're more comfortable back at 

counsel table just to --

MR. KAROTKIN: No. I'm fine up here.

THE COURT: Okay. Well, I mean look, I just went 

through it as much as I would do if I were reviewing a 

disclosure statement. I'd just say, well, wait a minute. What 

does this mean? Why is this here? So I'll start with page 3 

of the proposed order which is the ordering paragraph.

MR. KAROTKIN: Can I just ask a question?

THE COURT: Yeah.

MR. KAROTKIN: Are you looking at the claim or the 

mark?

THE COURT: The claim.

MR. KAROTKIN: Can you give me one second?

THE COURT: Sure. Yeah. Again, that's why if you're 

ready -- if you're more comfortable at counsel table, that's 

fine with me.

MR. KAROTKIN: Okay.

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THE COURT: Well, my first comment is on paragraph 3, 

which is page 3 of the proposed order, your proposed order, and 

it's a simple question, you and I are bankruptcy professionals 

as are a lot of people from the room here, but the capitalized 

term, bar date, isn't defined anywhere. Where does someone 

reading this know what a bar date is?

So in my mind, there should be, this means a deadline 

by which you have to do something. And I'm not unwilling to 

either back off of this or have some other alternative, but I'm 

worried about people that are overwhelmed by the complexity of 

something like a notice like this. So I don't think bar date 

is a defined term in this document. Maybe I missed it.

MR. KAROTKIN: It's on the next page, Your Honor.

THE COURT: Well, where is it because I didn't see it, 

but I went through -- I went through these things carefully, 

and I might have missed it.

MR. KAROTKIN: We can certainly clarify it, but on the 

next page, it's clear what the date is.

THE COURT: Just tell me what line to --

MR. KAROTKIN: It's on line --

THE COURT: No. Not the date. The term. What does 

the term bar date mean to a layperson? You and I know what it 

means.

MR. KAROTKIN: I understand. 

THE COURT: What does it mean?

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MR. KAROTKIN: We can clarify that.

THE COURT: What, but what -- give me the simple 

answer. You are --

MR. KAROTKIN: The bar date means the last --

THE COURT: -- an uneducated victim of a fire who 

lives in the woods somewhere. What does it mean when, oh, my 

God. There's a bar date? What does it mean? He says, I keep 

hearing it on the radio and I keep reading on my newspaper and 

I keep getting it on the TV. What does bar date mean to me? 

So can't we just say, this means the date of October bland or 

whatever date that your claim must be filed?

MR. KAROTKIN: Yes.

THE COURT: Just that simple.

MR. KAROTKIN: Sure.

THE COURT: In bold letters.

MR. KAROTKIN: And in the notice, the summary notice, 

I believe it does say that, but yes, we can certainly clarify 

that.

THE COURT: The next question, again, is one of those 

things like, why am I even asking this question, and that's in 

footnote 2, the term, Northern California wildfires is a 

defined term to exclude the fire that happened in 2016. The 

Ghost Ship fire happened in 2016. And so when you read the 

definition of Northern California wildfire, it's not in there. 

It wasn't a wildfire in a traditional sense like a forest fire. 

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It was a tragedy at a building where a lot of people died, but 

everybody in the Bay area and in Northern California knows 

about the Ghost Ship fire. So it's just a definition thing.

MR. KAROTKIN: Okay.

THE COURT: And I don't -- again, I don't care how you 

solve it. I want to make sure we're not inconsistent with the 

documentation. That's all.

MR. KAROTKIN: Okay. We can include that.

THE COURT: Okay. So in the standard form -- now, 

this is the -- the next question on the next page on page 4 on 

the standard claim, not the wildfire claim, where in the small 

print, little i, and this is in 7-B, standard claim, little ii, 

be denominated in lawful currency. 

Well, it seems to me, he aught to say, if known, 

because we are allowing, and your forms allow people to file a 

claim without quantifying their claim, right? And a lot of the 

tort victims don't have to quantity their claim at this point.

MR. KAROTKIN: Okay.

THE COURT: So do you have a problem just saying --

and this would show up in several cases. Again --

MR. KAROTKIN: Sure.

THE COURT: Mr. Karotkin, I don't want to put you on 

the spot. These are comments that I have, and if you have 

sober reflection in conferring with your colleagues and clients 

and others and say, wait a minute. There's a problem. I don't 

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want you to feel that these are nonnegotiable for me or 

anything, but this is why we're having this conversation. And 

sorry I was taking so much time with everyone listening, but I 

think it's important to me that a person who doesn't know how 

to quantify the claim isn't -- is not cut out because he or she 

hasn't done it. And it's the same question that shows up for 

the wildfire claims, and I just happened to think of it on the 

standard claim form first. You follow me?

MR. KAROTKIN: Yes.

THE COURT: Okay. And then again, a question that's 

pertinent to each of these paragraphs, why does the language 

say that if the claimant is not an individual, it has to be 

signed by an authorized agent? Why can't an agent for an 

individual sign as well like they do all the time? 

In other words, it says, the documentation must be 

signed by the claimant or if the claimant is not an 

individual -- well, individual claimants can have their agent 

sign for them, too. Lawyers do it all the time, right, unless 

there's a particular reason why you are insisting that the 

claimant --

MR. KAROTKIN: No. We can fix that.

THE COURT: Well again, I just want to -- I don't want 

a trap. I don't to have a situation six months from now where 

we have a claim objection. Wait a minute, attorney so and so 

signed for Ms. Smith in the forms that Ms. Smith had to sign. 

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Again, you decide whether this is a substantive issue. If not, 

let's --

MR. KAROTKIN: We can fix that. It certainly wasn't 

designed to be a trap. That I can assure you.

THE COURT: I didn't suggest it. Okay. Here's a 

broader question that's a bankruptcy lawyer question. And this 

has to do with -- still on page 4, subparagraph C. And the 

language is there, really, for the standard -- or my question 

is for the standard proof of claim as well as the wildfire 

claim.

But the standard proof of claim, generally, is for 

people that chose to be creditors, and they know what it means. 

And that is this, Mr. Karotkin. I'm inclined to say, where you 

put in there -- states that, as of the petition date what your 

claim is, is adding something like, even if calculated later, 

because again, you and I know that the petition date is a 

critical date for proofs of claim. But we also know that, 

particularly with torts, lots of times the calculation occurs 

much later.

And so it seems to me the proper way for a claim form 

to assert the claimant's entitlement is the best judgment, as 

of the -- as of the -- I mean, as of the time you're preparing 

a claim, what your claim was, as of the petition date, or would 

be, even if you had to calculate it. You follow me?

MR. KAROTKIN: Yes, sir.

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THE COURT: So why don't I ask that you make sure 

you're comfortable with that? And don't decide it right now. 

If you conclude that something like that is okay, then fine. 

If it's not okay, I'm not going to make an issue of it.

MR. KAROTKIN: Okay.

THE COURT: All right. Next question -- well, the 

next question is on page 5, and it's the same question for the 

several claims, the same as before, about if known. And so I 

won't repeat those.

MR. KAROTKIN: Okay.

THE COURT: On subparagraph E -- let's see. One 

second. Oh, yeah. What happens, in your mind -- if there is a 

class suit, or class action, or class proof of claim, what 

happens to an individual debtor who doesn't file a claim?

MR. KAROTKIN: Individual claimant?

THE COURT: In other words, I'm looking at 

subparagraph E on page 5. And so what I wrote in the margin 

for that is, "What if not separately filed", in other words, 

what your -- the language says that the holder of the claim 

must file a claim, even if it's done by class action suit, 

class -- adversary, et cetera. And my question to you is if 

Mr. Jones has five counsel representing him in five different 

class actions, but he doesn't file his own claim, is he out or 

not?

MR. KAROTKIN: The way this is written, yes.

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THE COURT: And is that the way the law would require 

it? In other words, is that the way you understand --

MR. KAROTKIN: I -- I --

THE COURT: -- is the outcome?

MR. KAROTKIN: I believe, Your Honor, you have the 

authority to do that.

THE COURT: Well, but if I -- again, we're back to the 

question of agent. If I sign up with a group of people, who --

again, I don't want to go back to the merits of the motion that 

I heard this morning, but at least until I make a ruling, there 

is, nominally, a group of people who believe they're in a class 

called the Herndon class. And if someone in that class has, 

through counsel for the class, asserted something, if your 

position is that the law means the individual is out of luck no 

matter what, I guess we'd better clarify that. And --

MR. KAROTKIN: I think that, Your Honor, to the extent 

that the attorney representing the class sets forth the 

information with respect to each claimant, as required by the 

form, that would be sufficient. But filing a blanket claim on 

behalf of a class of unknown people with no names, I don't 

think that works.

THE COURT: So if one of the --

MR. KAROTKIN: I'm not saying that they don't -- they 

could have power of attorney to file the claim, like any other 

power of attorney, if they're representing a claimant --

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THE COURT: Um-hum.

MR. KAROTKIN: -- to file an appropriate claim and 

sign that claim. But to file a class claim on behalf of John 

Doe and a group of unknown claimants, to me, that's 

inappropriate.

THE COURT: Okay. But going back to the power of 

attorney, so again, let's use the Herndon class today. If I 

toss that adversary proceeding, but Mr. Gottfried or his 

colleague, if they file something under a traditional power of 

attorney for the known people, then it seems to me you're 

conceding that that would be okay.

MR. KAROTKIN: If it includes the information --

THE COURT: Right.

MR. KAROTKIN: -- with respect to those people --

THE COURT: Right.

MR. KAROTKIN: -- in the claim form.

THE COURT: Got it.

MR. KAROTKIN: Yes, sir.

THE COURT: Got it. But then, therefore, you see, 

it's not consistent with --

MR. KAROTKIN: Okay.

THE COURT: -- subparagraph E. So again --

MR. KAROTKIN: We can clarify that.

THE COURT: -- it's clarification. Then yeah, now, 

again, on subparagraph F, it's just a point of -- I'm just 

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going to make sure I got it right, Mr. Karotkin.

The second sentence of paragraph F says that the 

wildfire claimants are deemed to have filed one claim in both 

debtors -- against both debtors. But if you're a contractual 

claimant, you have to -- you have to name one or both of your 

debtors, specifically.

MR. KAROTKIN: Yes, sir.

THE COURT: So on the claim form -- and I notice that 

on the actual claim form, the -- what we'll call the general or 

the normal claim, it does have the box for the two debtors. 

But for the wildfire and the several claims, it does not. And 

that's consistent with your understanding there; that right?

MR. KAROTKIN: Yes, sir.

THE COURT: That's right?

MR. KAROTKIN: Yes.

THE COURT: Okay. I mean, I -- my point is that it 

was one of those things where the first sentence raised the 

question in my mind. The second sentence answered it, but I 

wanted to make sure you confirm and so I have no question.

Now, next question, and this is a question about Prime 

Clerk, as much as anything else. What happens when a person 

files the claim electronically, Prime Clerk? There is a 

electronic claim form. What do they get back? They get a 

receipt? They get something? In other words, they get 

something that shows they're on file or not?

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MR. KAROTKIN: May I ask Mr. Weissmann to answer --

THE COURT: Yeah.

MR. KAROTKIN: -- that question?

THE COURT: Yeah, because, look. It's really 

critical. Think about it when you file something 

electronically in our court. You get an NEF back.

MR. KAROTKIN: Yeah.

THE COURT: So Mr. Weissmann, just answer that. What 

does the claimant who files electronically get, to know that he 

or she has filed a claim?

MR. WEISSMANN: As soon as they hit submit, they are 

emailed a receipt with a full copy of the claim that was 

submitted, an actual copy.

THE COURT: Okay. I think it would be helpful to say 

that, because here's my point. And I'm glad that's the answer 

that you gave me, because if it weren't, I'd probably tell you 

it has to be the answer. No, but the reason why is, elsewhere 

in the form, it makes a big deal, saying if you want a copy by 

mail, send us -- make sure you send one back. If you go to the 

claim processing center in Chico, bring a extra copy. Well, 

that's fine. And that's the way -- that's okay.

But in this electronic world, because Prime Clerk is 

going to allow and it has the ability to let a lot of people 

file electronically, all I want is they get something back. 

And I think it should say that in here --

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MR. KAROTKIN: We'll say that.

THE COURT: -- that something -- again, and I don't 

want to clutter up a very complicated form.

And Mr. Karotkin, I don't -- the fact that I'm making 

these comments, in the context of the order, is really -- it's 

really a claim form point. I mean, I don't care where we take 

care of it, but I think you and Mr. Weissmann have answered the 

question. Okay.

So okay. On page 6, you've already told me that the 

service centers will be staffed, beginning on July 15th. So 

there's a blank there. I mean it needs to be blank. Yeah. 

All right. This is where I -- it's on this page where I had 

made the notation of the question about how do you know your 

claim got filed electronically. So you're going to answer 

that.

MR. KAROTKIN: Yes, sir.

THE COURT: Yeah. This might be a nitpick again. On 

page 7, the paragraph L, you've got interests in there. And I 

think it should be -- hold to the claims. I mean --

MR. KAROTKIN: Yes, it's a mistake.

THE COURT: Yeah, okay. So okay. Again, a lesser 

point, and that's subparagraph N. You make reference to what 

the 503(b)(9) claim deadline was. I thought it would be useful 

just to put it in there. That was just a -- as I recall, it 

was just a date about twenty days after the petition date, 

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wasn't it?

MR. KAROTKIN: I believe it was.

THE COURT: Yeah. Well, let's just put it in there.

MR. KAROTKIN: Sure.

THE COURT: Okay. So then on paragraph O, still on 

page 7, there are two other references to interests, that I 

think don't belong here. But again, I'll leave it to you to 

make sure. You take it out if you agree with me that it should 

be out. I don't need further --

MR. KAROTKIN: I'll take a look. I'm not sure I 

necessarily agree, but I'll take a look.

THE COURT: Well, I went back and looked at the rules. 

Remember, I think we have -- I don't think we have anything in 

any form order that orders people to file proofs of interest.

MR. KAROTKIN: No, no. I think that --

THE COURT: And the national rules don't, either.

MR. KAROTKIN: I totally agree. I think --

THE COURT: Okay.

MR. KAROTKIN: -- that this may reflect that, to the 

extent you have a claim -- to the extent you're a stockholder 

and you have a claim -- a dollar claim --

THE COURT: No, it's a claim.

MR. KAROTKIN: -- this would require you to file.

THE COURT: No. No, you don't. If you're a 

stockholder, you're a stockholder.

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MR. KAROTKIN: No, no. But if you had --

THE COURT: You mean like a --

MR. KAROTKIN: -- a dol --

THE COURT: -- preferred stock?

MR. KAROTKIN: -- a rescission claim. Let's assume 

something like that.

THE COURT: Look. We --

MR. KAROTKIN: Yeah. I'll look --

THE COURT: Move on.

MR. KAROTKIN: -- at that.

THE COURT: I don't need anything back. The next time 

I see this, hopefully, I'll be signing an order, and the word 

interests will be there or not, as you've chosen. I'm not 

going to second-guess you on this one.

MR. KAROTKIN: Okay.

THE COURT: Okay. Page 9.

MR. KAROTKIN: 9?

THE COURT: Yes. One second. Oh, yeah. This is 

the -- this is the provision on page 9 in paragraph 12, where I 

believe you agreed with, perhaps, the TCC that you are cutting 

out post-petition claims. Because you're saying you don't file 

a claim -- remember, there are twelve paragraphs of people who 

don't file claims, right?

MR. KAROTKIN: Right.

THE COURT: And in paragraph 12, it's a person who 

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holds a claim for personal injury. And I think you should add, 

or wrongful death, because that's -- those two always go 

together. But the question, then, is shouldn't that also be 

expanded to contractual claims? In other words, a simple 

contractual claim, you and I can know that a contractual claim 

that arose on January 30th is not a subject of a proof of 

claim. Do you have a problem with expanding?

MR. KAROTKIN: But Your Honor, this was added to 

address a particular objection, not -- I don't even think from 

the TCC -- frankly, an objection we didn't really understand, 

but we accommodated people.

THE COURT: Okay.

MR. KAROTKIN: I think this is an extremely unusual 

provision.

THE COURT: Okay. Then I'll withdraw my comment.

MR. KAROTKIN: I mean, I would prefer to just 

eliminate it, entirely.

THE COURT: Well, but you've agreed to put it in, 

so --

MR. KAROTKIN: But so I would prefer to leave it the 

way it is.

THE COURT: Then how about at least add, though, or 

wrongful death?

MR. KAROTKIN: Yeah, yeah, of course.

THE COURT: Okay. Now, here, the next comment is on 

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paragraph 4 of page 9. I think one thing that I think you're 

just ignoring, perhaps, and not to be deceit -- to be tricky is 

the fact we have a very, very liberal principle in Ninth 

Circuit about informal proofs of claim. And you can send a 

postcard to the trustee in bankruptcy, and the Ninth Circuit 

has said, if it's timely and it asserts a right, it's an 

informal proof of claim that will survive.

And I think that that is -- this paragraph 4 has to, 

at least, acknowledge that the law, at least in this Circuit, 

does permit timely, informal proofs of claim. So tell me how 

you want to do it, because, I mean, I can -- I won't bore you, 

but I can think half a dozen different instances where the 

Ninth Circuit has let an untimely claim survive because it was 

informal but timely.

MR. KAROTKIN: I don't think this paragraph, in any 

way, precludes this. This paragraph was added at the request 

of a couple of parties, to clarify that, to the extent you 

timely file something and you amend it, that's not a problem.

THE COURT: Right. But if I -- if somebody listens to 

this hearing and sends you a letter next week that says, Dear 

Mr. Karotkin, I'm owed 5,000 dollars because my car got 

burned --

MR. KAROTKIN: Yeah.

THE COURT: -- you might not agree that that's good 

enough. But the Ninth Circuit might say, that's a timely 

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informal proof of claim.

MR. KAROTKIN: Well, Your Honor --

THE COURT: So I --

MR. KAROTKIN: -- I --

THE COURT: All I want to do is keep the -- is not 

mess with the law. That's all.

MR. KAROTKIN: But I think that particular piece of 

paper that I got, whether or not that is a good informal proof 

of claim, I think, would be subject to analysis on a case-bycase basis, okay?

THE COURT: I agree. I agree.

MR. KAROTKIN: So I don't think that this language is 

at all inappropriate. I mean, an informal proof of claim is 

either good or not good, and it'll be determined at the 

appropriate time.

THE COURT: So you think --

MR. KAROTKIN: This was here just to address the 

situation that people had asked, please make clear that if we 

file a claim and we amend it, it's still --

THE COURT: Do you think that line --

MR. KAROTKIN: -- be --

THE COURT: -- 22, the phrase, "Extent permitted by 

applicable law", includes controlling Ninth Circuit authority?

MR. KAROTKIN: I don't think this order, in this 

paragraph, implicates or tries to overrule controlling Ninth 

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Circuit law on informal proof of claim, in any respect. I 

don't think --

THE COURT: Okay. Again, I will accept your argument. 

When I hear from other counsel, if they want to make the pitch, 

I'll listen to them. If they don't make the pitch, I won't 

revisit again.

MR. KAROTKIN: And again, this was actual language 

requested by some objecting parties --

THE COURT: No, I --

MR. KAROTKIN: -- which we included.

THE COURT: I already said I'm not --

MR. KAROTKIN: Okay.

THE COURT: -- I'm not going to do anything more.

Next page, and that's the top of page 10, and it has 

to do with the exception for the various California agencies. 

It says the agency -- "No California agency shall be included 

in the wildfire claimant, and the claims of any California 

State agency may be submitted utilizing the standard claim". 

Is maybe rather than must be? Is there a difference, or do you 

care?

MR. KAROTKIN: No, I don't care.

THE COURT: Well, I mean, the fact is "must be" seems 

to be more --

MR. KAROTKIN: I know.

THE COURT: -- consistent with what we're requiring. 

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But that doesn't mean it wouldn't -- maybe -- I don't feel 

strongly. I just want your opinion on it.

MR. KAROTKIN: This, again, was language they 

requested and --

THE COURT: Okay.

MR. KAROTKIN: -- we've accommodated them.

THE COURT: Then I'll withdraw my comment.

On paragraph 6, you say, except for a wildfire proof 

of claim submitted by the U.S. or any agency, the supporting 

documentation submitted in connection with wildfire proof of 

claim, et cetera, is treated as -- shall remain confidential. 

But is that true? In other words, what -- wait one second. 

Let me just -- let me make sure I'm clear on this.

Yeah, I think you're excepting the California and 

State and U.S. government, so you're saying, for any wildfire 

proof of claim, supporting documentation shall remain 

confidential. But it won't be confidential if it's supporting 

a claim. So how will it be confidential if a --

MR. KAROTKIN: It would --

THE COURT: -- claimant includes it?

MR. KAROTKIN: Well, what we've provided is to the 

extent, for an example, that a wildfire proof of claimant 

submits medical records or things like that. We thought it 

would be appropriate to maintain the confidentiality --

THE COURT: Yeah, but --

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MR. KAROTKIN: -- of that.

THE COURT: -- but how do you -- how do you assure it? 

In other words, suppose --

MR. KAROTKIN: Well, Prime Clerk would have that 

information.

THE COURT: I know, but what if a claimant takes the 

standard wildfire proof of claim and attaches something that is 

personal and files it? What happens? How does it --

MR. KAROTKIN: That will be filed with Prime Clerk.

THE COURT: Well, maybe. Maybe it'll be filed in 

Chico at the --

MR. KAROTKIN: But ultimately, it will get to Prime 

Clerk.

THE COURT: Okay. So what does Prime Clerk do with 

the attachment to the proof of claim? In other words -- in 

other words, look. I understand the issue. And you, in your 

original form, wanted more stuff, and TCC wanted less stuff. 

And the U.S. Trustee weighed in on it, and we are where we are. 

My point is when you say, "Shall remain confidential", invites, 

well, what if it's not confidential to begin with?

So again, I'll take the hypothetical. Here's my proof 

of claim. Rightly or wrongly, I attached my medical records, 

and I hand it over to Prime Clerk. Does Prime Clerk extract it 

out of the proof of claim? I mean, I'm not so sure that's a 

good practice. So what is the -- what's the result?

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MR. KAROTKIN: I think they could do that. But Your 

Honor, look. As far as we're concerned, we're happy to 

eliminate this.

THE COURT: Again, like so many of the other things, I 

just want you to think about it and figure --

MR. KAROTKIN: Okay.

THE COURT: -- out what the better thing to do is. I 

don't want, any more than you want, individuals to be spreading 

on the public record things that they don't need to do. And it 

has nothing to do with whether somebody will have an objection 

to claim or whether the -- if the phony claim. I mean, the 

fact of the matter is we know there might be phony claims in 

this case. But even phony claims, the question is what's 

confidential; what isn't.

So it seems to me that, perhaps, the more correct 

thing to do is to warn the claimant not to include confidential 

things, so we don't require it. So again, if I'm the victim, 

and I was at the Camp Fire, and I lost my home, and I say, 

well, I'm a victim of the Camp Fire, and I lost my home, and I 

suffered damages of a million dollars; here's my proof of 

claim, that seems like it's proper.

But if I attach my medical records, it's part of the 

proof of claim. And I don't believe that we can suddenly make 

them unconfidential. I --

MR. KAROTKIN: Well, the other way to address it is 

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just to notify people, to the extent they include information, 

it will not be maintained confidential.

THE COURT: Right. In other words, something in this 

language or in the proof of claim form --

MR. KAROTKIN: Right.

THE COURT: -- or perhaps more. So whatever we talk 

about that, okay.

Again, in this same language, in same paragraph 6, you 

say that the information will be provided on a confidential and 

professionalized-only basis to counsel for the debtors. And 

don't you think that should also include financial advisors 

and --

MR. KAROTKIN: Well, I think the --

THE COURT: -- like we've done elsewhere? I mean, I think that 

language shows up elsewhere for --

MR. KAROTKIN: Okay. I think that based on your prior 

comment we'll probably eliminate this anyway.

THE COURT: Okay. The last comment, and on this page 

it's at the end of page 7, I think this might be wishful 

thinking, but what's stated in here is that: "Failure to 

comply shall not be treated by the creditor", et cetera, et 

cetera. Wait a minute. Let me rephrase that. 

Oh, yes. The phrase, "for purposes of voting and 

distribution with respect to any Chapter 11 plan or plans that 

may be filed", I think you mean confirmed.

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MR. KAROTKIN: Yes.

THE COURT: Not filed, because somebody might be 

filing a claim. All right. Whatever.

MR. KAROTKIN: Yes, sir. 

THE COURT: Now, maybe -- all right. I have a comment 

on page 11. And I must have missed something here, so please 

tell me if I missed it, and that has to do on paragraph 9 at 

the bottom of page 11, it says: "The Wildfire Claim Bar Date 

Notice.", "ninety-five days prior", et cetera, "debtor will 

cause to be mailed to Known Wildfire Claimants at the address 

for their attorney of record". 

And where is it that they will also be filed and 

mailed to the claimants? Did I miss that, that the claimant

who has an attorney of record isn't going to get the claim? 

And I thought you said earlier they are going to. So maybe I 

missed it or maybe there's just a drafting glitch.

MR. KAROTKIN: They will get it.

THE COURT: Well, that's what I thought.

MR. KAROTKIN: Yes.

THE COURT: So, I mean, think of the attorneys who 

have been active in the case. You know who the individual 

attorneys for certain claimants are. They are going to get 

them, but their clients are going to get the notice also, 

right? This is clarified?

MR. KAROTKIN: No, no.

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THE COURT: Let's take Mr. Singleton as an example.

MR. KAROTKIN: Mr. Singleton will get the notice.

THE COURT: He represents a lot of the victims.

MR. KAROTKIN: Yes.

THE COURT: But aren't those victims also getting the 

notice?

MR. KAROTKIN: That was not the intent, no.

THE COURT: No?

MR. KAROTKIN: No.

THE COURT: Why not?

MR. KAROTKIN: Because he's the attorney of record. 

THE COURT: I know. 

MR. KAROTKIN: He's representing them.

THE COURT: But what if the day before one of his 

clients discharges him?

MR. KAROTKIN: But that's the address we -- that's, I 

believe, the address we have for those people. Hum?

THE COURT: But if you have addresses --

MR. KAROTKIN: No, no. The address we have for those 

people is through their attorney.

THE COURT: If you have an address for a claimant who 

has an attorney --

MR. KAROTKIN: Yes. If they have it -- if we have an 

address, they will get it. And we can clarify that.

THE COURT: Well, are you clarifying that? Because --

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MR. KAROTKIN: Yes.

THE COURT: Just -- well, the gentleman -- I can't 

keep track of your names. Just say who you are.

MR. GOREN: Matthew Goren, Weil, Gotshal & Manges.

THE COURT: Oh, Mr. Goren, sure. Well, so Claimant 

Smith, represented by Attorney Jones, both will get the notice, 

right?

MR. GOREN: Correct, Your Honor. If we have a known 

address, both will get it, but for many of them we only have 

the attorney of record. That would go to the attorney of 

record.

THE COURT: Okay. But I don't think the language --

MR. GOREN: We can clarify that language.

THE COURT: I don't think the order, the way it reads, 

is clear.

MR. KAROTKIN: We'll clarify that.

THE COURT: Okay. Thank you. 

Okay. Okay. In paragraph 13 I had a number of 

questions about the frequency, but we've already talked about 

that. You've clarified that, so I don't need to go through 

that again.

There seemed to be a slight inconsistency in some 

terminology. Let me just make sure. I mean, I hate to be 

nitpicking, but I guess I am being. One second. 

Yes. Look on page 12. Lines 18 and 19 make reference 

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again to the "Bar Date" in capitalized terms, but on line 26 it 

makes reference to the "Bar Date Notice". And I wanted to make 

sure we're consistent with the -- the title of paragraph 9 on 

page 11 is the "Wildfire Claim Bar Date Notice", and then I see 

the phrase, "Bar Date Notice". And again, just be -- I just 

ask that you be consistent with the terminology on that.

MR. KAROTKIN: Sure.

THE COURT: I don't need anything further from you 

now.

So at the risk of belaboring this, I'm going to make a 

few more comments about forms, and you can tell me that they've 

been resolved.

MR. KAROTKIN: Sure.

THE COURT: First of all, am I correct, Form A-1, 

which is what we call the official form, except for putting in 

the name and the case numbers, this is the actual official 

form, right? The text of the official form.

MR. KAROTKIN: Yes, sir. 

THE COURT: Okay. So what would you consider about 

putting a footer on A-1 to say, "not to be used for wildfire 

claims or wildfire subrogation"?

MR. KAROTKIN: I'm sorry. I'm not -- where are you?

THE COURT: I'm on page 1 of official form 410, which 

is your Exhibit A-1, which is what we're calling the general 

claim form. I'm asking you if you think it would be 

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constructive to have a footer, at least on the first page if 

not every page, that not to be used for wildfire claims or 

wildfire subrogation claims?

MR. KAROTKIN: Sure.

THE COURT: And I'm not adamant about it. I want your 

thoughts on it. So putting it into this category of you think 

about it, talk to whomever you want to talk about it, and if 

you do it, fine. 

MR. KAROTKIN: Okay. 

THE COURT: I won't give you any brownie points, but 

if you don't do it, I won't criticize you either. I just raise 

the question.

MR. KAROTKIN: Okay. 

THE COURT: And then -- okay. So I didn't have any 

other questions about that form.

On the wildfire related form, did you and the TCC 

agree on what the title is going to be? Because I raised the 

question in my order of yesterday that says that you're using 

two different forms, right?

MR. KAROTKIN: May I approach?

THE COURT: Yes. Wildfire related.

MR. KAROTKIN: So I think that --

THE COURT: Yes, okay.

MR. KAROTKIN: The only outstanding issues between the 

debtors and the TCC with respect to the form, if you look at 

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the first page, which is highlighted in yellow --

THE COURT: Right. The title.

MR. KAROTKIN: The title. And then if you turn, Your 

Honor, to page -- in the instructions, the first page of the 

instructions, it's highlighted in yellow for you as well.

THE COURT: Okay. 

MR. KAROTKIN: Okay. So the only issue is on the 

first page whether it's fire claim -- fire related -- fire --

THE COURT: Fire --

MR. KAROTKIN: Fire claim.

THE COURT: Fire claim --

MR. KAROTKIN: -- or wildfire related.

THE COURT: -- or wildfire related. It doesn't matter 

to me. But have you agreed to call it wildfire related?

MR. KAROTKIN: No.

THE COURT: Oh. Do I have to decide?

MR. KAROTKIN: I think we're requesting "wildfire 

related", and they want "fire claim".

THE COURT: Do I have to make this decision?

MR. KAROTKIN: No. You don't have to make that 

decision. We can resolve that, okay?

THE COURT: Okay. 

MR. KAROTKIN: And then the only other issue is again, 

as on page 1 of the instructions, we didn't think it would be 

appropriate for the editorializing in that paragraph, so our

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language is the language that has not been stricken.

THE COURT: In the instructions?

MR. KAROTKIN: Correct.

THE COURT: Okay. Let's stick with the form for a 

minute.

MR. KAROTKIN: Sure.

THE COURT: Did you resolve the question that was 

still open about the TCC's question number 2 in part 1, which I 

said I thought was okay, was proper? In other words, that was 

where they put in the box for are you filing on behalf of your 

family?

MR. KAROTKIN: We've included that.

THE COURT: Oh, you did? Okay. Well, that was my 

question.

MR. KAROTKIN: Yes.

THE COURT: Okay.

MR. KAROTKIN: No. What I'm saying is we've -- this, 

what you're looking at, has been agreed to except for the two

highlighted sections.

THE COURT: Yes, but I haven't looked at them. You 

just handed them to me. 

MR. KAROTKIN: Okay. 

THE COURT: So it was on my question, so --

MR. KAROTKIN: So yes, we included that.

THE COURT: Okay. All right. So are there other 

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changes in the form of the proof of claim so -- that you've 

made they agreed to that I --

MR. KAROTKIN: I don't --

THE COURT: Well, I raise -- I raise the question. 

This is really actually on the form. Part 3 is where there was 

reference to the Ghost Ship fire in 2016, which raises that 

questions that I raised before about --

MR. KAROTKIN: I believe that's in here.

THE COURT: -- terminology. And that was in there. 

It's in there all along, but that was the point that --

MR. KAROTKIN: Yes.

THE COURT: -- needed to be clarified in terms of the 

language, and I had a little bit of a thought about it is --

never mind. I won't tell you what my thought was.

MR. KAROTKIN: I don't think there are any substantive 

changes. 

THE COURT: Okay. Let me look at the --

MR. KAROTKIN: Is that --

Eric, you -- right?

MR. GOREN: No, actually there's one at 11.

THE COURT: Which question?

(Counsel confer.)

THE COURT: What's the question?

MR. GOODMAN: I can wait, or I can come up now if you 

want.

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THE COURT: Well, it's just a question about this 

form?

MR. GOODMAN: Yes.

THE COURT: Just tell me what it is.

MR. GOODMAN: Oh, sure. Can you hear me from here?

THE COURT: Yes.

MR. GOODMAN: Does it work?

THE COURT: Just stand in my corner.

MR. GOODMAN: If you go to paragraph --

THE COURT: You're Mr. Goodman, right?

MR. GOODMAN: Eric Goodman, yes.

THE COURT: Okay. 

MR. GOODMAN: Baker & Hostetler, here on behalf of 

the --

THE COURT: Never mind. Okay. 

MR. GOODMAN: -- official committee of tort claimants. 

Paragraph 11, there's a reference here to how much is the 

claim.

THE COURT: Yes. Right. And what's the -- did you 

both --

MR. GOODMAN: We had agreed to include a line with the 

dollar amount so that our claimants would have the option.

THE COURT: I think I picked that up also? Didn't I 

see I agreed with you on that?

MR. GOODMAN: Yes. And the only difference, I think, 

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is our boxes, first you would check the to be determined amount 

according to proof, or if you felt that you could put a claim 

amount down, that you would, in the line, put in the amount as 

optional. I can't tell from this redline exactly what the 

clean version looks like.

MR. KAROTKIN: It's two boxes.

THE COURT: It's two boxes?

MR. GOODMAN: Yes. I think the -- this is a very 

technical issue, but --

THE COURT: I understand.

MR. GOODMAN: -- they're using the language unknown, 

to be determined at a later date. They had originally used the 

term or the word unknown, which to me is ambiguous. It could 

mean incapable of being known or unknown at this time, which is 

why we preferred the language that, sort of, had the future 

context that it would be determined in the future. 

THE COURT: Well, but then the question is who does 

the determining? So again, let's say I'm the claimant. I 

don't have a lawyer. I'm just reeling from all this, and I 

write down a million dollars, because I don't know. What are 

you -- I mean, who's going to determine it? 

And people, you know, under traditional pleadings you 

don't have to put in an exact amount. Obviously if you're a 

claimant who has already settled with the company but have not 

been paid that's easy, because they've got a finite liquidated 

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number. If you're a victim who hasn't even figured out how to 

protect your interest, you don't know. 

So I mean, to me the difference between "unknown" and 

"unknown, to be determined at a later date", it's six of one,

half a dozen of the other.

MR. GOODMAN: No, I think that the language here, I 

just can't tell from this redline document that I was just 

handed, is the option --

If you guys can clarify the record that you're either 

checking "unknown, to be determined at a later date", you would 

check that box, or the other option would be you would list a

dollar amount.

MR. KAROTKIN: Yes.

THE COURT: Well, Mr. Karotkin, do you care? I mean, 

can --

MR. KAROTKIN: I thought that we had agreed that this 

language was fine.

THE COURT: Which language? 

MR. KAROTKIN: It says --

THE COURT: Just the word "unknown" or the "unknown, 

to be determined at a later -- "

MR. KAROTKIN: "Unknown, to be determined at a later 

date". I don't care if you want to just say "unknown". 

Whatever you --

THE COURT: Well, unknown is fairly standard language 

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--

MR. KAROTKIN: That's fine.

THE COURT: -- to use on schedules and statements and 

--

MR. GOODMAN: Look, Your Honor, we just tried to 

accommodate the TCC.

THE COURT: Are you okay with this then, though?

MR. GOODMAN: My preference, actually, is for 

"unknown, to be determined at a later date".

THE COURT: But again, I'll ask the question then. 

Who is going to determine it? The claimant? The Court? The 

debtor on an objection? I mean, all I'm asking is to make this 

user friendly You and I know what it means. What does it mean 

to an unsophisticated victim of a fire? 

MR. GOODMAN: Again, I think that's why having the "to 

be determined at a later date" is more helpful to an 

unrepresented fire victim, because they would know by checking 

the box that it's something that would be determined in the 

future.

THE COURT: Okay. 

MR. GOODMAN: That's all.

THE COURT: All right. Give it to them, Mr. Karotkin.

MR. KAROTKIN: No, we already did.

THE COURT: Okay. Give it again.

MR. GOODMAN: Okay. 

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THE COURT: Okay. On the instructions I had a 

question for you more than an a -- more than something. Yes. 

So you have gone the round. You've accepted, I take it, the 

TCC suggestion in the instruction, the very first bullet point, 

fill in the information as of the date the claim form is filed. 

That changes what you previously had in there as January 29th. 

Am I accept --Do I read this correctly? You have agreed to the 

latter?

MR. KAROTKIN: Yes.

THE COURT: I mean, to the former, their language? 

MR. KAROTKIN: Yes. Yes.

THE COURT: Okay. I think that's the right result. 

And okay. So you want me to look at -- let me read 

this.

Well, Mr. Karotkin, I'm a little confused by the 

yellow that you showed me on this form.

MR. KAROTKIN: Okay. 

THE COURT: Because I don't know what I'm --

MR. KAROTKIN: Okay. 

THE COURT: -- what you want and what's in.

MR. KAROTKIN: Let me explain --

THE COURT: Yes.

MR. KAROTKIN: -- the way we think this should read. 

Okay?

THE COURT: Yes. Okay. 

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MR. KAROTKIN: The first sentence: "You may, but are 

not required, to attach supporting documents to this form".

THE COURT: Right.

MR. KAROTKIN: Period. Then if you drop down below 

the redline language, it says: 

"Supporting documents will be gathered, maintained, 

and provided at a later date as instructed by the Court. If 

you do attach documents, you should attach redacted documents. 

See the definition of redaction of information below. Do not 

attach original documents, because attachments may be destroyed 

after scanning." 

That's what we are suggesting, rather than the 

stricken language.

THE COURT: Well, but remember, though, that I hadn't 

exactly indicated if it's confidential, it may not stay 

confidential.

MR. KAROTKIN: Well, I know that. I realize that.

THE COURT: Okay. Okay. 

Mr. Goodman, is it important to you to keep this other 

language in there?

MR. GOODMAN: Yes, it is, Your Honor. Again, it is --

THE COURT: And why is that?

MR. GOODMAN: Coming at it from the perspective of an 

unrepresented fire victim looking at this sentence, we wanted 

to, sort of, give them comfort that, you know, by not including 

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supporting documentation with the form that was, you know, 

acceptable at this stage of the case, and to provide them, sort 

of, a reason or a rationale as to why that would not be the 

expectation at this point in time. 

THE COURT: No, I --

MR. GOODMAN: We're just trying to make it more reader 

friendly and less bankruptcy-esque.

MR. KAROTKIN: Your Honor, we tried to make it short 

and simple. The first sentence is pretty clear. 

THE COURT: I mean, I think the debtors' got the more 

persuasive argument here. I think it's got to be short and 

simple. And there's nothing wrong with community outreach, or 

the committee, or committee members, or individual people 

spinning all sorts of things. But to me, this is not relevant 

to the function of this form, so I'm going to stick with the 

debtors' view on that one language. 

MR. KAROTKIN: Okay. So --

THE COURT: And then, on the same form now, you're 

going to make a clarification on the confirmation that a 

claim's been filed. So this is the thing that --

MR. KAROTKIN: Yeah, yes. 

THE COURT: -- you talked before --

MR. KAROTKIN: Yes. 

THE COURT: -- so that needs to be changed. 

MR. KAROTKIN: Of course. 

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THE COURT: And then, in the same page where it says 

understand the terms used in this form, this is where I'm back 

to -- remember, I asked you either to find the bar date but in 

the alternative, where it says claim it says a creditor's right 

to receive payments that are owed on the date the debtor filed 

for bankruptcy. Stick in January 29th, 2019. 

MR. KAROTKIN: Yes, sir.

THE COURT: Okay?

MR. KAROTKIN: Yep. 

THE COURT: Okay. Let me see if I got any other 

questions. Okay. Well, I had -- okay, I had just a couple of 

minor questions on the subrogation claim I'll leave to -- you 

know, all the things that we've talked about before to the 

extent that they have any conforming changes, and that is 

simply the -- right in the proof claim for the subrogation 

insurers in the second sentence, in the little shaded box. It 

says include the aggregate total estimated amount of all 

insurance subrogation claims, and then the words across all 

individual policies. I just don't know quite what that phrase 

means, across all individual policies. If the lawyers 

representing insurance companies --

MR. KAROTKIN: Where?

THE COURT: -- are comfortable with that, I guess I 

should be, but I don't know what it means. 

MR. KAROTKIN: Yeah. This is -- this form was heavily 

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negotiated with the subro claimants. 

THE COURT: Okay. 

MR. KAROTKIN: So I think this is what everyone was 

looking for, and I think everyone understands it. 

THE COURT: Except me. That's okay. No, I kind of 

know. 

MR. KAROTKIN: Except me.

THE COURT: That's fine. I can take your --

MR. KAROTKIN: Okay. 

THE COURT: There are no changes necessary.

MR. KAROTKIN: Okay. 

THE COURT: And I'll accept your statement. Okay, 

hold on. I'm almost done. 

Okay. I have a couple of questions on the bar date 

notice. And again, Mr. Karotkin, if there's already been a 

resolution of some of these things, I apologize for beating it 

to death, but here are my few questions. We've already talked 

about the bar date and we'll -- I'll make a decision before the 

end of the hearing on what the date's got to be. 

MR. KAROTKIN: Okay. 

THE COURT: Yeah. On page 3 of the bar date notice, 

this again, goes to the discussion of the general claims, the 

standard claims. And you said before that there -- that the 

standard proof of claim being sent out to the claimants is 

going to be personalized, but the form doesn't tell me where 

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it's going to be. So the -- on page 3, it says the standard 

proof of claim also sets forth the amount of your claim as 

listed in the schedules. But I didn't see where that's going 

to be. Can you show me where that will be in the official 

form -- I mean, claims form, Form 401? 

Again, if you don't know exactly, that's okay. But I 

don't -- I didn't see where the recipient would find it. 

MR. KAROTKIN: I think -- and Mr. Weissmann can 

probably answer this question. I think when they customized 

the form, there is a box which would reflect the scheduled 

amount. 

THE COURT: Can you answer that for me, Mr. Weissberg 

(sic)? Is that right? The form is going to say -- so if John 

Smith is, not a tort victim, but he's a contractual 

counterparty to a PPA -- well, that's a poor example. That's a 

poor example. He is somebody who is owed money for goods and 

services. It's going to say it on the top or what?

MR. WEISSMANN: There will be an insert, Schedule D, 

E, and F. It will say their name, their address, and the 

scheduled claim amount so they have that information and they 

can submit it. For Schedule G, it will say you are contract 

counterparty. If you believe you are owed money, file the 

claim.

THE COURT: Okay. But leave out the counterparty. If 

Mr. Smith gets a thing from you that says he's owed 1,000 

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dollars, then he doesn't have to do anything, right?

MR. WEISSMANN: Right. 

THE COURT: For his 1,000 dollars. Does it say that?

MR. WEISSMANN: Yes. If you disagree, you must 

submit --

THE COURT: Okay. So -- but it -- so we're clear, 

he's getting this information on the proof of claim form. So 

the proof of claim form, in a sense, says if you agree with 

this you can throw this in the garbage can. 

MR. WEISSMANN: Yes. 

THE COURT: If you don't agree with it, you got to 

complete it and send it back. 

MR. WEISSMANN: That's correct. 

THE COURT: It says something to that effect?

MR. WEISSMANN: That is correct.

THE COURT: Okay. All right. One second, please. 

MR. KAROTKIN: We'll obviously make conforming changes 

to this to the extent of other items you had raised. 

THE COURT: Yeah, it may -- the proof of claim form --

I mean, excuse me, the notice for the wildfire claimant, I just 

had that same comment that I mentioned before about not listing 

the Ghost Ship fire in 2016 just to make sure that that's in 

there, because again, I realize the Ghost Ship fire is a 

discrete and perhaps some much smaller population of claimants. 

But they have been treated separately so -- I mean, treated 

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frequently and often in this form. So the legal notice needs 

to make sure --

MR. KAROTKIN: Yep. 

THE COURT: -- that they're mentioned in there. 

Again --

MR. KAROTKIN: I believe it's already in there. 

MR. WEISSMANN: Ghost Ship, yeah. It's in there.

THE COURT: Yeah.

MR. KAROTKIN: But we'll make sure. 

THE COURT: Okay. So, again, on the wildfire proof of 

claim -- I'm sorry, the wildfire notice -- not proof of claim, 

the notice -- at page 4, we have that same -- yeah, we have 

that same question that I raised before at line 16 about it 

must be signed by the claimant.

MR. KAROTKIN: Yes. We'll make the same conformity.

THE COURT: Yeah, okay. Well, just being -- to use 

one of the phrases that a number of you are using, to avoid all 

doubt. Isn't that the phrase that some of you --

MR. KAROTKIN: For the avoidance of doubt, yeah. 

THE COURT: Yeah. The avoidance of doubt. That's 

going to be the watch word here. The avoidance of doubt. 

Okay. Final question, just for my information, the notice 

going to the customer, is that intentionally not going to have 

a caption? It's just going to be just a form? I mean, we 

probably have a lot of customers here in the room. 

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MR. KAROTKIN: This would be on PG&E letterhead, in 

addition to --

THE COURT: Oh, okay. So they're going to get it to 

the customer --

MR. KAROTKIN: This is just for the customers, which 

will be on PG&E letterhead. 

THE COURT: I mean, a customer who is a tort victim, 

or a customer who is a contractual party in contract, they're 

going to be treated a number of different ways. 

MR. KAROTKIN: Correct. 

THE COURT: But a customer who is just a customer, is 

going to get not a legal pleading, but rather this --

MR. KAROTKIN: Correct. 

THE COURT: -- notice that says here we're telling you 

this, and if you have a proof of claim -- I mean, if you have a 

claim, then you have to do it, right?

MR. KAROTKIN: Correct. 

THE COURT: Okay. Again, I'm not going to second 

guess you on that. Okay. That concludes my comments about the 

forms and the orders. I don't know whether you would like to 

take a break, or want to hear from other counsel now, or what 

would you prefer to do? 

You know, we do have to talk about some other big 

issues, and it's ten after 11. We've been going for almost two 

hours. We can take a break or we can --

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MR. KAROTKIN: Whatever your pleasure. 

THE COURT: No, your pleasure. I'm --

MR. KAROTKIN: I'm happy to --

THE COURT: I just live here. 

MR. KAROTKIN: I feel like I do, too. 

THE COURT: Well, in that case, I have to point out 

something my courtroom deputy said. Don't say anything to him. 

I hope you notice the --

MR. KAROTKIN: I noticed. 

THE COURT: -- the memorial glass. 

MR. KAROTKIN: I did. 

THE COURT: All --

MR. KAROTKIN: I pointed it out to several people when 

I walked in.

THE COURT: All right. If any of you go out the door 

today and you bash your nose on the door out there with the 

seal on it, that's the Karotkin memorial seal --

MR. KAROTKIN: I appreciate that. 

THE COURT: -- etched in blood.

MR. KAROTKIN: I do. Yes. And black and blue. Black 

and blue for, like, a week and a half. 

THE COURT: Yeah. You did sign the release, though, 

didn't you?

MR. KAROTKIN: Yes. Your courtroom deputy made me do 

that as I left the courtroom that day. 

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THE COURT: What's your pleasure?

MR. KAROTKIN: Okay. I think the subro lawyers want 

to say something. But we're happy to continue. 

THE COURT: Okay. Subro. Subro lawyers.

MR. FOREMAN: Good morning, Your Honor. 

THE COURT: Thank you for your time and effort, Mr. 

Karotkin, and everybody that worked on all these details again. 

I understand they are getting so stringent about certain 

things, but it's a lot of work and I appreciate it. Yes?

MR. FOREMAN: Good morning, Your Honor. Daniel 

Foreman, Willke, Farr and Gallagher on behalf of the ad hoc of 

the subrogation claims. Very quickly, there was a back and 

forth about the ability to submit supporting documentation on a 

confidential basis, specifically to our claimants. There's an 

attachment contemplated in our proof of claim form that the 

debtors have agreed to receive on a confidential basis, so 

however that language is changed in the order, we don't want to 

override that process. 

THE COURT: Well, what do you think about it? Don't 

you think it should -- therefore, should not be on the proof of 

claim, should it?

MR. FOREMAN: Well, I don't think it would be attached 

to the proof of claim. I think it would be -- there's a thirty 

day period after the proof of claim is submitted where --

THE COURT: Okay. 

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MR. FOREMAN: -- the debtors want more information 

from us. We're willing to give it, but the way we're willing 

to give it is through this confidential professional --

THE COURT: No, that's fine. And I agree with you. 

MR. FOREMAN: Okay. 

THE COURT: I think -- my concern is I don't want to 

have somebody misled and think they have to disclose 

confidential stuff and then it's, kind of, hard to unring the 

bell. 

MR. FOREMAN: Understood, Your Honor. 

THE COURT: And Prime Clerk shouldn't be charged with 

that duty. That's all.

MR. FOREMAN: Understood, Your Honor. And we'll make 

sure that's done very carefully --

THE COURT: Okay. 

MR. FOREMAN: -- on our --

THE COURT: Okay. Thank you. 

MR. FOREMAN: Thank you. 

THE COURT: Anyone else want to be heard now? Mr. 

Pascuzzi?

MR. PASCUZZI: Yes, Your Honor. 

THE COURT: Morning. 

MR. PASCUZZI: Thank you. Paul Pascuzzi, Felderstein,

Fitzgerald, Willoughby & Pascuzzi, co-counsel with the 

California Attorney General's Office. We represent numerous 

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state agencies, California state agencies. 

THE COURT: I know who they are. 

MR. PASCUZZI: They're on our pleading. They change 

depending on the pleading, just to --

THE COURT: They change their names now and then, too. 

MR. PASCUZZI: Your Honor, just going through -- since 

you went through your comments, we have a few comments based on 

your comments and now might be the good time to raise them. 

THE COURT: Okay. 

MR. PASCUZZI: Your Honor, with regard to footnote 2 

in the order, you mentioned adding 2016 to the definition of 

Northern California wildfires and we had requested that as 

well. So we agree with that. But also, there were fires in 

2014, so --

THE COURT: And that's what I didn't remember, that. 

MR. PASCUZZI: Yeah. We had asked for that and we 

didn't hear back from the debtors. I don't know why there 

would be any opposition to that, so that's an additional 

request. 

THE COURT: Is that -- I mean, I wonder if we're 

getting into a slippery slope, if it would be better just to 

take the years out and let the forms speak for themselves. 

What do you think, Mr. Karotkin, or Mr. Goren?

MR. KAROTKIN: It says including without limitation, 

so I'm not sure I understand the concern. But I'm not aware of 

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the 2014 fires that --

THE COURT: Well --

MR. PASCUZZI: Your Honor, there are 2014 CAL FIRE as 

part of our client list, so they know. Your Honor, the problem 

is there's two definitions of Northern California wildfires in 

footnote 2. So, the first one says 2015, '17, and '18 and 

it'll be added '16. But then on the back, you've got Northern 

California wildfires include, and they -- you know, there's 

some 2016 fires --

THE COURT: And where is the other place you're 

looking?

MR. PASCUZZI: It's in the same footnote. 

THE COURT: Oh. 

MR. PASCUZZI: There's just two different references. 

THE COURT: Yeah. Yeah, I mean, I think that 

obviously, the major fires that teased so much attention were 

the ones that were ignored. 

MR. KAROTKIN: Your Honor, we can just say --

THE COURT: The Ghost fire is separate. 

MR. KAROTKIN: -- any pre-petition wildfires. Okay?

THE COURT: Again, I want you guys to put your heads 

together and come up with the right thing to do for the people 

that we're doing this for, because the -- we all know what 

we're dealing with. Definitions are important, and I don't 

want the perception to be that somehow the Court or the process 

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is excluding a category of victims. Even if there's only one 

victim, that victim is a victim and should be treated 

accordingly. So, Mr. Pascuzzi, that's fine that you raised it 

and they'll -- Mr. Karotkin and his colleagues will fix it in 

some way. 

And then this is going to change the forms, too. I 

mean, there's going to be some conforming changes to be 

consistent. 

MR. PASCUZZI: The second one, Your Honor, was in 

paragraph 3(O)(12). 

THE COURT: This is on which, the form or the order, 

or what?

MR. PASCUZZI: Of the order. 

THE COURT: Okay. 

MR. PASCUZZI: Your Honor, you had mentioned -- this 

was the exclusion --

THE COURT: Yeah. 

MR. PASCUZZI: -- from needing to file a claim --

THE COURT: Right, right. 

MR. PASCUZZI: -- for a personal injury or property 

damages to the extent they arise from an event that occurred 

after the petition date of January 29. 

THE COURT: Right. 

MR. PASCUZZI: We had raised in our pleading that 

state agencies like CAL FIRE, who have reimbursement costs for 

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dealing with the fires, don't have property damage or personal 

injury type claims. So you had suggested contractual. Our 

issue is statutory. They're statutory based, so --

THE COURT: But they're pre-petition claims, right?

MR. PASCUZZI: They are pre-petition claims, but the 

point of this paragraph is to say that if there's a fire after 

the petition date, these deadlines don't apply to that type of 

claim. 

THE COURT: Well, what do you want to do? I mean, 

what --

MR. PASCUZZI: Well, I would like -- you had suggested 

adding contract claims, and we would suggest adding contract 

claims and statutory claims.

THE COURT: Well, Mr. Karotkin, you were adamant about 

not expanding it, but it seems to me there's no harm here. 

MR. KAROTKIN: Your Honor, I thought you addressed in 

your order yesterday you weren't going to get into whether 

there are future claims or not future claims, or what happens 

with --

THE COURT: No. 

MR. KAROTKIN: -- it post-petition --

THE COURT: I wasn't. I wasn't. And if there is 

another fire in 2019, everybody has to figure out what does 

that mean. But I don't think Mr. Pascuzzi is asking that. 

MR. KAROTKIN: I think he is. 

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THE COURT: Well, do you?

MR. PASCUZZI: Your Honor, I'm asking for 

clarification so that we know what we need to file our claims 

for. And it should be clear.

MR. KAROTKIN: I think Mr. --

MR. PASCUZZI: There should be a clear line. 

MR. KAROTKIN: I think he should answer your question. 

THE COURT: Wait. One at a time. 

MR. PASCUZZI: There should be a clear line, Your 

Honor, and if there is a fire or something that happens after 

the petition date, we'll deal with it. But as far as having to 

file a proof of claim for something, it should only be dealing 

with events that happened prior to the petition. 

THE COURT: Well, let's pretend we have a run-of-themill every day type case. We wouldn't have a discussion. We'd 

have a bar date and the bar date would say what it says. And 

if there was an accident by -- a PG&E truck ran over somebody 

on Golden Gate Avenue on the day after bankruptcy, that would 

not be a pre-petition claim. The issue, I think -- and this 

goes back to something that Mr. Gilliam and others were raising 

before is what if the events have occurred, but it hasn't given 

actual fire? What if the utility has done something 

negligently that sets the stage for a fire? 

The Court and the cases have told us fair 

contemplation, what is and what isn't pre-petition. But I 

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think if we -- I mean, you're also making a good argument that 

Mr. Karotkin made of taking out paragraph 12 and letting the 

law solve the problem for us, right?

MR. PASCUZZI: Well, I am but I'm not, because I think 

there needs to be fair notice to the parties. And I think this 

was a good start. And I think we like the fact that it would 

be limited to things -- events that happened pre-petition, but 

just limiting it to property damage or personal injury was the 

issue. You had indicated wrongful death. I'm just 

indicating --

THE COURT: Well, but I mean, I used wrongful death 

because wrongful death and personal injury always get linked 

together, you know? It really was the broader question of 

something else. Well, again, let's come up with a solution. 

What do you recommend? And then I'll see if --

MR. PASCUZZI: Adding contract and statutory to 

personal injury and property damages. 

THE COURT: So that is a statement of the law. But 

what happens if you have a claim that, in fact, arose 

prepetition but you don't know about it, or you don't -- you 

had the fair contemplation -- let me try a different way. If 

we don't have anything in here, the law tells us that the 

petition date is the pivotal date anyway. The courts have 

talked about fair contemplation. If you couldn't have 

anticipated that you had a claim, you wouldn't be affected. 

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In fact, if the company really is solvent, as many 

people say and really survives, having a post-petition claim is 

probably a better thing to do, right? So the point is if we 

took paragraph 12 out and just said -- or we changed it to say 

this only pertains to claims that arose pre-January 29 --

MR. KAROTKIN: It already says that.

THE COURT: -- it solves the problem, doesn't it, 

right?

MR. PASCUZZI: It does, Your Honor. I mean, we were 

looking for some sort of bright line. It affects issues like 

discharge and plan treatment, and things like that. And if --

THE COURT: Well, I --

MR. PASCUZZI: We were trying to get the debtors to 

agree to draw that line now --

THE COURT: No, but I'm --

MR. PASCUZZI: -- so that we don't have that issue. 

THE COURT: I understand you are. And -- but Mr. 

Karotkin didn't like the suggestion that I include contract, 

and I'm saying to you, what if we take 12 out?

MR. PASCUZZI: I'd prefer it be in because then 

there's clarity. 

THE COURT: Then, what if we say any person who holds 

a claim to the extent that it arises from an event that 

occurred after January 29?

MR. PASCUZZI: That would be fine, too. 

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THE COURT: Without any -- what kind of claim. 

MR. PASCUZZI: That would be fine. 

THE COURT: Live with that?

MR. PASCUZZI: We actually proposed that to the 

debtors. 

THE COURT: Can you live with that?

MR. KAROTKIN: No.

THE COURT: And why not? I mean --

MR. KAROTKIN: Your Honor?

THE COURT: I mean, we do have --

MR. KAROTKIN: Paragraph 12, as you said, is unusual. 

Okay? 

THE COURT: Yeah. Right.

MR. KAROTKIN: The law is the law and that's how, as 

you said, it should be addressed. If you -- this already says 

you have to file the claim if it's a pre-petition claim. Let's 

not decide that now. The notice is clear. You file a prepetition claim. We don't need to clarify anything. The law is 

what it is. This is not an effort for people to bootstrap 

their positions. 

THE COURT: No, it's not. 

MR. KAROTKIN: I suggest we take it out. 

THE COURT: But if you put in there that says this is 

not -- you do not file a proof of claim if it arose after 

January 29th --

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MR. KAROTKIN: Right. We can say you do not have to 

file the claim if it is a post-petition claim. I'm happy to 

say that. Whatever that means, I'm happy to say that. But 

let's not try to parse through every single possibility --

THE COURT: I --

MR. KAROTKIN: -- that could happen. 

THE COURT: I just said arose on or after -- I mean, 

after January 29th. In other words, I think you're agreeing 

with me. If 12 reads any person or entity who holds a claim 

that arises from an event that occurred after January 29th --

MR. KAROTKIN: No, that arises after --

THE COURT: Yeah. 

MR. KAROTKIN: -- January 29th.

THE COURT: Yeah. 

MR. KAROTKIN: Not from an event, but arises after 

January 29th.

THE COURT: Yeah. Well, okay.

MR. KAROTKIN: Or --

THE COURT: All right. And so --

MR. KAROTKIN: Actually, what is more appropriate, 

Your Honor, is either to say nothing, or to say any person who 

has a post-petition claim is not required to file a proof of 

claim by the bar date. 

THE COURT: Mr. Pascuzzi?

MR. KAROTKIN: That's what is correct. 

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MR. PASCUZZI: That doesn't say anything, Your Honor. 

MR. KAROTKIN: Then don't say anything --

MR. PASCUZZI: No, I --

MR. KAROTKIN: -- and don't pre-judge it. They're 

trying to bootstrap their position here and it's not 

appropriate. 

THE COURT: Well, I mean, I -- see, I don't think they 

are trying to bootstrap their position. 

MR. ENGEL: Oh, yeah, but I'm on the same --

THE COURT: One second, Mr. Engel. 

Why are they bootstrapping it if they are better off 

having a post-petition claim? I mean, it seems to me --

MR. KAROTKIN: Then my language is perfect. 

THE COURT: Well, no, but why -- I'm just asking why 

do you call that bootstrapping? To me, a claim that's postpetition is a good thing to have if you have to have one. 

MR. KAROTKIN: Because they're trying to make clear 

it's post-petition today. 

MR. ENGEL: Your Honor? If I may --

THE COURT: Yeah, Mr. Engel?

MR. ENGEL: -- join in this debate? This is one of 

my core concerns. 

THE COURT: Okay. 

MR. ENGEL: And --

THE COURT: Join the --

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MR. ENGEL: -- the answer to the question -- that 

should be asked here is what you said earlier, which is how 

about the ordinary person who doesn't understand what 

postpetition means, right?

THE COURT: Right. 

MR. ENGEL: And I can tell you, because I get these 

questions, there are lots of nonbankruptcy lawyers who have no 

idea about where to draw the line on these issues as to --

THE COURT: There are probably a few bankruptcy 

lawyers that don't either. 

MR. ENGEL: -- remoteness and contingency. And, in 

fact, Judge Posner and Zell said that there is total confusion 

as to what the law is and where you draw --

THE COURT: So what do you suggest?

MR. ENGEL: I'm sorry?

THE COURT: What do you suggest?

MR. ENGEL: Exactly what you proposed. Just say 

events arising after the petition date. That's all we wanted, 

right, Paul?

MR. PASCUZZI: Yes, yes. 

MR. ENGEL: And I think that's understandable to 

people. Now, that doesn't mean that he can't make all the 

arguments that he wants to make in the future about, you know, 

what's pre-petition and what's post-petition. What it tells 

people is they don't have to file a proof of claim now on 

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account of that. We're not prejudging the legal issue. We're 

simply telling people they're not going to get screwed, pardon 

my French, because they didn't file a proof of claim. Right?

THE COURT: Well, but in effect, they are going to get 

screwed, pardon your French, if they should've filed a proof of 

claim and this tells them that they shouldn't. 

MR. ENGEL: Well, but then they've got more time to 

deal with the issue. 

THE COURT: No. No, on the contrary, they have 

October --

MR. ENGEL: Well, arises after is an event.

THE COURT: But that's -- again, that assumes that 

they know what that means. The person who suffered the fire 

doesn't know, you know, I have a right to pursue a claim. 

MR. ENGEL: You're --

THE COURT: Think about the people that suffer torts 

or classic nonpersonal injury type case, or people that suffer 

racial or employment discrimination, and they have no idea that 

it's even happening until years later. 

MR. ENGEL: And there's a fair contemplation case on 

that, great point.

THE COURT: Fair contemplation case, right. 

MR. ENGEL: Yes, there is. 

THE COURT: So --

MR. ENGEL: But we can only do the best we can do and 

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you're making an improvement, and taking it out would not be an 

improvement. It would be a detriment and I think many, on my 

side --

THE COURT: Anyone else want to be heard --

MR. ENGEL: -- join in that. 

THE COURT: -- on the subject? I mean, I'm going to 

make a decision, but I'm not going to let it go -- the subject 

go if anyone else wants to weigh in on it, not okay? 

Okay, Mr. Karotkin, I'm going to stick with Mr. Engel 

and Mr. Pascuzzi's suggestion and make it consistent with what 

they say, and not worry about it. And I think that it's not 

going to bootstrap anything. It might make it clear, so just 

please make that language consistent with what we just talked 

about. 

MR. KAROTKIN: I'm sorry. What is the language?

THE COURT: Say it again, Mr. Engel. 

MR. PASCUZZI: Well, it's --

THE COURT: Go ahead. 

MR. PASCUZZI: This is Paul Pascuzzi. It's deleting 

for personal injury or property damage. So any person or 

entity who --

THE COURT: Well, we don't need the solely, right? To 

the extent such claim arises from an event that occurred 

after --

MR. KAROTKIN: It should be solely. 

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MR. PASCUZZI: Solely is fine with us, Your Honor.

THE COURT: All right. Solely to the extent that such 

claim arises from an event that occurred -- well, we don't have 

to say event that occurred. Arises after January 29th. 

MR. PASCUZZI: No. The --

MR. KAROTKIN: Well, that's fine.

MR. ENGEL: That's fine, Your Honor. People need to 

know there's an event, a trigger, right? That's what they're 

looking for. The --

MR. KAROTKIN: Your Honor, we're fine with your 

language. 

THE COURT: Compromise. We got it.

MR. PASCUZZI: Is event in there or not? No?

THE COURT: Huh? 

MR. PASCUZZI: No event or event?

THE COURT: No, event.

MR. ENGEL: Event, good.

MR. PASCUZZI: Okay. 

MR. ENGEL: Thank you. 

MR. PASCUZZI: Your Honor, just two other points. You 

mentioned on the standard proof of claim form to have a 

footnote that says it doesn't apply to the wildfire --

THE COURT: In the official -- in form -- the --

MR. PASCUZZI: -- in the form itself, yeah. 

(Counsel confer.)

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THE COURT: Wait. Mr. Engel, if you want to have a 

sidebar, we got to wait. I just can't pick it up on the record 

here. That's all. 

MR. ENGEL: Forgive me, Your Honor. I'm sorry. 

THE COURT: Okay. Mr. Pascuzzi?

MR. PASCUZZI: Yes. You had made a comment on the 

form. 

THE COURT: I'd suggested a footer, that's all. 

MR. PASCUZZI: Yeah, a footnote that says don't use 

this for a wildfire --

THE COURT: No, not a footnote. A footer. 

MR. PASCUZZI: Oh. 

THE COURT: Yeah. 

MR. PASCUZZI: That says don't use --

THE COURT: Yeah. 

MR. PASCUZZI: -- for a wildfire. So in the order, in 

paragraph 5, they're carving out agencies -- governmental units 

of the State of California. So that could be confusing to some 

state agencies. As long as the order governs, that's fine. 

But it would cause a little bit of confusion. You could put in 

there except as otherwise provided in the order --

THE COURT: Well, I don't want the footer on the form 

to look like a legal document. I want a victim to say, wait a 

minute, I'm not supposed to file this one. I'm supposed to 

file this one. And if the victim happens to hold a contract 

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claim, he or she will have to file two proofs of claim; one for 

the fire, and one for the contract, right? But the agencies 

can figure out what to do. Right?

MR. PASCUZZI: Okay, Your Honor.

THE COURT: I mean, the agencies aren't asserting 

proofs of claim for wildfire claims, right?

MR. PASCUZZI: They'll be using the regular proof of 

claim form. 

THE COURT: Okay. 

MR. PASCUZZI: And so, adding that in there, there are 

a couple that we know of that do have actual fire type claims, 

but we wanted to use the standard proof of claim form. So 

that's what might cause the confusion. But we'll deal with it, 

Your Honor. 

THE COURT: Okay. 

MR. PASCUZZI: The last point, Your Honor, was there 

are a couple of paragraphs that reserve rights regarding 

executory contracts in the order; paragraphs 15 and 16. I'm 

not really sure why they're in there, but we had -- we have 

looked at Schedule G that the debtors had filed, and there are 

a lot of things on there that are actual orders, and covenants 

that run with the land, things that state agencies deal with 

that are not executory contracts. And we had asked for a 

reservation since they brought it up by adding these paragraphs 

that basically -- that nothing in the order is a waiver of the 

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right to object to any designation that a matter is an 

executory contract. There's similar language in there, Your 

Honor, but they've got, you know, specific things in there; 

contract, program, policy, lease. There's all kinds of things 

listed on Schedule G. 

And so we just want it to say matter. In any event, 

we're reserving our rights to object to any designation on the 

schedules, or in a motion to assume or object.

THE COURT: Well, I mean, but that's what the law lets 

you do, right? And the --

MR. PASCUZZI: It does. But I'm not sure why this 

order even deals with that. If they think it does do something 

with regard to executory contracts, I need to reserve my 

rights. 

THE COURT: Mr. --

MR. GOREN: Your Honor, again, we're happy to take 

this language out. We added it, again, at Mr. Pascuzzi's 

request. So if he wants it out now, we're fine with that. 

THE COURT: So you would take 15 and 16 out?

MR. ENGEL: Well, wait a minute. We asked for that as 

well, Your Honor. 

THE COURT: So if we don't want this to sound like a 

legal document where everybody is reserving everything for 

avoidance of doubt --

MR. PASCUZZI: Your Honor? Specifically, 16 they did 

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put in but we did not ask for that language. We raised the 

issue and they put that language in there to address it. But 

it -- we are reserving our rights to object to any designation 

that a matter on Schedule G or in a motion is -- it's 

actually --

THE COURT: But, Mr. Pascuzzi, my question for you is 

can't you reserve your rights just like you just did?

MR. PASCUZZI: I am reserving our rights right now, 

Your Honor. 

THE COURT: You are reserving your rights?

MR. PASCUZZI: Yes, Your Honor. 

THE COURT: And nobody is going to -- oh I got you --

on you if you come in next year and say hey, this is sudden --

no, I'm sorry, you didn't object to paragraph 15 or 16. 

MR. PASCUZZI: Understood, Your Honor. Thank you. 

THE COURT: And the same with Mr. Engel. Same with 

everybody. 

MR. ENGEL: Okay. Thank you. Your Honor, Larry 

Engel, Sonoma Clean Power Authority and various others that 

signed on to our pleadings or joined in it; mostly CCAs but 

some other governmental units. And that brings me to a quick 

question that comes up in your discussion on the form of order. 

We have an apparent difference between the TCC form of order 

and the PG&E form of order, on a paragraph that you addressed, 

which --

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THE COURT: Well, I never -- I told you earlier. I 

said I never even got to the TCC form. 

MR. ENGEL: Yeah.

THE COURT: I mean, I just couldn't --

MR. ENGEL: Understand and --

THE COURT: I couldn't keep up with it. 

MR. ENGEL: The issue is governmental unit of the 

State of California. That's the language that's in paragraph 5 

for PG&E which is defined as a California state agency. The 

TCC form, which goes to the question of the fire proof of claim 

which was adopted by PG&E from TCC, which fits into their 

order, includes local government agencies. So our view is that 

a governmental unit of the State of California includes cities, 

it includes counties, it includes joint power authorities, like 

CCAs, as well as the state agencies --

THE COURT: Yeah.

MR. ENGEL: -- that Mr. Pascuzzi represents.

THE COURT: Right, it does.

MR. ENGEL: There's an argument that --

THE COURT: I mean, I think it's consistent with --

it's consistent with the code definition. Right, yeah.

MR. ENGEL: Exactly consistent, but limited to people 

located in California. That's what should be -- and that's 

what we understand and hope the scope of this wording is, that 

it does not exclude cities and counties and is simply -- and 

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joint power authorities. It's simply not limited to state 

agencies represented by Mr. Pascuzzi, and there's been a lot of 

debate outside the courtroom over what this means, and I think 

it should be clear that governmental unit means governmental 

unit, and it's located in California. That's all that we need 

there.

THE COURT: Well -- but so you would tweak paragraph 

5, right?

MR. ENGEL: Yeah. And just -- yeah. Say, including 

cities, counties, joint power authorities, and other local 

agencies located in the State of California.

THE COURT: Mr. Goren?

MR. GOREN: Look, the defined term, Your Honor, of 

governmental unit is defined as the term used in the Bankruptcy 

Code. So I don't know that there's a need to go further to 

give color what that definition is.

MR. ENGEL: I'm just look --

MR. GOREN: But if --

THE COURT: Well compare --

MR. ENGEL: It --

MR. GOREN: -- that will resolve this issue, then 

fine.

MR. ENGEL: If he tells me that's what it means --

MR. GOREN: Yes.

MR. ENGEL: -- I accept his word.

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MR. GOREN: That is -- exactly. That's how --

MR. ENGEL: That's great.

MR. GOREN: -- it's defined in the motion, that's how 

it's incorporated into the --

MR. ENGEL: Okay.

MR. GOREN: -- order --

MR. ENGEL: Then --

MR. GOREN: -- and we will make that abundantly clear.

MR. ENGEL: Great.

THE COURT: But I'm unclear. Does that mean you'd 

change paragraph 5 to say governmental units?

MR. GOREN: It does say governmental units -- capital 

G, capital U.

MR. ENGEL: If he interprets it that way, I'm fine.

MR. GOREN: But we will define -- we'll make clear 

that that --

MR. ENGEL: I accept this stipulation on the record --

MR. GOREN: -- is the defined term.

MR. ENGEL: -- that that's what it means. No more 

changes are needed.

THE COURT: Okay. We'll take it.

MR. ENGEL: I can accommodate that. I'll take that. 

And that's sufficient.

The last point I wanted to raise, Your Honor, and I 

appreciate your indulgence here, and this won't just take a 

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second. We -- although it's not noted in Exhibit B, we did 

object on the late filed claim issue. It's very much like your 

informal proof of claim. We did put a big section in our 

papers on this. We believe that the law and late filed claims 

should be what it is. It shouldn't be pre-judged in the 

paragraph that you went through before. And so --

THE COURT: Well, but again, that was paragraph 4, 

right?

MR. ENGEL: Yeah. If you're --

THE COURT: But it did say "to the extent permitted by 

applicable law".

MR. ENGEL: And --

THE COURT: And Mr. Karotkin did --

MR. ENGEL: So --

THE COURT: -- point that out.

MR. ENGEL: It does, but the language -- I'm looking 

at their Exhibit B. It says "for the purposes of voting" --

they're cut out for purposes of voting and distribution. Now, 

that --

THE COURT: You're going too fast for me.

MR. ENGEL: I'm sorry.

THE COURT: I'm looking at paragraph 4 of the PG&E 

proposed order. If you want me to look at the exhibit --

MR. ENGEL: No. It -- paragraph 4. Okay. We'll go 

there, Your Honor.

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THE COURT: Well, the language is very similar. It's 

just that can I only think about one at a time, and so --

MR. ENGEL: I certainly understand the --

THE COURT: And I've made the comment to Mr. Karotkin, 

don't we have to deal with the Ninth Circuit informal proof of 

claim law, and he spoke to -- in response. And I believe that 

I was satisfied that "to the extent permitted by applicable 

law" works. 

MR. ENGEL: Well --

THE COURT: Now, if you think that --

MR. ENGEL: They're two different paragraphs we're 

looking at, Your Honor.

THE COURT: Okay.

MR. ENGEL: That's my confusion. And what I've led 

you into confusion on. If you look at paragraph 7, Your Honor.

THE COURT: Okay.

MR. ENGEL: That's the paragraph. You were discussing 

paragraph 4 for the informal proofs of claim. I'm talking 

about late claims, which I believe are dealt with in paragraph 

7. And what that says is that there shall not be treated as a 

creditor, line 17, for purposes of voting and distribution. 

That, in effect, pre-judges the late claim law, and we think 

that the law should be what it is, as you said earlier on the 

informal proofs of claim.

THE COURT: Well, maybe, could we answer it this way 

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then? 4 and 7 ought to be consistent.

MR. ENGEL: Yes.

THE COURT: And they're not. And there's a slight 

delta there.

MR. ENGEL: Yes.

THE COURT: Mr. Karotkin, can you solve this problem 

us that paragraph 4 reserves applicable law for what you file 

by a bar date? And I think Mr. Engel is saying it should be if 

it's good enough to get you past the bar date, it ought to be 

good enough to do what you get to do with an informal proof of 

claim.

MR. ENGEL: Exactly.

THE COURT: So again --

MR. KAROTKIN: Your Honor --

THE COURT: -- be consistent with the two, that's all.

MR. KAROTKIN: I understand. First of all, that's 

what the rule says. We're just quoting the rule in paragraph 

7, but paragraph 7 also says, "pursuant to Bankruptcy Rule 

3003(c)(2), but subject to paragraph 4 of this order".

THE COURT: Well, then paragraph -- then maybe that 

saves it with the reference to paragraph --

MR. ENGEL: You can --

MR. KAROTKIN: I mean, this -- can I finish?

MR. ENGEL: Please.

MR. KAROTKIN: Okay. This is a standard form of 

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paragraph in a bar date order consistent with the Bankruptcy 

Rule, and I think we've clarified it by saying "subject to 

paragraph 4", which I think is overkill in any event.

THE COURT: Well, a lot of people think it's overkill, 

but the Ninth Circuit has a long list of cases that couldn't be 

clearer. And maybe it's not necessarily the law in other 

circuits, but it's very much ingrained in the process here. 

So -- and some of us have been around for a while, lived 

through them as counsel in the early days, so we know it the 

hard way or the successful way.

But Mr. Engel, I think he's right. I think that it --

the reference in 7 to 4 saves it.

MR. ENGEL: Okay.

THE COURT: And -- I mean, again, I -- make sure that 

you don't have any late claims.

MR. ENGEL: Well, someone will have late claims, I'm 

sure. But you know, I appreciate the opportunity --

THE COURT: Okay.

MR. ENGEL: -- as with Mr. Pascuzzi, to reserve our 

rights with respect to this --

THE COURT: Everybody's rights are reserved.

MR. ENGEL: Thank you.

THE COURT: Now, Mr. Karotkin, do you want to take a 

break or keep going?

MR. KAROTKIN: It's up to you, sir. I'm happy to keep 

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going.

THE COURT: What do you what to do?

MR. EGGENBERGER: If I could just indulge two minutes 

of Your Honor's time? Michael Eggenberger on behalf of the 

Herndon plaintiffs. You had talked before about paragraph 3(e) 

in the debtor's proposed order. And we had objected to this 

and will, of course, refer to our objections.

THE COURT: Wait. Let me catch up with 3(e), please.

MR. EGGENBERGER: Absolutely.

THE COURT: Again, I can't keep track of all these 

things. We're doing 3(e)? What page?

MR. EGGENBERGER: It is page 5 of docket number 2646-

1.

THE COURT: Again, I can't keep track of all of the 

objections. So what's your problem with the paragraph?

MR. EGGENBERGER: So paragraph 3(e) combined with 

paragraph 7 would basically not allow class proofs of claim in 

this bankruptcy. And while we appreciate it, Your Honor could 

later address that through a Rule 9014 motion and decide if 

class proofs of claims do or do not apply. What this order 

says here is that if you do not apply with this procedure, 

including having a form -- file an individual proof of claim, 

notwithstanding that you're covered by a class proof of claim, 

that you are not allowed to be -- to receive distributions or 

entitled to vote in this bankruptcy.

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THE COURT: Well, I don't think that's what it says. 

Paragraph E says who has to file something. And the issue is, 

well, what if you don't file one, are you out of luck or are 

you protected by being a member of a class.

MR. EGGENBERGER: Absolutely, Your Honor. And what --

our argument is just that it's premature to decide whether or 

not class proofs of claim will be allowed in this bankruptcy. 

So this language is unnecessary. And I believe -- you know, 

Mr. Goodman can correct me if I'm wrong, but I believe the tort 

claimants committee proposed order does not have similar 

language. And as we pointed out in our brief, other orders 

that the debtors referred to do not have similar language prejudging class proofs of claim.

THE COURT: Well, what do you want me to do? I 

mean --

MR. EGGENBERGER: I would strike the language "class 

proof of claim" out of paragraph 3(e), and we can address the 

issue of whether or not people who are covered by class proofs 

of claim are entitled to act as creditors in this bankruptcy at 

the appropriate time, which would be through a Rule 9014 

motion.

THE COURT: But see you're not focusing on the 

paragraph that talks about entitled to a distribution.

MR. EGGENBERGER: Well, Your Honor, the way I read 

this is if you don't file these, which requires you to file an 

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individual proof of claim --

THE COURT: Right.

MR. EGGENBERGER: -- even if you're covered by a class 

proof of claim, then you're not entitled to distributions and 

voting rights. And to the extent Your Honor reads it as, you 

know, not addressing class proofs of claim at this time, that's 

fine by us. We just want to make sure that class proofs of 

claim will be addressed at the appropriate time.

THE COURT: But didn't I raise the question what if 

somebody doesn't do it? And then there was -- let's use you as 

an example. 

MR. EGGENBERGER: Yeah.

THE COURT: Let's suppose you file a class proof of 

claim and one of the members of your class doesn't. What's the 

outcome? What's the consequence?

MR. EGGENBERGER: Right. And Your Honor, the way we 

read it is that those people would be not entitled to be 

creditors because they haven't followed the procedures laid out 

here. And paragraph 7 says if you haven't followed these 

procedures, then you're not entitled to be a -- to receive 

distributions or vote as a creditor.

THE COURT: Well, I'm not sure what you want me to do. 

Mr. Karotkin, what do you want me to do in response 

there? I'm just losing the picture here, because we had --

distribution is different from having to file proof of claim.

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MR. KAROTKIN: First of all, this does not pre-judge 

whether or not a class proof of claim can be filed.

THE COURT: Right.

MR. KAROTKIN: They want to file a class proof of 

claim, they can file it, and you can determine whether --

THE COURT: Right.

MR. KAROTKIN: -- it's appropriate or not. All this 

requires is that individuals must file a claim regardless of 

whether they're included as John Does 1 through 5,000 in a 

class proof of claim so we can get information as to each 

individual member of that class. So as I said before, each 

individual member of a purported class, if the attorneys want 

to file it, fine, but they have to file that summary proof of 

claim form. Whether or not that ultimately they want to 

proceed as a class claim, you can decide. It's not pre-judging 

that. All this is saying is you must have an individual proof 

of claim on file.

THE COURT: Well, and --

MR. KAROTKIN: And if the attorneys want to file it, 

fine.

THE COURT: But to follow up on that, and using an 

example, if they -- this counsel files a class proof of claim 

and an individual who believes he's in that class doesn't file 

proof of claim, there may be consequences. And -- but we're 

not deciding it today.

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MR. KAROTKIN: That's correct.

THE COURT: We're saying, Mr. Jones, you didn't file a 

claim, therefore, what follows -- well, what follows. And if 

the answer is, well, you're in a class that's participant, 

you're home free. If you're not or the class isn't allowed, 

you're out of luck. The bottom line here is file proof of 

claim. Be on the safe side. Why was there any risk here? I 

mean, why not? Why take the risk?

MR. EGGENBERGER: Your Honor, we don't believe that --

it is good advice, of course, to file an individual class proof 

of claim. We're not disputing that. We're just concerned that 

the way this order is read, those people would not be covered. 

They would not be entitled to distributions because they didn't 

file individual class proof of claim, notwithstanding that 

later you --

THE COURT: But what I'm trying to say -- I guess I'm 

not making myself clear. We have -- whether it's October or 

January, we're coming up on a bar date soon, right?

MR. EGGENBERGER: Yes.

THE COURT: Maybe we'll have a plan confirmed next 

month, but maybe it'll be next year. I don't know when there 

will be a confirmed plan. But until there's a confirmed plan, 

we don't have anything to distribute, right? And so at some 

point, when there's a confirmed plan and there's a distribution 

entitlement, then if you have -- you or anyone else has 

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protected the interests of the individuals that you're arguing 

for by a proof of claim or a class proof of claim, an agent's 

claim, a something-else claim, you've done it. If you haven't, 

you haven't, and we can't say what will happen. But the law 

says -- and if we just -- like in any other case, it's so black 

and white. You file a proof of claim or you're out. Period. 

So I think what the debtor's saying is file proof of claim. 

And --

MR. EGGENBERGER: Your Honor, as long as it isn't 

determined to be a pre-judgment of the viability of class proof 

of claims --

THE COURT: It is not.

MR. EGGENBERGER: -- I guess we'll take that on your 

word.

THE COURT: It is not. It's a -- that's an open 

question. 

All right. I am going to take a fifteen-minute break. 

And if the rest of you want to stay here, you can stay here, 

but my courtroom staff is going to take a fifteen-minute break. 

And let me -- before I do, let me look at my agenda, see if I'm 

still following it.

Okay. Well, I guess that -- it seems to me is we then 

should talk about the bar date, just the pros and cons of the 

bar date.

Mr. Goodman, did you want to do it a different way?

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MR. GOODMAN: I -- actually, I was going to make the 

same suggestion, Your Honor, that we do a -- take a break. 

Just one issue before we move on to the bar date. Back on the 

claim form, as the Court noted, perception matters. It is --

we have two members on our committee who were victims of the 

2016 Ghost Ship fire.

THE COURT: Right. Yes, I know that.

MR. GOODMAN: That is not a wildfire. That was a fire 

that occurred in a warehouse in Oakland.

THE COURT: I know that, too.

MR. GOODMAN: So using the term wildfire -- I know the 

Court indicated in your order of notice yesterday that you were 

indifferent, but for the purpose of our committee, the term 

fire claim does have very real meaning and significance to us 

because we don't want anyone impacted by the Ghost Ship fire to 

see the heading on that form and reach the conclusion that that 

form can't be used. I know Ghost Ship is one of the boxes, but 

I do believe that if we can get that issue resolved, I think 

the claim form is done at this point.

THE COURT: So this is -- I mean, this is an argument 

for fire-related -- fire --

MR. GOODMAN: Yes.

THE COURT: Yeah. I know. I --

MR. GOODMAN: Using fire-related again, and this has 

been --

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THE COURT: But even -- and again --

MR. GOODMAN: -- given to us by our committee.

THE COURT: And this is by no means to minimize the 

tragedy of the Ghost Ship fire, the frays about the wildfires 

have been floating around for months. It's all over. It's in 

the press; it's in a lot of the documents. So we need to make 

it right, particularly for purposes of the victims of the Ghost 

Ship fire being able to know what they're -- what they have to 

do.

MR. GOODMAN: And --

THE COURT: So to the extent -- well, Mr. Karotkin, do 

you care on this, really?

MR. KAROTKIN: Your Honor --

THE COURT: I mean, don't -- can't we just call it 

fire-related?

MR. KAROTKIN: Yeah, that's fine. We said -- and 

we've raised this before. We said we'd work it out with Mr. 

Goodman.

THE COURT: Yeah, that's what I thought.

MR. KAROTKIN: That's fine. That's fine.

MR. GOODMAN: Okay.

THE COURT: That's what I thought. 

MR. KAROTKIN: I don't -- I'm not -- I'm curious why 

he's raising it now.

THE COURT: Well, okay, maybe just to avoid all -- a 

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month to avoid doubt.

MR. GOODMAN: I just wanted clarity on that issue. 

And with that, Your Honor, I would really appreciate if we 

could take a break.

THE COURT: I'll see you all at 12 o'clock, everyone.

(Recess from 11:44 a.m., until 12:01 p.m.)

THE CLERK: All rise.

THE COURT: Please remain seated.

Okay. Mr. Karotkin, what's next? Bar date?

MR. KAROTKIN: Yes, sir. I think that, Your Honor, I 

pretty much addressed that. I think that based on the notice 

program, the number of days, the fact that the proposed form --

and really this is the issue for the fire claimants -- is 

relatively quite simple to prepare, based on the notice program 

and the timing, there's more than enough time to prepare it.

As Your Honor knows, the proof of claim and the bar 

date is fundamental to the plan process, fundamental to --

there's an estimation hearing in this case. Hopefully that may 

not be necessary, but if there is one, it'll be fundamental to 

that, fundamental to plan distributions. I don't have to 

explain to you how important a bar date is to getting these 

companies out of Chapter 11.

And I will note, Your Honor, that with the recent 

announcement by Judge Newsom, that -- I'm sorry; Judge Newsom. 

I mean Governor Newsom --

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THE COURT: We had a Judge Newsom. You might get him 

later anyway.

MR. KAROTKIN: I do know -- actually --

THE COURT: Yeah, but he was --

MR. KAROTKIN: Actually, I had a case --

THE COURT: He was a --

MR. KAROTKIN: I've had a case -- two cases before 

Judge Newsom.

THE COURT: But you know that he mediated PG&E 1?

MR. KAROTKIN: I know he mediates in San Francisco. 

Yes, I do.

THE COURT: He mediated the first PG&E case.

MR. KAROTKIN: How about that?

THE COURT: Did you know that?

MR. KAROTKIN: I didn't know that, but I knew he was a 

mediator over at Gems (ph.).

But with Governor Newsom's --

THE COURT: Governor Newsom.

MR. KAROTKIN: -- Governor Newsom -- no 

relationship -- recent announcement that if PG&E wishes to 

participate in the Wildfire Fund that the legislature is 

currently contemplating creating, they will be unable to do so 

unless they exit Chapter 11 by June 30th of next year.

THE COURT: Oh, I was going to say, which year did he 

mention?

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MR. KAROTKIN: He mentioned June 30th of 2020. And I 

think, Your Honor, taking that into account, a January 31 bar 

date is completely impractical and really puts that at severe 

risk. 

But more importantly, Your Honor, it's not necessary. 

As I said, there's plenty of time -- we want to move these 

cases forward. Other parties want to move these cases forward.

I will point out a couple of other things. Number 

one, certainly by agreeing to the tort committee's summary 

proof of claim form, we by no means agree that that form 

provides sufficient information, and we reserve all of our 

rights --

THE COURT: I don't think anybody would think that.

MR. KAROTKIN: -- as to discovery.

THE COURT: I mean, even in the simplest of cases it 

just isn't --

MR. KAROTKIN: Right. But I just wanted to make that 

clear. 

THE COURT: -- isn't the test.

MR. KAROTKIN: And I know the other thing you wanted 

to address, Your Honor, as mentioned in your order, the TCC has 

requested that no objections to claims be permitted prior to 

the bar date. That to me would be unprecedented. I think 

it's -- in their own pleadings, they didn't cite any authority 

for that type of relief. We think that's completely 

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inappropriate. 

And, look, we're interested in getting out of Chapter 

11. They suggest in their papers that this case will go on 

until 2021. We don't think so. We don't want that to happen. 

Other parties don't want that to happen. 

(Phone ringing)

MR. KAROTKIN: Even that party doesn't want it to 

happen.

THE COURT: Let's wait.

Did that go off?

THE CLERK: That's someone on the line.

THE COURT: My question, though, is -- and I touched 

on this in the order that I issued yesterday. What's going to 

happen from your point of view as principal counsel for the 

debtor, whether -- at the moment the debtor hasn't filed a 

plan, one group has filed the motion to extend the -- shorten 

exclusivity, as you know. But what could happen before your 

bar date that would make even the bar date too late? Or in 

other -- or I'll try a different way.

What if I move the bar date a month? How is that 

going to negatively impact; certainly not going to impact 

distribution, is it? I mean --

MR. KAROTKIN: Your Honor, we may need to have an 

estimation hearing --

THE COURT: Um-hum.

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MR. KAROTKIN: -- before Your Honor. It's critical to 

get those claims in for that process. And again, we're focused 

on getting out before June 30th.

THE COURT: No, I understand.

MR. KAROTKIN: And --

THE COURT: And I'm not --

MR. KAROTKIN: -- the more you push that out, the more 

that jeopardizes our ability to do that.

THE COURT: No, but focus on the question of, if we 

were going to have an estimation hearing, it wouldn't be per 

claimant. Wouldn't it just be on a broad sort of macro level

about the estimation? Isn't that what a lot of the experts 

have been retained to talk about and to anticipate?

MR. KAROTKIN: Yes, but it would also involve, at the 

very least, Your Honor, an analysis of a sampling of proofs of 

claim that were filed as to their validity, as to the types of 

claims they're asserting, the basis for those claims, how they 

demonstrated their losses; so that would be essential to that 

process to get that moving. And again, there's no burden here. 

I mean --

THE COURT: No, I understand. I understand.

MR. KAROTKIN: So --

THE COURT: Look, we have a --

MR. KAROTKIN: And for purposes of planned voting --

THE COURT: -- culture here that -- with very early 

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bar dates. I mean, we had a -- I mean, even in the first PG&E 

case, we even shortened it to even a shorter time.

I realize that things are different with the tort 

claims and the thousands of victims, but no, there is a culture 

of doing it more quickly. I'm not -- you're preaching to the 

choir on that one.

MR. KAROTKIN: Okay.

THE COURT: But I'm really focusing on the difference 

between the October 21 date and some later date and how that 

might make a difference. And I realize that January 31 is four 

months, right? November, December, January. Three months. 

Three months difference.

But I guess I'm trying to -- from your --

MR. KAROTKIN: Three and a half.

THE COURT: Three and a half, yeah. I'm trying to 

think about, well, what is the practical value here? Your 

estimation perhaps is one of them. I understand. But I mean, 

on a best --

MR. KAROTKIN: I think the estimation part --

THE COURT: -- on a best-case basis, if you file a 

plan today, it would be several months before it would be up 

for confirmation, right?

MR. KAROTKIN: It would be, but again, Your Honor, 

claimants have to vote on a plan.

THE COURT: No, I -- of course.

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MR. KAROTKIN: And we need to get those claims in, at 

the very least for purposes of that, as well as an estimation 

hearing. And --

THE COURT: Unless they're unimpaired, in which case 

they don't have to vote. Well, they don't --

MR. KAROTKIN: It's hard for me to conceive how tort 

claimants can't be unimpaired. Not saying we don't pay 

hundreds --

THE COURT: You just pay them in full --

MR. KAROTKIN: I'm not saying we don't pay them in 

full --

THE COURT: -- on the effective date.

MR. KAROTKIN: -- but I'm not sure that's unimpairment 

in the technical sense.

THE COURT: Pay it in full on the --

MR. KAROTKIN: And that they wouldn't be able to vote 

on a plan.

THE COURT: Let's not --

MR. KAROTKIN: But we can address that later.

THE COURT: We can do that later.

MR. KAROTKIN: Yes.

THE COURT: But if you're paid in full on the 

effective date, you don't get to vote last time I checked.

MR. KAROTKIN: Yes, that's -- I --

THE COURT: Okay.

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MR. KAROTKIN: I would --

THE COURT: Okay.

MR. KAROTKIN: -- certainly agree with that. We 

certainly -- Your Honor, look, I've been very sensitive to the 

fact that there are wildfire claimants here, and if they have 

sufficient time -- in view of all the traumatic events that 

they've experienced -- sufficient time to file a claim, and 

we've tailored the notice specifically to address that. We've 

made it much longer than any other bar date in a conventional 

case as you, yourself, recognize.

And we have state-of-the-art, robust noticing 

procedures, which we think are fully compliant with due process 

and, more importantly, give people enough time --

THE COURT: Well --

MR. KAROTKIN: -- to do that.

THE COURT: Let me -- we're kind of digressing to the 

bigger question.

Unless the TCC persuades me not to approve the 

proposal you have for the promulgation of the bar date, that's 

the only option at the moment. I'm not going to second-guess 

it.

So the question is, whether the TCC is going to 

persuade me to put that on hold and consider the alternative 

one. But that's related to the bar date, but it's a discrete, 

separate question, right? Right?

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In other words, I mean, I understand, Ms. Finegan and 

her team and your team have said -- and you've made a strong 

case for your program, but the bar date is a separate question, 

right?

MR. KAROTKIN: The date of the bar date --

THE COURT: Yes. 

MR. KAROTKIN: -- is a separate question.

THE COURT: The deadline for the proof of claim. In 

other words, if I --

MR. KAROTKIN: But it's not --

THE COURT: -- if I said --

MR. KAROTKIN: I would say it's not completely 

separate. I mean, I think the issue is, Your Honor, does that 

program appropriate disseminate timely notice so people can 

file claims by October 21st, the day we settle. So I don't 

think they're completely unlinked, but --

THE COURT: Of course not. And of course, I know the 

obvious. 

Look, if you said we got this great program and we're 

going to have a bar date of July 15th --

MR. KAROTKIN: Right.

THE COURT: -- I would think you were crazy. And the 

question is whether October is enough.

But my point is, if I tell you that I believe it 

should be slightly later, I don't imagine you're going to fall 

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on your sword. You're just going to say, well, we'll have to 

deal with it later. And that you're making the pitch for the 

earlier date, and I respect that.

Why don't I just -- let's go for opposition. The 

debtors' proposal at the moment is, go with the debtors' plan, 

go with the October 21 bar date, and implicit in the debtors' 

plan are the start dates that we talked about this morning. 

MR. KAROTKIN: Right.

THE COURT: And let's see what anybody says about it.

MR. KAROTKIN: Okay. Thank you.

THE COURT: All right. So Mr. Goodman, are you going 

to make the pitch today or is someone else from your side? And 

do address the question of why you're adamant or it's important 

to even tell the debtor they can't object to claims. That's a 

separate issue, but it seems like a --

MR. GOODMAN: Yeah, on a housekeeping matter, Your

Honor, we actually struck that language from our proposed order 

on June 19th.

THE COURT: Oh, okay. Okay.

MR. GOODMAN: So that's, in our view, a nonissue.

THE COURT: I can't keep up with that.

MR. GOODMAN: Okay.

THE COURT: Okay. So the debtors' free to object to a 

claim tomorrow if they want, right?

MR. GOODMAN: They are free, in our view; that's 

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correct, Your Honor.

THE COURT: Okay.

MR. GOODMAN: And again, we're sorry for the 

confusion. We should've made it more clear that we were 

withdrawing that request.

THE COURT: Okay. That's fine. 

MR. GOODMAN: Okay. Thank you.

THE COURT: Get that out of the way.

MR. GOODMAN: Okay. And in terms of the presentation 

today, we do have a slight division of labor.

Again, Eric Goodman, BakerHostetler, here on behalf of 

the official committee of tort claimants. I'm going to be 

addressing issues primarily related to the bar date.

With me also is Ms. Elizabeth Cabraser.

THE COURT: All right. Good morning, Ms. Cabraser.

MR. GOODMAN: She represents a member of the 

creditors' committee and was also specifically tasked by the 

TCC of overseeing the development of our notice plan, so she'll 

be speaking to those issues.

THE COURT: Okay.

MR. GOODMAN: Okay. On the bar date, Your Honor, this 

is a unique case, right? I mean, the debtors filed as 

purportedly solvent entities. One of their first acts was to 

get approval of a DIP financing facility that would give them 

the ability to remain in bankruptcy for three years. We, 

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obviously, don't want them to remain in bankruptcy for three 

years, but that's -- the terms of their financing would permit 

it.

Given the financial condition of the debtor, what 

would be our expectation, obviously, the tort claims would be 

paid in full. Otherwise, equity, of course, would have to be 

cancelled in order for the plan to be confirmed.

So we're in a situation -- and also note that the 

Court has already seen that there has been one party that has 

already filed a motion to terminate exclusivity; that would be 

the bond holders --

THE COURT: I understand.

MR. GOODMAN: -- who filed a plan term sheet -- plan 

negotiations --

THE COURT: It'll come as no a surprise I haven't 

reviewed those papers. I've been a little busy. I'm sure you 

haven't either.

MR. GOODMAN: That's not for today, Your Honor, 

obviously.

But again, I would point out, I mean, the idea that 

plan negotiations can't proceed until the bar date has come and 

gone is obviously defeated by the fact that parties are already 

standing before the Court suggesting that they're prepared to 

go forward with a plan.

So we don't view a later bar date between October or 

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January as really an obstacle to getting a plan confirmed on a 

timely basis.

THE COURT: Well, you would agree, wouldn't you, that 

it would be kind bizarre to think, we're ready to confirm a 

plan except we have to wait for the bar date. That would be 

real bizarre.

MR. GOODMAN: That would be a luxury, Your Honor.

THE COURT: And not -- well, it'd be a luxury, but 

it'd be -- why should that even be a risk even thinking about 

it?

MR. GOODMAN: Again, it --

THE COURT: I mean, it is almost unheard of.

MR. GOODMAN: Yeah, and again, I think it's probably 

going to be unheard of in the context of this case.

THE COURT: Well.

MR. GOODMAN: On the estimation point, Mr. Karotkin 

did bring up that aspect, and again, I would note, PG&E did 

file an estimation motion in their prior bankruptcy before this 

court and before Your Honor in which they went forward with an 

estimation of their tort claims based on the historic data in 

PG&E's own claims database. And that information was obviously 

used to provide as estimation on an aggregate basis.

I've not saying that that necessarily has to be done 

here. I don't really take a position today, but I'm just 

saying, I think Your Honor understands that it's possible to 

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move forward with those types of proceedings.

THE COURT: Well, something tells me that if the 

debtor did that, there would be some opposition.

MR. GOODMAN: I'm sure there would.

THE COURT: Because -- and the leader of the 

opposition would be you and your colleague, Mr. Julian.

And so, I mean, who are we kidding? The debtor -- I 

mean, the day of reckoning may be the Court fixing an 

estimation if that's necessary.

MR. GOODMAN: Well --

THE COURT: And it may not be necessary.

MR. GOODMAN: Well, let me clarify. You raise a very 

good point.

I think -- and from our perspective, it is the work 

that needs to be done to get to the point where the parties can 

have an intelligent discussion about estimation, and that work 

is ongoing. It has begun, and that's kind of the point that I 

was trying to make.

THE COURT: Well, I understand, but you have to 

understand too that whatever the -- not the -- the parallel was 

in the prior case doesn't fit. I mean, we had some tort 

claims, but they were nothing like here. But --

MR. GOODMAN: Different, yet --

THE COURT: But when I think about all the cases I've 

either been involved with as a lawyer -- whenever that was in 

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my memory -- and as a judge, it almost is always given what the 

claims bar date is, and it's always in the past or imminent. 

And this has got this thing reversed. That just --

it's hard for to understand why there's a good reason for it 

and for delaying it. So that's really what I need you to tell 

me.

MR. GOODMAN: Okay.

THE COURT: Not the complexity of the estimation or 

what's going to happen in a competing plan and anything else. 

Why should it be January instead of October or anywhere in 

between? I don't know why, so you need to tell me why.

MR. GOODMAN: I will answer your question directly. I 

think the main concern for us are the unrepresented victims of 

the Camp Fire. That's the issue that we are struggling to 

address.

Now, the Court brought everyone's attention to the 

Mullane decision, which I read again last night and again this 

morning. And there's very key language -- because obviously 

notice and the bar date are somewhat related to each other --

about notice being reasonably calculated under all of the 

circumstances to apprise parties of their rights.

And here we have a situation where we have a fire, a 

disaster, that has displaced tens of thousands of people. 

Notice, in this case, is going to be far more difficult; it's 

going to be far more complicated than in your normal 

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bankruptcy.

For that reason, we believe that if necessary --

THE COURT: Well, let me pause you there.

MR. GOODMAN: Sure.

THE COURT: It's going to be far more difficult for an 

unknown quantity of victims. It's going to be a no-brainer for 

a vast quantity of victims, right?

MR. GOODMAN: Right. That --

THE COURT: So --

MR. GOODMAN: That is --

THE COURT: So whether it's the Dalkon Shield case 

that Mr. Julian had involvement with thirty years ago or sex 

abuse cases for the clergy or Gulf meltdowns of whatever the 

Gulfstream Horizon -- whatever the thing -- the Gulf; they're 

all going to be different, but you can't have a magic wand to 

get everybody to say okay because there's people that either 

will never know or will know and will do nothing about it. You 

can't change that, right?

MR. GOODMAN: I agree. But --

THE COURT: All the experts in the world, all the TV 

plugs, all the everything, there are going to be some people 

who aren't going to respond, and we can't change -- we don't 

hold up the train for the last holdout.

MR. GOODMAN: But I think we need to try.

THE COURT: Well, so do I.

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MR. GOODMAN: And that's --

THE COURT: And so does the debtor.

MR. GOODMAN: That's the key. That's the key. 

Because if the question is -- we need to try. We need to do 

our best. We need to make sure that we take -- put forward a 

reasonable program --

THE COURT: Reasonable.

MR. GOODMAN: Reasonable. Yes.

THE COURT: Reasonable under the circumstances.

MR. GOODMAN: Reasonable under the circumstances, 

reasonable given the economic situation of the case, reasonable 

given the reality of the 2018 Camp Fire, which is why my first 

response to Your Honor was -- you said, tell me why? And the 

answer is: it's the unrepresented victims of the 2018 Camp 

Fire.

There's also a seasonality concern that we have. We 

actually think that the response rate will be higher if we take 

advantage of the holidays when people are off work and have 

time to prepare claims. If we could get a bar date after 

Thanksgiving --

THE COURT: But again, I don't want to minimize it, 

how much preparation is there? You've made a very constructive 

suggestion on simplifying the claim form. So I --

MR. GOODMAN: It's also explaining the significance, 

though, of the bar date and getting the word out to victims 

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affected by the fire as to the consequence of not filing the 

claim.

And again, Judge, I noted getting a bar date at a time 

when people who are suffering from trauma might have an 

opportunity to spend the time off from work after Thanksgiving 

or the December holidays we think would make a meaningful 

difference.

So that actually concludes my remarks. At this time, 

I would like to turn the podium over to Ms. Cabraser.

THE COURT: But I thought she was going to talk about 

the procedure specifically.

MR. GOODMAN: Well --

THE COURT: But no, I'm not going to say I'm not going 

to listen to her; of course, I am.

But my question to you, still -- and it goes back to 

this question of what I tried to say in my order of 

yesterday -- the committee, through you today, is changing your 

position slightly, right, by clamoring and pushing and pushing, 

and now saying, but let's slow down? And there may be a good 

reason, but there are also appearances and optics. And if all 

these efforts are to let that small number of people have a 

chance at the cost and the delay of a large number of people, 

then it's not a good thing, is it?

And again, reasonable under the circumstances. So I 

could say, fine, you've really persuaded me. Let's have a bar 

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date of late 2020. I mean, obviously, that's crazy, but that's 

the logical conclusion, right.

MR. GOODMAN: Well, again, we're trying to strike a 

balance. 

THE COURT: Right. 

MR. GOODMAN: And proposing January 31st, just so the 

Court knows, the TCC sought input from the plaintiffs' counsel 

in the North Bay JCCP who also represented a substantial number 

of Camp Fire victims.

THE COURT: Right. 

MR. GOODMAN: And we said to them given your 

experience working with people who have been affected by the 

2018 Camp Fire, what do you think an acceptable bar date would 

be? And the answer that we got back was January of 2020. That 

was the time period they believed would be sufficient and 

adequate under all of the circumstances of this case to provide 

for proper notice, to explain to victims who have been 

traumatized, very real and meaningful ways, by the reality of 

the 2018 Camp Fire that they would need to file a proof of 

claim with this bankruptcy court in order to participate in the 

plan for voting and distribution purposes. 

So it is not a number that became plucked out of thin 

air. It was a number or a date that we believed was 

appropriate given the circumstances of the case. 

And again, I just want to make clear to Your Honor the 

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debtor, in their pleadings, quoted from Frank Petrie, Calhoun 

Bidotti (phonetic), other lawyers who appeared at the hearing. 

They are members who participate in our meetings. They were in 

the room when we picked January 31st, 2020. The notion that 

the victims in this case somehow are at odds with the TCC, I 

think, is somewhat of a bit of a fantasy. The folks who seem 

to think that are not the ones who are interacting with them on 

a daily basis. 

THE COURT: Listen, if I knew from a crystal ball that 

there's no way on earth there's going to be a distribution for 

some horrible, long period of time, that would be one thing but 

I don't know that. And there certainly seems to be 

pressures -- not internally here, coming from outside, from 

lots of sources that the last thing in the world would want to 

do for the benefit of the victims, and frankly the contract 

parties. I'm not forgetting the fact that there are thousands 

and thousands of creditors who aren't fire victims who are 

getting delayed also. 

So it seems like it's -- I've got to have a real sense 

that slowing it down has -- I've got to have a reason, and it 

is a -- if at the end of the day, there never is a plan to 

discuss until middle of next year, then who cares? I mean, the 

victims care, and the creditors care, but the system has worked 

the way it works, right or wrong.

But on the other hand, if we have a -- whether it be 

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the political forces, the governor or the PUC, legislature, the 

last thing in the world that I think would be regrettable would 

be if the bankruptcy system is slowing them down. The 

bankruptcy system, in my mind, needs to be out in front, and 

we've got to have all sorts of other regulatory concerns, CPUC, 

FERC, others -- legislature. Anyway, I'm repeating myself. Go 

ahead. 

MR. GOODMAN: Well, but again, I think the January bar 

date does fit within that timeline. I think the -- again, 

we're trying to balance a lot of competing interests. We're 

not unmindful of all of the concerns that Your Honor has just 

raised. However, we also are confronted daily with the reality 

of people who are homeless, people who ran for their lives, 

people who lost family members, daughters, husbands. This is a 

different a case for that reason.

And we have a debtor here who is purportedly solvent. 

If you had a plan filed tomorrow that said tort claims are 

reinstated or paid in full, again, just setting a later bar 

date to ensure that more people are able to participate in that 

process --

THE COURT: Something tells me if we had that kind of 

a plan, we'd figure out a way to make it happen faster. 

MR. GOODMAN: I'm sure we would. 

THE COURT: Well, I'm not --

MR. GOODMAN: Or not. 

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THE COURT: -- being --

MR. GOODMAN: Yeah. 

THE COURT: -- cavalier about this. I mean the 

complexity of this case goes without saying. Everybody repeats 

it, so we don't have to keep saying it. 

But again, my point is that the bankruptcy system that 

does allow some flexibility shouldn't become an impediment if 

all these other forces line up together. And it's not -- the 

problem isn't going to get solved in this courtroom, it's just 

going to get implemented perhaps in this courtroom, but it's 

outside court -- anyway, let's -- if Ms. Cabraser is going to 

help me understand it, I would like to hear from her. 

Good morning. 

MS. CABRASER: Good morning, Your Honor, or this 

after -- good afternoon. 

THE COURT: Well, it's morning in Hawaii. How's that?

MS. CABRASER: Yes. Aloha, Your Honor, and thank you 

very much for hearing from us today. And thank you for the 

time and care and attention that you have taken with respect to 

the bar date issues, the proof of claim form issues, the notice 

plan issues. It is of tremendous and unusual importance in 

this bankruptcy to the tort claimants. 

I do appear here as somewhat of a stranger. Unlike 

most lawyers in this courtroom, I am not a bankruptcy expert, 

I --

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THE COURT: Most of the experts -- most of the 

nonexperts have come in and make the mistake of announcing at 

the podium that they don't know what they're talking about. 

You're too well known and too respected to even make that 

mistake of saying that. 

MS. CABRASER: Well --

THE COURT: Some of us irreverent bankruptcy judges 

usually say, yeah, we knew that anyway. 

MS. CABRASER: The --

THE COURT: But we don't go into your forum and tell 

you how to do things. 

MS. CABRASER: And I'm not here to return the favor at 

all. 

But I think it's important, particularly since like 

this Court in this circumstance, I live and die in my 

particular practice --

THE COURT: Right. 

MS. CABRASER: -- by Mullane to ground what I'm going 

to say about the notice and outreach plan in that case, which 

is the one case that rules all.

And here, I think what --

THE COURT: Well, and we call it the seminal case, 

right? Right?

MS. CABRASER: The seminal case, it was the case that 

certainly is the touchstone for all things notice-related. And 

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the due process concept that is the most profound one in 

Mullane is that due process operationalizes the right to hear 

and be heard. 

The claim form, the proof of claim itself, 

operationalizes the right to be heard for claimants. The 

concern here is making sure they hear, making sure that we have 

enough reach, enough frequency through the media that these 

claimants use and understand so that they can take care of very 

clear, very reasonable principles or forms that Your Honor has 

developed in conjunction with the debtor and the TCC. 

So in that regard, I also have to say how much we 

appreciate the fact, as you heard this morning, that the notice 

plan has -- that the debtors proposed has substantially 

improved in response to the Angeion program. That's what 

happens when competitors compete. 

And I would like to focus on several remaining gaps 

that we believe can and should be filled, can be done. Right 

now, you'll notice that both plans have the same budget. It's 

now 21.5 million approximately, so --

THE COURT: I had a little trouble trying to figure 

out that. 

MS. CABRASER: Well, we --

THE COURT: That's why I asked for some information. 

MS. CABRASER: We did, too but I think the last 

comparison based on the 2.0 plan I think has the debtors 

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program at 21,500,000, and the Angeion program is at 

21,850,000.

The key differences don't have anything to do with 

mailing, but they have to do with aspects of the notice plan 

that would reach these claimants soonest and most effectively. 

And Your Honor that's where this interrelates with the bar 

date. You've heard all of the reasons why we believe the TCC 

proposed bar date is appropriate and that it will not impede 

with a swift resolution of the bankruptcy. That's what the TCC 

wants. They are not going to be the ones in front of that 

train.

But while those proceedings are progressing, if we can 

use the time that we have, whatever time Your Honor gives us 

for the bar date, to saturate these dispersed communities with 

effective notification, then we are increasing the probability 

that they will get their proofs of claim in on time. 

THE COURT: Well, how do we know that? How do we know 

we're not saturating them with then hearing the notice over and 

over again, as distinguished from an earlier notice that tells 

them what the consequences are?

MS. CABRASER: The notice plan -- the Angeion notice 

plan that we think should be adopted, whether Angeion does it 

or the debtors' vendor does it or some combination of joint 

notice plan, which would be ideal, is done, actually frontloads 

the type of notice that's going to be most effective in 

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reaching these people, and that's why I mentioned frequency of 

messaging. It's a tentative advertising that no one is 

actually hearing your message until you're so sick of it, you 

don't want ever to say it again. 

MR. KAROTKIN: Your Honor, can I interrupt? Is Ms. 

Cabraser here as a media expert and a noticing expert or is she 

here representing a client, because this sounds like testimony 

on behalf of Angeion. I'm confused. 

MS. CABRASER: It is not testimony on behalf of 

Angeion -- I will tell you exactly why and how I'm here, Your 

Honor, and it is a little unusual.

THE COURT: Well, you know that Angeion was notably 

absent when the debtor wanted to pin them down, and I made it 

clear that I wasn't going to turn this into a --

MS. CABRASER: Understood. 

THE COURT: -- you know what kind of a contest. 

MS. CABRASER: Understood. 

THE COURT: But that doesn't mean that suddenly we 

just pretend that they have provided the information to the 

debtor. I mean, to me you're making an argument for a later 

date. You haven't told me --

MS. CABRASER: Ah. 

THE COURT: -- and Mr. Karotkin's criticism, why don't 

I just say you've persuaded me on the date, we'll go with the 

debtors' plan and make it go longer or more frontloaded. I 

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mean --

MS. CABRASER: Right. They are interrelated issues, 

and that's a possibility, Your Honor. 

THE COURT: Yeah.

MS. CABRASER: Let me simply explain why we believe --

and look, I am not Angeion. I am not a notice expert, but I am 

a lawyer that --

THE COURT: No, but you're known for your expertise 

and experience and track record and good results in cases in 

this court and lots of other courts, so everybody knows who you 

are --

MS. CABRASER: All right. 

THE COURT: -- and including me, but that's the point. 

So therefore, what should I do that's different in this case?

MS. CABRASER: You --

THE COURT: And again, I made a comment earlier -- I 

don't know if you heard me -- your experience is in class 

actions, mostly, I guess, but class actions don't have bar 

dates. 

MS. CABRASER: They do --

THE COURT: I mean -- excuse me, they don't have 

discharge dates, right? If you never got notice of a class 

action, and the company is still around, you're still alive and 

well, aren't you?

MS. CABRASER: It depends, Your Honor. In class 

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actions settlements there are bar dates. 

THE COURT: Okay.

MS. CABRASER: There are claims deadlines. 

THE COURT: But if you don't know about it, there's no 

statutory bar date like a claims deadline in the statute, 

right?

MS. CABRASER: There is case law that says if you 

don't know about it, if the best -- if the most -- if the best 

practical use was given to you consistent with due process, and 

you were the one that didn't find out about it, and you didn't 

make a claim, you're out. So it is somewhat --

THE COURT: Is the debt discharged? I don't think so.

MS. CABRASER: Yes, there would be a class -- well, 

there would be a class-wide dismissal and release. 

THE COURT: Well, that could --

MS. CABRASER: It might be the --

THE COURT: But is it a legal discharge?

MS. CABRASER: It may be the -- it would be the 

functional equivalent of a discharge with respect to that 

claim. 

THE COURT: Well, it's well established in Ninth --

not Ninth Circuit; it's case law, and I believe the seminal 

case on this was the Tenth Circuit -- if you never know about 

the bar date, you're not discharged. That's the --

MS. CABRASER: Well, that's the no harm, no foul.

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THE COURT: Well, you know what? For most of our 

cases that I preside over, it's fatal because the debtor is 

gone. 

MS. CABRASER: That's right. 

THE COURT: I don't expect this debtor to be gone. 

And if a victim is able to persuade a court that it never knew 

of the discharge deadline, then it may not be discharged. And 

that's not such a bad thing if you've got a company like this 

company surviving. 

MS. CABRASER: It isn't a bad thing. What we believe 

is a better thing, Your Honor, is that tort claimants have the 

fullest opportunity to actually make their claims --

THE COURT: No, I understand. 

MS. CABRASER: -- while we're all in these 

proceedings. And so here are the major gaps --

THE COURT: Okay.

MS. CABRASER: -- that we see that can be filled, that 

should be filled, that would ensure Mullane compliance, that 

would maximize claims, and would do so without added cost 

overall. And this is first with respect to frequency of 

messaging. The TCC plan reaches all adults in Northern 

California on average of 51.95 times and reaches over eighty 

percent of all Californians, 28 times. 

The 2.0 plan from the debtor reaches Northern 

Californians eight times, and Californians only five times. 

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The reason frequency is important is to get people to 

hear. The people in this group are displaced; many are 

homeless, and they live by their phones. We know they have 

their phones. 

THE COURT: We don't have any data on this, though, 

right? I mean, I understand what you're saying, and I suspect 

you're right, but there's no real observable data about this 

out there. 

MS. CABRASER: Have public health folks been able to 

poll these people? No. We're in the process of trying to 

reach them. But I can tell you this, Your Honor, on behalf of 

my clients from the Camp Fires community. I represent wrongful

death claimants, as well as property claimants in both Camp 

Fire and North Bay. 

And by the way, many North Bay fires folks are still 

unrepresented. With respect to North Bay, I know that people 

live by their phones because I've seen my clients do it.

THE COURT: No, but my -- no, I'm sorry, my question 

was different. Is there any observable data on the number of 

people who literally are -- by homeless, I mean are out of 

touch with any kind of system where reliable notice might work 

for them?

MS. CABRASER: What we know is there are thousands of 

folks that don't have a new permanent address, don't have a 

forwarding address, are in touch with family members and 

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friends, and members of their former communities primarily by 

phone, and that is why our notice program focuses so heavily on 

frequency through social media -- Facebook, Instagram, 

Twitter -- and also why it focuses so heavily on a livestreaming audio because people listen to that on their 

smartphone. 

So here's what I would suggest as the gaps that can 

and should be filled without added expenses and without added 

time. And by the way, these are the aspects of a notice 

program that could be instituted most quickly, instantly. 

Social media can happen the day after Your Honor's order. 

THE COURT: No, I'm sure that's true. 

MS. CABRASER: Mailing is going to take two weeks 

before people receive letters, if indeed they get them. 

THE COURT: But we have a law that says it has to be 

mailed. 

MS. CABRASER: Of course. Of course. It's necessary 

here, but not sufficient, particularly when the addresses are 

of destroyed homes. But streaming audio, radio via smartphone, 

will reach people. It will reach them on a same-day basis, and 

it will reach them frequently.

The remaining gaps --

MR. KAROTKIN: Your Honor, I have to object. This is 

testimony. She is not a media expert. 

THE COURT: No, I understand. I understand. And I'm 

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not sure what to make of it. I'm going to let her finish the 

point.

MS. CABRASER: All right. We are suggesting to the 

Court features of a notice plan, court-approved, that would do 

what we know the Court wishes to do, and what we know the 

debtor has said it wishes to do. 

With respect to --

THE COURT: Wait, let's stop there. 

MS. CABRASER: Yes. 

THE COURT: Right. So why don't I just tell Mr. 

Karotkin I want to see a higher level of frequency, period? 

That doesn't answer the question of the bar date. I mean, 

that -- so it isn't related to the bar date. 

MS. CABRASER: All right. 

THE COURT: You just said it's frontloaded. So I 

mean, this is why I'm having trouble, and I'm not going to --

MS. CABRASER: All right. Let me try to tie it 

together. 

THE COURT: I'm not going to throw you off because 

you're not a qualified expert in media, but you've got to 

understand, we've got to focus on the different issues here. 

I've got a decision to make about a deadline, which is 

clear, and I've got a decision to approve the debtors' 

comprehensive plan or an alternative plan that frankly isn't 

very complete, except you're telling me how it can do all these 

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things. But I have the Angeion -- I mean, I find it strange, 

to be honest with you, that we would have this hearing, and the 

Angeion principals haven't even made themselves available to be 

deposed or interviewed by the debtor. And I'm supposed to say 

okay, well, let's just forget that. Let's just take a very 

respected, and -- respected member of the bar tell me why they 

should go with the Angeion who hasn't complied with very 

fundamental procedural processes, okay?

MS. CABRASER: My --

THE COURT: So let's mix the --

MS. CABRASER: All right. 

THE COURT: Let's get the -- separate these things 

out. 

MS. CABRASER: We'll separate them out. 

THE COURT: Because you know why? You're making a 

very persuasive argument for me to tell Mr. Karotkin, you've 

got an October deadline; pick up the media and the audio 

streaming --

MS. CABRASER: Okay.

THE COURT: -- in the frontload. 

MS. CABRASER: The deadline issue is this, Your Honor. 

And they are interrelated, and I'll try to extricate them to 

the extent I can. 

THE COURT: Well, you've got to. Yeah, you've got to.

MS. CABRASER: All right. 

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THE COURT: Okay. 

MS. CABRASER: The point that was made about 

seasonality is an important one. It's not anyone's fault that 

it's June and that a notice program would not launch into July. 

We have to live with that, but the reality of that under 

Mullane is that it's most difficult -- I don't think anybody 

would disagree for lots of reasons, it is most difficult to 

reach folks and motivate them to act over the summer months. 

It gets easier --

MR. KAROTKIN: Your Honor, I really -- this is expert 

testimony on noticing. This is completely inappropriate. 

THE COURT: I know, Mr. Karotkin. I'm not going to 

make a finding. I'm just listening to the argument. I 

understand your point. I understand your point but make --

MS. CABRASER: Okay. My clients tell me -- without 

waiving attorney-client privilege --

THE COURT: Well, you're about to waive it. So --

MS. CABRASER: Generically, generically --

THE COURT: Yeah.

MS. CABRASER: -- that --

THE COURT: Shall we forget the hearsay rule while 

we're at it?

MS. CABRASER: We may forget a lot of things and --

THE COURT: Okay, you're in the bankruptcy court now. 

MS. CABRASER: We're in the bankruptcy court. We're 

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in the bankruptcy court, Your Honor, and --

THE COURT: Yes, go ahead, what? Without waiving 

privilege and forgetting the rules of hearsay, what is the 

point?

MS. CABRASER: Community members gather, again, by 

phone, by social media, physically where they can during the 

holiday season. This happened --

THE COURT: Well, but so do nonvictims. So do people.

MS. CABRASER: Yes. 

THE COURT: Just people. 

MS. CABRASER: And --

THE COURT: Nonvictims. 

MS. CABRASER: Yes, this is not specific to victims. 

That is why this is not a matter of notice expertise. This is 

a matter of recognizing the reality of human life that is even 

more important to displaced and dispersed victims to know that 

if we want to have an effective claim program with a meaningful 

bar date that is consistent with due process and that 

reasonably makes all reasonable efforts to apprise folks of the 

ability to file a proof of claim and get those claims in so 

that the bankruptcy can proceed, we would want to take 

advantage if at all humanly possible of the holiday season when 

people are most likely -- people, just people -- forget the 

particular needs of these people, my clients, just people --

are more likely to gather, to speak with each other, to 

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reinforce and encourage each other. 

THE COURT: But what are they likely to do when they 

either get something in the mail or if they don't have mail 

delivery, get something in the newspaper or on their streaming 

phones that says you have to file a claim in the bankruptcy 

court? There can't be a victim alive who has intelligence who 

doesn't know that PG&E is in bankruptcy. 

So what they shouldn't -- I can't assume they do 

know -- are the fine points of bankruptcy law and procedure, or 

any other civil procedure. What's going to be different about 

telling them fifty times rather than thirty times? If they're 

not going to do it, they're not going to do it. And if they 

know there's a deadline, why aren't they going to do it?

In other words, put it a different way and --

MS. CABRASER: What is different?

THE COURT: Put it this way, if I tell you ten times 

you've got to do it by a deadline, and you don't, and I tell 

you ten more, and ten more, and ten more, is something going to 

change? 

MS. CABRASER: Yes. 

THE COURT: What?

MS. CABRASER: It's going to get through to a 

traumatized victim, a dispersed victim, that they have to do 

it. They are going to --

THE COURT: But how many does it take?

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MS. CABRASER: I could not tell you --

THE COURT: Okay.

MS. CABRASER: -- how many is enough. But the more we 

can give with a -- cost-effectively -- and remember, social 

media is very inexpensive, and frequency is very inexpensive. 

THE COURT: I already agreed with you that maybe the 

simple solution is to increase the frequency and --

MS. CABRASER: To increase the frequency and to give 

enough time, Your Honor. These are the two aspects of it. 

THE COURT: Okay.

MS. CABRASER: It is a balance. 

THE COURT: But I need to have a better --

MS. CABRASER: And it is an art. 

THE COURT: I need to have a better sense -- I mean 

the art -- the experts have just demonstrated a lot of art.

MS. CABRASER: Um-hum. 

THE COURT: You're not an expert in this, nor am I, 

and I've read from both sides; whether there are difference of 

opinions as to who should be believed, they are both telling me 

things that I'm not familiar with. So I have to rely on them. 

But this notion that people are going to gather around 

at Christmastime because they can put together a proof of claim 

is not very persuasive compared to doing it now or in October 

or September, if they are bombarded with information and 

reminders again and again, do it. 

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It's almost if you keep telling them, they don't do 

it, they'll never do it. So why should I assume that after 

telling people fifty times, we should tell them ten more times? 

I mean that's really what you're saying. 

MS. CABRASER: The --

THE COURT: Because it's the holidays. 

MS. CABRASER: Well, there's --

THE COURT: And I don't see the connection. 

MS. CABRASER: There is a substantial difference --

THE COURT: Okay.

MS. CABRASER: -- between telling someone something 

five times and telling them fifty times. Is fifty the minimum? 

Is it somewhere in between? I don't know that standing here 

today, but I do know that more is better. 

THE COURT: What's the experience -- what's the class 

action experience?

MS. CABRASER: The class action --

THE COURT: And I'm not talking about people who got 

a -- paid too much for their Volkswagen that polluted the air. 

I'm talking about tort victims. 

MS. CABRASER: That was an easy one, Your Honor. 

THE COURT: Yeah, I'm sure it was. But I'm talking 

about tort victims. 

MS. CABRASER: Tort victims. 

THE COURT: So what's the magic formula?

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MS. CABRASER: The magic formula is maximum frequency 

over maximum time through the most number of media, which is 

why on the class action side you see notice plans like the plan 

that you see developing before you in this courtroom through 

the back and forth of the debtor and the TCC. It's getting 

there. There's a plan. It's a multimedia plan. There are a 

couple of features that the debtor plan doesn't have yet that 

we thought it should: the public relations and word on the 

street. 

On the class action side, we don't start from a clean 

slate every time. We go back to the last program that worked 

well that we have metrics for in a given type of case. 

THE COURT: Right. 

MS. CABRASER: And then we build on it because the 

technology is advanced --

THE COURT: Right. 

MS. CABRASER: -- and because we learned from it. 

It's an iterative process. That's why the TCC submitted the 

declaration that it did from Mr. Deon (phonetic), who deals 

with traumatized folks. 

THE COURT: Well, there are some --

MS. CABRASER: And I'm relying on --

THE COURT: But there's some question about the 

validity of the reliability of that. 

MS. CABRASER: And --

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THE COURT: But that's neither here nor there. 

MS. CABRASER: And when -- I'm just speaking from 

personal experience, not an expert -- when I worked on the 

notice program in Deepwater Horizon that Your Honor mentioned, 

where we had Gulf States, we didn't have mass injury claims but 

we had economic trauma.

THE COURT: Um-hum. 

MS. CABRASER: So it was a little milder but it was 

acute. People were out of jobs. They were out of work. Their 

businesses were closed. 

THE COURT: Yeah. No, I'm aware of that. 

MS. CABRASER: We did a very similar plan to this one. 

There was actually more frequency. We --

THE COURT: What was the time frame? What was the --

MS. CABRASER: We had a longer time frame. We had 

about a year, Your Honor, and so we took full advantage of 

that. And so this one is really scaled to --

THE COURT: Is there any --

MS. CABRASER: -- we have less time. 

THE COURT: Is there any data as to if you had a 

window that was a year long, when the claims built up or didn't 

build up? In other words, it's one thing to say, okay, 

Deepwater took a year, but if did a chart to go when were the 

claims filed --

MS. CABRASER: Oh, month-by-month? It -- fall, 

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fall/winter, the holiday season. And that's something that 

seems to repeat across --

THE COURT: But when was the accident to begin with?

MS. CABRASER: The accident was --

THE COURT: I don't remember. 

MS. CABRASER: -- in April of 2010. 

THE COURT: Okay. 

MS. CABRASER: There were various notice programs for 

various purposes throughout the life of the proceedings because 

it's a maritime case and there -- where there were different 

notices. The class notice --

THE COURT: Well, I know it's a maritime case but the 

people on the land who --

MS. CABRASER: Oh. 

THE COURT: -- suffered oil or whatever the 

chemicals --

MS. CABRASER: Class notice started in April 2012 and 

went through April of the following year. 

THE COURT: But my question was if you had a chart 

that showed what the frequency of the claims --

MS. CABRASER: Of the claims --

THE COURT: -- filing, and you told me that ninetyfive percent of them were the first three months, and there 

were eight claims filed in the last three months, you won't 

persuade me to do something different here. 

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THE COURT: Again, due process is what it is, but the 

notion that we delay a process by a couple of more months to 

pick up three claims or two claims or six claims is not very --

MS. CABRASER: Understood.

THE COURT: -- persuasive. Because, again, I'm not 

unsympathetic to those people, but how many times do you have 

to tell them?

And I'll grant you that if there's a victim out there 

who doesn't know about it until the last day, I want that 

person and you want that person to be able to assert a claim.

MS. CABRASER: Um-hum.

THE COURT: But at some point, you have to draw the 

line, right?

MS. CABRASER: Understood. 

THE COURT: Okay.

MS. CABRASER: Understood, Your Honor.

THE COURT: So the question is --

MS. CABRASER: We're trying to assist in --

THE COURT: -- with Deepwater as --

MS. CABRASER: -- the right balance.

THE COURT: So we're going to forget smoking 

Volkswagens and we're going to talk about large-scale torts. 

Is there any information that you can share about the timeline 

of the window to assert the claim compared to the actual 

assertions of claim?

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MS. CABRASER: Yes. We know that the claims ramped up 

toward the -- what we could call a bar date, the end date for 

claims. You couldn't make any --

THE COURT: Well, that's probably always the standard.

MS. CABRASER: That's very standard.

THE COURT: That's human nature, right?

MS. CABRASER: That's fairly standard. That's going 

to happen here. I think we can predict that.

THE COURT: Yeah.

MS. CABRASER: I would have to compile the charts. 

These were reported monthly by the claims administrator.

THE COURT: Okay.

MS. CABRASER: But we know that the claims spiked in 

the fall after the summer. We know the claims spiked over the 

holiday season. And so frankly, Your Honor, just 

experientially, not as an expert, what we're trying to do here 

in striking a balance between a bar date and maximizing the 

reasonable opportunity for folks --

THE COURT: When the notices --

MS. CABRASER: -- was to use that.

THE COURT: -- went out in something like Deepwater --

or again, I'm not focusing only on Deepwater, but I want to --

MS. CABRASER: Um-hum.

THE COURT: -- talk about mass torts. I presume the 

original notices also had the deadlines?

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MS. CABRASER: Yes.

THE COURT: So the ramping up of the claims filing is 

a direct function of what the deadline was in the first place. 

So there's no data, I presume, that tells us what is 

the sequencing or the frequency of people asserting and filing

claims after they first know of the claims.

MS. CABRASER: No.

THE COURT: In other words, if I am a victim of the 

Deepwater and I get a notice in April that says file your claim 

by next April, I'm going to say, okay. I'll get around to it. 

If I get a notice in PG&E that the bankruptcy court says file 

your claim in October, I'm going to file my claim in October 

unless I don't know in the first place, which gets back --

MS. CABRASER: Um-hum.

THE COURT: -- to the question of well, okay. Let's 

just front-load the noticing.

MS. CABRASER: Well, and that's the reach question, 

Your Honor. The reach question is the right to hear. So we 

need to get to folks, really decide the frequency which 

reinforces the idea and motivates. Let's just talk about the 

reach and how to get to people with a date so they can do 

something --

THE COURT: Okay.

MS. CABRASER: -- in a way they can understand.

THE COURT: But then, see, now we're where Mr. 

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Karotkin was going to object. He's objected a couple of times 

to your statement and I let you make the statement. 

But how do I, as the poor old bankruptcy judge, know 

why I should tell Ms. Finegan in her effort, no, that's not 

good enough. Agajanian's is better. I don't know. There's no 

way of knowing this. I mean, you're making a pitch for why the 

Agajanian proposal is better, and why some victims of Camp Fire 

are maybe going to do better if they have more time. But I 

haven't heard you say anything, really, that's flawed about the 

debtors' proposal, other than maybe there ought to be a little 

more front-loading of the notice. But that doesn't speak to 

the question of the deadline. 

So they --

MS. CABRASER: Speaking to --

THE COURT: -- I'm not asking you to make my 

decisions.

MS. CABRASER: Okay.

THE COURT: My decisions are to make, and I'll make it 

as soon as -- I finish --

MR. CABRASER: Right.

THE COURT: -- hearing the arguments. But it's one of 

these things where the reason why things are happening is 

because other things aren't happening. And there doesn't seem 

to be any very reliable evidence that we are actually going to 

save the day for some victims who are in that category of not 

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knowing, not communicated, not being -- and not responding 

to --

MS. CABRASER: Um-hum.

THE COURT: -- the first twenty-eight notices --

MS. CABRASER: Okay.

THE COURT: -- but maybe the last fifteen notices.

MS. CABRASER: Well, first of all to reach them, 

whatever the timing is, and to optimally reach them, more media 

are better. So public relations, free news reports, the street 

teams, old school hand-to-hand noticing --

THE COURT: Yeah, I know, I read that.

MS. CABRASER: -- community activation --

THE COURT: I don't know how that happens. I mean, 

that --

MS. CABRASER: People go out their way and distribute 

flyers in known population centers, (indiscernible) centers, 

Chico, Redding, where we know people are. In the areas of 

Sonoma County where we know people are. That's something the 

tort claims committee would be involved in personally because 

they know -- they know their communities. 

The deadline, Your Honor, it is a balancing act. I 

don't think anybody, whether they're a notice expert or an 

advocate or someone that's had forty years' experience of 

trying to do the best plans in tort situations, as I have, 

could tell you that there is definitive data which is going to 

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drive the absolutely perfect date. 

THE COURT: You haven't had any experience in another 

bankruptcy case where we've had this happen, have you?

MS. CABRASER: In the zone light aspect of the W.R. 

Grace bankruptcy, Your Honor, we did a homeowners' class 

notice. We did it in conjunction with a plan. We had a 

relatively long bar date, primarily because it took folks a 

while to figure out, once we reached them, whether or not they 

had the asbestos-containing insulation in their attics, and we 

couldn't ask them to go up and look or they would get exposed. 

So that was a very particular problem.

But in a sense, we're dealing with an equally unique 

problem here, just trying to deal, as best we all can, with 

what we all understand or believe to be the reality of these 

particular tort claimants. And these particular tort claimants 

are the guinea pigs in an experiment. This experiment hasn't 

been run before, so we're doing the best we can.

THE COURT: No, I understand. Okay. I want to hear 

from any other parties that want to be heard.

MS. CABRASER: Thank you.

THE COURT: And then Mr. Karotkin, I'll come back to 

you for a closing. 

Anyone else want to be heard on the issue? Well, oh. 

For the OCC?

MR. LEBLANC: Yes, Your Honor.

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THE COURT: Okay. Yeah, and I'll come to you after 

that.

Thank you, Ms. Cabraser. 

Yes? Go ahead, Mr. LeBlanc.

MR. LEBLANC: Your Honor, Andrew LeBlanc again, of 

Millbank on behalf of the official committee. Your Honor, we 

rise to just make a few points.

And I know Your Honor had in your hearing order a 

request to discuss the BrownGreer database issues.

THE COURT: Well, I mean, it was -- should I touch on 

that subject in the time we have, yeah? 

MR. LEBLANC: Your Honor, let me give you the 

committee's perspective throughout this process. And we 

agreed -- when the bar date motion was first filed, it was 

filed on May 1st.

THE COURT: Right.

MR. LEBLANC: So we're already several -- two months 

delayed from --

THE COURT: No, I'm aware --

MR. LEBLANC: -- the time it was filed.

THE COURT: -- I'm well aware of that.

MR. LEBLANC: And a large part of that delay, Your 

Honor, was we agreed with the TCC to push off this hearing the 

first time from the 25th of May, when it was originally 

scheduled, to June 11th. And we agreed with that expressly for 

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the purpose of meeting and trying to get access to information 

that would allow these claims to move forward without 

respect -- or the analysis of the claims to move forward 

without, necessarily, regard to the bar date. And that's 

why --

THE COURT: Right.

MR. LEBLANC: -- we raised this in our objections.

THE COURT: They're separate. Separate issues, right?

MR. LEBLANC: It's a separate issue --

THE COURT: Yeah.

MR. LEBLANC: -- but it's related in the sense that 

you have to get this information somehow to move these cases 

forward. And what the committee -- what the official committee 

is singularly focused on is making sure that we can move these 

cases forward in an efficient and effective manner. And that's 

what we've been trying to do from the very beginning. And one 

way that we know we have to do that is through an exchange of 

information.

THE COURT: Um-hum.

MR. LEBLANC: And --

THE COURT: Right.

MR. LEBLANC: -- the debtors' bar date, as the claims 

form, as originally proposed, we thought would provide an 

alternative to that information. And we were supportive of 

that. But if we could get the information through other means 

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meaning, in particular, access to the BrownGreer database, that 

may have obviated the need for the debtors' more expansive 

claims form. 

That issue was taken off the table. We put it in our 

pleadings that we didn't necessarily agree with that decision, 

but that decision has been made. 

THE COURT: Made.

MR. LEBLANC: So we need to get access to this 

information because I think there are a few data points that I 

think are critical to the question of what the right bar date 

is here, given what has to happen in these cases.

First is that there has been a motion to terminate 

exclusivity in a planned term sheet that's been filed, that's 

only just been filed.

THE COURT: Right.

MR. LEBLANC: There's also -- the debtors' exclusivity 

today, based upon Your Honor's order, we -- Your Honor will 

recall they asked for an extension of six months --

THE COURT: Right.

MR. LEBLANC: -- we objected to it. 

THE COURT: You got four.

MR. LEBLANC: Your Honor, we settled on four months. 

It expires on September 26th. 

We share Your Honor's concern that if we are at 

September 26th, just to use that date as an example, and the 

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bar date is not for another five months, I don't know how 

people are going to do what they need to do to move these cases 

forward in any expeditious manner, either to meet Governor 

Newsom's requirements or even just to ensure that we don't 

languish in bankruptcy through another fire season, which as 

everyone knows is --

THE COURT: Well --

MR. LEBLANC: -- critically important.

THE COURT: -- unfortunately, we are going to be at 

bankruptcy in another fire season.

MR. LEBLANC: Well, Your Honor, I mean next year's 

fire season.

THE COURT: Well, then another one.

MR. LEBLANC: Regardless of what Governor Newsom has 

said --

THE COURT: Yeah.

MR. LEBLANC: -- the fire season that begins in June 

of 2020 --

THE COURT: Right.

MR. LEBLANC: -- is what we're concerned about.

THE COURT: Okay. 

MR. LEBLANC: And so what's critical to us is to take 

the steps necessary to move these cases forward. And that's 

why we believe the debtors' bar date is critical to getting 

this done.

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From the time that this was filed, and I know it 

doesn't help the uneducated, unrepresented people who aren't 

versed in bankruptcy, the fact that it was filed two months 

ago, but it's critical that we start this process, get the 

notice out, give them adequate time to respond, and I think the 

debtors have done a good job of striking the right balance. 

It is unfortunate that we have to have a hearing of 

this length to deal with things like how many Twitter posts or 

how many influencers should be used. Those are the kinds of 

things that we should have been able to work out without having 

to come before the Court.

THE COURT: Okay. But it didn't happen, so here we 

are.

MR. LEBLANC: It didn't.

THE COURT: So the question is, what do I do?

MR. LEBLANC: So here we are. 

So what we would urge, what the official committee 

would urge, is that Your Honor set the bar date that the 

debtors have requested of October 21st, that Your Honor approve 

the notice program that --

THE COURT: Do you have a --

MR. LEBLANC: -- has been devised.

THE COURT: -- Does the OCC have a position on 

tweaking the debtors' proposal also? I mean, what Ms. Cabraser 

talked about, that kind of thing?

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MR. LEBLANC: No, we don't, Your Honor.

THE COURT: Because I don't know how to know how to 

tell them what to do. 

MR. LEBLANC: Well, Your Honor, I think we would rely 

on the experts, and the experts who have been retained --

THE COURT: Right.

MR. LEBLANC: -- in this case are Prime Clerk to do 

this notice.

THE COURT: Right.

MR. LEBLANC: We -- we were also the official 

committee in the Takata case where a Prime Clerk was the 

noticing agent and served eighty-eight million notices to 

people who -- and unlike in this case, who may not have even 

known that they had a potentially defective air bag, may have 

lost value in their car. These were latent potential tort 

claims that needed to get notice --

THE COURT: Now, listen. Let me stop you. This is 

not about promoting or bashing Prime Clerk. The issue is 

deadline and whether I should try to second-guess any of the 

experts and say, well, I think you ought to do a little more 

here, a little more there. Ms. Cabraser made her argument 

about it. I have to decide whether I buy that argument. My 

guess is if I tell Prime Clerk to do it, they'll do it. But 

the question is should I be telling them to do it?

But you made your point. Your point is stick with the 

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October 21st --

MR. LEBLANC: Yes.

THE COURT: -- proposal.

MR. LEBLANC: Our point, stick with the October 21st, 

and with respect the notice program, if Prime Clerk has devised 

a notice program that they think is adequate, we support that 

notice program based on -- not based on it being Prime Clerk, 

but they're retained for this purpose in these cases and we had 

no concerns about their notice program even before it was 

supplemented through what Mr. Karotkin said today. We think 

it's an adequate notice program, under the circumstances, to 

provide notice.

THE COURT: And as long as you're up there, what am I 

supposed to do about this BrownGreer report? Anything? Do 

nothing? Act on it? Not act on it? What's your take?

MR. LEBLANC: Your Honor, I think you should enter an 

order to show cause as to why. And to be clear about what 

we're asking for, we served a document request on the TCC. We 

also served a document request on the debtors, we served a 

documents request on the subrogation claimants in which we 

asked of the TCC, just give us a password to this database, 

that's it. And we asked of the debtors -- we asked for the 

debtors to produce the documents that the TCC said to them, you 

would have to produce these documents for us to give you access 

to the database. And to be clear, they were talking about 

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giving access to us, to the TCC, and to the debtors. That's 

the request that we made.

The response we got from the tort committee was to 

accuse us of sanctionable conduct. They literally sent us a 

letter that twice argued that we were violating Rule 11 in 

asking for a username and password.

THE COURT: Well, I issued an order yesterday that was 

going to be a little earlier than I wanted -- than I had 

planned -- and on that day I said, tell me whether I should do 

something about this BrownGreer report. I'm not going to do 

anything today because that would be unfair to everyone. 

But it's sort of like a 800-pound gorilla sitting in 

the living room. And I've got to go in the living room and see 

if he's in there. I don't even know what to do with it and how 

it relates to the questions before the house today. There's 

only two questions, there were three today. And that's why I'm 

not going to act on BrownGreer. 

But so one more question for you, Mr. Leblanc, the OCC 

has accepted the debtors' willingness to go with the TCC's 

form. You've made it clear on the proposed deadline. I take 

it, then, when and how you get the BrownGreer information is 

not relevant to either of those two questions?

MR. LEBLANC: It no longer is --

THE COURT: Okay.

MR. LEBLANC: -- Your Honor --

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THE COURT: Okay.

MR. LEBLANC: -- because --

THE COURT: Okay.

MR. LEBLANC: -- the debtors' claim form is not --

THE COURT: Correct.

MR. LEBLANC: -- the more expansive claims form is no 

longer here.

THE COURT: And so if I go with the debtors' claim 

form and it goes out, then something's going to happen, and 

whatever information needs to be obtained later, we deal with 

it later.

MR. LEBLANC: Yes. So I mean, Your Honor, the 

issue -- one of the issues that we were struggling with is, 

when the debtors advised everyone, the TCC and UCC at the same 

time, that they were moving to the TCC's claims form and away 

from their form, we then realized that our entire position, 

which was we just need to get this information --

THE COURT: Yeah.

MR. LEBLANC: -- whichever way we can, that that was 

affected by that. So we immediately served document requests 

pursuant under this motion.

THE COURT: Okay.

MR. LEBLANC: And the issue, Your Honor, is that among 

the objections that the TCC had was, well, you need to seek 

this under Rule 2004 and follow your -- serve a subpoena on us 

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under Rule 2004. And we'll obviously do that. 

I think, Your Honor, it is -- the elephant in the room 

is this database because we've been told by the TCC and by the 

constituent members of the TCC that this database has the 

information that we'll all need to build up a claims estimate.

THE COURT: Okay. Well, again, I'm not going to act 

on it today.

MR. LEBLANC: Your Honor, we would urge the Court, 

though, to enter an order to show cause as to why that 

shouldn't be produced. Alternatively, we'll seek authority 

under Rule 2004 and begin pursuing it that way. It gets to the 

same place. I think we should -- it's been many months since 

we've had discussions about this database and haven't had 

access. So we'll deal with it in a different procedural way if 

we have to. But we think an order to show cause --

THE COURT: Okay.

MR. LEBLANC: -- would make sense.

THE COURT: Thank you, Mr. LeBlanc.

MR. LEBLANC: Thank you, Your Honor.

MR. GOODMAN: Your Honor, could I just be briefly 

heard on the --

THE COURT: Well --

MR. GOODMAN: -- BrownGreer issue?

THE COURT: -- what?

MR. GOODMAN: Could I just be briefly heard on the 

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BrownGreer issue? I want to clarify --

THE COURT: Well, I'm not going to act on it. I'd 

rather that we get to the critical question, so let me come 

back to that.

So the gentleman over here. You wanted to be heard, 

so come on.

MR. LEMON: Thank you, Your Honor.

THE COURT: And then I'll go to you next, sir.

Again, just state your name for the record. I think I 

keep track of lawyers who have been appearing frequently, 

but --

MR. LEMON: Thank you. John Lemon, appearing for the 

Singleton firm on behalf of the Singleton firm's fire victims.

THE COURT: And you got on your plane late, but you 

got here, see?

MR. LEMON: I did. I made it.

THE COURT: Yeah. Well, the hearing went late, too.

So Mr. Lemon, what do you want me to do today?

MR. LEMON: I just wanted to address this issue of the 

bar date. And specifically, the Singleton firm -- I appreciate 

Your Honor's concerns about moving this process along. And 

frankly, we agree that the holiday season is not going to see a 

spike in claim forms being filed. We actually tend to agree 

more with the debtor than with the TCC.

However, we think that what strikes the best balance 

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here is a deadline of November 8th, which would be exactly one 

year since the Camp Fire.

THE COURT: But I mean, is there some magic to that? 

Is it because it's psychological or --

MR. LEMON: Exactly.

THE COURT: -- otherwise?

MR. LEMON: I just think it's easy. Because word of 

mouth, people can remember it. If your house or whatever 

burned down in the Camp Fire on November 8th, 2018, you have 

until November 8th, 2019 to file the claim in the bankruptcy. 

It's very similar to the debtors' bar date, but I think it 

would work better for everyone --

THE COURT: I mean, it's two and a half weeks.

MR. LEMON: Right.

THE COURT: Okay.

MR. LEMON: That's our request.

THE COURT: That's all?

MR. LEMON: Thank you.

THE COURT: Yes?

MR. STAMER: Good afternoon, Your Honor. For the 

record, Michael Stamer from Akin Gump Strauss Hauer & Feld, 

here on behalf of the ad hoc noteholder committee.

Your Honor, I'll be relatively brief.

THE COURT: That's okay. Take whatever time you want, 

Mr. Stamer.

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MR. STAMER: I greatly appreciate that. 

Your Honor, the members of the ad hoc committee hold 

approximately -- or in excess of ten billion dollars of the 

unsecured bond and bank debt of the debtors in these Chapter 11 

cases. Your Honor, we filed a very short joinder to the UCC or 

the OCC's objection to the TCC's bar date motion, if you can 

follow that.

THE COURT: Well, I mean, there's just been a flurry 

of stuff.

MR. STAMER: I'll distill it.

THE COURT: And one of the great joys in life is to be 

told there's an update on something because then I don't have 

to read what's being updated.

MR. STAMER: Here's the update. Your Honor, I'll 

distill it. 

We fully support the debtors' request for a bar date 

date of October 21st. As you'll hear in my presentation, it's 

bit of a back-handed support. But nevertheless we support --

THE COURT: Hey --

MR. STAMER: -- October 21st --

THE COURT: -- it's a support. 

MR. STAMER: A support is a support.

Your Honor, also as referenced earlier, we filed 

yesterday a motion to terminate the debtors' exclusive 

periods --

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THE COURT: Wait, Mr. Stamer, do you have a position 

on the methodology of -- maybe you heard Ms. Cabraser and 

others comment, and do you have -- your committee doesn't take 

a position on that?

MR. STAMER: We join the committee's pleading that 

they filed. From our perspective -- again, we support the 

debtors with respect to --

THE COURT: The debtors' proposal.

MR. STAMER: -- their proposed bar date. So their 

procedures and --

THE COURT: Well, bar date and procedure.

MR. STAMER: -- their date. Correct, Your Honor.

THE COURT: Okay.

MR. STAMER: We support the debtors on both.

THE COURT: Okay. So I mean, if you want to tell me 

that you filed the motion for exclusivity that's fine, but what 

else? That's not an action item today, right?

MR. STAMER: Actually, Your Honor, it's not. And I 

don't intend to stand at the podium and talk about it. In your 

provisional order, you asked the question regarding the status 

of the plan. And --

THE COURT: Right.

MR. STAMER: -- from our perspective, it was 

unfortunate that the company did not respond to your question 

directly.

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So you asked the question in your order, is there a 

cause for delay? There's nothing public with respect to the 

filing of the plan. Is a later bar date going to be a problem? 

And again, we agree that it is a significant problem. And the 

reason is, Your Honor, we believe that this case, more than 

anything else, needs a greater sense of urgency, a greater 

sense of transparency, and frankly, a greater sense of 

cooperation.

Your Honor, as people have said over and over again, 

these cases were filed principally to deal with the fire 

claims.

THE COURT: Right.

MR. STAMER: Equitable, fair treatment of the fire 

claimants. And Your Honor, as far as we can tell, and I say it 

with all due respect, the debtors have made very little 

progress with respect to reconciling fire claims. 

They did, in fact, make a public announcement that 

they settled a billion dollars -- or they settled certain 

public entity claims for about a billion dollars. And Your 

Honor, many of us found out about that for the first time in 

the press reports. Which again, we think is --

THE COURT: You can add me to that list, by the way.

MR. STAMER: -- cooperation -- excuse me, Your Honor?

THE COURT: You can add me to that list.

MR. STAMER: Understood. But there's a lot of stuff 

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that you find out through the press. Something like that, 

actually we shouldn't be reading about. We should be hearing 

about it from the debtors --

THE COURT: But again --

MR. STAMER: -- the UCC should as well.

THE COURT: -- I can't solve that problem today, can 

I? I mean, I can give everybody a lot of lecture about 

cooperate, but I can't make it happen.

MR. STAMER: Your Honor, you're exactly right. 

THE COURT: Everybody knows my views on exclusivity if 

you haven't -- you've been living on the moon.

MR. STAMER: We have, Your Honor. And I understand we 

filed our pleading at 5 o'clock in the morning, California 

time, yesterday -- it seems like a month ago -- and Your Honor 

hasn't had an opportunity to read it.

THE COURT: I didn't say that.

MR. STAMER: You read it quickly. You read it 

quickly.

Your Honor, again, in the spirit of trying to move the 

case forward and in connection with answering your question in 

your provisional ruling, we do think that you need -- for the 

reasons that the debtor said as well, you need to have the 

earliest possible bar date.

The term sheet that we filed attached to the 

exclusivity motion calls for -- and this is all over the press, 

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Your Honor -- up to a thirty billion dollar new investment, 

Your Honor, with up to eighteen and a half billion dollars set 

aside for purposes of satisfying fire claims.

Now, as part of that construct there needs to be a 

determination, whether consensually or by the Court, as to what 

the amount of the fire claims are. There needs to be some form 

of a metric in place because this company's not going to get 

out of bankruptcy --

THE COURT: No. I'm well aware of that. And I got 

it. Of course, I understand that.

MR. STAMER: Again, also relevant to the timing here, 

one of the crazy things about this Chapter 11 case like no 

other, except for the prior PG&E Chapter 11 case, is there is a 

very significant political element to it, which is hard to kind 

of get your head around. 

What we have done, Your Honor, in our proposal, when 

you read it a second time, is we have made this, the 

investment, attractive to hopefully everyone involved, but 

attractive to the politicians and the people that elected them 

to serve in the state congress and the governor's office. It's 

rate neutral. The idea is to put money in, not rely on the 

backs of the ratepayers in order to satisfy the fire claim.

MR. KAROTKIN: Excuse me. Is Mr. Stamer arguing his 

exclusivity motion now?

UNIDENTIFIED SPEAKER: I think so.

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THE COURT: No. He's actually supporting your 

positions. 

MR. STAMER: Exactly, Your Honor. Exactly.

THE COURT: But let's -- 

MR. KAROTKIN: I think he's made that clear, and he 

can sit down now.

THE COURT: -- let's move on. 

MR. STAMER: Right. It's a little bit of a backhanded support, but a support is a support.

THE COURT: Make sure you open the door when you go 

out.

MR. STAMER: All right. Probably a good idea.

THE COURT: Okay. Bust seriously, Mr. Stamer, I need 

to hear from others about this subject.

MR. STAMER: Just, Your Honor --

THE COURT: Okay.

MR. STAMER: -- I'll echo one other thing. Actually 

two other things, if I could. 

You've heard about the governor's wildfire package. 

Again, we think that should be a wakeup call for this case. 

Again, the need for a greater sense of urgency.

Your Honor, with respect to BrownGreer -- and I give 

the tort claimants a tremendous amount of credit because they 

have masterfully held on to the relevant information to the 

detriment, I think, of everyone involved. 

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We don't minimize their struggles with respect to the 

damage cause by the fire, but our view is we want to get a plan 

confirmed that pays fire victims. And the best way to do that 

is to have everyone move this process along, to have an open 

and transparent process.

And Your Honor, what we would like -- and we joined 

the discovery requests that were made by the official committee 

seeking the relevant information. We would echo the 

committee's request with respect to the BrownGreer information. 

Finding a way to make that available, whether it's through 

order to show cause by this Court or otherwise, and if we have 

to go through the formal discovery process, it will be timeconsuming and expensive. But it shouldn't just be limited to 

BrownGreer. It should be an open and transparent process so we 

can collectively get to the bottom of the fire claims to get 

this company out of bankruptcy as quickly as possible.

THE COURT: Well, I'll just make the statement to you, 

but I'm really making it to every lawyer in the room. I don't 

like to get bogged down on formalities of discovery requests in 

a culture that makes things happen more quickly, and people 

exchange information. I don't like the idea of on my own 

deciding to issue an order to show cause about somebody 

produced this report. But if nothing happens, I will be 

receptive to that. 

But somebody either needs to meet and confer and come 

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to an understanding on how this information can be exchanged, 

or I will act quickly on a motion for somebody to compel it. 

So leave it at that for now. Let's stick with what I have to 

decide today. And I want to know if there's anyone else who 

wants to be heard on the subject of either the claims bar date 

or the methodology. Gentlemen --

MR. STAMER: Thank you, Your Honor.

THE COURT: Yes, sir. 

MR. SKIKOS: Good afternoon, I'm Steve Skikos. I was 

liaison in the state court proceedings, and I will have a 

couple comments connected -- or facts, actually, to provide 

Your Honor that might help you in your determination as to the 

bar date and the notice.

THE COURT: Just tell me, what -- liaison in some of 

the state court coordinated litigation?

MR. SKIKOS: Yeah. There was --

THE COURT: The fire --

MR. SKIKOS: one --

THE COURT: Okay, yeah.

MR. SKIKOS: -- state court coordinated litigation --

THE COURT: Okay.

MR. SKIKOS: -- for the North Bay fires --

THE COURT: Yeah, all right.

MR. SKIKOS: -- run by --

THE COURT: I understand that.

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MR. SKIKOS: Okay. So it's unfortunate that the issue 

of BrownGreer has come up in this context because this hearing 

is supposed to be about notice and the bar date and the proof 

of claims.

THE COURT: No, but I take responsibility for putting 

the BrownGreer out in the paper because I kept hearing about 

it.

MR. SKIKOS: Right. And it has some relevance, 

though.

THE COURT: But I told you I'm not going to act on it 

today.

MR. SKIKOS: Right. But it does have some relevance.

THE COURT: Okay.

MR. SKIKOS: There's 75,000 to 100,000 people who live 

outside this bankruptcy who have potential claims. Over half 

of them are unrepresented. There are tens of thousands of 

people who have been displaced. And within the BrownGreer 

system, which exists outside of this bankruptcy, it is not in 

the possession, custody or control of the TCC. It is not in 

the possession, custody, and control of BakerHostetler, they 

never had access to it. It is not in the possession, custody, 

and control of any financial analyst. It is the work product 

property of sixty law firms who got together when, after the 

Camp Fire happened and before the bankruptcy, and said, we have 

to do something because we are going to fall behind. And the 

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tort claimants are so far behind in this case and this race to 

the bar date, with the insurance companies and with the UCC, 

that they need some way to try to catch up. 

And so what we did with BrownGreer is we said to the 

sixty law firms, continue what you did in the state court. The 

state court -- BrownGreer exists as part of the state court 

orders --

THE COURT: Um-hum.

MR. SKIKOS: -- a set of integrated orders within the 

state court system which I will take two minutes to describe in 

a minute. But it's important for your ultimate decision here.

What we did is we said to the insurance companies and 

to PG&E and to the public entities, let's use what we did, what 

we accomplished in the state court here in this bankruptcy.

And I came to this Court on January 31st and I said, 

we should try this. Because we have to take 75 to 100,000 

people out of being way behind the curve in this case and give 

them a chance to work up their claims safely and put their work 

product in with their damage categories without being attacked.

So what BrownGreer is, as it exists today, it exists 

completely outside of this bankruptcy. It is information 

created to help create a proof of claim form. We spent five 

months on a two-page document. I went to PG&E and to everybody 

else at the start and said, guys, we did the notice of adoption 

and short-form complaint and it's the same document, basically. 

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Why can't we use the same systems we used in the state court 

case? 

MR. SKIKOS: Now, Your Honor nailed it today when you 

analyzed the proof of claim. We have gone through this proof 

of claim form and you have to understand, sir, a couple of 

things about it. There are going to be a thousand questions. 

There's going to be immense confusion with this proof of claim 

form. The amount of time we have done just testing it, is 

unbelievable. And what's going to happen in the real world is 

that these people are going to get this proof of claim form and 

they're going to have tens of thousands of questions. What 

BrownGreer exists for is to run -- is to take the proof of 

claim form that the Court ultimately orders and allow the firms 

to put their data in, merge it, and run test plans within the 

work product. 

THE COURT: But I'm losing something here because the 

claim form asks for a name, a date, nature of the damage -- I 

mean, the harm, you know, home, house, personal injury, and an 

estimate of claim. Period. 

MR. SKIKOS: Loss -- loss of use, where did the use 

occur? 

THE COURT: Right. 

MR. SKIKOS: What is the damage? 

THE COURT: Right. But I mean, is that -- I realize, 

that might be more than some unsophisticated people are 

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comfortable trying to assemble but it's not a lot of 

information. 

MR. SKIKOS: We've done a good job. 

THE COURT: Yeah. 

MR. SKIKOS: Mainly us.

THE COURT: I'm not sure of the point you're making. 

You might've had a legitimate complaint about the form that the 

debtor wanted but that's iffy. You're not unhappy with the 

form that's in place now, right? 

MR. SKIKOS: There's still going to be -- my point 

about BrownGreer is this. There's still going to be thousands 

of questions. 

THE COURT: Okay. 

MR. SKIKOS: Family versus individual. 

THE COURT: Got it. 

MR. SKIKOS: And what we are trying to do, BrownGreer 

exists for one reason at the start which is to allow firms to 

safely put the data in to run test proof of claims so that they 

can put together their families, their information related to 

that. That's just work product. BrownGreer exists because 

there're damage categories that people were doing under the 

state court system. Those damage categories are work product. 

BrownGreer exists to keep the medical information and the 

insurance information for an individual law firm to work within 

the system to put up work product so that we can do this in a 

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systematic way. And what we did is we went from 3,000 cases 

that were in within the JCCP, to 23,000 people outside of this 

bankruptcy. 

And here's the most important part. I went to the 

debtor and to the insurance companies and to the public 

entities and said, we have protections in the state court 

system if we're going to use BrownGreer. We have case 

management orders that say it's work product. We have case 

management orders that say that the damages discovery will not 

be done against this. We have case management orders that deal 

with a bunch of different factors relating to this product. I 

said why aren't we using this in this case? Because everybody 

wants to speed this up. We could -- we would be at 35,000 

cases right now. We would be at damage categories that would 

make sense. We would have an estimation worth that's moving 

forward.

Instead what we've done is we've taken five months to 

do a two-page form. And here's the problem we have, the sixty 

law firms are -- who are putting work product in there, they're 

not going to agree to turn over their work product to PG&E. 

They don't have any obligation to do that. But what we can do, 

is we could come up with a case-specific system in this 

bankruptcy that will speed this process dramatically. How do I 

know that? Because we did it in the state court case. We did 

the exact same thing.

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And here's the issues for your notice and for your bar 

date. We know from our work in the state court cases, 

unraveling 3,000 mixed cases and putting them into 2,000 cases, 

that it took about thirteen months for people to get together 

to start being able to recover from these fires. We know -- so 

that -- if you do the thirteen months, it's basically 

Thanksgiving. 

We know from the state court case that with respect to 

the notice program, there is so much -- it's not the number of 

times. That's irrelevant. It's the substantive information 

that is missing for these people. These people have been told 

for a year by PG&E in ads that their fires were caused by 

climate change exclusively. These people have never been told 

that the insurance companies are making claims on their cases. 

These people have no idea what's going on with respect to the 

issues within the bankruptcy and that's why there's 75,000 

people who are not in this court. And what we need to do -- my 

proposal is this. A Thanksgiving party, a notice program that 

allows for substantive facts to be presented. Because I don't 

have any opinion. 

THE COURT: I don't know what you mean. What are you 

saying? 

MR. SKIKOS: Substantive facts meaning there are 

certain facts, misinterpretations that exist out there. I'm 

not an expert in notice. I'm not going to even talk about 

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procedure. But there are misunderstandings out there that 

people are saying, I don't have a claim, because PG&E went 

bankrupt. I don't have a claim, even though my insurance 

company made a claim on my case. And they didn't know that. 

MR. KAROTKIN: Your Honor, is this more testimony now? 

MR. SKIKOS: This is just facts. 

MR. KAROTKIN: Mr. Skikos didn't even file the 

responsive pleading and now he's testifying? 

THE COURT: I know. I'm trying to figure out what to 

make of this. 

Finish your point and tell me what your proposed 

action item is here. 

MR. SKIKOS: Here are my proposed action items. 

THE COURT: Because I still, like I said over and over 

again, I got two decisions to make. 

MR. SKIKOS: Right. All I want is for the BrownGreer 

discussion to be one of an informed discussion for this Court 

to consider. 

THE COURT: And I already said three times, I'm not 

going to act on it today. 

MR. SKIKOS: Okay. And --

THE COURT: BrownGreer surfaced in the bankruptcy

court yesterday because I put it into an order saying, somebody 

ought to tell me about it. You've told me some information 

about it. I'm not going to issue an order for you to produce 

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it. If somebody makes a motion to order it, I'll hear the

arguments. But let me, Mr. Skikos, did I get it right? 

MR. SKIKOS: Close enough. 

THE COURT: Skikos. Bar date and procedure. Tell me 

what you recommend? 

MR. SKIKOS: Bar date, based upon our experience in 

the North Bay cases, it takes about thirteen months for people 

to get moving again. I would propose November. 

THE COURT: November what? 

MR. SKIKOS: November -- Thanksgiving. Sorry. 

THE COURT: Well, November what? 

MR. SKIKOS: 28th. 

THE COURT: November 28th. Okay. That is actually 

Thanksgiving. We don't really want the claims --

MR. SKIKOS: Notre Dame/USC game. 

THE COURT: -- to be filed on Thanksgiving day. Huh? 

MR. SKIKOS: The Notre Dame/USC game. 

THE COURT: You had to say that, didn't you? 

MR. SKIKOS: Yeah. 

THE COURT: Okay. But you don't really want me to put 

a claims deadline of Thanksgiving? 

MR. SKIKOS: No. But I mean around that day. That 

will give people -- what Ms. Cabraser said is accurate. There 

is going to be some holiday discussions and the holiday 

discussions have nothing to do with the number of times they've 

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seen it. The holiday discussions are going to be, oh my God, I 

didn't know my insurance companies were filing claims on my 

case, oh my God, I didn't know X, Y, and Z, that this wasn't 

climate change exclusively. So that's what the holiday 

discussions are about. So --

THE COURT: But if you get in the mail from somebody 

that says, I'm in bankruptcy and if you'd like to file a claim, 

you can file a claim. Do you have to get into a debate about 

climate change or what your insurance company did? 

MR. SKIKOS: Yeah, because people -- these are not 

litigious people --

THE COURT: I know that. 

MR. SKIKOS: -- these people just want to know --

THE COURT: I understand that. But if you get a form 

that says, if you sign this form and send it back, you're going 

to be in the system with a claim on file. I mean, that's --

that seems simple. Whether it's --

MR. SKIKOS: It seems simple but the unfortunate facts 

of this circumstance which I've been living since the fire, I'm 

from Santa Rosa --

THE COURT: Okay. 

MR. SKIKOS: -- is that the people have been -- don't 

have sufficient information to make an informed decision. 

THE COURT: I guess what I'm debating, and Mr. 

Karotkin is going to complain that you're testifying and you're 

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acting as an expert, is what information does a person need to 

know to file a proof of claim? You're saying, well, I need to 

know whether I can even assert a claim. Okay. I can't change 

that, and TV ads or serious radio isn't going to tell me that. 

It's going to tell me, if you have a claim, file it by a 

certain date. So you're arguing for November 28th, I've got 

October 21, November 8th, November 28th, and April -- I mean, 

January 31st. But what about the procedure? What about the 

notice procedure? Are you --

MR. SKIKOS: I can't --

THE COURT: Do you have a position one way or the 

other on that? 

MR. SKIKOS: I have no understanding of notice 

procedures. 

THE COURT: Okay. 

MR. SKIKOS: Just bar date. 

THE COURT: So focusing on -- so let's leave it at 

that. You're not taking a position on which procedure. You 

made an argument as to why I should move the date roughly one 

month down the road, despite the arguments of two other counsel 

representing different interests. And your view is that by 

putting another month in there, something will facilitate or 

make life a little more bearable for some of the victims to 

assert a claim. 

MR. SKIKOS: A significant percentage --

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THE COURT: It's hard to know the difference between 

October 21 and November 28 but it's five weeks. So --

MR. SKIKOS: Well, it's because we're going to get 

through fire season. And there's two other points. The social 

media aspect that Ms. Cabraser talked about is incredibly 

important in this particular context. The -- I'm just telling 

you from a factual standpoint, dealing with -- as liaison in 

dealing with sixty law firms in the North Bay cases, that there 

is a significant movement, a change in the people after about 

thirteen months. 

THE COURT: Okay. I'll accept that. But I also have 

to assume that those sixty law firms have at least sixty 

clients and probably a lot more than sixty, and they are 

responsible members of the bar and they will pass on the word 

to their clients, you've got to file a claim because the 

bankruptcy court has said you have to. And you know, word of 

mouth is important and victims know about the fate of other 

victims. So again, I will make a decision on a date and I 

think leave it at that. 

MR. SKIKOS: I, 100 percent agree with you on 

everything you just said. 

THE COURT: Okay. 

MR. SKIKOS: The only caveat I would say is this. 

Over fifty percent of the people are unrepresented. 

THE COURT: No, I got -- I understand that. 

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MR. SKIKOS: So anyway. Thank you, Your Honor. 

THE COURT: Anyone else want to be heard before I --

Mr. Karotkin make closing argument? Any more opposition to 

this?

Yes. You were here before.

MR. GOODMAN: Thank you. 

THE COURT: Go ahead. 

MR. GOODMAN: Again, I just wanted to clarify --

THE COURT: Mr. Goodman. 

MR. GOODMAN: -- something. Because I know that, you 

know, coming down the road, this issue of data and documents 

information, it's not here today and I appreciate the Court 

making that clear, but it is coming. You know, the TCC does 

not have possession, custody, or control of the BrownGreer 

database. I don't have access to it. Baker & Hostetler

doesn't have access to it. The TCC's financial advisors don't 

have access to it. 

THE COURT: Okay. But the bankruptcy lawyers can at 

least inform people like Mr. Sacos (phonetic) and others who 

aren't familiar with bankruptcy what the strengths and 

weaknesses are, and if work product says information cannot be 

obtained, it can't be. If Rule 2004 and the more generous 

discovery procedures of the bankruptcy law,do allow that 

information, then I suggest that somebody ought to get on with 

making it available. That's all. And we'll treat it 

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confidentially, and it's not going to go on the internet. It's 

going to be done -- something's going to be done with it 

properly. But that, again, I promise it's not an action item 

today. 

MR. GOODMAN: And thank you for that clarification 

again. I appreciate that. But I also wanted to make this 

point as well is that the TCC does not have access to the 

debtors' database. BakerHostetler does not have access to the 

debtors' database. Our financial advisors don't have access.

THE COURT: But for what?

MR. GOODMAN: Well, I'm just saying to the extent that 

we end up in a situation involving BrownGreer it's also going 

to involve PG&E's data. 

THE COURT: Well, it's a 2004, and before we get to 

2004, it's the same judge who insists on lawyers, responsible 

lawyers being cooperative, and if not, we'll do it the hard 

way. That's all. What's the point?

MR. GOODMAN: Thank you, Your Honor.

THE COURT: Okay. Mr. Karotkin, you've got the 

closing argument here. 

MR. KAROTKIN: I'll be very brief.

THE COURT: You don't have to be. No one else has 

been.

MR. KAROTKIN: That's why I'll be very brief. First 

of all, I got up a number of times because no evidence has been 

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put in in any --

THE COURT: And no findings have been made, either.

MR. KAROTKIN: All right. But to in any way question 

the notice program that we have proposed, no evidence. It's 

all colloquy. It's all hearsay. Nothing has been presented to 

you to question --

THE COURT: Well, but you know what, I'm going to 

interrupt you by saying this. I know and respect experienced 

lawyers, and they don't make a habit -- and you're one of 

them -- don't make a habit of making stuff up. So when 

respected members of the bar like your opponents make a 

statement, I take them as officers of the court trying to 

persuade me to reach an outcome. And you shouldn't take 

offense at it any more than I take offense at argument you 

make. 

So they can make their argument. I'm not going to 

make a finding that something needs to be something. This is a 

discretionary call, as you know, and I have the very, very 

persuasive argument you presented. I have to decide whether to 

tweak it or reject it or something. That's all.

MR. KAROTKIN: Okay, but Your Honor --

THE COURT: Okay.

MR. KAROTKIN: -- what I'm saying is nothing was 

presented to you to give you a basis to tweak it. Nothing. 

THE COURT: Well, certainly the opinions of a couple 

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of experienced lawyers.

MR. KAROTKIN: And let's go to Ms. Cabraser's opinion.

THE COURT: Okay.

MR. KAROTKIN: When you asked her what is the 

frequency in class action cases, you specifically asked her 

that question; she didn't answer that question. But our expert 

did answer that question. And she, in her affidavit, said it's 

a lot -- significantly less than the frequency we have here. 

In addition, our expert, and she'll get on the stand 

and tell you right now, that what you said was exactly right. 

After ten times or fifteen times or twenty times -- and it's in 

her declaration -- there are diminishing returns. That's the 

situation. So just adding a hit of fifty-eight times is a 

waste of money. It actually is counterproductive. And if you 

want to hear testimony on that --

THE COURT: I don't.

MR. KAROTKIN: -- we have testimony on that.

THE COURT: It's in the record, and I've reviewed it.

MR. KAROTKIN: So as I'm saying -- what I'm saying, 

there is no basis to second-guess what we're proposing. 

As to the October 21st date, again, we think it's more 

than adequate. No one has come up with any logical reason why 

it should be extended, particularly under the circumstances 

here where the proof of claim form has been modified to make it 

extremely simple. In the Takata case, a mass tort case, I 

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believe that Mr. Leblanc referred to it, that notice was eighty

days. There is an eighty-day bar date notice in a mass tort 

case for eighty-nine million people who got notice. 

THE COURT: Yeah, I think people get a recall notice 

because their air bag might blow up are a little different from 

people whose house did blow up. So I mean it's different.

MR. KAROTKIN: But that was personal injuries, as 

well.

THE COURT: Well, a few. A very few.

MR. KAROTKIN: All right.

THE COURT: Most of the Takata airbags were recalled 

for people like my wife who got a notice saying I've got to 

take this damn thing in to get it fixed. And she had to stand 

in line to get it fixed and got it fixed. But, fortunately, it 

didn't blow up and --

MR. KAROTKIN: Fortunately.

THE COURT: -- kill her in the meantime.

MR. KAROTKIN: Yes.

THE COURT: Okay.

MR. KAROTKIN: But again, Your Honor, we're talking 

ninety, ninety-five days for people, actual notice. The notice 

will go out quickly. It's more than adequate and it's 

important -- as you said, bankruptcy should be leading this, 

not dragging this case to conclusion. 

I'll make a couple of remarks about Mr. Stamer. I'm 

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not going to argue the exclusivity motion here today. Suffice 

it to say we will formally respond at the appropriate time and 

demonstrate why that motion should not be granted. 

Talk about transparency and notice and cooperation, 

Mr. Stamer called me two minutes before his motion was filed. 

So if that demonstrates cooperation and transparency, well so 

be it. 

And I will note that in their plan, he complains about 

nothing being resolved. Nothing is resolved in their plan. 

They have no deal with --

THE COURT: We're not arguing the --

MR. KAROTKIN: -- the fire claimants.

THE COURT: We're not arguing the exclusivity motion.

MR. KAROTKIN: I understand, but I think it's 

important to make sure the record is clear. And the only 

settlement in their so-called plan is the settlement we reached 

with the public entities, so let's leave it at that. 

So Your Honor, we would ask that you approve the 

October 21st bar date and our noticing plan so that we can move 

these cases forward.

THE COURT: Mr. Goodman, we talked about, and I said 

in my order of yesterday, that I was going to decide whether to 

go with the debtors' plan or whether the TCC alternative should 

be chosen now or deferred. I mean, is this what I'm -- your 

view that I'm supposed to now make a choice between one or the 

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other and that's it? 

I mean, there's still some of these failings or 

weaknesses that the debtor pointed out about the Angeion plan 

and Ms. Cabraser made some arguments, largely in favor of it, 

but don't you think that my only choice today is to approve the 

debtors' plan or disapprove it, because there isn't in the form 

of evidence and opportunity for the debtor to vet a comparative 

of Angeion as the other choice today. You agree or disagree?

MR. GOODMAN: I would say this. I think my 

understanding is that if the Court determines that there are 

factual disputes on these issues, it could schedule an 

evidentiary hearing --

THE COURT: Well, we'd never get this done. You'd 

have -- your motion will be granted by lethargy.

MR. GOODMAN: And given that response, obviously, I 

think we need to get this done today. I think on that point I 

would come back with this. The debtors, from when they first 

filed their plan to when they filed their reply brief seven 

days ago, to what they handed to you this morning and to us 

this morning for the first time, they've obviously made 

significant movements --

THE COURT: Right.

MR. GOODMAN: -- in response to what was filed by 

Angeion.

THE COURT: So the system works in that regard.

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MR. GOODMAN: So that was positive news on the day. 

Obviously, I think that the critical issue for us right now is 

the bar date in terms of what that date ultimately ends up 

being. And that, in my view, Your Honor, that's not a -- one 

statute that I notice isn't cited in anyone's papers is Section 

363(b). Right. We're not here on the debtors' business 

judgment. We're here on what is appropriate under the 

circumstances.

THE COURT: No, this is discretion to me, I'm sure.

MR. GOODMAN: Correct.

THE COURT: So I've got the Notre Dame game. What's 

the day of the presidential election? Oh, that's November 5th, 

I believe. Somebody else suggested November 8.

MR. GOODMAN: 2020, Your Honor.

THE COURT: Presidential election day, hm.

MR. GOODMAN: That's 2020, Your Honor.

THE COURT: Oh, yeah, that's right. 2020. Wishful 

thinking. I didn't say that. They'll call for my impeachment, 

but I can't even be impeached. 

MR. GOODMAN: We have a range, obviously, before the 

Court, right. A number or a date in December I think would be 

very meaningful for the victims of the Camp Fire. Not in terms 

of the time that that would provide, but I also do believe Ms. 

Cabraser, and I take her at her word, that there are meaningful 

changes in terms of activity in the holiday season. If we 

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could get a date in December, if it's December 1st which is 

after Thanksgiving, just after Thanksgiving, or December 31st, 

so that you take the advantage of the December holiday season, 

I really do believe that that would make a meaningful 

difference in this case and could result in not just one or 

two, but potentially several thousand fire victims being able 

to file claims in this case and participate and be in a point 

where they can get a distribution. 

And it's very critical, Your Honor, that we have the 

sufficient time to implement the notice procedures because if 

we do it right now, if we get -- if we allow sufficient time 

and we do a robust notice plan, what that means is on the 

backend of this case you have fewer issues where people show up 

and say I didn't know; I didn't hear notice.

THE COURT: No, I know.

MR. GOODMAN: We're just trying to avoid that. And we 

think if we do it right on the frontend we're maximizing the 

likelihood that that's not going to happen. I really 

appreciate the time and effort the Court has put into --

THE COURT: Well, I appreciate --

MR. GOODMAN: -- these issues.

THE COURT: -- all of your efforts, too. We can joke 

about things, but this is not a joking matter. It's serious 

business. Okay. 

Let me just take one second to get my thought 

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together, but Mr. Karotkin, I wonder whether, given the time 

we've put in on this, whether we ought to defer this whole 

protective order issue to another day. Do you really want me 

to try to deal with that today? I mean, I won't take a break 

here until I tell you what my decision is on these two critical 

issues, but the question is we've been going -- it's twenty to 

2 and people might want to have some food and take a break. 

And I'll resume if we think it's productive on the protective 

order, or we can do it either -- and we don't have to put it 

over to the next hearing. We can have a phone conference or 

something else. What do you recommend and the committee?

MR. KAROTKIN: Mr. Slack, can answer your question.

THE COURT: Yeah, what do you --

MR. SLACK: Your Honor, we're okay -- it's been a long 

day -- putting it off. We wouldn't want to put it off very 

long, and I would suggest doing it in person given the number 

of interested parties. 

And the other thing I can say, Your Honor, is we've 

made a lot of progress --

THE COURT: Right.

MR. SLACK: -- in narrowing the issues. So hopefully 

we can make that presentation to you with even further narrowed 

issues.

THE COURT: Well, Mr. Goodman, are you in charge of 

this, too? You're pointing to your partner.

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MR. GOODMAN: No, I'm not, Your Honor. That would be 

my partner Mr. Lars Fuller, who's --

THE COURT: So Mr. Fuller, do you agree to the changes 

that the debtors agreed to about this joint statement? I mean, 

if you are, then we can solve this problem.

MR. FULLER: Your Honor, the TCC and the debtors are 

aligned, I think, with respect to the issues that we were 

disputing. There's a number of other parties that have weighed 

in, and so separately, because we have two competing --

THE COURT: Yeah.

MR. FULLER: -- motions again --

THE COURT: Right.

MR. FULLER: -- the TCC has communicated with the 

NextEra objectors. It is not opposed to their proposed 

language. I don't think we're in alignment with PG&E in that 

respect. We've also communicated with the state agencies and 

the federal, the USA. 

THE COURT: Right.

MR. FULLER: We're not opposed to their modifications. 

I think we are aligned with PG&E on those modifications. We 

almost need a Venn diagram at this point. But at least with 

respect to the disagreements that we were having, I think we're 

aligned.

THE COURT: Okay. Yes, sir, let me hear from you. 

And I promise I want to get this hearing over and resume it or 

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reschedule it, but --

MR. ESSER: Your Honor, good afternoon. Mike Esser, 

Kirkland & Ellis on behalf of Calpine Corporation. We were one 

of the objectors to the protective order, and we do have 

outstanding objections that are not yet as resolved. So we 

would actually welcome the opportunity to continue to engage 

with the debtors regarding those objections --

THE COURT: Okay, Mr. Esser.

MR. ESSER: -- and would encourage --

THE COURT: Anyone else? Is there anyone else who 

thinks I really need to do this today? Because I have a 

suggestion on how perhaps we can make some progress. And there 

is a gentleman in the other room, too. So let me take the 

gentleman at the podium, and then I'll go to the courtroom.

MR. FOREMAN: Daniel Foreman, Willkie Farr, on behalf 

of the ad hoc group of subrogation claimants. We also still 

have an outstanding objection and echo what was just said. 

We'll welcome the opportunity to continue to discuss it with 

the debtors.

THE COURT: Okay. In the courtroom? Who's there, 

please? Can you hear me in the other courtroom?

MR. DEGONCALVES: Yes, Your Honor.

THE COURT: Okay. What do you want -- sorry, your 

name, sir?

MR. DEGONCALVES: My name is Dario deGoncalves 

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(phonetic).

THE COURT: Oh, yes, sir, I recognize you now that I 

see you on the side. What do you want to say about the 

protective order?

MR. DEGONCALVES: Well, I did file an objection, 

limited objection, and nobody's contacted us to discuss it, and 

nobody contacted us prior to filing either of the motions, and 

we're open to discussion.

THE COURT: Okay. Here's what I propose. What I'd 

like to do is have Mr. Fuller and Mr. Slack, or whoever's going 

to do it for the debtor, if you two have agreed, circulate a 

form of agreed protective order that you think will work, and 

send it and file it or upload it for me. And I will look and 

see -- well, what I may do is schedule another hearing. I 

can't really schedule it today or tomorrow, but if necessary, I 

probably could do it next week, if necessary. But I don't know 

that it has to be done that quickly. Or we could have a phone 

conference. And I am more encouraged that you gentlemen will 

work it out. Right? Okay?

MR. FULLER: Yes, Your Honor. And I think we largely 

have. I think our only concern is speed and urgency in this 

context. In particular, we have outstanding discovery, and the 

protective order is impacting disclosures and --

THE COURT: Well, no, it's important, but it's one of 

those things where it's a protective order, but it's not --

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what are we protecting at this point? It's going to be much 

different when there's a motion to reject or a motion to assume 

or a motion to do this or motion to do that. I understand, and 

I appreciate the hard work in trying to get together, and I 

like some of the progress we made. 

Again, it's like everything else: I cannot keep up 

with -- my two law clerks and me and my courtroom staff, we 

just simply can't keep up with this, the papers coming in 

constantly. So I have to pick my priorities and, obviously, 

today's was the higher priority, and I just couldn't know what 

the outcome was on the protective order yet anyway except that 

you're about to resolve it, hopefully. 

So what I get, therefore, and if the OCC has agreed 

with the form of order, then give me an order that the three 

principal players have agreed to, and I will set a further 

hearing if necessary. I might roll it over to the next regular 

calendar, but I don't want people who are left out or people 

like the PPAs. Everybody needs to be in the game. But if 

there's no particular discovery relevant at the moment, then 

there's no urgency in my mind about resolving the protective 

order. That's why the two committees and the debtor are the 

principal players. Which is another way of saying to all of 

you who are representing other parties, this won't be in 

concrete. We can adjust it and make different arrangements as 

appropriate for the needs of any particular constituent. Okay? 

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All right. Mr. Pascuzzi, back for more?

MR. PASCUZZI: I just want to make sure we're going to 

have a chance to at least look at whatever order they do and 

respond to it because there's one issue we still have 

outstanding.

THE COURT: No, they are.

MR. PASCUZZI: Okay.

THE COURT: So I'll repeat it again. What I want TCC, 

OCC, and debtor is -- their counsel seem to be in agreement --

that they submit and go ahead and file it as tentative or 

proposed, whatever you want to call it, protective order and I 

won't act on it. It'll go out electronically and, therefore, 

whether it be Mr. D'Ghataldi (sic) or you, Mr. Pascuzzi, or any 

other counsel, I will figure out a way, and it might very well 

be I'll put it on the agenda for our next calendar, which I 

think is July 9th, isn't it? So July 9th we're due, and the 

only question that I have to decide is whether there's a reason 

to try to solve it before then. And I don't really think there 

is, but if there is we'll try to make it work, okay?

MR. PASCUZZI: Thank you, Your Honor.

THE COURT: One more person want to be heard?

MR. GORTON: Good afternoon, Your Honor. Mark Gorton 

of Boutin Jones.

THE COURT: Oh, Mr. Gorton, again. Good to see you 

again.

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MR. GORTON: Appreciate that. We filed objections on 

behalf of the Sonoma Clean Power, the Redwood Coast Energy 

Authority, Pioneer Community Energy, and Valley Clean Energy. 

They joined our objection. In addition, the objection was 

joined on behalf of Northern California Power Agency and the 

City of San Francisco, Clean Power of San Francisco, Monterey 

Bay Community Power Authority, and the City of San Jose. So we 

would also like to have an opportunity to engage in that. We 

are having conversations. We have no objection to a 

continuance to the 9th of July. We agree with Your Honor: the 

issue isn't really ripe, if you will, in so far as there's no 

discovery --

THE COURT: Well, Mr. Gorton, again, thank you for 

coming up. I'll tweak it this way. In the next few days, I'm 

going to see from the principal players, the three 

constituents, what they three, those three have agreed on. I 

will anticipate for you or anyone else who still thinks there's 

a problem, I'll invite it to be up for further discussion on 

the 9th of July when we have a regular calendar.

MR. GORTON: Very good.

THE COURT: And there's nothing I can do about the 

fact that we've all, all of you have put in so many hours today 

for what seemed to be a simple question; obviously, it's not a 

simple question. It's very important, and I'm glad we took the 

time to do it.

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MR. GORTON: Thank you, Your Honor.

THE COURT: All right.

MR. LEBLANC: Andrew Leblanc on behalf of the 

committee. Just one proposed tweak to what Your Honor just 

said. As between the TCC, the official committee, and the 

debtor, we've agreed on the form that the debtor's prepared to 

submit. We would like it entered, though, because there is --

as between us, there is exchange of information going on 

currently that is governed by just --

THE COURT: Okay. Well, let's make it -- maybe on its 

face to say this is just as to these two parties for these 

purposes.

MR. LEBLANC: That's exactly what I would suggest, 

Your Honor. And then we're more than happy to try to work in 

whatever -- because the effort was to make this a universal 

protective order. We can do that between now and the 9th and 

then take up those issues on the 9th. But I think for our 

purposes, it's important to get it entered as soon as possible.

THE COURT: I think we should have a quiz for 

everybody. Ms. Finegan has really impressed me today, and I 

think what we'll do is we'll do for all the lawyers who are 

fighting about protective orders, we're going to have a 

Facebook page and Instagram, and we're going to stream online. 

And so you're going to be polled on your iPhone and your Apple 

watches on how you vote on the things. And I will be watching 

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the Notre Dame game at the same time. All right.

MR. LEBLANC: Thank you, Your Honor.

THE COURT: I appreciate the fervor and the energy and 

the activities of both committees and all the experts that came 

and helped me today. And this is not a science, and I 

appreciate from the Finegan declaration and the other 

declarations on both sides that there's more to the science of 

what those professionals do than I had any exposure to.

But this comes down to just going with what feels 

right. My instincts tell me that whereas many of the arguments 

that Ms. Cabraser and others talked about in terms of the 

emotions and the trauma and so on, I am not unsympathetic, but 

I simply don't believe that, given the circumstances, it would 

be appropriate for me to start to second-guess these things. 

And so if I were just going to use a crystal ball and go with 

what felt right I might pick a different date, but I can't do 

that. I have to stick with the debtors' proposal here and hope 

for the best. 

And obviously, if there's some reason, as much as I 

hope this won't happen, to revisit it as we approach October 

21st, if for some reason there's a need to extend that out, I 

guess I'll deal with it at that time. But for now the proposal 

that the debtor has supplemented frequently, including today, 

will be approved, and the deadline and the claims bar date of 

October 21st will be what I'll order.

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Again, this is not -- this is my discretionary call 

based upon the factors. It is not a call that is a disapproval 

of Angeion or criticism of Angeion or TCC lawyers. It's going 

with something that works and is likely, in my mind -- and Ms. 

Cabraser may have a slightly different view -- it's faithful to 

what the Supreme Court in Mullane and everywhere else has told 

us. And if I knew it were precise and I knew that we could 

bring one more claimant into the field of those who are going 

to get the benefit and have lost property or homes or loved 

ones but for the deadline, I would change the deadline. But 

there's no way that I can do that.

So I will stick with the debtors' judgment on this one 

and approve the October 21 bar date, provided that the debtor 

then acts consistently with what Mr. Karotkin said about the 

timing. 

So I'm looking at the piece of paper that I set aside 

somewhere, his timeline that talks about when the notices will 

be going out. And I believe his -- I set it aside, but it's 

July 15th seems to be the day that things start to go. And if 

for some reason the system breaks down or Prime can't make it 

happen and that date has to get changed, I might have to 

revisit this.

So the admonition here is to get moving on that 

schedule so that the methodology, what the experts call the 

frequency and the -- what's the other word --

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UNIDENTIFIED SPEAKER: The reach, Your Honor.

THE COURT: The reach, that's right. The reach. I 

used to think that was a sailing term, but the reach and the 

frequency get going and the many, many victims get the due 

process for them. 

So thank you all for your time. Court will stand 

adjourned.

(Whereupon these proceedings were concluded at 1:53 PM)

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C E R T I F I C A T I O N

I, Jennifer Hamilton, certify that the foregoing transcript is 

a true and accurate record of the proceedings.

________________________________________ 

/s/ JENNIFER HAMILTON

eScribers

7227 N. 16th Street, Suite #207

Phoenix, AZ 85020

Date: June 27, 2019

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of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

A

A-1 (3)

 53:14,20,24

abilities (1)

 17:8

ability (7)

 17:7,10;38:23;72:13;

 111:8;117:25;141:20

able (9)

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above (2)

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absent (1)

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absolutely (5)

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abundantly (2)

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abuse (1)

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accept (6)

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acceptable (2)

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accepted (2)

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access (13)

 155:1;156:1,8;

 160:24;161:1;163:14;

 174:21;185:15,16,17;

 186:7,8,9

accident (3)

 78:17;147:3,4

accommodate (2)

 61:6;94:22

accommodated (2)

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accomplished (1)

 175:14

according (1)

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accordingly (1)

 76:3

account (3)

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accurate (1)

 181:23

accuse (1)

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achieve (2)

 19:3,4

acknowledge (1)

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across (3)

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act (12)

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 199:12

acting (1)

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action (16)

 19:14,19,24,25;

 34:13,20;133:23;

 144:16,17;145:3,10;

 167:17;180:12,13;

 186:3;188:5

actions (4)

 34:23;133:18,18;

 134:1

activation (1)

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active (1)

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activities (2)

 8:1;202:4

activity (1)

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acts (2)

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actual (9)

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 53:16;78:22;89:11,21;

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actually (27)

 12:19;57:5,20;61:8;

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 108:3,5;116:17;

 123:17;124:8;131:24;

 132:3;135:12;146:13;

 151:24;164:23;167:18;

 169:2;171:1,17;

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 196:6

acute (1)

 146:9

ad (4)

 72:11;165:22;166:2;

 196:16

adamant (4)

 12:9;54:5;77:14;

 116:13

add (6)

 14:2;17:1;42:1,22;

 168:22,24

added (12)

 14:23;15:19,23;17:2;

 18:2;42:8;43:16;75:7;

 90:17;135:19;137:8,8

adding (8)

 33:15;74:11;77:12,

 12;79:16;89:10,24;

 188:13

addition (5)

 13:16;14:22;70:2;

 188:9;200:4

additional (11)

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 18:2,5,5;74:18

address (27)

 7:3;9:15;11:8;14:7;

 21:14;42:9;44:17;

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 19,21,24;52:9;67:19;

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addressed (5)

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addresses (5)

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addressing (2)

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adequacy (1)

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adequate (7)

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adjourned (1)

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adjust (1)

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administration (1)

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administrator (1)

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admonition (1)

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adopted (2)

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adoption (1)

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ads (4)

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adults (4)

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advance (1)

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advanced (1)

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advantage (4)

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adversary (2)

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advertising (1)

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advice (1)

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advised (1)

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advisors (3)

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advocate (1)

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affected (5)

 18:13;79:25;124:1;

 125:12;162:20

affects (1)

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affidavit (1)

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affording (1)

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afraid (1)

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afternoon (5)

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 173:9;196:2;199:22

again (131)

 8:3;9:25;10:8;11:11;

 13:4,16;17:1;18:1;

 19:12;20:18,25;24:9;

 25:13,25;26:14,21,23;

 27:1,14;28:4,22;30:19;

 31:5,20;32:10,22;33:1,

 16;35:7,9;36:7,22,25;

 39:2,17,21;40:7;45:3,6,

 7;46:3;47:21;48:4,17;

 49:8;52:21;53:1,5;

 55:23;59:18;61:10,15,

 24;63:21;66:15,22;

 67:6;68:23;69:5,10;

 70:18;72:7;75:21;

 79:14;85:12;86:16;

 90:16,17;95:7;97:13;

 98:14;99:10,14;

 105:24;106:1;111:2,

 19;112:23;117:3,11;

 118:20;119:11,13,17;

 121:17,17;123:21;

 124:3,24;125:3,25;

 127:8,9,18;128:6;

 131:19;132:4;133:16;

 141:5;143:25,25;

 148:1,5;149:22;154:5;

 163:6;164:9;167:6;

 168:4,9,21;169:4,19;

 170:11;171:20,21;

 180:15;181:8;184:18;

 185:8;186:3,6;188:21;

 189:20;195:11;198:6;

 199:8,24,25;200:13;

 203:1

against (3)

 20:18;37:4;178:10

Agajanian (1)

 151:7

Agajanian's (1)

 151:5

age (2)

 18:17,23

agencies (14)

 45:15;74:1,1;76:25;

 88:17,19;89:2,5,22;

 92:12,15;93:2,11;

 195:16

agency (6)

 45:16,16,18;46:9;

 92:9;200:5

agenda (2)

 104:20;199:15

agent (5)

 32:13,13,17;35:8;

 159:12

agent's (1)

 104:2

aggregate (2)

 65:17;119:22

ago (5)

 21:6;122:12;158:4;

 169:14;191:19

agree (25)

 40:8,11,17;43:24;

 44:11,11;54:17;68:8,

 11;73:4;74:13;80:14;

 109:10;114:3;119:3;

 122:19;156:5;164:22,

 23;168:4;178:20;

 184:20;191:8;195:3;

 200:10

agreed (23)

 9:25;27:14;41:20;

 42:18;55:14;56:18;

 57:2;58:21,24;60:16;

 62:7;72:16;143:6;

 154:14,23,25;195:4;

 197:11,12;198:13,15;

 200:16;201:6

agreeing (2)

 82:8;109:9

agreement (2)

 8:15;199:9

Ah (1)

 132:22

ahead (9)

 11:2,2;14:8;86:18;

 127:7;141:2;154:4;

 185:7;199:10

air (4)

 125:23;144:19;

 159:14;189:5

airbags (1)

 189:11

Akin (1)

 165:21

aligned (3)

 195:7,20,23

alignment (1)

 195:15

alive (2)

 133:23;142:6

allow (9)

 31:15;38:23;99:17;

 128:7;155:2;176:13;

 177:17;185:23;193:11

allowed (3)

 99:24;100:7;103:5

allowing (1)

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(1) A-1 - allowing Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 206

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 31:15

allows (1)

 179:19

almost (8)

 10:10;21:4;66:13;

 70:24;119:12;121:1;

 144:1;195:21

Aloha (1)

 128:17

along (3)

 57:10;164:21;172:4

alternative (7)

 21:3;29:9;65:4;

 114:23;138:24;155:24;

 190:23

Alternatively (1)

 163:10

although (3)

 8:20;20:3;95:1

always (5)

 42:2;79:12;121:1,2;

 149:4

amazed (1)

 20:24

ambiguous (1)

 59:13

amend (2)

 43:18;44:19

among (1)

 162:23

amount (15)

 19:17;28:5;58:22;

 59:1,3,3,23;60:12;

 65:17;67:2,11,20;

 170:6;171:23;176:8

analysis (3)

 44:9;111:15;155:3

analyst (1)

 174:22

analyzed (1)

 176:4

Andrew (2)

 154:5;201:3

Angeion (18)

 18:11;21:1;130:14;

 131:1,21,22;132:8,10,

 12;133:6;139:1,3,7;

 191:3,8,24;203:3,3

announcement (3)

 107:24;108:20;

 168:17

announcing (1)

 129:2

answered (2)

 37:18;39:7

anticipate (2)

 111:13;200:17

anticipated (1)

 79:25

anxious (1)

 11:3

apologize (1)

 66:16

apparent (1)

 91:23

apparently (1)

 12:3

appear (1)

 128:23

appearances (1)

 124:20

appeared (1)

 126:2

appearing (2)

 164:10,12

Apple (1)

 201:24

applicable (4)

 44:23;95:11;96:7;

 97:7

apply (4)

 77:7;87:22;99:20,21

appreciate (17)

 71:18;72:9;94:25;

 98:17;99:18;107:3;

 130:12;164:20;166:1;

 185:12;186:6;193:19,

 20;198:4;200:1;202:3,

 6

apprise (2)

 121:21;141:19

approach (5)

 9:19;14:10;22:20;

 54:20;202:20

appropriate (17)

 10:2;36:2;44:15;

 46:24;55:25;82:20;

 83:6;100:20;101:8;

 102:7;115:14;125:24;

 131:8;190:2;192:7;

 198:25;202:14

approval (1)

 117:24

approve (6)

 114:18;138:23;

 158:19;190:18;191:5;

 203:13

approved (1)

 202:24

approximately (4)

 15:3;19:16;130:19;

 166:3

April (6)

 147:6,17,18;150:9,

 10;183:7

area (3)

 17:9,18;31:2

areas (6)

 15:4,5,6;17:8;18:19;

 152:17

argue (1)

 190:1

argued (1)

 161:5

arguing (5)

 104:1;170:23;183:6;

 190:11,13

argument (17)

 45:3;64:11;79:1;

 92:19;100:6;105:20;

 132:20;139:16;140:13;

 159:21,22;183:19;

 185:3;186:20;187:14,

 16,19

arguments (6)

 84:23;151:21;181:2;

 183:20;191:4;202:10

arise (1)

 76:21

arises (8)

 80:23;82:10,11,15;

 85:11;86:23;87:3,4

arising (1)

 84:18

arose (5)

 42:6;79:19;80:5;

 81:24;82:7

around (8)

 24:13;98:8;106:5;

 133:23;143:21;150:10;

 170:15;181:22

arrangements (1)

 198:24

art (3)

 143:13,15,15

asbestos-containing (1)

 153:9

aside (3)

 170:3;203:16,18

aspect (3)

 119:17;153:4;184:5

aspects (3)

 131:4;137:9;143:9

assemble (1)

 177:1

assert (5)

 33:21;148:10,24;

 183:3,24

asserted (1)

 35:13

asserting (3)

 89:5;111:17;150:5

assertions (1)

 148:25

asserts (1)

 43:6

assign (1)

 22:12

assist (1)

 148:18

assisted (1)

 22:16

assume (9)

 22:12;23:1,4;41:5;

 90:8;142:8;144:2;

 184:12;198:2

assumes (1)

 85:12

assuming (2)

 22:23;26:21

assure (3)

 17:19;33:4;47:2

attach (5)

 48:22;63:2,8,8,10

attached (3)

 47:22;72:22;169:24

attaches (1)

 47:7

attachment (2)

 47:15;72:15

attachments (1)

 63:10

attacked (1)

 175:19

attention (3)

 75:16;121:16;128:19

attics (1)

 153:9

attorney (15)

 32:24;35:17,24,25;

 36:7,10;50:11,14;

 51:11,20,22;52:6,10,

 10;73:25

attorney-client (1)

 140:16

attorneys (4)

 50:20,22;102:12,19

attractive (2)

 170:18,19

audience (2)

 15:15;19:16

audio (3)

 137:5,19;139:17

aught (1)

 31:14

authorities (3)

 92:14;93:1,10

authority (7)

 35:6;44:23;91:19;

 109:24;163:10;200:3,7

authorized (1)

 32:13

available (3)

 139:3;172:10;185:25

Avenue (1)

 78:18

average (5)

 15:16;18:17,21,24;

 135:22

avoid (4)

 69:17;106:25;107:1;

 193:16

avoidance (4)

 69:19,20,21;90:24

aware (5)

 74:25;146:11;

 154:19,21;170:9

away (1)

 162:15

B

back (31)

 10:8;21:8;24:9;28:8;

 29:9;35:7,9;36:6;

 37:23;38:6,19,24;

 40:12;41:11;65:2;

 68:12;72:12;74:17;

 75:7;78:20;105:3;

 124:15;125:14;145:5,

 11;150:13;153:21;

 164:4;182:15;191:17;

 199:1

back- (1)

 171:8

back-and-forth (1)

 21:19

backend (1)

 193:13

background (1)

 19:8

back-handed (1)

 166:18

backs (1)

 170:22

bad (2)

 135:8,10

bag (2)

 159:14;189:5

Baker (2)

 58:13;185:15

BakerHostetler (3)

 117:11;174:20;186:8

balance (7)

 125:4;127:10;

 143:11;148:20;149:17;

 158:6;164:25

balancing (1)

 152:21

ball (2)

 126:9;202:15

bank (1)

 166:4

bankrupt (1)

 180:3

bankruptcy (61)

 11:14;19:21;20:2,7;

 29:3;33:6;43:5;65:6;

 78:18;84:9;93:14;

 97:18;98:1;99:18,25;

 100:7,19;117:25;

 118:1;119:18;122:1;

 125:20;127:3,4;128:6,

 22,24;129:7;131:9;

 140:24,25;141:1,21;

 142:5,7,9;150:11;

 151:3;153:3,5;157:5,

 10;158:3;165:10;

 170:8;172:16;174:15,

 18,24;175:14,21;178:3,

 23;179:16;180:22;

 182:7;184:16;185:18,

 20,23;189:23

bankruptcy-esque (1)

 64:7

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(2) allows - bankruptcy-esque Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 207

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

bar (106)

 7:8;8:22;10:2;25:22;

 27:22;29:5,6,11,22;

 30:4,7,9;50:8;53:1,2,4,

 5;65:3;66:14,18,21;

 78:16,16;82:23;97:8,9;

 98:1;103:18;104:23,

 24;105:3;107:9,16,21;

 109:2,23;110:18,18,20;

 112:1;114:9,19,24;

 115:3,5,20;116:6;

 117:13,21;118:21,25;

 119:5;121:2,19;

 123:19,25;124:3,25;

 125:13;127:8,18;

 128:20;131:6,8,14;

 133:18;134:1,5,24;

 138:12,13;139:6;

 141:18;149:2,17;

 153:7;154:14;155:4,

 22;156:10;157:1,24;

 158:18;164:20;165:11;

 166:6,16;167:9,11;

 168:3;169:23;173:5,

 13;174:3;175:2;179:1;

 181:4,6;183:16;

 184:14;187:11;189:2;

 190:19;192:3;202:24;

 203:13

based (13)

 9:13;49:16;74:7;

 77:3;107:11,14;

 119:20;130:25;156:17;

 160:7,7;181:6;203:2

bash (1)

 71:16

bashing (1)

 159:18

basically (4)

 89:25;99:17;175:25;

 179:6

basis (12)

 44:10;49:10;72:14,

 16;111:17;112:20;

 119:2,22;126:8;

 137:20;187:24;188:20

Bay (9)

 31:2;125:8;136:14,

 15,16;173:22;181:7;

 184:8;200:7

bearable (1)

 183:23

beating (1)

 66:16

became (1)

 125:22

become (1)

 128:7

begin (3)

 47:20;147:3;163:11

Beginning (3)

 27:11;39:10;155:16

begins (1)

 157:17

begun (1)

 120:17

behalf (18)

 35:20;36:3;56:10;

 58:13;72:11;99:4;

 117:11;132:8,9;

 136:11;154:6;164:13;

 165:22;196:3,15;

 200:2,5;201:3

behind (3)

 174:25;175:1,17

beings (1)

 27:8

belaboring (1)

 53:10

believes (1)

 102:23

bell (1)

 73:9

belong (1)

 40:7

below (2)

 63:4,9

benefit (2)

 126:15;203:9

best (13)

 22:11;33:21;85:25;

 112:18;123:5;134:8,8;

 152:24;153:13,17;

 164:25;172:3;202:18

best-case (1)

 112:20

better (15)

 12:15;35:15;48:7;

 74:21;80:3;83:11;

 135:11;143:12,14;

 144:14;151:5,7,8;

 152:9;165:12

beyond (8)

 15:22;16:22,24;

 17:23;19:18,19;20:12;

 21:23

Bidotti (1)

 126:2

big (3)

 38:18;70:23;95:3

bigger (1)

 114:17

billion (5)

 166:3;168:18,19;

 170:1,2

bit (5)

 57:13;88:20;126:6;

 166:18;171:8

bizarre (2)

 119:4,6

black (3)

 71:20,20;104:5

bland (1)

 30:10

blank (2)

 39:11,11

blanket (1)

 35:19

blood (1)

 71:19

blow (3)

 189:5,6,15

blue (2)

 71:20,21

bogged (1)

 172:19

bold (1)

 30:15

bombarded (1)

 143:24

bond (2)

 118:11;166:4

bootstrap (4)

 81:19;83:5,8;86:12

bootstrapping (2)

 83:11,15

bore (1)

 43:11

both (17)

 7:25;10:6;17:11,11;

 37:3,4,5;52:6,9;58:20;

 130:18;136:13;143:18,

 19;167:14;202:4,7

bottom (3)

 50:8;103:6;172:15

Boutin (1)

 199:23

box (6)

 37:10;56:10;60:11;

 61:18;65:16;67:10

boxes (4)

 59:1,6,7;105:17

break (9)

 70:21,25;98:24;

 104:17,19;105:2;

 107:4;194:4,7

breaks (1)

 203:20

brief (5)

 100:11;165:23;

 186:21,24;191:18

briefly (2)

 163:20,25

bright (1)

 80:10

bring (3)

 38:20;119:17;203:8

brings (1)

 91:21

broad (1)

 111:11

broadcast (1)

 18:7

broader (2)

 33:6;79:13

brought (2)

 89:24;121:16

BrownGreer (27)

 154:9;156:1;160:14;

 161:10,17,21;163:23;

 164:1;171:22;172:9,

 14;174:2,6,17;175:4,6,

 20;176:12;177:11,16,

 20,23;178:7;180:16,

 22;185:14;186:12

brownie (1)

 54:10

budget (1)

 130:18

build (3)

 145:14;146:22;163:5

building (2)

 18:3;31:1

built (1)

 146:21

bullet (1)

 62:4

bunch (1)

 178:11

burden (1)

 111:19

burdensome (2)

 27:17,20

burned (2)

 43:22;165:9

business (4)

 27:3,8;192:6;193:24

businesses (1)

 146:10

Bust (1)

 171:13

busy (1)

 118:16

buy (1)

 159:22

C

cable (2)

 18:7,8

Cabraser (130)

 117:14,15;124:9;

 128:11,14,17;129:6,9,

 12,18,24;130:22,24;

 131:21;132:6,9,15,17,

 22;133:2,5,12,15,20,

 25;134:3,7,13,16,18,

 25;135:4,10,14,17;

 136:9,23;137:13,17;

 138:3,9,14,17;139:9,

 11,14,19,21,25;140:2,

 15,18,20,23,25;141:5,

 9,11,13;142:15,20,22;

 143:1,3,8,11,13,16;

 144:5,7,9,11,17,21,24;

 145:1,14,17,22,25;

 146:2,8,12,15,19,25;

 147:4,6,8,14,17,21;

 148:4,11,14,16,18,20;

 149:1,5,7,10,13,20,23;

 150:1,7,14,17,24;

 151:14,17,20;152:3,5,

 7,12,15;153:4,20;

 154:3;158:24;159:21;

 167:2;181:23;184:5;

 191:4;192:24;202:11;

 203:5

Cabraser's (1)

 188:2

CAL (2)

 75:3;76:25

calculate (1)

 33:24

calculated (2)

 33:15;121:20

calculation (1)

 33:18

calendar (3)

 198:17;199:15;

 200:19

Calhoun (1)

 126:1

CALIFORNIA (27)

 6:1;15:24;18:20,23;

 22:17;30:21,24;31:2;

 45:15,16,17;46:14;

 73:25;74:1,12;75:5,8;

 88:18;92:8,9,13,23;

 93:5,11;135:22;

 169:13;200:5

Californians (3)

 135:23,25,25

Call (17)

 6:3;20:8;21:25;37:9;

 53:15;55:14;83:15;

 106:14;129:22;149:2;

 171:20;187:18;192:18;

 199:11;203:1,2,24

called (4)

 13:2;16:20;35:12;

 190:5

calling (1)

 53:24

calls (1)

 169:25

Calpine (1)

 196:3

came (2)

 175:15;202:4

Camp (15)

 48:18,19;121:14;

 123:12,14;125:9,13,19;

 136:12,13;151:7;

 165:2,9;174:24;192:22

campaigns (1)

 11:14

can (122)

 7:9,22;9:17;11:20;

 14:13;17:18,22;26:17;

 28:16,21;29:17;30:1,

 17;31:8;32:17,21;33:3,

 4;36:23;42:5;43:4,11,

 12;48:23;51:24;52:13;

 53:11;55:21;57:24,24;

 58:5;60:9,15;66:8;

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(3) bar - can Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 208

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 67:4,8,12,21;68:9,9;

 70:25,25;75:18;81:6;

 82:1;84:6;85:25,25;

 89:3;94:22;96:2;97:6,

 22,23;100:9,17;102:2,

 5,5,10,15;104:18;

 105:18;113:19,20;

 115:14;120:15;130:8,

 17,17;131:12;132:5;

 135:17;136:11;137:7,

 11;138:25;139:23;

 141:6,21;143:4,22;

 148:23;149:8;150:21,

 24;153:13,17;155:14;

 162:19;165:8;166:6;

 168:14,22,24;169:6,7;

 171:6;172:15;173:1;

 177:19,25;178:21;

 182:8;183:3;185:18;

 187:16;190:19;193:8,

 22;194:9,10,12,18,22;

 195:5;196:12,21;

 198:24;200:21;201:16;

 203:11

cancelled (1)

 118:7

capabilities (1)

 16:22

capital (2)

 94:12,13

capitalized (2)

 29:4;53:1

caption (1)

 69:24

car (2)

 43:21;159:15

care (12)

 31:5;39:6,7;45:20,

 21;60:14,23;106:12;

 126:23,23;128:19;

 130:8

carefully (2)

 29:15;73:14

cares (1)

 126:22

carving (1)

 88:17

case (75)

 12:4;19:14,20;20:3;

 22:11;44:10;48:13;

 50:21;53:16;64:2;71:6;

 78:15;85:17,20,22;

 104:5;107:18;108:5,7,

 12;110:3;112:2;113:4;

 114:10;115:3;117:22;

 119:14;120:21;121:24;

 122:11;123:11;125:16,

 24;126:5;127:15;

 128:4;129:19,20,22,24,

 24;133:14;134:7,22,

 23;145:12;147:10,12;

 153:3;159:7,11,13;

 168:5;169:20;170:12,

 13;171:20;175:1,17;

 176:2;178:7,8,10,12,

 24;179:8;180:4;182:3;

 188:25,25;189:3,24;

 193:5,7,13

case-by- (1)

 44:9

cases (32)

 11:18,19;13:1;31:20;

 78:24;98:5;108:7;

 109:7,7,15;120:24;

 122:13;133:9;135:2;

 155:12,15;156:11;

 157:2,23;160:8;166:5;

 168:10;178:1,14;

 179:2,3,3,14;181:7;

 184:8;188:5;190:20

case-specific (1)

 178:22

catch (2)

 99:8;175:3

categories (4)

 175:19;177:21,22;

 178:14

category (3)

 54:6;76:1;151:25

cause (10)

 50:10;88:20;89:13;

 160:17;163:9,15;

 168:2;172:2,11,22

caused (1)

 179:12

cavalier (1)

 128:3

caveat (1)

 184:23

CCAs (2)

 91:20;92:15

center (1)

 38:20

centers (5)

 24:14;27:2;39:10;

 152:16,16

certain (7)

 20:3;26:11;50:22;

 72:8;168:18;179:24;

 183:6

certainly (14)

 20:16;25:18;26:10;

 29:17;30:17;33:3;96:3;

 109:9;110:21;114:3,4;

 126:12;129:25;187:25

certainty (1)

 19:23

cetera (6)

 27:24;34:21;46:11;

 49:21,22;50:9

chance (3)

 124:22;175:18;199:3

change (13)

 74:3,5;76:6;94:11;

 122:18,22;142:19;

 179:13;182:4,9;183:3;

 184:9;203:10

changed (4)

 64:24;72:17;80:4;

 203:21

changes (11)

 13:5;57:1,16;62:6;

 65:14;66:10;68:17;

 76:7;94:20;192:25;

 195:3

changing (1)

 124:17

Chapter (8)

 19:20;49:24;107:22;

 108:23;110:2;166:4;

 170:12,13

charge (1)

 194:24

charged (1)

 73:11

chart (3)

 14:18;146:23;147:19

charts (1)

 149:10

check (2)

 59:1;60:11

checked (1)

 113:23

checking (2)

 60:10;61:17

chemicals (1)

 147:16

Chico (3)

 38:20;47:11;152:17

chief (2)

 6:20,24

choice (3)

 190:25;191:5,8

choices (1)

 22:3

choir (1)

 112:6

chose (1)

 33:12

chosen (2)

 41:13;190:24

Christmastime (1)

 143:22

Circuit (11)

 43:4,5,9,13,25;

 44:23;45:1;96:5;98:5;

 134:22,23

circuits (1)

 98:7

circulate (1)

 197:11

circumstance (2)

 129:15;182:19

circumstances (11)

 20:7;121:21;123:9,

 10;124:24;125:16,24;

 160:11;188:23;192:8;

 202:13

cite (1)

 109:24

cited (1)

 192:5

cities (3)

 92:13,25;93:10

city (3)

 22:17;200:6,7

civil (1)

 142:10

claim (240)

 7:8,16,25;8:18;

 23:18;27:15,18;28:18,

 20;30:11;31:11,11,12,

 16,16,17;32:5,8,24;

 33:9,10,11,15,17,20,23,

 23;34:13,14,19,20,23;

 35:19,24;36:2,3,3,16;

 37:3,8,9,10,22,23;

 38:10,12,20;39:6,14,

 23;40:20,21,21,22;

 41:5,22;42:1,5,5,7;

 43:4,7,10,13;44:1,9,13,

 19;45:1,18;46:9,11,16,

 18;47:7,15,22,24;

 48:11,11,21,23;49:4;

 50:3,8,14;53:4,25;55:8,

 10,11,18;57:1;58:18;

 59:2;62:5;65:4,12,15;

 66:24;67:2,2,20,23;

 68:7,8,19;69:11,11;

 70:15,16;72:15,21,23,

 24;76:18;77:8;78:12,

 19;79:19,25;80:2,23;

 81:1,16,16,18,24;82:2,

 2,9,22,23;83:12,15;

 84:25;85:3,6,14;86:23;

 87:3,21;89:1,1,6,8,12;

 92:10;95:2,3;96:6,18,

 22,24;97:11;99:17,22,

 23;100:7,13,17,19;

 101:1,4,6,8,14,25;

 102:2,5,8,10,14,15,17,

 22,24;103:3,7,11,14;

 104:2,2,3,3,6,7;105:4,

 14,19;107:16;109:10;

 111:16;114:7;115:8;

 116:24;123:23;124:2;

 125:20;128:20;130:4,

 4;131:16;134:11,20;

 141:17,20;142:5;

 143:22;148:10,24,25;

 150:9,12,12;162:4,8;

 164:23;165:10;170:22;

 175:22;176:4,5,7,10,

 13,17,19;180:2,3,4;

 182:7,8,16;183:2,3,5,

 24;184:15;188:24

claimant (26)

 22:16;25:7;32:12,16,

 16,20;34:15;35:18,25;

 37:5;38:9;45:17;46:20,

 22;47:6;48:16;50:13;

 51:21;52:5;59:18,24;

 61:11;68:20;69:14;

 111:11;203:8

claimants (41)

 8:16;11:9,24;23:6,

 19,25;25:8,18;32:17;

 36:4;37:3;50:10,13,22;

 58:16,22;66:1,24;

 68:24;72:14;100:10;

 107:13;112:24;113:7;

 114:5;117:12;128:22;

 130:5,8;131:5;135:11;

 136:13,13;153:15,15;

 160:20;168:14;171:23;

 175:1;190:12;196:16

claimant's (1)

 33:21

Claims (103)

 6:21;9:13;11:21;

 25:9;32:7;34:8;37:11;

 39:19;41:21,23;42:4;

 45:17;48:12,13;53:21;

 54:2,3;65:18;66:22,23;

 67:5;72:12;77:2,4,5,12,

 13,13,18,18;78:3;80:5;

 89:6,11;95:4;96:19;

 98:15,16;99:20;

 104:11;109:22;111:2,

 17,17;112:4;113:1;

 115:15;116:14;118:5;

 119:20,21;120:22;

 121:2;123:19;127:17;

 134:3,5;135:12,19;

 141:20;146:5,21,24;

 147:20,21,24;148:3,3,

 3;149:1,3,11,13,14;

 150:2,6,6;152:19;

 155:2,3,22;156:3;

 159:16;162:6,15;

 163:5;168:11,16,19;

 170:3,6;172:15;173:5;

 174:4,15;175:18;

 177:18;179:14;181:14,

 21;182:2;193:7;202:24

claim's (1)

 64:20

clamoring (1)

 124:18

clarification (5)

 12:10;36:24;64:19;

 78:3;186:5

clarified (4)

 50:24;52:20;57:12;

 98:2

clarify (14)

 29:17;30:1,17;35:15;

 36:23;43:17;51:24;

 52:13,16;60:9;81:18;

 120:12;164:1;185:8

clarifying (1)

 51:25

clarity (2)

 80:21;107:2

class (58)

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(4) cancelled - class Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 209

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 19:13,19,24,25;

 34:13,13,13,20,21,23;

 35:11,12,12,13,17,20;

 36:3,7;99:17,20,23;

 100:4,7,13,16,18;

 101:3,6,7,13,14;102:2,

 4,10,11,12,15,22,23;

 103:4,5,10,14;104:2,

 10;133:17,18,22,25;

 134:13;144:15,17;

 145:3,10;147:11,17;

 153:5;188:5

classic (1)

 85:17

class-wide (1)

 134:14

clean (6)

 59:5;91:19;145:10;

 200:2,3,6

clear (30)

 11:5;27:25;29:18;

 44:18;46:13;52:15;

 64:9;68:6;78:4,6,9;

 81:17;83:17;86:12;

 93:4;94:8,15;103:17;

 109:18;117:4;125:25;

 130:9;132:14;138:23;

 160:17,25;161:20;

 171:5;185:13;190:15

clearer (1)

 98:6

clearly (2)

 11:17;28:5

clergy (1)

 122:13

CLERK (20)

 6:4,25;37:21,22;

 38:22;47:4,9,13,14,23,

 23;73:11;107:7;

 110:11;159:7,11,18,23;

 160:5,7

clerks (1)

 198:7

client (2)

 75:4;132:7

clients (9)

 31:24;50:23;51:15;

 136:12,17;140:15;

 141:24;184:13,15

climate (3)

 179:13;182:4,9

Close (1)

 181:3

closed (1)

 146:10

closing (3)

 153:22;185:3;186:20

clutter (1)

 39:3

Coast (1)

 200:2

co-counsel (1)

 73:24

code (2)

 92:21;93:15

colleague (2)

 36:9;120:6

colleagues (2)

 31:24;76:4

collectively (1)

 172:15

colloquy (1)

 187:5

color (1)

 93:16

combination (1)

 131:23

combined (2)

 19:1;99:16

comfort (1)

 63:25

comfortable (7)

 8:7;25:19;28:8,23;

 34:2;65:23;177:1

coming (8)

 6:23;63:23;103:18;

 126:13;185:11,13;

 198:8;200:14

commence (1)

 26:20

commenced (1)

 11:18

comment (13)

 7:14;29:1;42:15,25;

 46:7;49:17,18;50:5;

 68:21;88:6;96:4;

 133:16;167:3

comments (16)

 6:12;8:3;9:12;10:15;

 15:13;17:3;20:18;

 21:18;31:23;39:5;

 53:11;70:19;74:7,7,8;

 173:11

commercials (1)

 18:7

committee (35)

 11:9,23;12:3,3,8,21;

 15:21,25;16:23;17:25;

 25:21;58:16;64:13,13;

 100:10;105:5,13;

 106:2;117:12,17;

 124:17;152:19;154:6;

 155:13,13;158:17;

 159:11;161:3;165:22;

 166:2;167:3;172:7;

 194:11;201:4,5

committees (2)

 198:21;202:4

committee's (5)

 17:2;109:9;154:13;

 167:5;172:9

common (2)

 7:25;8:5

communicated (3)

 152:1;195:13,16

communities (3)

 131:14;137:1;152:20

community (7)

 19:2;64:12;136:12;

 141:5;152:12;200:3,7

companies (7)

 65:21;107:22;175:2,

 12;178:5;179:14;182:2

company (9)

 59:24;80:1;133:23;

 135:8,9;167:24;

 172:16;180:4;182:9

company's (1)

 170:7

comparative (1)

 191:7

compare (1)

 93:19

compared (2)

 143:23;148:24

comparison (1)

 130:25

compel (1)

 173:2

compete (1)

 130:15

competing (3)

 121:9;127:10;195:9

competitors (1)

 130:15

compile (1)

 149:10

complain (1)

 182:25

complains (1)

 190:8

complaint (2)

 175:25;177:7

complete (3)

 27:18;68:12;138:25

completed (3)

 23:6;24:6,25

completely (8)

 12:1;23:20;109:3,25;

 115:12,16;140:11;

 175:21

complex (1)

 20:25

complexity (3)

 29:10;121:8;128:4

compliance (1)

 135:18

compliant (1)

 114:12

complicated (2)

 39:3;121:25

complied (1)

 139:7

comply (1)

 49:21

comprehensive (2)

 11:13;138:24

Compromise (1)

 87:12

conceding (1)

 36:11

conceive (1)

 113:6

concept (1)

 130:1

concern (7)

 73:6;74:25;121:13;

 123:16;130:6;156:24;

 197:21

concerned (4)

 12:19;48:2;103:11;

 157:20

concerns (7)

 14:9;17:24;83:22;

 127:5,11;160:9;164:21

conclude (1)

 34:3

concluded (1)

 204:8

concludes (2)

 70:19;124:8

conclusion (3)

 105:16;125:2;189:24

concrete (1)

 198:24

condition (1)

 118:4

conduct (1)

 161:4

confer (3)

 57:22;87:25;172:25

conference (2)

 194:10;197:18

conferring (1)

 31:24

confidential (16)

 46:11,17,17,18;

 47:19,20;48:14,16;

 49:2,9;63:15,16;72:14,

 16;73:3,8

confidentiality (1)

 46:24

confidentially (1)

 186:1

confirm (4)

 17:22;19:13;37:19;

 119:4

confirmation (2)

 64:19;112:22

confirmed (8)

 49:25;103:20,22,22,

 24;118:7;119:1;172:3

conforming (3)

 65:14;68:17;76:7

conformity (1)

 69:15

confronted (1)

 127:12

confused (2)

 62:15;132:8

confusing (1)

 88:18

confusion (8)

 10:11;84:12;88:20;

 89:13;96:14,15;117:4;

 176:7

congress (1)

 170:20

conjunction (2)

 130:10;153:6

connected (1)

 173:11

connection (3)

 46:10;144:8;169:20

cons (1)

 104:23

consensually (1)

 170:5

consequence (2)

 101:15;124:1

consequences (2)

 102:24;131:20

consider (3)

 53:19;114:23;180:18

consistent (17)

 10:15;36:20;37:12;

 45:25;53:3,6;76:8;

 86:10,13;92:20,21,22;

 97:1,15;98:1;134:9;

 141:18

consistently (2)

 11:17;203:14

constantly (1)

 198:9

constituent (2)

 163:4;198:25

constituents (1)

 200:16

construct (1)

 170:4

constructive (3)

 13:1;54:1;123:22

constructively (1)

 13:1

consuming (1)

 172:13

contacted (2)

 197:6,7

contemplated (1)

 72:15

contemplating (1)

 108:22

contemplation (5)

 78:25;79:21,24;

 85:20,22

contest (1)

 132:16

context (6)

 39:5;59:16;119:14;

 174:2;184:6;197:22

contingency (1)

 84:11

continuance (1)

 200:10

continue (4)

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(5) classic - continue Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 210

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 72:3;175:5;196:6,18

contract (11)

 67:21;70:8;77:12,12;

 79:16;80:18;88:25;

 89:2;90:2,4;126:15

contracts (3)

 89:18,23;90:13

contractual (9)

 25:7,8;37:4;42:4,5,5;

 67:14;70:8;77:2

contrary (1)

 85:9

control (4)

 174:19,20,22;185:14

controlling (2)

 44:23,25

conventional (1)

 114:9

conversation (1)

 32:2

conversations (1)

 200:9

cooperate (1)

 169:8

cooperation (4)

 168:8,23;190:4,6

cooperative (1)

 186:16

coordinated (2)

 173:15,20

copies (1)

 14:15

copy (4)

 38:12,13,18,20

core (1)

 83:22

corner (1)

 58:8

Corporation (2)

 6:4;196:3

correctly (1)

 62:7

cost (3)

 12:25;124:22;135:19

cost-effectively (1)

 143:4

costs (1)

 76:25

counsel (18)

 7:24;24:10;28:9,23;

 34:22;35:13;45:4;

 49:10;57:22;70:21;

 87:25;98:9;102:22;

 110:14;125:7;183:20;

 199:9,14

counterparty (3)

 67:15,22,24

counterproductive (1)

 188:14

counties (5)

 15:10;18:19;92:14,

 25;93:10

County (1)

 152:18

couple (16)

 7:9;8:10;10:23;

 43:17;65:11;66:14;

 89:11,17;109:8;145:7;

 148:2;151:1;173:11;

 176:5;187:25;189:25

course (15)

 6:18;20:2;22:21;

 42:24;64:25;99:7;

 103:10;112:25;115:17,

 17;118:6;124:14;

 137:17,17;170:10

Court (936)

 6:3,5,8,11,15,18,23;

 7:1,6,11,13;8:5,11,13,

 17,24;9:2,4,6,9,17,21;

 10:3,6,8,13,18,21,25;

 11:2,4;12:5,7,17;13:4,

 6,11,13,18,20,23,25;

 14:2,4,6,8,11,13,16,24;

 15:7,11;16:5,10,13,15,

 18;17:13,16;19:6,7,8,

 11,21;20:6,10,13,16,

 22;21:5,11,13,16,18,

 25;22:5,10,15,19,21,

 24;23:2,8,12,14,17,22,

 24;24:2,7,9,17,22,24;

 25:4,12,15,20,25;26:5,

 8,13,16,18,22,24;27:2,

 5,8,11,13,16,19,24;

 28:1,3,8,11,17,20,22;

 29:1,14,19,21,25;30:2,

 5,13,15,19;31:5,9,19,

 22;32:10,22;33:5;34:1,

 6,11,16;35:1,4,7,22;

 36:1,6,13,15,17,19,22,

 24;37:8,14,16;38:2,4,6,

 8,14;39:2,17,21;40:3,5,

 12,16,18,22,24;41:2,4,

 7,9,11,16,18,25;42:12,

 15,18,22,25;43:19,24;

 44:3,5,11,16,20,22;

 45:3,9,11,13,22,25;

 46:5,7,20,25;47:2,6,10,

 14;48:4,7;49:3,6,14,18;

 50:2,5,18,20;51:1,3,5,

 8,10,12,14,18,21,25;

 52:2,5,12,14,17;53:8,

 14,19,23;54:5,10,14,

 21,23;55:2,6,9,11,13,

 16,19,22;56:2,4,7,13,

 16,20,23,25;57:4,9,12,

 17,21,23;58:1,4,6,8,10,

 12,15,19,23;59:7,10,

 17;60:14,18,20,25;

 61:3,7,10,11,20,22,24;

 62:1,10,12,18,20,22,

 25;63:3,7,14,18,22;

 64:5,10,18,22,24;65:1,

 8,10,23;66:2,5,8,10,12,

 21;67:12,24;68:3,6,11,

 14,16,19;69:4,8,10,16,

 20;70:3,7,11,14,18;

 71:2,4,6,10,12,15,19,

 22;72:1,4,6,19,25;73:4,

 6,11,15,17,19,22;74:2,

 5,9,15,20;75:2,10,13,

 15,19,21,25;76:11,14,

 17,19,23;77:4,9,14,20,

 22;78:1,8,14,24;79:11,

 18;80:7,12,15,17,22;

 81:1,3,6,8,10,13,21,23;

 82:5,7,12,14,17,19,24;

 83:7,10,14,20,23,25;

 84:5,9,14,16;85:4,9,12,

 16,22,24;86:4,6,16,18,

 22;87:2,12,14,16,23;

 88:1,5,8,11,13,15,22;

 89:5,9,15;90:9,15,19,

 22;91:6,10,12,16;92:1,

 4,6,16,18,20;93:7,12,

 19;94:10,21;95:7,10,

 13,15,20,22;96:1,4,10,

 13,16,25;97:3,6,13,15,

 20;98:4,14,18,21,23;

 99:2,8,10,14;100:1,14,

 22;101:2,9,13,22;

 102:3,6,18,21;103:2,

 16,20;104:12,15;105:4,

 7,10,12,20,23;106:1,3,

 11,14,19,22,25;107:5,

 8;108:1,4,6,9,12,14,18,

 24;109:13,15,19;110:9,

 12,25;111:4,6,9,21,23,

 25;112:8,15,20,25;

 113:4,9,12,15,18,20,22,

 25;114:2,14,16;115:6,

 8,11,17,22;116:9,11,

 19,21,23;117:2,6,8,15,

 20;118:9,12,15,23;

 119:3,8,12,15,19;

 120:2,5,8,11,19,24;

 121:8,16;122:3,5,9,11,

 20,25;123:2,7,9,21;

 124:10,13;125:5,7,10,

 20;126:9;127:21,24;

 128:1,3,11,16;129:1,7,

 10,15,17,22;130:20,23;

 131:17;132:12,16,18,

 23;133:4,8,10,13,16,

 21;134:2,4,12,15,17,

 21;135:1,5,6,13,16;

 136:5,18;137:12,15,25;

 138:4,5,8,10,15,19;

 139:10,12,15,20,24;

 140:1,12,17,19,21,24,

 24,25;141:1,2,8,10,12;

 142:2,6,16,21,25;

 143:2,6,10,12,14,17;

 144:6,8,10,15,18,22,

 25;145:13,16,21,23;

 146:1,7,11,14,18,20;

 147:3,5,7,12,15,19,22;

 148:1,5,12,15,17,19,

 21;149:4,6,9,12,19,21,

 24;150:2,8,11,15,23,

 25;151:15,18,21;152:4,

 6,11,13;153:2,18,21;

 154:1,10,16,19,21;

 155:6,8,10,19,21;

 156:7,15,19,21;157:7,

 9,13,16,19,21;158:11,

 12,15,21,23;159:2,6,9,

 17;160:3,13;161:7,24;

 162:1,3,5,8,18,22;

 163:6,8,16,18,22,24;

 164:2,8,14,17;165:3,6,

 13,15,17,19,24;166:8,

 11,19,21;167:1,8,11,

 13,15,22;168:12,22,24;

 169:4,6,10,16;170:5,9;

 171:1,4,7,10,13,16;

 172:11,17;173:8,10,14,

 15,17,19,20,21,23,25;

 174:5,10,13;175:5,6,6,

 8,10,14,15;176:1,13,

 16,22,24;177:4,6,13,

 15,22;178:6,24;179:2,

 8,17,21;180:9,14,17,

 19,22,23;181:4,9,11,

 13,16,18,20;182:6,12,

 14,21,24;183:11,15,17;

 184:1,11,16,22,25;

 185:2,7,9,12,18;

 186:10,14,19,22;187:2,

 7,12,22,25;188:3,16,

 18;189:4,9,11,17,19;

 190:11,13,21;191:10,

 13,22,25;192:9,11,15,

 17,21;193:15,19,20,22;

 194:13,20,24;195:3,10,

 12,18,24;196:8,10,20,

 23;197:2,9,24;199:6,8,

 21,24;200:13,21;201:2,

 10,19;202:3;203:6;

 204:2,6

court-approved (1)

 138:4

courtroom (14)

 14:17;71:7,24,25;

 93:3;104:19;128:9,10,

 24;145:4;196:14,20,

 21;198:7

courts (2)

 79:23;133:10

covenants (1)

 89:21

cover (1)

 15:15

coverage (2)

 18:6,9

covered (4)

 99:23;100:18;101:3;

 103:12

covers (1)

 15:10

CPUC (1)

 127:5

crazy (4)

 7:21;115:22;125:1;

 170:12

create (1)

 175:22

created (1)

 175:22

creating (2)

 10:11;108:22

credit (1)

 171:23

creditor (3)

 49:21;96:21;101:21

creditors (8)

 12:3;23:5,18;33:12;

 100:19;101:18;126:17,

 23

creditors' (1)

 117:17

creditor's (1)

 65:4

critical (11)

 33:17;38:5;111:1;

 156:10;157:22,24;

 158:4;164:3;192:2;

 193:9;194:5

critically (1)

 157:8

criticism (2)

 132:23;203:3

criticize (1)

 54:11

cross-platforms (1)

 18:10

crystal (2)

 126:9;202:15

culture (3)

 111:25;112:4;172:20

curious (1)

 106:23

currency (1)

 31:13

current (1)

 14:20

currently (2)

 108:22;201:9

curve (1)

 175:17

custody (4)

 174:19,20,21;185:14

customer (6)

 69:23;70:4,7,8,11,11

customers (5)

 23:5;24:5,25;69:25;

 70:5

customized (3)

 23:16,21;67:9

cut (2)

 32:5;95:18

cutting (1)

 41:20

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(6) contract - cutting Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 211

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

D

daily (2)

 126:8;127:12

Dalkon (1)

 122:11

damage (10)

 77:1;79:8;86:20;

 172:2;175:19;176:17,

 23;177:21,22;178:14

damages (4)

 48:20;76:21;79:17;

 178:9

Dame (2)

 192:11;202:1

Dame/USC (2)

 181:15,17

damn (1)

 189:13

Daniel (2)

 72:10;196:15

Dario (1)

 196:25

data (12)

 119:20;136:5,7,19;

 146:20;150:4;152:25;

 156:9;176:14;177:18;

 185:11;186:13

database (11)

 119:21;154:9;156:1;

 160:21,25;163:3,4,13;

 185:15;186:8,9

date (159)

 7:8;8:22;10:2;12:15;

 21:15,21,23,23;22:7;

 25:19,22;26:3,11;

 27:22;29:5,6,11,18,21,

 22;30:4,7,9,10,11;

 33:14,16,17,23;39:25,

 25;50:8;53:1,2,4,5;

 59:12;60:4,10,23;61:9,

 16;62:5;63:7;65:3,5;

 66:14,18,21;76:22;

 77:7;78:11,16,16;

 79:23,23;82:23;84:18;

 97:8,9;98:1;103:18;

 104:23,24;105:3;

 107:9,17,21;109:3,23;

 110:18,18,20;112:9,9;

 113:12,23;114:9,19,24;

 115:3,5,5,20;116:3,6;

 117:13,21;118:21,25;

 119:5;121:2,19;

 123:19,25;124:3;

 125:1,13,23;127:9,19;

 128:20;131:7,8,14;

 132:21,24;134:5,24;

 138:12,13;141:18;

 149:2,2,17;150:21;

 153:1,7;154:14;155:4,

 22;156:10,25;157:1,

 24;158:18;164:20;

 165:11;166:6,16,17;

 167:9,11,12;168:3;

 169:23;173:5,13;

 174:3;175:2;176:17;

 179:2;181:4,6;183:6,

 16,19;184:18;188:21;

 189:2;190:19;192:3,3,

 21;193:1;202:16,24;

 203:13,21

dates (5)

 112:1;116:7;133:19,

 22;134:1

date's (1)

 66:19

daughters (1)

 127:14

day (22)

 14:23;16:10;51:14;

 71:25;72:24;78:15,18;

 115:15;120:8;126:21;

 137:11;148:9;151:25;

 161:9;181:16,22;

 192:1,12,15;194:3,15;

 203:19

days (18)

 8:2;22:19;24:6,18,

 20,21,22;25:1,2,23;

 39:25;50:9;98:9;

 107:12;189:2,21;

 191:19;200:14

deadline (21)

 24:13;29:7;39:23;

 115:8;134:5;135:7;

 138:22;139:17,21;

 142:13,17;150:3;

 151:12;152:21;159:19;

 161:20;165:1;181:21;

 202:24;203:10,10

deadlines (3)

 77:7;134:3;149:25

deal (16)

 38:18;78:11;85:8;

 89:13,22;96:5;116:2;

 153:13;158:8;162:10;

 163:14;168:10;178:10;

 190:10;194:4;202:22

dealing (6)

 75:24;77:1;78:12;

 153:12;184:7,8

deals (2)

 90:12;145:19

dealt (1)

 96:19

Dear (1)

 43:20

death (7)

 42:2,23;66:17;79:9,

 11,12;136:13

debate (3)

 83:21;93:3;182:8

debating (1)

 182:24

debt (2)

 134:12;166:4

debtor (35)

 34:14;50:9;61:12;

 65:5;110:15,15;

 116:14;118:4;120:3,7;

 123:2;126:1;127:16;

 130:10;132:13,20;

 135:2,5,24;138:6;

 139:4;145:5,7;164:24;

 169:22;177:8;178:5;

 191:3,7;197:11;

 198:21;199:9;201:6;

 202:23;203:13

debtors (36)

 6:17;11:17;18:11;

 37:4,4,6,10;49:10;

 54:25;72:16;73:1;

 74:17;80:13;81:5;

 89:20;100:12;117:22;

 130:13,25;158:6,19;

 160:19,22,23;161:1;

 162:14;166:4;167:7,

 14;168:15;169:3;

 191:17;195:4,6;196:7,

 19

debtors' (30)

 18:15;64:10,16;

 116:5,5,6,23;131:23;

 132:25;138:23;151:10;

 155:22;156:2,16;

 157:24;158:24;161:19;

 162:4,8;165:11;

 166:16,24;167:8;

 186:8,9;190:23;191:6;

 192:6;202:17;203:12

debtor's (4)

 14:20;99:6;104:7;

 201:6

deceit (1)

 43:2

December (7)

 112:11;124:6;

 192:21;193:1,1,2,3

decide (13)

 33:1;34:2;55:16;

 81:17;99:19;100:6;

 102:15;150:19;159:22;

 173:4;187:19;190:22;

 199:17

deciding (2)

 102:25;172:22

decision (14)

 12:11;55:19,21;

 66:18;86:7;121:17;

 138:22,23;156:5,6;

 175:11;182:23;184:18;

 194:5

decisions (3)

 151:16,18;180:15

declarants (1)

 6:18

declaration (5)

 11:11;18:1;145:19;

 188:12;202:6

declarations (2)

 20:24;202:7

deemed (1)

 37:3

Deepwater (6)

 146:4,23;148:19;

 149:21,22;150:9

defeated (1)

 118:22

defective (1)

 159:14

defer (1)

 194:2

deferred (1)

 190:24

define (1)

 94:15

defined (8)

 29:5,12;30:22;92:9;

 93:13,14;94:3,18

definition (6)

 30:24;31:3;63:9;

 74:11;92:21;93:16

definitions (2)

 75:5,24

definitive (1)

 152:25

DEGONCALVES (4)

 196:22,25,25;197:5

delay (4)

 124:22;148:2;

 154:22;168:2

delayed (2)

 126:18;154:18

delaying (1)

 121:5

deleting (1)

 86:19

delivery (1)

 142:4

delta (1)

 97:4

demonstrate (1)

 190:3

demonstrated (2)

 111:18;143:15

demonstrates (1)

 190:6

denominated (1)

 31:13

Deon (1)

 145:19

depending (1)

 74:4

depends (1)

 133:25

deposed (1)

 139:4

deputy (2)

 71:7,24

describe (1)

 175:10

designated (3)

 15:4,5;18:19

designation (3)

 90:1,7;91:3

designed (2)

 15:15;33:4

despite (2)

 19:25;183:20

destroyed (2)

 63:10;137:19

detail (1)

 16:16

details (1)

 72:7

determination (2)

 170:5;173:12

determine (3)

 59:21;61:11;102:5

determined (12)

 44:14;59:1,12,16;

 60:4,10,21,22;61:9,16,

 18;104:10

determines (1)

 191:10

determining (1)

 59:18

detriment (2)

 86:2;171:25

developed (1)

 130:10

developing (1)

 145:4

development (1)

 117:18

devised (2)

 158:22;160:5

D'Ghataldi (1)

 199:13

diagram (1)

 195:21

die (1)

 129:15

died (1)

 31:1

difference (12)

 45:19;58:25;60:3;

 91:23;112:8,10,12;

 124:7;143:18;144:9;

 184:1;193:5

differences (1)

 131:3

different (32)

 24:3;34:22;43:12;

 54:19;70:9;75:14;

 79:21;96:11;101:25;

 104:25;110:19;112:3;

 120:23;122:15;127:15;

 133:14;136:19;138:21;

 142:10,14,15;147:10,

 25;163:14;178:11;

 183:21;189:5,6;198:2,

 24;202:16;203:5

difficult (4)

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of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 121:24;122:5;140:6,

 7

digressing (1)

 114:16

diminishing (1)

 188:12

DIP (1)

 117:24

direct (1)

 150:3

directly (2)

 121:12;167:25

disagree (3)

 68:4;140:7;191:8

disagreements (1)

 195:22

disapproval (1)

 203:2

disapprove (2)

 21:8;191:6

disaster (1)

 121:23

discharge (8)

 20:1,2,4;80:11;

 133:22;134:17,19;

 135:7

discharged (3)

 134:12,24;135:7

discharges (1)

 51:15

disclose (1)

 73:7

disclosure (1)

 28:13

disclosures (1)

 197:23

discovery (9)

 109:14;172:7,12,19;

 178:9;185:23;197:22;

 198:19;200:12

discrete (3)

 10:4;68:24;114:24

discretion (1)

 192:9

discretionary (2)

 187:18;203:1

discrimination (1)

 85:18

discuss (4)

 126:22;154:9;

 196:18;197:6

discussing (1)

 96:17

discussion (8)

 66:22;78:15;91:22;

 120:16;180:17,17;

 197:8;200:18

discussions (5)

 163:13;181:24,25;

 182:1,5

dismissal (1)

 134:14

dispersed (3)

 131:14;141:16;

 142:23

displaced (4)

 121:23;136:2;

 141:16;174:17

disposed (1)

 9:14

disputes (1)

 191:11

disputing (2)

 103:11;195:8

disseminate (1)

 115:14

distill (2)

 166:10,15

distinguished (1)

 131:19

distribute (2)

 103:23;152:15

distribution (11)

 15:19;49:24;95:18;

 96:21;100:23;101:25;

 103:24;110:22;125:21;

 126:10;193:8

distributions (7)

 11:20,22;99:24;

 101:4,21;103:13;

 107:20

division (2)

 6:20;117:10

DMAs (2)

 15:5;18:18

docket (1)

 99:12

document (9)

 29:12;60:7;88:23;

 90:23;160:18,19;

 162:20;175:23,25

documentation (6)

 31:7;32:15;46:10,16;

 64:1;72:13

documents (10)

 63:2,6,8,8,10;106:6;

 160:20,23,24;185:11

Doe (1)

 36:4

dol (1)

 41:3

dollar (4)

 40:21;58:22;60:12;

 170:1

dollars (9)

 43:21;48:20;59:20;

 68:1,3;166:3;168:18,

 19;170:2

done (29)

 7:16;17:10;19:19,20;

 20:15;32:6;34:20;

 49:14;66:13;73:14;

 78:22;104:3;105:19;

 119:23;120:15;130:17;

 131:24;157:25;158:6;

 170:16;176:8;177:3;

 178:10,17;186:2,2;

 191:13,16;197:17

door (3)

 71:15,16;171:10

doubt (7)

 19:3;69:18,19,20,21;

 90:24;107:1

down (17)

 7:18;8:7;20:6;59:3,

 20;63:4;124:19;

 126:20;127:3;132:13;

 165:9;171:6;172:19;

 183:20;185:11;202:9;

 203:20

dozen (2)

 43:12;60:5

drafting (1)

 50:16

dragging (1)

 189:24

dramatically (1)

 178:23

draw (4)

 80:14;84:8,13;

 148:12

drive (1)

 153:1

drop (4)

 22:16;24:13;27:2;

 63:4

due (14)

 11:7;19:23;25:7,10;

 28:6;114:12;130:1,2;

 134:9;141:18;148:1;

 168:15;199:16;204:4

during (2)

 27:8;141:6

duties (1)

 11:24

duty (1)

 73:12

E

earlier (11)

 21:22;24:12;50:15;

 84:2;92:1;96:23;116:3;

 131:19;133:16;161:8;

 166:23

earliest (1)

 169:23

early (2)

 98:9;111:25

earth (1)

 126:10

easier (1)

 140:9

easy (5)

 23:23;27:19;59:25;

 144:21;165:7

echo (3)

 171:17;172:8;196:17

economic (2)

 123:11;146:6

editorializing (1)

 55:25

effect (3)

 68:14;85:4;96:22

effective (6)

 113:12,23;131:15,

 25;141:17;155:15

effectively (1)

 131:5

efficient (1)

 155:15

effort (6)

 19:3;72:6;81:19;

 151:4;193:19;201:15

efforts (5)

 19:23,25;124:21;

 141:19;193:22

EGGENBERGER (15)

 99:3,4,9,12,16;100:5,

 16,24;101:3,12,16;

 103:9,19;104:9,13

eight (3)

 18:18;135:25;147:24

eighteen (5)

 15:3;18:17,21,23;

 170:2

eighty (4)

 19:14,15;135:22;

 189:1

eighty-day (1)

 189:2

eighty-eight (1)

 159:12

eighty-nine (1)

 189:3

eighty-one (1)

 18:20

either (21)

 10:15;25:8;29:9;

 40:16;44:14;54:11;

 60:9;65:3;82:21;84:10;

 118:17;120:25;122:16;

 142:3;157:3;161:22;

 172:25;173:5;187:2;

 194:9;197:7

elected (1)

 170:19

election (2)

 192:12,15

electronic (2)

 37:23;38:22

electronically (6)

 37:22;38:6,9,24;

 39:14;199:12

element (1)

 170:14

elephant (1)

 163:2

eliminate (3)

 42:17;48:3;49:17

Elizabeth (1)

 117:14

Ellis (1)

 196:3

else (25)

 10:6;13:21;20:17;

 37:21;73:19;79:14;

 86:4,8;103:25;116:12;

 121:9;153:23;167:17;

 168:6;173:4;175:24;

 185:2;186:22;192:13;

 194:11;196:10,10;

 198:6;200:17;203:6

elsewhere (3)

 38:17;49:14,15

emailed (1)

 38:12

emotions (1)

 202:12

employment (1)

 85:18

encourage (2)

 142:1;196:9

encouraged (1)

 197:18

end (5)

 49:19;66:19;126:21;

 149:2;186:12

ends (1)

 192:3

Energy (4)

 200:2,3,3;202:3

engage (2)

 196:6;200:8

ENGEL (71)

 83:9,10,19,20,21,24;

 84:1,6,11,15,17,21;

 85:7,11,15,20,23,25;

 86:5,9,16;87:7,17,19;

 88:1,4;90:20;91:16,18,

 19;92:3,5,7,17,19,22;

 93:9,17,20,23,25;94:2,

 5,7,9,14,17,19,22;95:9,

 12,14,16,21,24;96:3,9,

 11,14,17;97:2,5,8,12,

 22,24;98:11,13,16,19,

 22

English-speaking (1)

 17:4

enormous (1)

 18:12

enough (12)

 43:25;97:9,10;

 107:15;114:13;115:23;

 130:7,7;143:3,9;151:5;

 181:3

ensure (3)

 127:19;135:18;157:4

enter (3)

 22:23;160:16;163:9

entered (2)

 201:7,18

entire (1)

 162:16

entirely (1)

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PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 42:17

entities (4)

 117:23;175:13;

 178:6;190:17

entitled (8)

 25:7;99:25;100:19,

 23;101:4,17,20;103:13

entitlement (2)

 33:21;103:25

entity (3)

 82:9;86:21;168:19

entry (2)

 25:23;26:20

envelopes (1)

 23:10

equally (1)

 153:12

Equitable (1)

 168:13

equity (1)

 118:6

equivalent (1)

 134:19

Eric (3)

 57:19;58:11;117:11

essential (1)

 111:18

ESSER (4)

 196:2,2,8,9

established (1)

 134:21

estimate (2)

 163:5;176:19

estimated (3)

 15:2;18:16;65:17

estimation (15)

 107:18;110:24;

 111:10,12;112:17,19;

 113:2;119:16,18,20,22;

 120:9,16;121:8;178:15

et (6)

 27:24;34:21;46:11;

 49:21,21;50:9

etched (1)

 71:19

even (38)

 8:1,2;20:3;30:20;

 33:15,24;34:20;42:9;

 48:13;60:1;76:1;85:19;

 90:12;92:2;101:3;

 106:1;109:15;110:7,

 18;112:1,2,2;116:14;

 119:9,9;129:4;139:3;

 141:15;157:4;159:13;

 160:9;161:14;179:25;

 180:3,7;183:3;192:19;

 194:22

event (16)

 76:21;80:23;82:10,

 15;85:11;86:23;87:3,4,

 8,13,15,15,16,17;90:6;

 98:3

events (6)

 9:13;78:13,21;79:7;

 84:18;114:6

everybody (14)

 31:2;72:7;77:23;

 90:23;91:17;122:16;

 128:4;133:10;169:7,

 10;175:23;178:12;

 198:18;201:20

Everybody's (1)

 98:21

everyone (11)

 32:3;66:3,4;107:5;

 157:6;161:11;162:14;

 165:12;170:18;171:25;

 172:4

everyone's (1)

 121:16

everywhere (1)

 203:6

evidence (4)

 151:24;186:25;

 187:4;191:7

evidentiary (1)

 191:12

exact (2)

 59:23;178:25

Exactly (16)

 23:13;59:4;63:15;

 67:6;84:17;92:22;94:1;

 97:12;132:10;165:1,5;

 169:9;171:3,3;188:10;

 201:13

example (8)

 8:6;46:22;51:1;

 67:15,16;101:11;

 102:22;156:25

except (10)

 46:8;53:15;56:18;

 66:5,7;88:21;119:5;

 138:25;170:13;198:11

excepting (1)

 46:14

exception (1)

 45:15

excess (1)

 166:3

exchange (3)

 155:17;172:21;201:8

exchanged (1)

 173:1

exclude (2)

 30:22;92:25

excluding (1)

 76:1

exclusion (1)

 76:16

exclusive (1)

 166:24

exclusively (2)

 179:13;182:4

exclusivity (10)

 110:17;118:10;

 156:13,16;167:16;

 169:10,25;170:24;

 190:1,13

excuse (5)

 20:22;68:20;133:21;

 168:23;170:23

executive (1)

 6:24

executory (4)

 89:18,23;90:2,13

Exhibit (4)

 53:24;95:1,17,23

exist (1)

 179:24

exists (8)

 174:18;175:6,20,20;

 176:12;177:17,20,23

exit (1)

 108:23

expanded (1)

 42:4

expanding (2)

 42:7;77:15

expansive (2)

 156:2;162:6

expect (1)

 135:5

expectation (2)

 64:4;118:5

expeditious (1)

 157:3

expeditiously (2)

 11:20;12:6

expense (1)

 12:25

expenses (1)

 137:8

expensive (1)

 172:13

experience (9)

 125:12;133:9,17;

 144:15,16;146:3;

 152:23;153:2;181:6

experienced (3)

 114:7;187:8;188:1

experientially (1)

 149:16

experiment (2)

 153:16,16

expert (15)

 128:24;132:6,6;

 133:6;137:24;138:20;

 140:10;143:17;146:3;

 149:16;152:22;179:25;

 183:1;188:6,9

expertise (2)

 133:8;141:14

experts (10)

 17:22;111:12;

 122:20;129:1;143:15;

 159:5,5,20;202:4;

 203:24

expires (1)

 156:23

explain (6)

 9:25;16:21;62:21;

 107:21;125:17;133:5

explaining (1)

 123:24

explana (1)

 19:9

explanation (1)

 19:9

exposed (1)

 153:10

exposure (1)

 202:8

expressly (1)

 154:25

extend (2)

 110:16;202:21

extended (2)

 25:22;188:23

extension (1)

 156:18

extent (23)

 7:15;8:19;9:24;

 23:19;35:16;40:20,20;

 43:17;44:22;46:22;

 49:1;65:14;68:18;

 76:21;80:23;86:23;

 87:2;95:10;96:7;101:5;

 106:11;139:23;186:11

extra (1)

 38:20

extract (1)

 47:23

extremely (2)

 42:13;188:25

extricate (1)

 139:22

F

face (1)

 201:11

Facebook (3)

 17:19;137:3;201:23

facilitate (1)

 183:22

facilities (1)

 17:12

facility (1)

 117:24

fact (17)

 11:22;39:4;43:3;

 45:22;48:12;79:6,19;

 80:1;84:12;107:12;

 114:5;118:22;126:16;

 130:12;158:3;168:17;

 200:22

factors (2)

 178:11;203:2

facts (6)

 173:11;179:19,23,

 24;180:6;182:18

factual (2)

 184:7;191:11

failings (1)

 191:2

Failure (1)

 49:20

fair (10)

 9:15,22;13:7;78:24;

 79:5,21,24;85:20,22;

 168:13

fairly (3)

 7:6;60:25;149:7

faithful (1)

 203:5

fall (4)

 115:25;146:25;

 149:14;174:25

fall/winter (1)

 147:1

familiar (3)

 10:14;143:20;185:20

families (1)

 177:19

family (4)

 56:11;127:14;

 136:25;177:14

fantasy (1)

 126:6

far (8)

 48:2;78:11;121:24,

 25;122:5;168:14;

 175:1;200:11

Farr (2)

 72:11;196:15

fast (1)

 95:20

faster (1)

 127:22

fatal (1)

 135:2

fate (1)

 184:17

fault (1)

 140:3

favor (2)

 129:12;191:4

features (2)

 138:4;145:7

February (1)

 12:10

federal (1)

 195:17

feel (3)

 32:1;46:1;71:5

feels (1)

 202:9

Feld (1)

 165:21

Felderstein (1)

 73:23

felt (2)

 59:2;202:16

FERC (1)

 127:6

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(9) entities - FERC Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 214

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

fervor (1)

 202:3

few (12)

 7:12;8:2;24:18;

 53:11;66:17;74:7;84:9;

 154:7;156:9;189:9,9;

 200:14

fewer (1)

 193:13

fiduciary (1)

 11:24

field (1)

 203:8

fifteen (3)

 15:23;152:6;188:11

fifteen-minute (2)

 104:17,19

fifty (5)

 142:11;144:3,12,12;

 184:24

fifty-eight (1)

 188:13

fighting (1)

 201:22

figure (9)

 21:25;48:5;77:23;

 89:3;127:22;130:20;

 153:8;180:9;199:14

figured (1)

 60:1

file (76)

 25:9;31:15;34:14,20,

 23;35:24;36:2,3,9;

 37:25;38:5,24;40:14,

 23;41:21,23;43:18;

 44:19;67:22;76:18;

 78:3,12;81:16,17,24;

 82:2,22;84:25;85:3;

 88:24,25;89:1;97:7;

 99:22;100:2,3,25,25;

 101:13,25;102:4,5,8,

 13,13,17,19,23;103:2,

 6,10,14;104:6,7;

 112:20;114:7;115:15;

 119:18;125:19;141:20;

 142:5;150:9,11,12;

 165:10;180:7;182:7,8,

 16;183:2,5;184:15;

 193:7;197:5,13;199:10

filed (54)

 8:21,24;10:1;11:11;

 12:21,23;30:11;34:18;

 37:3;38:10;39:14;47:9,

 10;49:25;50:2,12;62:5;

 64:20;65:5;85:5;89:20;

 95:2,4;102:2;110:15,

 16;111:16;117:22;

 118:10,13;127:17;

 146:24;147:24;154:14,

 15,20;156:13,14;158:1,

 3;164:23;166:5,23;

 167:6,16;168:10;

 169:13,24;181:16;

 190:5;191:18,18,23;

 200:1

files (4)

 37:22;38:9;47:8;

 102:22

filing (10)

 35:19;50:3;56:10;

 124:1;147:22;150:2,5;

 168:3;182:2;197:7

fill (1)

 62:5

filled (4)

 130:17;135:17,18;

 137:8

Final (1)

 69:22

financial (5)

 49:11;118:4;174:22;

 185:16;186:9

financing (2)

 117:24;118:2

find (7)

 12:20;17:18;65:3;

 67:7;134:10;139:1;

 169:1

finding (3)

 140:13;172:10;

 187:17

findings (1)

 187:2

fine (31)

 25:2;28:10,24;34:3;

 38:21;54:8;60:17;61:2;

 66:8;73:4;76:3;80:25;

 81:2;87:1,6,7,10;

 88:19;90:18;93:22;

 94:14;101:7;102:13,

 20;106:16,20,20;

 117:6;124:25;142:9;

 167:16

Finegan (8)

 6:19;19:5,13;21:1;

 115:1;151:4;201:20;

 202:6

Finegan's (4)

 11:10;13:20;18:1;

 20:24

finish (4)

 97:23;138:1;151:19;

 180:11

finite (1)

 59:25

fire (74)

 30:5,22,23,25;31:3;

 48:18,19;55:8,8,8,9,10,

 11,18;57:6;61:14,17;

 63:24;68:22,23;75:3,

 19;76:25;77:6,23;

 78:10,22,23;85:13;

 89:2,11;92:10;105:6,8,

 14,15,21;106:4,8;

 107:13;121:14,22;

 123:12,15;124:1;

 125:9,13,19;126:17;

 136:14;151:7;157:5,

 10,12,17;164:13;165:2,

 9;168:10,13,16;170:3,

 6,22;172:2,3,15;

 173:17;174:24;182:19;

 184:4;190:12;192:22;

 193:6

fire-related (3)

 105:21,24;106:15

fires (12)

 18:13,19;74:13;75:1,

 9,16;77:1;136:12,15;

 173:22;179:5,12

firm (3)

 164:13,20;177:24

firms (7)

 174:23;175:5;

 176:13;177:17;178:19;

 184:8,12

firm's (1)

 164:13

first (39)

 11:11;16:14;22:13;

 25:2;26:12,12;29:1;

 32:8;37:17;53:14;54:1;

 55:1,4,8;59:1;62:4;

 63:1;64:9;75:6;97:16;

 102:1;108:12;112:1;

 117:23;123:12;135:20;

 147:23;150:3,6,13;

 152:4,7;154:14,24;

 156:12;168:20;186:24;

 191:17,20

fit (2)

 120:21;127:9

fits (1)

 92:11

Fitzgerald (1)

 73:24

five (11)

 18:22;27:3;34:22,22;

 135:25;144:12;147:23;

 157:1;175:22;178:17;

 184:2

fix (3)

 32:21;33:3;76:4

fixed (3)

 189:13,14,14

fixing (1)

 120:8

flawed (1)

 151:9

flexibility (1)

 128:7

floating (1)

 106:5

flood (1)

 8:1

flurry (1)

 166:8

flush (1)

 8:1

flyers (1)

 152:16

focus (4)

 12:8;111:9;130:16;

 138:21

focused (2)

 111:2;155:14

focuses (2)

 137:2,4

focusing (5)

 25:5;100:22;112:8;

 149:22;183:17

folks (10)

 126:6;136:9,15,24;

 140:8;141:19;145:20;

 149:18;150:19;153:7

follow (6)

 6:8;32:8;33:24;

 102:21;162:25;166:7

followed (2)

 101:18,19

following (2)

 104:21;147:18

followings (1)

 18:12

follows (3)

 18:16;103:3,3

food (1)

 194:7

footer (5)

 53:20;54:1;88:8,11,

 22

footnote (7)

 30:21;74:10;75:6,12;

 87:22;88:9,11

forces (2)

 127:1;128:8

FOREMAN (12)

 72:5,10,11,22;73:1,5,

 10,13,16,18;196:15,15

forest (1)

 30:25

forget (5)

 139:5;140:21,23;

 141:23;148:21

forgetting (2)

 126:16;141:3

Forgive (1)

 88:4

form (106)

 7:8,14,16,25;8:18;

 10:9;27:15,18;31:9;

 32:8;33:20;35:19;

 36:16;37:8,9,23;38:18;

 39:3,6;40:14;47:17;

 49:4;53:14,15,17,17,

 23,25;54:15,16,25;

 56:4;57:1,5;58:2;62:5,

 16;63:2;64:1,15,18;

 65:2,25;66:25;67:5,5,5,

 10,13;68:7,8,19;69:1,

 24;72:15;76:11;87:21,

 23,24;88:7,22;89:8,12;

 91:22,23,24;92:2,10;

 97:25;99:22;102:14;

 105:4,16,17,19;107:12;

 109:10,10;123:23;

 128:20;130:4;155:23;

 156:3;161:20;162:4,6,

 9,15,16;170:6;175:22;

 176:5,8,10,13,17;

 177:7,9;178:18;

 182:14,15;188:24;

 191:6;197:12;198:14;

 201:6

formal (1)

 172:12

formalities (1)

 172:19

formally (1)

 190:2

former (2)

 62:10;137:1

forms (10)

 23:18;31:15;32:25;

 53:11;54:19;70:20;

 74:22;76:6;130:9;

 164:23

formula (2)

 144:25;145:1

forth (5)

 14:19;35:17;67:2;

 72:13;145:5

fortunately (2)

 189:14,16

forty (1)

 152:23

forum (1)

 129:10

forward (18)

 11:19;12:4;13:1;

 109:7,7;118:24;

 119:19;120:1;123:5;

 155:2,3,13,15;157:3,

 23;169:20;178:16;

 190:20

forwarding (1)

 136:25

foul (1)

 134:25

found (1)

 168:20

four (9)

 15:4,5;17:4;18:18,

 24;27:3;112:10;

 156:21,22

frame (2)

 146:14,15

FRANCISCO (4)

 6:1;108:10;200:6,6

Frank (1)

 126:1

frankly (7)

 12:25;42:10;126:15;

 138:24;149:15;164:22;

 168:7

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(10) fervor - frankly Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 215

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

frays (1)

 106:4

free (4)

 103:5;116:23,25;

 152:9

French (2)

 85:3,5

frequency (25)

 15:1;18:15,18,21,24;

 26:1;52:19;130:7;

 132:1;135:20;136:1;

 137:3;138:11;143:5,7,

 8;145:1;146:13;

 147:20;150:5,19;

 188:5,8;203:25;204:4

frequent (1)

 17:8

frequently (4)

 69:1;137:21;164:10;

 202:23

friendly (2)

 61:13;64:7

friends (1)

 137:1

front (2)

 127:4;131:10

frontend (1)

 193:17

frontload (1)

 139:20

front-load (1)

 150:16

frontloaded (2)

 132:25;138:15

front-loading (1)

 151:11

frontloads (1)

 131:24

full (8)

 38:12;113:9,11,15,

 22;118:6;127:18;

 146:16

Fuller (8)

 195:2,3,6,11,13,19;

 197:10,20

fullest (1)

 135:12

fully (2)

 114:12;166:16

function (2)

 64:15;150:3

functional (1)

 134:19

Fund (1)

 108:21

fundamental (5)

 107:17,17,19,20;

 139:8

further (10)

 9:25,25;12:10;19:10;

 40:9;53:8;93:15;

 194:22;198:15;200:18

future (7)

 9:18;59:15,16;61:19;

 77:18,18;84:23

G

Gallagher (1)

 72:11

game (5)

 181:15,17;192:11;

 198:18;202:1

gaps (4)

 130:16;135:15;

 137:7,22

garbage (1)

 68:9

Gate (1)

 78:18

gather (3)

 141:5,25;143:21

gathered (1)

 63:6

gave (1)

 38:16

Gems (1)

 108:16

general (3)

 37:9;53:24;66:22

generally (1)

 33:11

General's (1)

 73:25

generically (2)

 140:18,18

generous (1)

 185:22

gentleman (4)

 52:2;164:5;196:13,

 14

Gentlemen (2)

 173:6;197:18

gets (4)

 67:25;140:9;150:13;

 163:11

Ghost (12)

 30:23;31:3;57:6;

 68:22,23;69:7;75:19;

 105:6,15,17;106:4,7

Gilliam (1)

 78:20

given (15)

 78:21;106:2;118:4;

 121:1;123:11,12;

 125:11,24;134:9;

 145:12;156:11;191:15;

 194:1,16;202:13

gives (1)

 131:13

giving (1)

 161:1

glad (2)

 38:15;200:24

glass (1)

 71:10

glitch (1)

 50:16

goal (4)

 11:18,24,25;12:4

God (3)

 30:7;182:1,3

goes (11)

 17:23;18:14;19:18;

 20:12;21:3;66:22;

 78:20;92:10;124:15;

 128:4;162:9

Golden (1)

 78:18

good (39)

 6:5,7,23;7:21;26:16;

 43:24;44:8,14,14;

 47:25;72:5,10;74:8;

 79:1,6;83:16;87:17;

 97:9,10;103:10;

 117:15;120:13;121:4;

 124:19,23;128:13,14,

 15;133:9;151:5;158:6;

 165:20;171:12;173:9;

 177:3;196:2;199:22,

 24;200:20

GOODMAN (100)

 57:24;58:3,5,7,9,10,

 11,11,13,16,21,25;

 59:8,11;60:6;61:5,8,15,

 21,25;63:19,21,23;

 64:6;100:9;104:25;

 105:1,8,11,22,24;

 106:2,10,18,21;107:2;

 116:11,16,20,22,25;

 117:3,7,9,11,16,21;

 118:13,18;119:7,11,13,

 16;120:4,10,12,23;

 121:7,12;122:4,8,10,

 19,24;123:1,3,8,10,24;

 124:12;125:3,6,11;

 127:8,23,25;128:2;

 163:20,23,25;185:6,8,

 9,10;186:5,11,18;

 190:21;191:9,15,23;

 192:1,10,14,16,20;

 193:16,21;194:24;

 195:1

goods (1)

 67:16

Goren (20)

 52:4,4,5,8,13;57:20;

 74:23;90:16;93:12,13,

 18,21,24;94:1,3,6,8,12,

 15,18

gorilla (1)

 161:12

Gorton (7)

 199:22,22,24;200:1,

 13,20;201:1

Gotshal (2)

 6:16;52:4

Gottfried (1)

 36:8

governed (1)

 201:9

government (2)

 46:15;92:12

governmental (9)

 88:17;91:21;92:7,13;

 93:4,4,14;94:11,12

Governor (7)

 107:25;108:17,18,

 19;127:1;157:3,14

governor's (2)

 170:20;171:19

governs (1)

 88:19

Grace (1)

 153:5

grant (1)

 148:8

granted (2)

 190:3;191:14

great (5)

 85:21;94:2,9;115:19;

 166:11

greater (5)

 19:4;168:6,6,7;

 171:21

greatly (1)

 166:1

ground (1)

 129:18

Group (7)

 6:21;35:8,11;36:4;

 110:16;136:2;196:16

Guardian (1)

 7:1

guess (12)

 35:15;52:24;65:23;

 70:19;103:16;104:13,

 22;112:13;133:18;

 159:23;182:24;202:22

guinea (1)

 153:16

Gulf (3)

 122:13,14;146:5

Gulfstream (1)

 122:14

Gump (1)

 165:21

guys (3)

 60:9;75:21;175:24

H

habit (2)

 187:9,10

half (8)

 43:12;60:5;71:21;

 112:14,15;165:13;

 170:2;174:15

hand (2)

 47:23;126:25

handed (4)

 56:21;60:8;171:9;

 191:19

hand-to-hand (1)

 152:10

happen (22)

 22:13;82:6;104:4;

 110:4,5,8,14,17;121:9;

 127:22;137:11;149:8;

 153:3;156:11;158:12;

 162:9;169:8;172:20;

 176:9;193:18;202:20;

 203:21

happened (7)

 30:22,23;32:7;78:13;

 79:7;141:7;174:24

happening (3)

 85:19;151:22,23

happens (11)

 34:12,14;37:21;47:8;

 77:18;78:10;79:19;

 88:25;130:15;152:13;

 172:23

happy (11)

 7:2;10:19;28:7;48:2;

 71:3;72:3;82:2,3;

 90:16;98:25;201:14

hard (8)

 73:8;98:10;113:6;

 121:4;170:14;184:1;

 186:16;198:4

harm (3)

 77:15;134:25;176:18

hate (1)

 52:23

Hauer (1)

 165:21

Hawaii (1)

 128:16

head (1)

 170:15

heading (1)

 105:16

heads (1)

 75:21

health (1)

 136:9

hear (19)

 10:4;19:5;45:4;58:5;

 70:21;74:17;128:12;

 130:2,6;136:2;150:18;

 153:18;166:17;171:14;

 181:1;188:15;193:14;

 195:24;196:21

heard (19)

 35:10;73:19;86:4;

 130:3,5,12;131:7;

 133:17;151:9;153:19,

 23;163:21,25;164:5;

 167:2;171:19;173:5;

 185:2;199:21

hearing (26)

 7:3;30:8;43:20;

 66:19;107:18;110:24;

 111:10;113:3;126:2;

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of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 128:18;131:18;132:3;

 139:2;151:21;154:8,

 23;158:7;164:17;

 169:2;174:2,6;191:12;

 194:10;195:25;197:14;

 198:16

hearsay (3)

 140:21;141:3;187:5

heavily (3)

 65:25;137:2,4

Heffler (1)

 6:21

held (1)

 171:24

help (4)

 128:12;158:2;

 173:12;175:22

helped (2)

 19:11;202:5

helpful (5)

 7:13,18;26:6;38:14;

 61:16

helps (1)

 10:9

Here's (10)

 33:5;38:15;47:21;

 48:20;137:7;166:14;

 178:4,18;179:1;197:9

Herndon (3)

 35:12;36:7;99:5

hey (2)

 91:13;166:19

HF (1)

 6:20

higher (3)

 123:17;138:11;

 198:10

highlighted (3)

 55:1,5;56:19

historic (1)

 119:20

history (1)

 11:14

hit (2)

 38:11;188:13

hm (1)

 192:15

hoc (4)

 72:11;165:22;166:2;

 196:16

hold (6)

 39:19;66:13;88:25;

 114:23;122:23;166:2

holder (1)

 34:19

holders (2)

 11:21;118:11

holdout (1)

 122:23

holds (3)

 42:1;80:22;82:9

holiday (11)

 141:7,22;147:1;

 149:15;164:22;181:24,

 24;182:1,4;192:25;

 193:3

holidays (3)

 123:18;124:6;144:6

home (4)

 48:18,19;103:5;

 176:18

homeless (3)

 127:13;136:3,20

homeowners' (1)

 153:5

homes (2)

 137:19;203:9

honest (1)

 139:2

Honor (206)

 7:2;9:11;11:5,10,15,

 18,23;12:19;13:2,10;

 14:19;15:5;17:23,25;

 18:14;19:12,18,19;

 20:11;23:15;25:17,21;

 27:14;29:13;35:5,16;

 42:8;44:2;48:2;52:8;

 55:4;61:5;63:21;64:8;

 72:5,10;73:10,13,21;

 74:6,10;75:3,4,18;76:9,

 15;77:16;78:2,10;80:9;

 81:9;82:21;83:1,19;

 87:1,7,10,20;88:4;89:4,

 14,16;90:3,16,21,25;

 91:9,11,15,18;93:13;

 94:24;95:25;96:12,15;

 97:14;99:18;100:5,24;

 101:5,16;103:9;104:9;

 105:2;106:13;107:3,

 10,16,23;109:2,5,21;

 110:23;111:1,15;

 112:23;114:4;115:13;

 116:17;117:1,21;

 118:18;119:7,19,25;

 123:13;125:25;127:11;

 128:14,17;130:9;

 131:6,13;132:5,11;

 133:3,25;135:11;

 136:11;137:23;139:21;

 140:10;141:1;143:9;

 144:21;146:4,16;

 148:16;149:15;150:18;

 152:21;153:5,25;

 154:5,6,8,12,23;

 156:17,22;157:11;

 158:18,19;159:1,4;

 160:16;161:25;162:12,

 23;163:2,8,19,20;

 164:7;165:20,23;

 166:2,5,14,23;167:12,

 18;168:5,9,14,20,23;

 169:9,12,14,19;170:1,

 2,16;171:3,15,22;

 172:6;173:7,12;176:3;

 180:5;185:1;186:18;

 187:21;189:20;190:18;

 192:4,14,16;193:9;

 194:14,18;195:1,6;

 196:2,22;197:20;

 199:20,22;200:10;

 201:1,4,14;202:2;

 204:1

Honor's (5)

 99:4;137:11;156:17,

 24;164:21

hope (4)

 71:8;92:24;202:17,

 20

hopefully (5)

 41:12;107:18;

 170:18;194:21;198:12

Horizon (2)

 122:14;146:4

horrible (1)

 126:11

host (1)

 17:6

Hostetler (2)

 58:13;185:15

hours (3)

 27:9;70:25;200:22

house (4)

 161:15;165:8;

 176:18;189:6

housekeeping (1)

 116:16

How's (1)

 128:16

huge (1)

 9:17

Huh (2)

 87:14;181:16

Hum (1)

 51:17

human (3)

 27:8;141:15;149:6

humanly (1)

 141:22

hundred (3)

 24:20,21,22

hundreds (2)

 21:6;113:8

husbands (1)

 127:14

hypothetical (1)

 47:21

I

idea (9)

 7:21;84:8;85:18;

 118:20;150:20;170:21;

 171:12;172:21;179:15

ideal (1)

 131:24

ideally (1)

 24:12

iffy (1)

 177:8

ignored (1)

 75:17

ignoring (1)

 43:2

ii (1)

 31:12

Illustrated (2)

 15:20,22

imagine (1)

 115:25

immediately (1)

 162:20

immense (1)

 176:7

imminent (1)

 121:2

impact (2)

 110:21,21

impacted (1)

 105:15

impacting (1)

 197:23

impeached (1)

 192:19

impeachment (1)

 192:18

impede (1)

 131:8

impediment (1)

 128:7

implement (1)

 193:10

implemented (1)

 128:10

implicates (1)

 44:25

implicit (1)

 116:6

importance (1)

 128:21

important (19)

 32:4;63:19;75:24;

 107:21;116:13;129:14;

 136:1;140:3;141:16;

 157:8;175:11;178:4;

 184:6,17;189:23;

 190:15;197:24;200:24;

 201:18

importantly (3)

 18:11;109:5;114:13

impractical (1)

 109:3

impressed (1)

 201:20

impressions (1)

 18:9

improved (1)

 130:14

improvement (2)

 86:1,2

inappropriate (4)

 36:5;44:13;110:1;

 140:11

incapable (1)

 59:14

inclined (1)

 33:13

include (9)

 26:10;31:8;48:16;

 49:1,11;58:21;65:17;

 75:8;80:18

included (5)

 45:10,16;56:12,24;

 102:9

includes (9)

 14:21;19:18;36:12;

 44:23;46:20;92:12,13,

 14,14

including (8)

 12:2;23:5;63:25;

 74:24;93:9;99:22;

 133:13;202:23

incomprehensible (1)

 21:4

inconsistency (1)

 52:22

inconsistent (1)

 31:6

incorporated (1)

 94:4

incorporates (1)

 18:5

increase (4)

 16:22;18:6;143:7,8

increased (4)

 15:14,14;17:1;18:9

increasing (1)

 131:15

incredibly (1)

 184:5

indeed (1)

 137:14

indicated (3)

 63:15;79:9;105:12

indicating (1)

 79:10

indifferent (1)

 105:13

indiscernible (1)

 152:16

individual (22)

 24:10;32:12,14,17,

 17;34:14,15;35:14;

 50:21;64:13;65:19,20;

 99:22;101:1;102:11,

 12,16,23;103:10,14;

 177:14,24

individuals (3)

 48:8;102:8;104:1

indulge (1)

 99:3

indulgence (1)

 94:25

inexpensive (2)

 143:5,5

influencers (2)

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PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 18:12;158:9

inform (1)

 185:19

informal (13)

 43:4,7,10,14;44:1,8,

 13;45:1;95:3;96:5,18,

 24;97:10

information (46)

 35:18;36:12;47:5;

 49:1,9;62:5;63:9;

 67:20;68:7;69:22;73:1;

 102:10;109:11;119:21;

 130:23;132:19;143:24;

 148:23;155:1,12,18,24,

 25;156:9;161:21;

 162:10,17;163:5;

 171:24;172:8,9,21;

 173:1;175:21;177:2,

 19,23,24;179:10;

 180:24;182:23;183:1;

 185:12,21,24;201:8

informed (2)

 180:17;182:23

ingrained (1)

 98:7

initially (1)

 16:19

injuries (1)

 189:7

injury (10)

 42:1;76:20;77:2;

 79:8,12,17;85:17;

 86:20;146:5;176:18

input (1)

 125:7

insert (1)

 67:18

insisting (1)

 32:19

insists (1)

 186:15

Instagram (3)

 17:19;137:3;201:23

instances (1)

 43:12

instantly (1)

 137:10

Instead (3)

 12:23;121:10;178:17

instincts (1)

 202:10

instituted (1)

 137:10

instructed (1)

 63:7

instruction (1)

 62:4

instructions (5)

 55:4,5,24;56:2;62:1

insulation (1)

 153:9

insurance (10)

 65:18,21;175:2,12;

 177:24;178:5;179:14;

 180:3;182:2,9

insurers (1)

 65:16

integrated (1)

 175:9

intelligence (1)

 142:6

intelligent (1)

 120:16

intend (1)

 167:19

intent (1)

 51:7

intentionally (1)

 69:23

interacting (1)

 126:7

interest (3)

 12:1;40:14;60:2

interested (2)

 110:2;194:17

interests (6)

 39:18;40:6;41:13;

 104:1;127:10;183:21

internally (1)

 126:13

internet (1)

 186:1

interprets (1)

 94:14

interrelated (2)

 133:2;139:22

interrelates (1)

 131:6

interrupt (2)

 132:5;187:8

interval (1)

 16:7

intervals (2)

 16:7,9

interviewed (1)

 139:4

intimidated (1)

 27:21

into (18)

 16:15;21:3;25:14;

 54:6;74:21;77:17;

 92:11;94:4;96:15;

 109:2;129:10;132:14;

 140:4;179:3;180:23;

 182:8;193:19;203:8

introduce (1)

 6:19

investment (2)

 170:1,18

invite (1)

 200:18

invites (1)

 47:19

involve (2)

 111:14;186:13

involved (4)

 120:25;152:19;

 170:18;171:25

involvement (1)

 122:12

involving (1)

 186:12

iPhone (1)

 201:24

irrelevant (1)

 179:10

irreverent (1)

 129:7

issue (46)

 9:14;10:2;12:8;33:1;

 34:4;47:16;55:7,23;

 59:9;77:3;78:19;79:9;

 80:16;85:1,8;91:2;

 92:7;93:21;95:2;100:2,

 18;105:3,18;107:2,13;

 115:13;116:15;121:14;

 139:21;153:23;155:9;

 156:4;159:18;162:13,

 23;163:23;164:1,19;

 172:22;174:1;180:25;

 185:11;192:2;194:3;

 199:4;200:11

issued (3)

 7:4;110:13;161:7

issues (29)

 7:6,7;9:23;11:9;

 12:22;54:24;70:24;

 80:10;84:8;117:13,19;

 128:20,20,21;133:2;

 138:21;154:9;155:8;

 162:13;179:1,16;

 191:11;193:13,21;

 194:6,21,23;195:7;

 201:17

item (3)

 167:17;180:12;186:3

items (3)

 7:9;68:18;180:13

iterative (1)

 145:18

J

January (25)

 12:9,12;42:6;62:6;

 65:6;76:22;80:24;

 81:25;82:8,10,13,16;

 87:4;103:18;109:2;

 112:10,11;119:1;

 121:10;125:6,14;

 126:4;127:8;175:15;

 183:8

JCCP (2)

 125:8;178:2

jeopardizes (1)

 111:8

job (2)

 158:6;177:3

jobs (1)

 146:9

John (4)

 36:3;67:13;102:9;

 164:12

join (4)

 83:21,25;86:5;167:5

joinder (1)

 166:5

joined (4)

 91:20;172:6;200:4,5

joint (5)

 92:14;93:1,10;

 131:23;195:4

joke (1)

 193:22

joking (1)

 193:23

Jones (4)

 34:22;52:6;103:2;

 199:23

Jose (1)

 200:7

jot (1)

 7:18

Journal (1)

 16:3

joys (1)

 166:11

Judge (9)

 84:12;107:24,24;

 108:1,8;121:1;124:3;

 151:3;186:15

judges (1)

 129:7

judging (1)

 100:13

judgment (4)

 20:8;33:21;192:7;

 203:12

Julian (2)

 120:6;122:12

July (19)

 22:12;23:1,4,7;24:6,

 13;25:1;26:21,21;27:4,

 11;39:10;115:20;

 140:4;199:16,16;

 200:10,19;203:19

JUNE (8)

 6:1;108:23;109:1;

 111:3;116:18;140:4;

 154:25;157:17

K

Karotkin (450)

 6:5,7,10,14,16,16,24;

 7:2,12;8:4,9,12,14,18;

 9:1,3,5,7,10,19,22;

 10:5,7,12,17,19,23;

 11:1,3,5;12:6,16,18;

 13:5,9,12,14,19,22,24;

 14:1,3,5,7,9,12,15,18,

 25;15:9,12;16:9,12,14,

 17;17:15,17;19:7,10,

 12;20:5,9,11,14,20;

 21:10,12,14,17,24;

 22:4,9,14,18,20,22;

 23:1,4,11,13,15,18,23;

 24:1,4,8,16,20,23,25;

 25:11,13,16,21;26:4,7,

 9,15,17,19,23,25;27:4,

 7,10,12,14,17,23,25;

 28:2,4,10,16,18,21,25;

 29:13,17,20,24;30:1,4,

 12,14,16;31:4,8,18,21,

 22;32:9,21;33:3,13,25;

 34:5,10,15,25;35:3,5,

 16,23;36:2,12,14,16,

 18,21,23;37:1,7,13,15;

 38:1,3,7;39:1,4,16,20;

 40:2,4,10,15,17,19,23;

 41:1,3,5,8,10,15,17,24;

 42:8,13,16,20,24;

 43:15,21,23;44:2,4,7,

 12,17,21,24;45:7,10,

 12,21,24;46:3,6,19,21;

 47:1,4,9,12;48:1,6,25;

 49:5,13,16;50:1,4,17,

 19,25;51:2,4,7,9,11,13,

 16,19,23;52:1,16;53:7,

 13,18,22;54:4,9,13,20,

 22,24;55:3,7,10,12,15,

 17,20,23;56:3,6,12,15,

 17,22,24;57:3,8,11,15,

 18;59:6;60:13,14,16,

 19,22;61:2,22,23;62:9,

 11,15,17,19,21,23;

 63:1,4,17;64:8,17,21,

 23,25;65:7,9,22,25;

 66:3,7,9,11,15,20;67:8;

 68:17;69:3,6,9,15,19;

 70:1,5,10,13,17;71:1,3,

 5,9,11,13,17,18,20,24;

 72:2,7;74:23,24;75:18,

 20;76:4;77:14,16,21,

 25;78:5,7;79:2;80:6,

 18;81:7,9,11,14,22;

 82:1,6,11,13,15,18,20,

 25;83:2,4,13,17;86:9,

 15,25;87:6,10;95:13;

 96:4;97:6,14,16,23,25;

 98:23,25;101:23;

 102:1,4,7,19;103:1;

 106:11,13,16,20,23;

 107:9,10;108:3,5,7,10,

 13,15,19;109:1,14,17,

 20;110:7,23;111:1,5,7,

 14,22,24;112:7,14,19,

 23;113:1,6,10,13,16,

 19,21,24;114:1,3,15;

 115:5,7,10,12,21;

 116:8,10;119:16;

 132:5;137:23;138:11;

 139:16;140:10,12;

 151:1;153:21;160:10;

 170:23;171:5;180:5,7;

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PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 182:25;185:3;186:19,

 21,24;187:3,21,23;

 188:2,4,17,19;189:7,

 10,16,18,20;190:12,14;

 194:1,12;203:14

Karotkin's (1)

 132:23

keep (18)

 30:7,8,9;44:5;52:3;

 63:19;92:6;98:24,25;

 99:10,14;116:21;

 128:5;144:1;164:10;

 177:23;198:6,8

kept (1)

 174:6

key (4)

 121:18;123:3,3;

 131:3

kidding (1)

 120:7

kill (1)

 189:17

kind (15)

 8:3;10:3;17:13;25:6;

 66:5;73:8;81:1;114:16;

 119:4;120:17;127:21;

 132:16;136:21;158:25;

 170:14

kinds (3)

 13:6;90:4;158:9

Kirkland (1)

 196:3

knew (6)

 108:15;126:9;129:8;

 135:6;203:7,7

knowing (2)

 151:6;152:1

known (13)

 23:5,6,6;31:14;34:8;

 36:10;50:10;52:8;

 59:14;129:4;133:8;

 152:16;159:14

knows (6)

 31:2;107:16;125:7;

 133:10;157:6;169:10

L

labor (1)

 117:10

laid (1)

 101:18

land (2)

 89:22;147:13

language (44)

 32:11;33:8;34:19;

 44:12;45:7;46:3;49:4,

 8,15;52:12,13;56:1,1;

 57:13;59:11,15;60:6,

 17,18,25;62:10;63:5,

 13,20;64:16;72:17;

 83:13;86:13,15;87:11;

 90:2,17;91:1,2;92:8;

 95:16;96:1;100:8,11,

 12,16;116:17;121:18;

 195:15

languish (1)

 157:5

large (2)

 124:22;154:22

largely (2)

 191:4;197:20

larger (1)

 16:11

large-scale (1)

 148:22

largest (1)

 11:13

Larry (1)

 91:18

Lars (1)

 195:2

last (20)

 8:2;10:1;14:22,23;

 18:24;26:13;30:4;

 49:18;89:16;94:24;

 113:23;121:17;122:23;

 126:14;127:2;130:24;

 145:11;147:24;148:9;

 152:6

late (10)

 95:2,4;96:19,22;

 98:15,16;110:18;

 125:1;164:14,17

latent (1)

 159:15

later (27)

 26:3,11;33:15,19;

 59:12;60:4,10,21,22;

 61:9,16;63:7;85:19;

 99:19;103:15;108:2;

 112:9;113:19,20;

 115:25;116:2;118:25;

 127:18;132:20;162:10,

 11;168:3

latter (1)

 62:8

launch (1)

 140:4

law (35)

 20:3;35:1,14;43:9;

 44:6,23;45:1;79:3,18,

 22;81:14,14,18;84:13;

 90:9;95:4,11;96:6,8,22,

 23;97:7;98:6;104:4;

 134:7,22;137:15;

 142:9;174:23;175:5;

 177:24;178:19;184:8,

 12;198:7

lawdo (1)

 185:23

lawful (1)

 31:13

lawyer (5)

 33:6;59:19;120:25;

 133:7;172:18

lawyers (17)

 21:21;32:18;65:20;

 72:2,4;84:7,10;126:2;

 128:24;164:10;185:18;

 186:15,16;187:9;

 188:1;201:21;203:3

layers (1)

 18:5

layperson (1)

 29:22

leader (1)

 120:5

leading (1)

 189:23

learned (1)

 145:17

lease (1)

 90:4

least (12)

 27:8;35:10;42:22;

 43:9,9;54:1;111:15;

 113:2;184:12;185:19;

 195:21;199:3

leave (8)

 40:7;42:20;65:12;

 67:24;173:3;183:17;

 184:19;190:17

leaves (1)

 24:6

LEBLANC (51)

 153:25;154:4,5,5,12,

 17,20,22;155:7,9,11,

 20,22;156:8,16,20,22;

 157:8,11,14,17,20,22;

 158:14,16,22;159:1,4,

 7,10;160:2,4,16;

 161:18,23,25;162:2,4,

 6,12,19,23;163:8,17,

 18,19;189:1;201:3,3,

 13;202:2

lecture (1)

 169:7

led (1)

 96:14

left (3)

 17:17;71:25;198:17

legal (7)

 27:21;69:1;70:12;

 85:1;88:23;90:23;

 134:17

legislature (3)

 108:21;127:1,6

legitimate (2)

 17:24;177:7

LEMON (11)

 164:7,12,12,16,18,

 19;165:5,7,14,16,18

length (1)

 158:8

less (5)

 25:10;47:17;64:7;

 146:19;188:8

lesser (1)

 39:21

lethargy (1)

 191:14

lets (1)

 90:9

letter (2)

 43:20;161:5

letterhead (2)

 70:1,6

letters (2)

 30:15;137:14

letting (2)

 21:20;79:2

level (2)

 111:11;138:11

leveraging (1)

 18:12

liaison (3)

 173:10,14;184:7

liberal (1)

 43:3

life (4)

 141:15;147:9;

 166:11;183:23

light (2)

 20:23;153:4

likelihood (1)

 193:18

likely (4)

 141:23,25;142:2;

 203:4

limitation (1)

 74:24

limited (7)

 7:6;19:16;79:7;

 92:22;93:1;172:13;

 197:6

limiting (1)

 79:8

line (19)

 8:7;29:19,20;44:20;

 53:1;58:21;59:3;69:13;

 78:6,9;80:10,14;84:8;

 96:21;103:6;110:11;

 128:8;148:13;189:14

Lines (1)

 52:25

linked (1)

 79:12

liquidated (1)

 59:25

list (5)

 60:11;75:4;98:5;

 168:22,24

listed (2)

 67:3;90:5

listen (7)

 20:17;21:7;45:5;

 124:14;126:9;137:5;

 159:17

listening (2)

 32:3;140:13

listens (1)

 43:19

listing (1)

 68:21

literally (2)

 136:20;161:4

litigation (2)

 173:15,20

litigious (1)

 182:11

little (19)

 22:2;31:12,12;57:13;

 62:15;65:16;88:20;

 118:16;130:20;132:11;

 146:8;151:10;159:20,

 21;161:8;168:15;

 171:8;183:23;189:5

live (9)

 18:23;71:4;81:3,6;

 129:15;136:3,17;

 140:5;174:14

live- (1)

 137:4

lived (2)

 17:9;98:8

lives (3)

 18:13;30:6;127:13

living (4)

 161:13,13;169:11;

 182:19

local (4)

 16:25;18:8;92:12;

 93:10

locally (1)

 18:7

located (3)

 92:23;93:5,11

logical (2)

 125:2;188:22

lone (1)

 25:22

long (10)

 22:6;88:19;98:5;

 104:9;126:11;146:21;

 153:7;160:13;194:14,

 16

longer (5)

 114:9;132:25;

 146:15;161:23;162:7

look (32)

 14:18;15:1,12,25;

 22:24;28:11;38:4;

 40:10,11;41:7,8;47:16;

 48:2;52:25;54:25;

 57:17;61:5;62:13;

 88:23;93:13,17;95:23;

 96:15;104:20;110:2;

 111:23;114:4;115:19;

 133:6;153:10;197:13;

 199:3

looked (3)

 40:12;56:20;89:20

looking (12)

 28:18;34:16;56:18;

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(14) Karotkin's - looking Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 219

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 63:24;66:4;75:11;

 80:10;87:9;95:16,22;

 96:12;203:16

looks (1)

 59:5

losing (2)

 101:24;176:16

loss (2)

 176:20,20

losses (1)

 111:18

lost (5)

 48:18,19;127:14;

 159:15;203:9

lot (22)

 21:2;29:4;31:1,16;

 38:23;51:3;69:25;72:9;

 89:21;93:2;98:4;106:6;

 111:12;127:10;140:23;

 143:15;168:25;169:7;

 177:1;184:13;188:8;

 194:19

lots (5)

 33:18;84:7;126:14;

 133:10;140:7

loved (1)

 203:9

luck (3)

 35:14;100:3;103:6

luxury (2)

 119:7,8

M

macro (1)

 111:11

Magazine (4)

 15:19,20,22;18:6

magazines (1)

 15:18

magic (4)

 122:15;144:25;

 145:1;165:3

mail (6)

 22:16;24:14;38:19;

 142:3,3;182:6

mailed (5)

 24:15,18;50:10,13;

 137:16

mailing (6)

 23:4,5;24:4;26:16;

 131:4;137:13

main (1)

 121:13

Mainly (1)

 177:5

maintain (1)

 46:24

maintained (2)

 49:2;63:6

major (2)

 75:16;135:15

makes (5)

 38:18;53:2;141:19;

 172:20;181:1

making (18)

 20:23;39:4;79:1;

 86:1;103:17;116:2;

 130:6,6;132:20;

 139:15;151:6;155:14;

 172:18;177:6;179:14;

 185:13,25;187:10

management (3)

 178:8,9,10

Manges (2)

 6:17;52:4

manned (1)

 27:6

manner (2)

 155:15;157:3

many (17)

 48:4;52:9;80:1;86:2;

 136:2,15;142:25;

 143:3;148:6;158:8,9;

 163:12;168:20;200:22;

 202:10;204:4,4

margin (1)

 34:17

maritime (2)

 147:10,12

mark (2)

 28:19;199:22

market (4)

 15:4,5;17:5;18:19

markup (1)

 9:6

mass (4)

 146:5;149:24;

 188:25;189:2

masterfully (1)

 171:24

Matter (11)

 6:4;35:15;48:12;

 55:13;90:1,6;91:4;

 116:16;141:14,15;

 193:23

matters (2)

 7:17;105:4

Matthew (1)

 52:4

maximize (1)

 135:19

maximizing (2)

 149:17;193:17

maximum (2)

 145:1,2

may (29)

 21:19;22:18,20;38:1;

 40:19;45:18;49:25;

 54:20;63:1,10,15;

 68:19;83:19;102:24;

 107:18;110:23;120:8,

 11;124:19;134:18;

 135:7;140:23;154:15,

 24;156:2;159:13,14;

 197:14;203:5

maybe (21)

 25:9;29:12;45:19;

 46:1;47:10,10;50:5,15,

 16;96:25;97:20;98:6;

 103:20,21;106:25;

 143:6;151:8,10;152:6;

 167:2;201:10

mean (127)

 6:12;7:14,22;13:18,

 21;16:10;22:1,1,24;

 23:24;25:6;26:14;

 28:11,14;29:22,25;

 30:6,7,9;33:22;37:16;

 39:6,11,19;41:2;42:16;

 43:11;44:13;45:22;

 46:1;47:24;48:11;

 49:14,25;50:20;52:23;

 59:14,21;60:3,14;

 61:12,13;62:10;64:10;

 67:5;68:20,25;69:24;

 70:7,15;74:20;75:15;

 76:7;77:9,24;79:1,11;

 80:9;81:8,10;82:7;

 83:7,12;84:22;86:6;

 89:5;90:9;92:4,20;

 94:10;97:23;98:14;

 100:15;103:8;105:20;

 106:14;107:25;109:15;

 110:22;111:20;112:1,

 1,17;115:1,13;117:22;

 118:20;119:12;120:7,

 8,21;125:1;126:22;

 128:3;132:18,20;

 133:1,21;136:6,20;

 138:12,16;139:1;

 143:14;144:4;151:6;

 152:13;154:10;157:11;

 158:24;162:12;165:3,

 13;166:8;167:15;

 169:7;176:18,24;

 179:21;181:22;182:16;

 183:7;189:6;190:24;

 191:2;194:4;195:4

meaning (3)

 105:14;156:1;179:23

meaningful (6)

 124:6;125:18;

 141:17;192:22,24;

 193:4

means (23)

 15:16;19:17;27:22;

 29:7,23;30:4,10;33:12;

 35:14;61:13;65:20,24;

 82:3;84:4;85:13;93:3,

 4,23;94:19;106:3;

 109:10;155:25;193:12

meantime (1)

 189:17

measured (1)

 19:2

Media (15)

 6:20,20;11:14;130:7;

 132:6;137:3,11,24;

 138:20;139:17;141:6;

 143:5;145:2;152:8;

 184:5

mediated (2)

 108:9,12

mediates (1)

 108:10

mediator (1)

 108:16

medical (4)

 46:23;47:22;48:22;

 177:23

meet (2)

 157:3;172:25

meeting (1)

 155:1

meetings (1)

 126:3

meltdowns (1)

 122:13

member (5)

 100:4;102:11,12;

 117:16;139:6

members (12)

 64:13;101:14;105:5;

 126:3;127:14;136:25;

 137:1;141:5;163:4;

 166:2;184:14;187:11

memorial (2)

 71:10,17

memory (1)

 121:1

mention (1)

 108:25

mentioned (11)

 21:5;22:23;68:21;

 69:4;74:11;76:15;

 87:21;109:1,21;132:1;

 146:4

merge (1)

 176:14

merits (1)

 35:9

mess (1)

 44:6

message (2)

 13:13;132:3

messaging (2)

 132:2;135:21

methodology (3)

 167:2;173:6;203:24

methods (1)

 19:2

metric (1)

 170:7

metrics (1)

 145:12

Michael (2)

 99:4;165:21

middle (1)

 126:22

might (30)

 7:11,19,20,21;10:11;

 12:10;27:20;29:16;

 39:17;43:24,25;48:12;

 49:19;50:2;74:8;86:12;

 89:13;108:1;112:10;

 124:4;134:16;136:21;

 173:12;176:25;189:5;

 194:7;198:16;199:14;

 202:16;203:21

might've (1)

 177:7

Mike (1)

 196:2

milder (1)

 146:8

mill (1)

 78:15

Millbank (1)

 154:6

million (6)

 24:5;48:20;59:20;

 130:19;159:12;189:3

mind (10)

 6:14;11:1;29:7;

 34:12;37:18;57:14;

 58:15;127:4;198:20;

 203:4

minds (1)

 10:13

minimize (3)

 106:3;123:21;172:1

minimum (1)

 144:12

minor (1)

 65:12

minute (8)

 28:13;31:25;32:24;

 49:22;56:5;88:24;

 90:20;175:11

minutes (4)

 7:12;99:3;175:10;

 190:5

mirrors (1)

 7:15

misinterpretations (1)

 179:24

misled (1)

 73:7

miss (1)

 50:13

missed (5)

 29:12,16;50:6,7,16

missing (2)

 21:20;179:11

mistake (3)

 39:20;129:2,5

mistaken (1)

 19:24

misunderstandings (1)

 180:1

mix (1)

 139:10

mixed (1)

 179:3

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(15) looks - mixed Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 220

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

modifications (4)

 11:16;17:21;195:19,

 20

modified (1)

 188:24

moment (5)

 22:3;110:15;114:20;

 116:5;198:19

money (4)

 67:16,22;170:21;

 188:14

Monterey (1)

 200:6

month (6)

 103:21;107:1;

 110:20;169:14;183:20,

 22

month-by-month (1)

 146:25

monthly (1)

 149:11

months (22)

 32:23;106:5;112:11,

 11,12,21;140:8;147:23,

 24;148:2;154:17;

 156:18,22;157:1;

 158:3;163:12;175:23;

 178:17;179:4,6;181:7;

 184:10

moon (1)

 169:11

more (81)

 7:2;8:7;10:15,22,23;

 11:6,22;13:22;14:2,3,5,

 6,6;18:8;25:16;28:8,

 23;45:13,23;47:17;

 48:8,15;49:6;53:11;

 61:16;62:2,2;64:6,10;

 73:1;82:20;85:7;94:19;

 107:15;109:5;111:7,7;

 112:5;114:13;117:4;

 121:24,25;122:5;

 127:19;132:25;141:16,

 25;142:18,18,18;

 143:3;144:3,14;

 146:13;148:2;151:8,

 11;152:8;156:2;

 159:20,21;161:18;

 162:6;164:24;168:5;

 172:20;176:25;180:5;

 183:23;184:13;185:3,

 22;187:14;188:21;

 189:22;197:18;199:1,

 21;201:14;202:7;203:8

moreover (1)

 23:15

morning (17)

 6:5,7,23;35:10;72:5,

 10;73:22;116:7;

 117:15;121:18;128:13,

 14,16;130:12;169:13;

 191:19,20

most (21)

 7:7;11:13;12:19,20;

 20:14;22:15;128:24;

 129:1,1;130:1;131:5,

 25;134:8;135:1;

 137:10;140:6,7;

 141:23;145:2;178:4;

 189:11

mostly (2)

 91:20;133:18

motion (31)

 12:21,24,24;35:9;

 90:8;91:4;94:3;99:19;

 100:21;110:16;118:10;

 119:18;154:14;156:12;

 162:21;166:6,24;

 167:16;169:25;170:24;

 173:2;181:1;190:1,3,5,

 13;191:14;198:2,2,3,3

motions (2)

 195:11;197:7

motivate (1)

 140:8

motivates (1)

 150:20

motive (1)

 12:14

mouth (2)

 165:8;184:17

move (19)

 11:19;13:1;41:9;

 105:3;109:6,7;110:20;

 120:1;155:2,3,12,14;

 157:2,23;169:19;

 171:7;172:4;183:19;

 190:19

moved (1)

 18:24

movement (1)

 184:9

movements (1)

 191:21

moving (7)

 12:4;111:19;162:15;

 164:21;178:15;181:8;

 203:23

much (21)

 7:15,16;25:10;28:12;

 32:3;33:19;37:21;

 58:17;68:24;75:16;

 95:2;98:7;107:11;

 114:9;123:22;128:18;

 130:11;144:19;179:9;

 198:1;202:19

Mullane (9)

 19:22;21:5;28:6;

 121:17;129:18;130:2;

 135:18;140:6;203:6

multimedia (1)

 145:6

must (10)

 30:11;32:15;34:20;

 45:19,22;50:6;68:4;

 69:14;102:8,16

myself (2)

 103:17;127:6

mystify (2)

 12:1,2

N

nailed (1)

 176:3

name (7)

 37:5;53:16;67:19;

 164:9;176:17;196:24,

 25

names (4)

 23:19;35:20;52:3;

 74:5

narrowed (1)

 194:22

narrowing (1)

 194:21

national (2)

 15:19;40:16

nationwide (3)

 18:6,8,23

nature (2)

 149:6;176:17

necessarily (5)

 40:11;98:6;119:23;

 155:4;156:5

necessary (12)

 17:24;66:10;107:19;

 109:5;120:9,11;122:2;

 137:17;157:23;197:15,

 16;198:16

need (45)

 16:15;25:5;40:9;

 41:11;48:9;52:20;53:8;

 78:3;81:18;86:22;87:7;

 90:13;93:5,15;106:6;

 110:23;113:1;121:5,

 11;122:24;123:4,4,5;

 125:19;143:12,14;

 150:19;156:2,8;157:2;

 162:17,24;163:5;

 169:21,22;171:13,21;

 175:3;179:17;183:1,2;

 191:16;195:21;196:11;

 202:21

needed (3)

 57:12;94:20;159:16

needing (1)

 76:18

needs (15)

 39:11;64:24;69:1;

 79:5;120:15;127:4;

 141:24;162:10;168:6;

 170:4,6;172:25;

 187:17;198:18,25

NEF (1)

 38:6

negatively (1)

 110:21

negligently (1)

 78:23

negotiated (1)

 66:1

negotiations (2)

 118:14,21

neither (1)

 146:1

neutral (1)

 170:21

nevertheless (1)

 166:18

new (4)

 21:1;22:17;136:24;

 170:1

news (4)

 17:11,12;152:9;

 192:1

Newsom (8)

 107:24,24,25;108:1,

 8,18,19;157:14

Newsom's (2)

 108:17;157:4

newspaper (4)

 25:3,23;30:8;142:4

newspapers (3)

 15:23,24;26:1

next (26)

 29:13,18;30:19;

 31:10,10;34:6,7;37:20;

 41:11;42:25;43:20;

 45:14;91:13;103:20,

 21;107:9;108:23;

 126:22;150:10;157:11;

 164:8;194:10;197:16;

 198:16;199:15;200:14

NextEra (1)

 195:14

night (1)

 121:17

ninety (1)

 189:21

ninety- (1)

 147:22

ninety-five (6)

 15:3;18:16;19:15;

 22:7;50:9;189:21

ninety-seven (2)

 24:6;25:1

ninety-two (1)

 25:2

Ninth (10)

 43:3,5,13,25;44:23,

 25;96:5;98:5;134:21,

 22

nitpick (1)

 39:17

nitpicking (1)

 52:24

nitpicks (2)

 10:10,10

nobody (2)

 91:12;197:7

nobody's (1)

 197:6

no-brainer (1)

 122:6

nominally (1)

 35:11

non (1)

 23:25

nonbankruptcy (1)

 84:7

nonexperts (1)

 129:2

nonissue (2)

 7:19;116:20

nonnegotiable (1)

 32:1

nonpersonal (1)

 85:17

nontort (1)

 23:25

nonvictims (2)

 141:8,12

nor (2)

 143:17;146:1

normal (2)

 37:10;121:25

North (7)

 125:8;136:14,15,16;

 173:22;181:7;184:8

Northern (10)

 15:24;30:21,24;31:2;

 74:12;75:5,7;135:21,

 24;200:5

nose (1)

 71:16

notably (1)

 132:12

notation (1)

 39:13

note (7)

 15:20;16:23;19:12;

 107:23;118:8;119:17;

 190:8

noted (5)

 7:5;17:3;95:1;105:4;

 124:3

noteholder (1)

 165:22

notice (114)

 9:24;11:6,12,13,13;

 14:21;15:16;17:19;

 18:2,4,4,5,15;19:2,13,

 17;20:1,4;25:6;28:5;

 29:11;30:16,16;37:8;

 50:9,23;51:2,6;52:6;

 53:2,4,5;66:15,21;

 68:20;69:1,11,12,22;

 70:14;71:8;79:5;81:17;

 105:12;107:11,14;

 114:8;115:14;117:18;

 121:19,20,24;125:17;

 128:20;129:19;130:12,

 18;131:4,18,19,21,21,

 24,25;133:6,22;

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(16) modifications - notice Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 221

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 136:21;137:2,9;138:4;

 140:4;141:14;145:3;

 146:4;147:8,11,17;

 150:9,11;151:11;

 152:22;153:6;158:5,

 20;159:8,16;160:5,6,7,

 9,11,12;173:13;174:3;

 175:24;179:1,9,18,25;

 183:9,13;187:4;189:1,

 2,3,4,12,21,21;190:4;

 192:5;193:10,12,14

noticed (1)

 71:9

notice-related (1)

 129:25

notices (8)

 16:2;147:11;149:19,

 25;152:4,6;159:12;

 203:17

noticing (11)

 12:22;13:16;14:20;

 17:7;114:11;132:6;

 140:11;150:16;152:10;

 159:12;190:19

notification (1)

 131:15

notify (1)

 49:1

notion (3)

 126:4;143:21;148:2

Notre (4)

 181:15,17;192:11;

 202:1

notwithstanding (2)

 99:23;103:14

November (15)

 112:11;165:1,9,10;

 181:8,9,10,11,13;

 183:6,7,7;184:2;

 192:12,13

number (23)

 18:6;22:19;52:18;

 56:8;60:1;69:17;70:9;

 99:12;107:12;109:8;

 124:21,22;125:8,22,23;

 136:19;145:2;179:9;

 181:25;186:25;192:21;

 194:16;195:8

numbers (1)

 53:16

numerous (1)

 73:25

O

Oakland (1)

 105:9

object (10)

 90:1,7,8;91:3,14;

 95:2;116:14,23;

 137:23;151:1

objected (3)

 99:6;151:1;156:20

objecting (1)

 45:8

objection (12)

 32:24;42:9,10;48:10;

 61:12;166:6;196:17;

 197:5,6;200:4,4,9

objections (10)

 8:19;9:11;99:7,15;

 109:22;155:7;162:24;

 196:5,7;200:1

objectors (2)

 195:14;196:4

obligation (1)

 178:21

observable (2)

 136:7,19

obstacle (1)

 119:1

obtain (1)

 17:9

obtained (2)

 162:10;185:22

obviated (1)

 156:2

obvious (1)

 115:18

Obviously (18)

 59:23;68:17;75:16;

 118:1,5,19,22;119:21;

 121:18;125:1;163:1;

 191:15,20;192:2,20;

 198:9;200:23;202:19

OCC (5)

 153:24;158:23;

 161:18;198:13;199:9

OCC's (1)

 166:6

occur (1)

 176:21

occurred (10)

 15:9;18:20;76:21;

 78:21;80:24;82:10;

 86:23;87:3,4;105:9

occurs (1)

 33:18

o'clock (2)

 107:5;169:13

October (33)

 12:12;21:14;24:8,16,

 18;25:1;26:5,16;30:10;

 85:10;103:17;112:9;

 115:15,23;116:6;

 118:25;121:10;139:17;

 143:23;150:12,12;

 158:19;160:1,4;

 166:17,20;183:7;

 184:2;188:21;190:19;

 202:20,25;203:13

odds (1)

 126:5

off (10)

 29:9;83:11;110:10;

 123:18;124:5;138:19;

 154:23;156:4;194:15,

 15

offense (2)

 187:14,14

Office (2)

 73:25;170:20

officer (2)

 6:20,25

officers (1)

 187:12

official (14)

 53:15,16,17,23;

 58:16;67:4;87:23;

 117:12;154:6;155:13;

 158:17;159:10;172:7;

 201:5

often (1)

 69:1

oil (1)

 147:15

Okay22 (1)

 23:22

old (2)

 151:3;152:10

older (3)

 15:4;18:17,21

once (2)

 16:4;153:8

one (91)

 7:21;8:24;9:3,4,5;

 11:13;12:15,18;21:21;

 24:14;28:21;30:19;

 34:11;35:22;37:3,5,17;

 38:19;41:14,18;43:1;

 46:12;51:14;52:24;

 57:20;60:4;64:16;

 68:16;69:17;75:6;76:1,

 9;78:8;83:10,16,21;

 88:24,25;89:1,2;96:2;

 100:3;101:14;105:3,

 17;107:19;109:9;

 110:16;112:6,17;

 114:24;117:23;118:9;

 126:11;129:20;130:1;

 132:2;134:10;140:3;

 144:21;146:12,17,22;

 151:21;155:16;157:13;

 161:18;162:13;165:1;

 166:11;170:12;171:17;

 173:18;177:17;180:17;

 183:11,19;186:22;

 187:9;188:22;190:25;

 192:4;193:5,25;196:3;

 197:24;199:4,21;

 201:4;203:8,12

ones (6)

 16:14;25:6;75:17;

 126:7;131:10;203:10

ongoing (1)

 120:17

online (6)

 17:6,6;18:10,10;

 19:17;201:23

only (25)

 7:9;9:23;15:21;

 16:24;19:14;52:9;

 54:24;55:7,23;58:25;

 76:1;78:12;80:5;85:25;

 96:2;114:20;135:25;

 149:22;156:14;161:16;

 184:23;190:15;191:5;

 197:21;199:17

oOo- (1)

 6:2

open (8)

 7:9;27:3;56:8;

 104:15;171:10;172:4,

 14;197:8

opening (1)

 6:12

operationalizes (2)

 130:2,5

opinion (3)

 46:2;179:20;188:2

opinions (2)

 143:19;187:25

opponents (1)

 187:11

opportunity (9)

 98:17;124:5;135:12;

 149:18;169:15;191:7;

 196:6,18;200:8

opposed (2)

 195:14,19

opposition (5)

 74:18;116:4;120:3,6;

 185:3

optics (1)

 124:20

optimally (1)

 152:8

option (4)

 58:22;60:8,11;

 114:20

optional (1)

 59:4

order (93)

 6:3;7:3,5,14,15;8:2,

 6,21,22;9:12;10:9;

 11:3,8;14:7;20:19;

 21:17;22:10,23;25:24;

 26:10,10,20;28:7,15;

 29:2,2;39:5;40:14;

 41:12;44:24;52:14;

 54:18;72:17;74:11;

 76:11,13;77:17;88:16,

 19,21;89:18,25;90:12;

 91:22,23,24;92:12;

 94:6;95:23;97:19;98:1;

 99:6,20;100:10;

 103:12;105:12;109:21;

 110:13;116:17;118:7;

 124:16;125:20;137:11;

 154:8;156:17;160:17;

 161:7;163:9,15;

 167:20;168:1;170:22;

 172:11,22;180:23,25;

 181:1;190:22;194:3,9;

 196:4;197:4,12,23,25;

 198:11,14,14,21;199:3,

 11;201:16;202:25

ordering (1)

 28:15

orders (11)

 40:14;70:20;89:21;

 100:11;175:7,9;

 176:13;178:8,9,10;

 201:22

ordinary (1)

 84:3

original (8)

 11:6;14:20;15:2,2;

 18:3;47:17;63:10;

 149:25

originally (3)

 59:12;154:24;155:23

Others (9)

 7:20;31:25;78:20;

 91:19;127:6;167:3;

 171:14;185:19;202:11

otherwise (4)

 88:21;118:6;165:6;

 172:11

OTT (1)

 18:8

ought (7)

 97:1,9;151:10;

 159:20;180:24;185:24;

 194:2

out (86)

 6:18;12:18;21:25;

 23:12;25:22;32:5;

 34:23;35:14;40:8,9;

 41:21;47:24;48:7;60:1;

 66:24;67:24;71:6,13,

 15,16;74:22;77:23;

 79:2;80:4,19;81:22;

 86:1;88:17;89:3;90:17,

 18,19;95:15,18;100:3,

 11,17;101:18;103:6;

 104:6;106:17;107:22;

 109:8;110:2;111:3,7;

 117:8;118:20;123:25;

 125:22;127:4,22;

 130:21;134:10,11;

 136:8,20;139:13,14;

 146:9,9;148:8;149:21;

 152:15;153:8;158:5,

 10;162:9;168:20;

 169:1;170:8;171:11;

 172:16;174:6;175:17;

 179:24;180:1,9;

 189:22;191:3;197:19;

 198:17;199:12,14;

 202:21;203:18

outcome (4)

 35:4;101:15;187:13;

 198:11

outreach (4)

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(17) noticed - outreach Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 222

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 19:3,17;64:12;

 129:19

outside (9)

 12:13;18:23;93:3;

 126:13;128:11;174:15,

 18;175:21;178:2

outstanding (6)

 9:11;54:24;196:5,17;

 197:22;199:5

over (27)

 18:20,22;47:23;

 78:17;93:3;106:5;

 108:16;124:9;131:18,

 19;135:2,22;140:8;

 145:2;149:14;164:5;

 168:9,9;169:25;

 174:15;178:20;180:14,

 14;184:24;194:10;

 195:25;198:16

overall (2)

 19:3;135:20

overkill (2)

 98:3,4

override (1)

 72:18

overrule (1)

 44:25

overseeing (1)

 117:18

overwhelmed (1)

 29:10

overwhelming (1)

 13:23

owed (5)

 43:21;65:5;67:16,22,

 25

own (4)

 34:23;109:24;

 119:21;172:21

P

package (1)

 171:19

page (39)

 28:14;29:2,13,18;

 31:10,10;33:7;34:7,17;

 39:9,12,18;40:6;41:16,

 19;43:1;45:14,14;

 49:18,19;50:6,8;52:25;

 53:4,23;54:1,2;55:1,4,

 4,8,24;65:1;66:21;

 67:1;69:12;99:11,12;

 201:23

paid (5)

 59:25;113:22;118:6;

 127:18;144:19

Pandora (1)

 17:2

paper (3)

 44:8;174:6;203:16

papers (6)

 13:20;95:4;110:3;

 118:16;192:5;198:8

Paradise (1)

 22:17

paragraph (58)

 11:12;18:2,14;28:15;

 29:1;37:2;39:18;40:5;

 41:19,25;43:1,8,15,16;

 44:25;46:8;49:8;50:7;

 52:18;53:3;55:25;58:9,

 17;76:10;77:6;79:2;

 80:4;81:11;88:17;

 91:14,24;92:8;93:7;

 94:11;95:6,7,22,24;

 96:15,17,18,19;97:7,

 17,18,19,20,21;98:1,3;

 99:5,15,16,17;100:2,

 17,23;101:19

paragraphs (6)

 32:11;41:22;89:17,

 18,24;96:11

parallel (1)

 120:20

paramount (1)

 11:25

pardon (2)

 85:2,5

parse (1)

 82:4

part (9)

 48:22;56:8;57:5;

 75:4;112:19;154:22;

 170:4;175:6;178:4

participant (1)

 103:4

participate (5)

 108:21;125:20;

 126:3;127:19;193:7

particular (13)

 32:19;42:9;44:7;

 129:16;141:24;153:11,

 15,15;156:1;184:6;

 197:22;198:19,25

particularly (7)

 9:11;23:24;33:18;

 106:7;129:14;137:18;

 188:23

parties (16)

 12:2;25:18;43:17;

 45:8;79:5;109:7;110:5;

 118:22;120:15;121:21;

 126:16;153:19;194:17;

 195:8;198:23;201:11

partner (2)

 194:25;195:2

party (4)

 70:8;110:7;118:9;

 179:18

Pascuzzi (72)

 73:20,21,23,23,24;

 74:3,6,10,16;75:3,12,

 14;76:3,9,13,15,18,20,

 24;77:5,11,24;78:2,6,9;

 79:4,16;80:9,13,16,20,

 25;81:2,4;82:24;83:1,

 3;84:20;86:17,19,19;

 87:1,5,13,15,18,20,24;

 88:5,6,9,12,14,16;89:4,

 7,10,16;90:11,25;91:6,

 8,11,15;92:17;93:2;

 98:19;199:1,2,7,13,20

Pascuzzi's (2)

 86:10;90:17

pass (1)

 184:14

password (2)

 160:21;161:6

past (2)

 97:9;121:2

Paul (3)

 73:23;84:19;86:19

pause (1)

 122:3

pay (4)

 113:7,9,10,15

payments (1)

 65:5

pays (1)

 172:3

people (124)

 10:13;14:14,16;

 15:19,21;17:7,9,17;

 20:3;29:4,10;31:1,15;

 33:12;35:8,11,20;

 36:10,14;38:23;40:14;

 41:22;42:11;44:18;

 49:1;51:17,20;59:22;

 64:13;71:13;75:22;

 80:2;81:19;84:22,25;

 85:2,16,17;87:7;92:22;

 98:4;100:18;101:17;

 103:12;114:13;115:14;

 121:23;122:16,21;

 123:18;124:4,21,22;

 125:12;127:13,13,14,

 19;132:1;136:1,2,10,

 16,20;137:5,14,20;

 141:8,10,23,23,23,24,

 24;143:21;144:3,18;

 146:9;147:13;148:6;

 150:5,21;152:15,17,18;

 157:2;158:2;159:13;

 165:8;168:9;170:19;

 172:20;174:14,17;

 175:17;176:10,25;

 177:21;178:2;179:4,

 11,11,13,15,17;180:2;

 181:7,23;182:10,11,13,

 22;184:9,24;185:19;

 189:3,4,6,12,21;

 193:13;194:7;198:17,

 17

per (1)

 111:10

percent (12)

 15:3,15;18:17,20,22;

 19:14,15,15;135:23;

 147:23;184:20,24

percentage (1)

 183:25

perception (2)

 75:25;105:4

perfect (2)

 83:13;153:1

perhaps (9)

 12:20;41:20;43:2;

 48:15;49:6;68:24;

 112:17;128:10;196:12

period (8)

 16:11;63:4;72:24;

 104:6;125:15;126:11;

 138:11;176:19

periods (1)

 166:25

permanent (1)

 136:24

permit (2)

 43:10;118:2

permitted (4)

 44:22;95:10;96:7;

 109:22

person (15)

 20:1;32:4;37:21;

 41:25;80:22;82:9,21;

 84:3;85:13;86:20;

 148:10,10;183:1;

 194:16;199:21

personal (11)

 42:1;47:8;76:20;

 77:1;79:8,12,17;86:20;

 146:3;176:18;189:7

personalized (1)

 66:25

personally (1)

 152:19

perspective (6)

 13:10;63:23;120:14;

 154:13;167:6,23

persuade (4)

 114:23;135:6;

 147:25;187:13

persuaded (2)

 124:25;132:24

persuades (1)

 114:18

persuasive (5)

 64:11;139:16;

 143:23;148:5;187:19

pertains (1)

 80:5

pertinent (1)

 32:11

petition (12)

 33:14,16,23;39:25;

 76:22;77:7;78:11,13;

 79:23;81:18;83:16;

 84:18

Petrie (1)

 126:1

PG&E (23)

 6:4;70:1,6;78:17;

 91:24;92:9,11;95:22;

 108:9,12,20;112:1;

 119:17;142:7;150:11;

 170:13;175:13,23;

 178:20;179:12;180:2;

 195:15,20

PG&E's (2)

 119:21;186:13

ph (1)

 108:16

Phone (5)

 110:6;137:2;141:6;

 194:10;197:17

phones (4)

 136:3,4,17;142:5

phonetic (4)

 126:2;145:19;

 185:19;197:1

phony (3)

 48:11,12,13

phrase (5)

 44:22;49:23;53:5;

 65:19;69:18

phrases (1)

 69:17

physically (2)

 27:5;141:6

pick (6)

 21:21;88:2;139:17;

 148:3;198:9;202:16

picked (3)

 22:24;58:23;126:4

picture (1)

 101:24

piece (2)

 44:7;203:16

pieces (1)

 24:5

pigs (1)

 153:16

pin (1)

 132:13

Pioneer (1)

 200:3

pitch (5)

 45:4,5;116:2,12;

 151:6

pivotal (1)

 79:23

place (6)

 75:10;150:3,13;

 163:12;170:7;177:9

places (1)

 27:3

plaintiffs (1)

 99:5

plaintiffs' (1)

 125:7

plan (69)

 11:13;14:20,21;

 17:23;18:4,4,16;19:18,

 18;20:14;49:24;80:11;

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(18) outside - plan Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 223

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 103:20,22,22,24;

 107:17,20;110:16;

 112:21,24;113:17;

 116:5,7;117:18;118:7,

 13,13,21,24;119:1,5;

 121:9;125:21;126:21;

 127:17,22;128:21;

 129:19;130:13,25;

 131:4,21,22,24;132:25;

 135:21,24;138:4,24,24;

 145:3,6,6,7;146:12;

 153:6;167:21;168:3;

 172:2;190:8,9,16,19,

 23;191:3,6,18;193:12

plane (1)

 164:14

planned (3)

 111:24;156:13;161:9

plans (6)

 21:3;49:24;130:18;

 145:3;152:24;176:14

players (3)

 198:15,22;200:15

playing (1)

 21:1

pleading (7)

 70:12;74:3,4;76:24;

 167:5;169:13;180:8

pleadings (7)

 8:15;25:17;59:22;

 91:20;109:24;126:1;

 156:5

please (8)

 44:18;50:6;68:16;

 86:13;97:24;99:8;

 107:8;196:21

pleasure (3)

 71:1,2;72:1

plenty (1)

 109:6

plucked (1)

 125:22

plugs (1)

 122:21

pm (2)

 107:6;204:8

podium (4)

 124:9;129:3;167:19;

 196:14

point (50)

 12:18;20:19,23;

 31:17;36:25;37:16;

 38:15;39:6,22;47:19;

 57:10;62:4;64:4;71:6;

 77:6;80:3;85:21;89:16;

 94:24;95:15;103:24;

 105:19;109:8;110:14;

 115:24;118:20;119:16;

 120:13,15,17;128:6;

 133:13;138:2;140:2,

 14,14;141:4;148:12;

 159:25,25;160:4;

 177:6,10;180:11;

 186:7,17;191:16;

 193:7;195:21;198:1

pointed (3)

 71:13;100:11;191:3

pointing (1)

 194:25

points (9)

 10:9;12:11;26:22;

 54:10;87:20;142:9;

 154:7;156:9;184:4

policies (2)

 65:19,20

policy (1)

 90:4

political (2)

 127:1;170:14

politicians (1)

 170:19

poll (1)

 136:10

polled (1)

 201:24

polluted (1)

 144:19

poor (3)

 67:15,16;151:3

population (2)

 68:24;152:16

position (11)

 35:14;83:5,8;119:24;

 124:18;158:23;162:16;

 167:1,4;183:11,18

positions (2)

 81:20;171:2

positive (1)

 192:1

positively (1)

 19:24

Posner (1)

 84:12

possession (4)

 174:19,20,21;185:14

possibility (2)

 82:4;133:3

possible (7)

 11:20,21;119:25;

 141:22;169:23;172:16;

 201:18

post- (1)

 83:15

postcard (1)

 43:5

postpetition (1)

 84:4

post-petition (9)

 9:13;41:21;77:21;

 80:2;82:2,22;83:12,18;

 84:24

posts (1)

 158:8

potential (3)

 9:13;159:15;174:15

potentially (2)

 159:14;193:6

power (12)

 35:24,25;36:6,9;

 91:19;92:14;93:1,10;

 200:2,5,6,7

PPA (1)

 67:15

PPAs (1)

 198:18

practical (2)

 112:16;134:9

practice (3)

 12:24;47:25;129:16

pre- (2)

 81:17;100:12

preaching (1)

 112:5

precise (1)

 203:7

precludes (1)

 43:16

predict (1)

 149:8

prefer (4)

 42:16,20;70:22;

 80:20

preference (1)

 61:8

preferred (2)

 41:4;59:15

pre-January (1)

 80:5

pre-judge (2)

 83:4;102:1

pre-judged (1)

 95:5

pre-judges (1)

 96:22

prejudging (1)

 85:1

pre-judging (1)

 102:15

pre-judgment (1)

 104:10

premature (1)

 100:6

preparation (1)

 123:22

prepare (3)

 107:14,15;123:19

prepared (3)

 18:2;118:23;201:6

preparing (1)

 33:22

prepetition (1)

 79:20

pre-petition (8)

 75:20;77:4,5;78:19,

 25;79:7;81:16;84:24

present (1)

 7:18

presentation (3)

 117:9;166:17;194:22

presented (4)

 179:19;187:5,19,24

preside (1)

 135:2

president (1)

 6:20

presidential (2)

 192:12,15

press (4)

 106:6;168:21;169:1,

 25

pressure (1)

 25:10

pressures (1)

 126:13

presumably (1)

 24:18

presume (2)

 149:24;150:4

pretend (2)

 78:14;132:19

pretty (3)

 27:15;64:9;107:11

previously (1)

 62:6

primarily (3)

 117:13;137:1;153:7

Prime (20)

 6:25;21:1;23:8;

 37:20,22;38:22;47:4,9,

 12,14,23,23;73:11;

 159:7,11,18,23;160:5,

 7;203:20

principal (6)

 11:18;23:9;110:14;

 198:15,22;200:15

principally (1)

 168:10

principals (1)

 139:3

principle (2)

 21:4;43:3

principles (3)

 19:21;20:7;130:9

print (3)

 15:18;16:2;31:12

prior (9)

 24:19;49:16;50:9;

 78:13;109:22;119:18;

 120:21;170:13;197:7

priorities (1)

 198:9

priority (1)

 198:10

privilege (2)

 140:16;141:3

probability (1)

 131:15

probably (11)

 38:16;49:17;67:9;

 69:25;80:3;84:9;

 119:13;149:4;171:12;

 184:13;197:16

problem (19)

 6:9;31:19,25;42:7;

 43:18;75:4;79:3;80:7;

 97:6;99:15;128:9;

 153:11,13;168:3,4;

 169:6;178:18;195:5;

 200:18

procedural (2)

 139:8;163:14

procedure (10)

 99:21;124:11;142:9,

 10;167:11;180:1;

 181:4;183:8,9,18

procedures (7)

 101:18,20;114:12;

 167:10;183:14;185:23;

 193:10

proceed (3)

 102:15;118:21;

 141:21

proceeding (1)

 36:8

proceedings (6)

 120:1;131:12;

 135:15;147:9;173:10;

 204:8

process (30)

 11:7;19:23;25:8,10;

 28:6;72:18;75:25;98:7;

 107:17;111:2,19;

 114:12;127:20;130:1,

 2;134:9;136:10;

 141:18;145:18;148:1,

 2;154:13;158:4;

 164:21;172:4,5,12,14;

 178:23;204:5

processes (1)

 139:8

processing (1)

 38:20

produce (3)

 160:23,24;180:25

produced (2)

 163:10;172:23

product (11)

 174:22;175:19;

 176:15;177:20,22,25;

 178:8,11,19,20;185:21

productive (1)

 194:8

professional (1)

 73:3

professionalized-only (1)

 49:10

professionals (2)

 29:3;202:8

profound (1)

 130:1

progeny (1)

 19:22

program (26)

 14:20;90:4;107:12,

 14;115:3,14,19;123:6;

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(19) plane - program Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 224

of 233
PG&E CORPORATION AND PACIFIC GAS 

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Case No. 19-30088; Chapter 11

June 26, 2019

 130:14;131:1,1;137:2,

 10;140:4;141:17;

 145:11;146:4;158:20;

 160:5,6,7,9,11;179:9,

 18;187:4

programs (1)

 147:8

progress (4)

 168:16;194:19;

 196:12;198:5

progressing (1)

 131:12

promise (2)

 186:3;195:25

promoting (1)

 159:18

promulgation (1)

 114:19

proof (92)

 7:8,16,25;8:18;33:9,

 11;34:13;42:6;43:7;

 44:1,8,13;45:1;46:8,10,

 16,22;47:7,15,21,24;

 48:20,23;49:4;57:1;

 59:2;65:15;66:24;67:2;

 68:7,8,19;69:10,11;

 70:15;72:15,20,23,24;

 78:12;81:24;82:22;

 84:25;85:3,5;87:21;

 89:7,12;92:10;95:3;

 96:5;97:10;99:22,23;

 100:17;101:1,4,13,25;

 102:2,4,10,13,16,22,

 24;103:6,10,14;104:2,

 2,6,7,10;107:16;

 109:10;115:8;125:19;

 128:20;130:4;141:20;

 143:22;174:3;175:22;

 176:4,4,7,10,12;

 177:18;183:2;188:24

proofs (17)

 33:17;40:14;43:4,10;

 89:1,6;96:18,24;99:17,

 20;100:7,13,18;101:6,

 7;111:15;131:16

proper (4)

 33:20;48:21;56:9;

 125:17

properly (1)

 186:3

property (8)

 76:20;77:1;79:8,17;

 86:20;136:13;174:23;

 203:9

proposal (13)

 15:2;21:8;114:19;

 116:5;151:7,10;

 158:24;160:3;167:8;

 170:16;179:18;202:17,

 22

propose (2)

 181:8;197:9

proposed (30)

 7:15;8:2,6,21;11:6;

 13:19;14:21;26:10,10;

 28:15;29:2,2;81:4;

 84:17;95:23;99:6;

 100:10;107:12;116:17;

 130:13;131:8;155:23;

 161:20;167:9;180:11,

 13;187:4;195:14;

 199:11;201:4

proposing (3)

 13:16;125:6;188:20

pros (1)

 104:23

protect (1)

 60:2

protected (2)

 100:4;104:1

protecting (1)

 198:1

protections (1)

 178:6

protective (12)

 194:3,8;196:4;197:4,

 12,23,25;198:11,20;

 199:11;201:16,22

provide (7)

 64:2;119:22;125:16;

 155:23;160:12;173:11;

 192:23

provided (6)

 46:21;49:9;63:7;

 88:21;132:19;203:13

provides (1)

 109:11

provision (2)

 41:19;42:14

provisional (2)

 167:20;169:21

provisions (1)

 14:23

psychological (1)

 165:4

public (10)

 48:9;136:9;145:8;

 152:9;168:2,17,19;

 175:13;178:5;190:17

publication (8)

 16:3,6;25:23;26:2,3,

 11,12,13

publications (2)

 16:1,8

publish (1)

 26:5

published (1)

 16:4

PUC (1)

 127:1

purchased (1)

 17:3

purported (1)

 102:12

purportedly (2)

 117:23;127:16

purpose (3)

 105:13;155:1;160:8

purposes (12)

 49:23;95:17,18;

 96:21;106:7;111:24;

 113:2;125:21;147:9;

 170:3;201:12,18

pursuant (2)

 97:18;162:21

pursue (1)

 85:14

pursuing (1)

 163:11

push (2)

 111:7;154:23

pushing (2)

 124:18,18

put (38)

 14:13;26:17;31:22;

 33:14;39:24;40:3;

 42:18;56:10;59:2,3,23;

 75:21;81:23;88:20;

 91:1,2;95:3;114:23;

 123:5;142:14,16;

 143:22;156:4;170:21;

 175:18;176:14;177:18,

 19,25;180:23;181:20;

 187:1;193:19;194:2,9,

 15;199:15;200:22

puts (2)

 13:9;109:3

putting (9)

 23:9;53:15,20;54:6;

 174:5;178:19;179:3;

 183:22;194:15

Q

qualified (1)

 138:20

quantify (1)

 32:5

quantifying (1)

 31:16

quantity (3)

 31:17;122:6,7

quick (1)

 91:21

quickly (11)

 11:22;72:12;112:5;

 137:10;169:17,18;

 172:16,20;173:2;

 189:22;197:17

quite (2)

 65:19;107:14

quiz (1)

 201:19

quoted (1)

 126:1

quoting (1)

 97:17

R

race (1)

 175:1

racial (1)

 85:18

radio (11)

 16:25,25;17:1,4;

 18:9,9;24:12;26:20;

 30:8;137:19;183:4

raise (7)

 54:11;57:4,4;74:8;

 94:24;101:9;120:12

raised (14)

 7:3;11:9;22:7;37:17;

 54:17;57:7;68:18;

 69:13;76:3,24;91:1;

 106:17;127:12;155:7

raises (1)

 57:6

raising (2)

 78:20;106:24

ramped (1)

 149:1

ramping (1)

 150:2

ran (2)

 78:17;127:13

range (2)

 12:13;192:20

rate (2)

 123:17;170:21

ratepayers (1)

 170:22

rather (8)

 12:14;21:16;24:14;

 45:19;63:12;70:12;

 142:11;164:3

rationale (1)

 64:3

reach (26)

 15:1,3,14,14;18:15,

 16,20,22;105:16;

 130:7;131:5;136:11;

 137:20,20,21;140:8;

 150:17,18,21;152:7,8;

 187:13;204:1,2,2,3

reached (3)

 8:15;153:8;190:16

reaches (4)

 19:14;135:21,22,24

reaching (1)

 132:1

read (20)

 13:20;15:7;19:8;

 20:23,24;30:23;62:7,

 13,23;100:24;101:17;

 103:12;121:17;143:18;

 152:11;166:13;169:15,

 17,17;170:17

reader (1)

 64:6

reading (3)

 29:6;30:8;169:2

reads (3)

 52:14;82:9;101:5

ready (2)

 28:23;119:4

real (6)

 105:14;119:6;

 125:18;126:19;136:7;

 176:9

reality (6)

 123:12;125:18;

 127:12;140:5;141:15;

 153:14

realize (5)

 63:17;68:23;112:3,

 10;176:24

realized (1)

 162:16

really (42)

 7:23;10:9;12:13;

 20:6;22:7;25:5;27:20;

 33:8;38:4;39:5,6;

 42:10;57:5;79:13;80:1,

 2;89:19;106:12;107:3,

 13;109:3;112:8;119:1,

 24;121:5;124:25;

 140:10;144:4;146:17;

 150:19;151:9;172:18;

 181:14,20;193:4,18;

 194:3;196:11;197:15;

 199:18;200:11;201:20

reason (18)

 12:14;32:19;38:17;

 64:3;121:4;122:2;

 124:20;126:20;127:15;

 136:1;151:22;168:5;

 177:17;188:22;199:17;

 202:19,21;203:20

reasonable (14)

 19:22;20:7,12;123:6,

 7,8,9,10,11,11;124:24;

 130:9;141:19;149:18

reasonably (2)

 121:20;141:19

reasons (4)

 12:1;131:7;140:7;

 169:22

recall (4)

 16:6;39:24;156:18;

 189:4

recalled (1)

 189:11

receipt (2)

 37:24;38:12

receive (5)

 65:5;72:16;99:24;

 101:20;137:14

recent (2)

 107:23;108:20

receptive (1)

 172:24

Recess (1)

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of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 107:6

recipient (1)

 67:7

reckoning (1)

 120:8

recognize (2)

 114:10;197:2

recognizing (1)

 141:15

recommend (3)

 79:15;181:5;194:11

recommended (1)

 11:14

recommends (1)

 25:23

reconciling (1)

 168:16

record (14)

 48:9;50:11,14;51:11;

 52:10,11;60:9;88:2;

 94:17;133:9;164:9;

 165:21;188:18;190:15

records (3)

 46:23;47:22;48:22

recover (1)

 179:5

redacted (1)

 63:8

redaction (1)

 63:9

Redding (1)

 152:17

redline (3)

 59:4;60:7;63:5

Redwood (1)

 200:2

reeling (1)

 59:19

refer (4)

 17:25;18:1,11;99:7

reference (9)

 8:14;11:10;39:22;

 52:25;53:2;57:6;58:17;

 97:21;98:12

referenced (2)

 23:20;166:23

references (2)

 40:6;75:14

referred (2)

 100:12;189:1

reflect (2)

 40:19;67:10

reflection (1)

 31:24

regard (5)

 74:10;90:13;130:11;

 155:4;191:25

regarding (3)

 89:17;167:20;196:7

regardless (2)

 102:8;157:14

regrettable (1)

 127:2

regular (3)

 89:7;198:16;200:19

regulatory (1)

 127:5

reimbursement (1)

 76:25

reinforce (1)

 142:1

reinforces (1)

 150:20

reinstated (1)

 127:18

reject (2)

 187:20;198:2

relate (1)

 9:23

related (13)

 54:16,21;55:8,12,13,

 14,18;114:24;117:13;

 121:19;138:13;155:11;

 177:19

relates (1)

 161:15

relating (1)

 178:11

relations (2)

 145:8;152:9

relationship (1)

 108:20

relatively (4)

 14:25;107:14;153:7;

 165:23

release (2)

 71:22;134:14

relevance (2)

 174:8,12

relevant (6)

 64:14;161:22;

 170:11;171:24;172:8;

 198:19

reliability (1)

 145:24

reliable (2)

 136:21;151:24

relief (1)

 109:25

rely (3)

 143:20;159:4;170:21

relying (1)

 145:22

remain (6)

 46:11,16;47:19;

 107:8;117:25;118:1

remaining (3)

 9:23;130:16;137:22

remarks (4)

 8:10;10:24;124:8;

 189:25

Remember (8)

 40:13;41:22;63:14;

 65:3;74:15;143:4;

 147:5;165:8

reminders (1)

 143:25

remoteness (1)

 84:11

repeat (3)

 34:9;147:2;199:8

repeating (1)

 127:6

repeats (1)

 128:4

rephrase (1)

 49:22

reply (2)

 8:14;191:18

report (3)

 160:14;161:10;

 172:23

reported (1)

 149:11

reports (3)

 20:24;152:9;168:21

represent (2)

 73:25;136:12

represented (4)

 24:10;52:6;93:2;

 125:8

representing (9)

 25:18;34:22;35:17,

 25;51:13;65:21;132:7;

 183:21;198:23

represents (3)

 51:3;92:17;117:16

request (14)

 16:23;17:2;43:16;

 74:19;90:18;117:5;

 154:9;160:18,19,20;

 161:2;165:16;166:16;

 172:9

requested (8)

 15:21,24;16:24;45:8;

 46:4;74:12;109:22;

 158:19

requesting (1)

 55:17

requests (3)

 162:20;172:7,19

require (3)

 35:1;40:23;48:17

required (3)

 35:18;63:2;82:22

requirements (2)

 28:6;157:4

requires (2)

 100:25;102:8

requiring (1)

 45:25

reschedule (1)

 196:1

rescission (1)

 41:5

reservation (1)

 89:24

reserve (5)

 89:17;90:13;91:7;

 98:19;109:11

reserved (1)

 98:21

reserves (1)

 97:7

reserving (5)

 90:7,23;91:3,8,10

residents (1)

 18:21

resolution (2)

 66:16;131:9

resolve (4)

 55:21;56:7;93:21;

 198:12

resolved (10)

 7:7,20;8:20,23;9:11;

 53:12;105:18;190:9,9;

 196:5

resolving (1)

 198:20

respect (37)

 7:7,8;8:21;9:13;

 14:19;15:18,23;16:20,

 25,25;35:18;36:14;

 45:1;49:24;54:25;

 98:20;116:3;128:19;

 134:19;135:20;136:16;

 138:7;155:3;160:5;

 167:7;168:2,15,16;

 171:22;172:1,9;179:8,

 15;187:8;195:7,16,22

respected (4)

 129:4;139:6,6;

 187:11

respond (5)

 122:22;158:5;

 167:24;190:2;199:4

responding (1)

 152:1

response (9)

 22:6;96:6;101:23;

 123:13,17;130:14;

 161:3;191:15,23

responsibility (1)

 174:5

responsible (2)

 184:14;186:15

responsive (1)

 180:8

rest (1)

 104:18

result (3)

 47:25;62:12;193:5

results (2)

 19:4;133:9

resume (2)

 194:8;195:25

retained (3)

 111:13;159:5;160:8

return (1)

 129:12

returns (1)

 188:12

reversed (1)

 121:3

review (2)

 7:17;8:2

reviewed (2)

 118:16;188:18

reviewing (1)

 28:12

revised (3)

 8:22,22;18:4

revisit (3)

 45:6;202:20;203:22

right (189)

 6:11;8:7,17;10:17;

 17:3;20:8;22:1,19;

 23:17;24:4,24;25:6,10,

 15;26:8,22;28:3;31:16;

 32:18;34:2,6;36:13,15;

 37:1,12,14;39:12;

 41:23,24;43:6,19;49:3,

 5;50:3,5,24;52:7;

 53:17;54:19;55:2;

 56:25;57:19;58:10,19;

 61:22;62:12;63:3;65:4,

 15;67:13;68:1,2,16;

 70:16;71:15;75:22;

 76:19,19,23;77:4;79:3;

 80:3,8;81:13;82:1,19;

 84:4,5,19;85:3,14,22;

 86:22;87:2,8;89:2,3,6;

 90:1,10;91:8;92:18,21;

 93:8;95:8;98:11;101:2,

 16;102:3,6;103:18,23;

 104:17;105:7;106:7;

 109:17;112:11,22;

 114:25,25;115:4,21;

 116:8,11,24;117:15,22;

 122:7,8,18;124:18;

 125:2,5,10;126:24;

 129:17,23,23;130:2,5,

 17;133:2,12,22;134:6;

 135:4;136:6,7;138:3,

 10,14,17;139:11,25;

 145:13,16;148:13,20;

 149:6;150:18;151:20;

 154:16;155:6,8,21;

 156:10,15,19;157:19;

 158:6;159:6,9;165:14;

 167:17,22;168:12;

 169:9;171:8,12;

 173:23;174:8,12;

 176:22,24;177:9;

 178:14;180:16;181:2;

 187:3;188:10,10;

 189:10;191:22;192:2,

 6,17,21;193:11,17;

 194:20;195:12,18;

 197:19;199:1;201:2;

 202:1,10,16;204:2

right-hand (2)

 15:13,25

Rightly (1)

 47:22

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(21) recipient - Rightly Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 226

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

rights (12)

 89:17;90:7,14;91:3,

 7,8,10;98:20,21;101:5;

 109:12;121:21

ringing (1)

 110:6

ripe (1)

 200:11

rise (2)

 107:7;154:7

risk (6)

 20:2;53:10;103:7,8;

 109:4;119:9

road (2)

 183:20;185:11

robust (4)

 18:8;20:14;114:11;

 193:12

roll (1)

 198:16

room (8)

 29:4;69:25;126:4;

 161:13,13;163:2;

 172:18;196:13

Rosa (1)

 182:20

roughly (1)

 183:19

round (1)

 62:3

rounds (1)

 11:8

rule (12)

 97:17,17,18;98:2;

 99:19;100:20;140:21;

 161:5;162:25;163:1,

 11;185:22

rules (4)

 40:12,16;129:20;

 141:3

ruling (2)

 35:10;169:21

run (7)

 16:1;89:22;153:17;

 173:24;176:12,14;

 177:18

running (1)

 8:8

run-of-the- (1)

 78:14

S

Sacos (1)

 185:19

safe (1)

 103:7

safely (2)

 175:18;177:18

sailing (1)

 204:3

same (24)

 32:6;34:7,8;49:8,8;

 64:18;65:1;68:21;

 69:12,13,15;75:12;

 83:9;91:16,16;105:2;

 130:18;162:14;163:12;

 175:25;176:1;178:25;

 186:15;202:1

same-day (1)

 137:20

sampling (1)

 111:15

SAN (5)

 6:1;108:10;200:6,6,7

sanctionable (1)

 161:4

Santa (1)

 182:20

satellite (1)

 24:12

satisfied (3)

 11:7;28:6;96:7

satisfy (1)

 170:22

satisfying (1)

 170:3

saturate (1)

 131:14

saturating (1)

 131:18

save (1)

 151:25

saves (2)

 97:21;98:12

savvy (1)

 24:11

saw (1)

 16:5

saying (36)

 9:14;20:11;24:22;

 31:19;35:23;38:18;

 41:21;46:15;56:17;

 80:19;97:8;98:2;

 102:16;103:2;104:7;

 113:7,10;119:23,25;

 124:19;128:4,5;129:5;

 136:6;144:4;179:22;

 180:2,23;183:2;

 186:11;187:8,23;

 188:19,19;189:12;

 198:22

scaled (1)

 146:17

scanning (1)

 63:11

scary (2)

 17:13,15

Schedule (9)

 67:18,21;89:20;90:5;

 91:4;191:11;197:14,

 15;203:24

scheduled (4)

 23:20;67:10,20;

 154:25

schedules (5)

 23:20;25:9;61:3;

 67:3;90:8

school (1)

 152:10

science (2)

 202:5,7

scope (1)

 92:24

screen (1)

 14:14

screwed (2)

 85:2,5

seal (2)

 71:17,17

search (1)

 17:11

season (12)

 141:7,22;147:1;

 149:15;157:5,10,12,17;

 164:22;184:4;192:25;

 193:3

seasonality (2)

 123:16;140:3

seated (1)

 107:8

second (16)

 10:1;28:21;34:12;

 37:2,18;41:18;46:12;

 52:24;65:16;68:16;

 70:18;76:9;83:10;95:1;

 170:17;193:25

second-guess (5)

 41:14;114:20;

 159:19;188:20;202:14

section (2)

 95:3;192:5

sections (1)

 56:19

seek (2)

 162:24;163:10

seeking (1)

 172:8

seem (4)

 11:3;126:6;151:23;

 199:9

seemed (3)

 26:2;52:22;200:23

seems (19)

 20:16;22:3;31:14;

 33:20;36:10;45:22;

 48:15,21;77:15;83:12;

 104:22;116:15;126:12,

 19;147:2;169:14;

 182:17,18;203:19

selected (1)

 25:19

self-explanatory (1)

 14:25

seminal (3)

 129:22,24;134:22

send (6)

 38:19,19;43:4;68:12;

 182:15;197:13

sends (1)

 43:20

sense (14)

 10:10;30:25;68:8;

 113:14;126:19;143:14;

 153:12;155:11;163:17;

 168:6,7,7;171:21;

 178:15

sensitive (1)

 114:4

sent (2)

 66:24;161:4

sentence (7)

 37:2,17,18;63:1,24;

 64:9;65:16

separate (11)

 75:19;114:25;115:3,

 7,13;116:15;139:12,

 14;155:8,8,9

separately (3)

 34:18;68:25;195:9

September (3)

 143:24;156:23,25

sequence (2)

 6:6;16:6

sequencing (2)

 26:17;150:5

series (1)

 7:22

serious (2)

 183:4;193:23

seriously (1)

 171:13

serve (2)

 162:25;170:20

served (5)

 159:12;160:18,19,

 19;162:20

service (2)

 24:14;39:10

services (1)

 67:17

set (6)

 158:18;170:2;175:9;

 198:15;203:16,18

sets (4)

 14:19;35:17;67:2;

 78:23

setting (1)

 127:18

settle (1)

 115:15

settled (4)

 59:24;156:22;

 168:18,18

settlement (2)

 190:16,16

settlements (1)

 134:1

seven (3)

 24:5;25:23;191:18

seventy (2)

 19:14,14

seventy-eight (1)

 18:22

seventy-five (1)

 24:11

several (8)

 31:20;34:8;37:11;

 71:13;112:21;130:16;

 154:17;193:6

severe (1)

 109:3

sex (1)

 122:12

shaded (1)

 65:16

shall (8)

 26:11;45:16;46:11,

 16;47:19;49:21;96:20;

 140:21

share (3)

 12:4;148:23;156:24

shared (2)

 11:23,25

sheet (3)

 118:13;156:13;

 169:24

Shield (1)

 122:11

Ship (11)

 30:23;31:3;57:6;

 68:22,23;69:7;105:6,

 15,17;106:4,8

short (3)

 64:8,11;166:5

shorten (1)

 110:16

shortened (1)

 112:2

shorter (2)

 22:19;112:2

short-form (1)

 175:25

shortly (1)

 11:16

show (8)

 31:20;67:4;160:17;

 163:9,15;172:11,22;

 193:13

showed (2)

 62:16;147:20

shows (3)

 32:6;37:25;49:15

sic (2)

 67:13;199:13

sick (1)

 132:3

side (10)

 13:8;15:13,25;22:12;

 86:3;103:7;116:12;

 145:3,10;197:3

sidebar (1)

 88:2

sides (3)

 10:6;143:18;202:7

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(22) rights - sides Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 227

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

sign (7)

 32:14,18,25;35:8;

 36:3;71:22;182:15

signed (5)

 32:13,16,25;69:14;

 91:20

significance (2)

 105:14;123:24

significant (5)

 168:4;170:14;

 183:25;184:9;191:21

significantly (1)

 188:8

signing (2)

 22:10;41:12

similar (6)

 90:2;96:1;100:10,12;

 146:12;165:11

simple (15)

 21:20;27:15;29:3;

 30:2,13;42:4;64:9,12;

 107:14;143:7;182:17,

 18;188:25;200:23,24

simplest (1)

 109:15

simplifying (1)

 123:23

simply (7)

 65:15;85:2;92:25;

 93:1;133:5;198:8;

 202:13

single (1)

 82:4

Singleton (5)

 51:1,2;164:13,13,20

singularly (1)

 155:14

sit (1)

 171:6

sites (1)

 17:18

sitting (1)

 161:12

situation (7)

 32:23;44:18;118:8;

 121:22;123:11;186:12;

 188:13

situations (1)

 152:24

six (6)

 15:10;18:19;32:23;

 60:4;148:3;156:18

sixty (7)

 174:23;175:5;

 178:18;184:8,12,12,13

Skikos (48)

 173:9,9,16,18,20,22,

 24;174:1,8,12,14;

 175:9;176:3,20,23;

 177:3,5,10,14,16;

 179:23;180:6,7,13,16,

 21;181:2,3,4,6,10,12,

 15,17,19,22;182:10,13,

 18,22;183:10,13,16,25;

 184:3,20,23;185:1

Slack (4)

 194:12,14,21;197:10

slate (1)

 145:11

slight (3)

 52:22;97:3;117:10

slightly (3)

 115:25;124:18;203:5

slippery (1)

 74:21

slope (1)

 74:21

slow (1)

 124:19

slowing (2)

 126:20;127:3

small (2)

 31:11;124:21

smaller (1)

 68:24

smartphone (2)

 137:6,19

Smith (5)

 32:25,25;52:6;67:14,

 25

smoking (1)

 148:21

sober (1)

 31:24

so-called (1)

 190:16

social (6)

 18:12;137:3,11;

 141:6;143:4;184:4

solely (4)

 86:22,25;87:1,2

solution (2)

 79:14;143:7

solve (6)

 31:6;79:3;97:6;

 169:6;195:5;199:18

solved (1)

 128:9

solvent (3)

 80:1;117:23;127:16

solves (1)

 80:7

Somebody (16)

 24:12;43:19;48:10;

 50:2;67:16;73:7;78:17;

 101:10;172:22,25;

 173:2;180:23;181:1;

 182:6;185:24;192:13

somehow (3)

 75:25;126:5;155:12

someone (10)

 19:25;27:18,20;29:5;

 35:12;98:16;110:11;

 116:12;144:11;152:23

something-else (1)

 104:3

something's (2)

 162:9;186:2

somewhat (4)

 121:19;126:6;

 128:23;134:11

somewhere (3)

 30:6;144:13;203:17

Sonoma (3)

 91:19;152:18;200:2

soon (5)

 11:21;38:11;103:18;

 151:19;201:18

soonest (1)

 131:5

sorry (13)

 32:3;53:22;69:11;

 84:15;86:15;88:4;

 91:14;95:21;107:24;

 117:3;136:18;181:10;

 196:23

sort (6)

 59:15;63:25;64:2;

 80:10;111:11;161:12

sorts (2)

 64:14;127:5

sought (1)

 125:7

sound (1)

 90:22

sounds (1)

 132:7

source (1)

 23:9

sources (1)

 126:14

Spanish-speaking (1)

 17:4

speak (4)

 20:17;74:22;141:25;

 151:11

SPEAKER (2)

 170:25;204:1

speaking (3)

 117:19;146:2;151:14

specific (4)

 17:7,8;90:3;141:13

specifically (8)

 37:6;72:14;90:25;

 114:8;117:17;124:11;

 164:20;188:5

speculating (1)

 9:18

speed (3)

 178:13,23;197:21

spend (1)

 124:5

spent (1)

 175:22

spike (1)

 164:23

spiked (2)

 149:13,14

spinning (1)

 64:14

spirit (1)

 169:19

spoke (1)

 96:6

Sports (2)

 15:19,22

spot (1)

 31:23

spots (1)

 26:20

spreading (1)

 48:8

staff (2)

 104:19;198:7

staffed (2)

 27:3;39:10

stage (2)

 64:2;78:23

STAMER (33)

 165:20,21,25;166:1,

 10,14,20,22;167:1,5,9,

 12,14,18,23;168:13,23,

 25;169:5,9,12,17;

 170:11,23;171:3,8,12,

 13,15,17;173:7;

 189:25;190:5

stand (7)

 6:22;7:5;58:8;

 167:19;188:9;189:13;

 204:6

standard (19)

 31:9,11,12;32:8;

 33:8,9,11;45:18;47:7;

 60:25;66:23,24;67:1;

 87:21;89:12;97:25;

 149:4,5,7

standing (2)

 118:23;144:13

standpoint (1)

 184:7

start (14)

 9:18;16:19;21:4;

 22:13;28:14;79:6;

 116:7;145:10;158:4;

 175:24;177:17;179:5;

 202:14;203:19

started (1)

 147:17

starting (1)

 16:14

State (31)

 45:18;46:15;74:1,1;

 76:25;88:18,19;89:22;

 92:8,9,13,15;93:1,11;

 164:9;170:20;173:10,

 15,20;175:5,6,6,10,14;

 176:1;177:22;178:6,

 24;179:2,8;195:16

stated (2)

 11:17;49:20

statement (9)

 11:15;28:13;66:12;

 79:18;151:2,2;172:17;

 187:12;195:4

statements (1)

 61:3

state-of-the-art (1)

 114:11

states (3)

 11:12;33:14;146:5

stations (2)

 17:5,5

status (1)

 167:20

statute (2)

 134:5;192:5

statutory (5)

 77:3,3,13;79:16;

 134:5

stay (3)

 63:15;104:18,18

Stephen (1)

 6:16

steps (1)

 157:23

Steve (1)

 173:9

stick (10)

 24:10;56:4;64:15;

 65:6;86:9;159:25;

 160:4;173:3;202:17;

 203:12

still (16)

 33:7;40:5;44:19;

 56:8;104:21;124:15;

 133:23,23;136:15;

 177:10,11;180:14;

 191:2;196:16;199:4;

 200:17

stipulation (1)

 94:17

stock (1)

 41:4

stockholder (3)

 40:20,25,25

stop (2)

 138:8;159:17

strange (1)

 139:1

stranger (1)

 128:23

Strauss (1)

 165:21

stream (1)

 201:23

streaming (7)

 17:1,12;18:9;137:5,

 19;139:18;142:4

Street (3)

 16:3;145:9;152:9

strengths (1)

 185:20

stricken (2)

 56:1;63:13

strike (2)

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(23) sign - strike Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 228

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 100:16;125:3

strikes (1)

 164:25

striking (2)

 149:17;158:6

stringent (1)

 72:8

strong (1)

 115:2

strongly (1)

 46:2

struck (1)

 116:17

struggles (1)

 172:1

struggling (2)

 121:14;162:13

stuff (6)

 47:17,17;73:8;166:9;

 168:25;187:10

stuffing (1)

 23:9

subject (9)

 42:6;44:9;86:6,7;

 97:19;98:2;154:11;

 171:14;173:5

submit (6)

 38:11;67:21;68:5;

 72:13;199:10;201:7

submits (1)

 46:23

submitted (7)

 7:15;38:13;45:18;

 46:9,10;72:24;145:18

subparagraph (6)

 33:7;34:11,17;36:22,

 25;39:22

subpoena (1)

 162:25

subro (4)

 66:1;72:2,4,4

subrogation (9)

 8:15;53:21;54:3;

 65:12,15,18;72:12;

 160:20;196:16

substantial (2)

 125:8;144:9

substantially (1)

 130:13

substantive (5)

 33:1;57:15;179:10,

 19,23

successful (1)

 98:10

sudden (1)

 91:13

suddenly (2)

 48:23;132:18

suffer (3)

 20:1;85:16,17

suffered (3)

 48:20;85:13;147:15

suffering (1)

 124:4

Suffice (1)

 190:1

sufficient (10)

 35:19;94:23;109:11;

 114:6,7;125:15;

 137:18;182:23;193:10,

 11

suggest (10)

 33:5;77:12;81:22;

 84:14,16;110:3;137:7;

 185:24;194:16;201:13

suggested (4)

 77:2,11;88:8;192:13

suggesting (3)

 63:12;118:23;138:3

suggestion (6)

 62:4;80:18;86:10;

 105:2;123:23;196:12

suit (2)

 34:13,20

summary (4)

 22:2;30:16;102:13;

 109:9

summer (2)

 140:8;149:14

Sunset (1)

 15:20

supplement (1)

 10:1

supplemental (6)

 9:24;11:12;14:19;

 18:3,4,15

supplemented (3)

 14:21;160:10;202:23

supplements (1)

 11:8

support (12)

 160:6;166:16,18,18,

 21,22,22;167:6,14;

 171:9,9,9

supporting (8)

 46:9,16,17;63:2,6;

 64:1;72:13;171:1

supportive (1)

 155:24

suppose (2)

 47:3;101:13

supposed (6)

 88:24,24;139:4;

 160:14;174:3;190:25

Supreme (1)

 203:6

sure (54)

 6:15;8:11,13;10:12;

 14:11;28:22;30:14;

 31:6,21;34:1;37:1,19;

 38:19;40:4,8,10;46:13;

 47:24;52:5,23;53:3,7,

 13;54:4;56:6;58:5;

 68:22;69:2,9;73:14;

 74:25;89:19;90:11;

 98:14,17;101:7,22;

 113:13;118:16;120:4;

 122:4;123:5;127:23;

 130:6,6;137:12;138:1;

 144:22;155:14;171:10;

 177:6;190:15;192:9;

 199:2

surfaced (1)

 180:22

surprise (1)

 118:15

survive (2)

 43:7,13

survives (1)

 80:2

surviving (1)

 135:9

suspect (1)

 136:6

swift (1)

 131:9

sword (1)

 116:1

system (16)

 11:23;27:21;126:23;

 127:3,4;128:6;136:21;

 174:18;175:10;177:22,

 25;178:7,22;182:16;

 191:25;203:20

systematic (1)

 178:1

systems (1)

 176:1

T

table (3)

 28:9,23;156:4

tailored (1)

 114:8

Takata (3)

 159:11;188:25;

 189:11

talk (17)

 12:14,14;20:18,21;

 49:6;54:7,7;70:23;

 104:23;111:13;124:10;

 148:22;149:24;150:20;

 167:19;179:25;190:4

talked (12)

 52:19;64:22;65:13;

 66:17;79:24;86:13;

 99:5;116:7;158:25;

 184:5;190:21;202:11

talking (7)

 96:18;129:3;144:18,

 20,22;160:25;189:20

talks (2)

 100:23;203:17

target (4)

 15:15;17:7;18:18;

 19:15

tasked (1)

 117:17

taught (1)

 21:5

TCC (45)

 7:24;8:3;20:17;

 41:20;42:10;47:17;

 54:16,25;61:6;62:4;

 91:23;92:2,10,11;

 109:21;114:18,22;

 117:18;125:7;126:5;

 130:10;131:7,9;

 135:21;145:5,18;

 154:23;160:18,21,23;

 161:1;162:14,24;

 163:3,4;164:24;

 174:19;185:13;186:7;

 190:23;195:6,13;

 199:8;201:5;203:3

TCC's (5)

 56:8;161:19;162:15;

 166:6;185:16

team (2)

 115:2,2

teams (1)

 152:10

teased (1)

 75:16

tech- (1)

 24:10

technical (2)

 59:9;113:14

technology (2)

 21:2;145:15

television (3)

 16:20;18:7,8

telling (11)

 70:14;85:2;138:25;

 142:11;143:19;144:1,

 3,11,12;159:24;184:6

tells (8)

 79:22;84:24;85:6;

 93:23;120:2;127:21;

 131:19;150:4

ten (10)

 15:16,17;70:24;

 142:16,18,18,18;144:3;

 166:3;188:11

tend (1)

 164:23

tens (3)

 121:23;174:16;

 176:11

tentative (2)

 132:2;199:10

Tenth (1)

 134:23

term (17)

 16:20;29:5,12,21,22;

 30:21,22;59:13;93:13,

 14;94:18;105:11,13;

 118:13;156:13;169:24;

 204:3

terminate (3)

 118:10;156:12;

 166:24

terminology (3)

 52:23;53:6;57:9

terms (10)

 25:10;53:1;57:12;

 65:2;117:9;118:2;

 192:3,22,25;202:11

territory (1)

 21:2

test (3)

 109:19;176:14;

 177:18

testifying (2)

 180:8;182:25

testimony (7)

 132:7,9;137:24;

 140:11;180:5;188:15,

 17

testing (1)

 176:8

Thanksgiving (10)

 123:20;124:5;179:7,

 18;181:10,14,16,21;

 193:2,2

therefore (7)

 10:14;36:19;72:20;

 103:3;133:14;198:13;

 199:12

there're (1)

 177:21

thin (1)

 125:22

thinking (3)

 49:20;119:9;192:18

thirteen (4)

 179:4,6;181:7;

 184:10

thirty (4)

 72:23;122:12;

 142:11;170:1

thirty-four (1)

 17:5

though (11)

 42:22;61:7;63:14;

 71:22;110:12;123:25;

 136:5;163:9;174:9;

 180:3;201:7

thought (18)

 11:23,25;21:3;39:23;

 46:23;50:15,18;56:9;

 57:13,14;60:16;77:16;

 106:19,22;124:10;

 145:8;155:23;193:25

thoughts (1)

 54:6

thousand (2)

 176:6;193:6

thousands (8)

 112:4;121:23;

 126:16,17;136:23;

 174:16;176:11;177:11

three (18)

 12:23;16:2;19:16;

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PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 112:11,12,14,15;

 117:25;118:1;147:23,

 24;148:3;161:16;

 180:19;198:14;200:15,

 16,16

throughout (2)

 147:9;154:13

throw (2)

 68:9;138:19

tie (1)

 138:17

time- (1)

 172:12

timeline (3)

 127:9;148:23;203:17

timely (7)

 43:6,10,14,18,25;

 115:14;119:2

times (31)

 15:14,16,17;16:2;

 18:18,22,25;19:16;

 24:11;33:18;135:22,

 23,25,25;142:11,11,16;

 144:3,3,12,12;148:6;

 151:1;179:10;180:19;

 181:25;186:25;188:11,

 11,11,13

timetable (2)

 26:25;28:5

timing (5)

 16:18;107:15;152:8;

 170:11;203:15

title (4)

 53:3;54:17;55:2,3

today (51)

 6:8,19;7:5,6;12:2,11,

 24;13:14;17:23;19:7;

 22:2,11;36:7;71:16;

 83:18;102:25;112:21;

 116:12;117:10;118:18;

 119:24;124:17;128:18;

 144:14;156:17;160:10;

 161:11,15,16;163:7;

 164:18;167:17;169:6;

 173:4;174:11;175:20;

 176:3;180:20;185:12;

 186:4;190:1;191:5,8,

 16;194:4;196:11;

 197:15;200:22;201:20;

 202:5,23

today's (2)

 22:24;198:10

together (12)

 23:9;42:3;75:22;

 79:13;128:8;138:18;

 143:22;174:23;177:19;

 179:4;194:1;198:4

told (12)

 39:9;78:24;92:1;

 132:21;147:22;163:3;

 166:12;174:10;179:11,

 13;180:24;203:6

tomorrow (3)

 116:24;127:17;

 197:15

took (7)

 25:13;80:4;146:16,

 23;153:7;179:4;200:24

top (2)

 45:14;67:17

tort (42)

 11:9,22,23;12:3,8,

 20;15:21,25;16:23;

 17:2,25;25:5,18,21;

 31:17;58:16;67:14;

 70:7;100:9;109:9;

 112:3;113:6;117:12;

 118:5;119:20;120:21;

 127:17;128:22;135:11;

 144:20,23,24;152:19,

 24;153:15,15;159:15;

 161:3;171:23;175:1;

 188:25;189:2

torts (4)

 33:18;85:16;148:22;

 149:24

toss (1)

 36:8

total (4)

 16:1;17:5;65:17;

 84:12

totally (1)

 40:17

touch (3)

 136:21,25;154:10

touched (1)

 110:12

touchstone (1)

 129:25

toward (1)

 149:2

track (7)

 17:10,18;52:3;99:10,

 14;133:9;164:10

traditional (3)

 30:25;36:9;59:22

tragedy (2)

 31:1;106:4

train (2)

 122:23;131:11

transparency (3)

 168:7;190:4,6

transparent (2)

 172:5,14

trap (2)

 32:23;33:4

trauma (3)

 124:4;146:6;202:12

traumatic (1)

 114:6

traumatized (4)

 27:21;125:18;

 142:23;145:20

treat (1)

 185:25

treated (7)

 46:11;49:21;68:25,

 25;70:9;76:2;96:20

treating (1)

 10:3

treatment (2)

 80:11;168:13

tremendous (2)

 128:21;171:23

tricky (1)

 43:2

tried (5)

 12:11;27:23;61:5;

 64:8;124:16

tries (1)

 44:25

trigger (1)

 87:8

trouble (2)

 130:20;138:16

troubling (1)

 12:20

TRPs (2)

 16:21,22

truck (1)

 78:17

true (2)

 46:12;137:12

trustee (2)

 43:5;47:18

try (16)

 13:7;16:21;79:21;

 82:4;110:19;122:24;

 123:4;138:17;139:22;

 159:19;175:3,16;

 194:4;199:18,19;

 201:14

trying (26)

 64:6;80:13;83:5,8,

 17;103:16;112:13,15;

 120:18;125:3;127:10;

 130:20;136:10;148:18;

 149:16;152:24;153:13;

 155:1,16;169:19;

 177:1,16;180:9;

 187:12;193:16;198:4

Tt's (1)

 22:19

turn (4)

 55:3;124:9;132:14;

 178:20

TV (4)

 26:19;30:9;122:20;

 183:4

tweak (5)

 93:7;187:20,24;

 200:14;201:4

tweaking (1)

 158:24

twelve (1)

 41:22

twenty (3)

 39:25;188:11;194:6

twenty-eight (1)

 152:4

twenty-nine (1)

 16:1

twice (1)

 161:5

Twitter (2)

 137:4;158:8

two (42)

 11:8;17:4;19:16;

 26:20;37:10;40:6;42:2;

 54:19;56:18;59:6,7;

 70:24;75:5,14;87:20;

 89:1;96:11;97:15;99:3;

 105:5;108:7;137:13;

 143:9;148:3;154:17;

 158:3;161:16,22;

 165:13;171:18;175:10;

 180:15;183:20;184:4;

 190:5;193:6;194:5;

 195:9;197:11;198:7,

 21;201:11

two-page (2)

 175:23;178:18

type (9)

 26:25;77:2,7;78:15;

 85:17;89:11;109:25;

 131:25;145:12

types (3)

 17:12;111:16;120:1

typical (1)

 19:13

typically (1)

 25:8

U

UCC (4)

 162:14;166:5;169:5;

 175:2

ultimate (1)

 175:11

ultimately (4)

 47:12;102:14;

 176:13;192:3

Um-hum (12)

 8:4;15:11;36:1;

 110:25;143:16;146:7;

 148:11;149:23;150:14;

 152:3;155:19;175:8

unable (1)

 108:22

unbelievable (1)

 176:9

unclear (1)

 94:10

unconfidential (1)

 48:24

under (19)

 10:14;20:7;28:6;

 36:9;59:22;121:20;

 123:9,10;124:24;

 125:16;140:5;160:11;

 162:21,25;163:1,11;

 177:21;188:23;192:7

understandable (1)

 84:21

understands (2)

 66:4;119:25

Understood (9)

 73:10,13;91:15;

 132:15,17;148:4,14,16;

 168:25

uneducated (2)

 30:5;158:2

unfair (1)

 161:11

unfortunate (4)

 158:7;167:24;174:1;

 182:18

unfortunately (1)

 157:9

unhappy (1)

 177:8

unheard (2)

 119:12,14

UNIDENTIFIED (2)

 170:25;204:1

unimpaired (2)

 113:4,7

unimpairment (1)

 113:13

unique (2)

 117:22;153:12

unit (5)

 92:7,13;93:4,5,14

units (4)

 88:17;91:21;94:11,

 12

universal (1)

 201:15

unknown (15)

 35:20;36:4;59:11,13,

 14;60:3,4,10,20,20,22,

 23,25;61:9;122:6

Unless (6)

 21:19;32:18;108:23;

 113:4;114:18;150:13

unlike (3)

 19:24;128:23;159:13

unlinked (1)

 115:16

unmindful (1)

 127:11

unnecessary (1)

 100:8

unprecedented (1)

 109:23

unraveling (1)

 179:3

unrepresented (8)

 61:17;63:24;121:13;

 123:14;136:16;158:2;

 174:16;184:24

unring (1)

 73:8

unsecured (2)

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of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 12:3;166:4

unsophisticated (2)

 61:14;176:25

unsympathetic (2)

 148:6;202:12

untechnical (1)

 22:15

untimely (1)

 43:13

unusual (4)

 42:13;81:11;128:21;

 132:11

unwilling (1)

 29:8

up (55)

 6:22;28:10;31:20;

 32:6;35:8;39:3;49:15;

 57:24;58:23;75:22;

 79:14;88:2;89:24;

 91:22;92:6;98:25;99:8;

 102:21;103:18;112:21;

 116:21;119:17;122:23;

 128:8;139:17;146:21,

 22;148:3;149:1;150:2;

 153:10;160:13;163:5;

 170:1,2;174:2;175:3,

 18;177:25;178:13,22;

 186:12,25;187:10;

 188:22;189:5,6,15;

 192:3;193:13;198:6,8;

 200:14,18;201:17

update (2)

 166:12,14

updated (1)

 166:13

upload (1)

 197:13

upon (3)

 156:17;181:6;203:2

urge (3)

 158:17,18;163:8

urgency (4)

 168:6;171:21;

 197:21;198:20

USA (1)

 195:17

use (19)

 15:21;36:7;61:3;

 69:16;88:9,14;89:12;

 101:10;130:8;131:13;

 134:9;149:20;156:25;

 175:13;176:1,20,20;

 178:7;202:15

used (11)

 53:20;54:2;59:12;

 65:2;79:11;93:14;

 105:17;119:22;158:9;

 176:1;204:3

useful (1)

 39:23

user (1)

 61:13

username (1)

 161:6

using (8)

 54:18;59:11;69:17;

 89:7;102:21;105:11,

 24;178:12

usually (1)

 129:8

utility (1)

 78:22

utilizing (1)

 45:18

V

validity (2)

 111:16;145:24

Valley (1)

 200:3

value (2)

 112:16;159:15

various (4)

 45:15;91:19;147:8,9

vary (1)

 26:2

vast (1)

 122:7

vendor (1)

 131:23

Venn (1)

 195:21

versed (1)

 158:3

version (1)

 59:5

versions (1)

 7:25

versus (3)

 21:1;22:15;177:14

vet (1)

 191:7

via (1)

 137:19

viability (1)

 104:10

victim (20)

 30:5;48:17,19;60:1;

 61:14,17;63:24;67:14;

 70:7;76:2,2,2;88:23,

 25;135:6;142:6,23,23;

 148:8;150:8

victims (34)

 25:5;31:17;51:3,5;

 76:1;105:5;106:7;

 112:4;121:13;122:6,7;

 123:14,25;125:9,17;

 126:5,15,17,23;141:13,

 16;144:20,23,24;151:7,

 25;164:13;172:3;

 183:23;184:17,18;

 192:22;193:6;204:4

video (1)

 18:10

view (16)

 7:4;9:10,12;11:6;

 64:16;92:12;110:14;

 114:6;116:20,25;

 118:25;172:2;183:21;

 190:25;192:4;203:5

views (1)

 169:10

violating (1)

 161:5

visit (2)

 17:11,18

Volkswagen (1)

 144:19

Volkswagens (1)

 148:22

vote (7)

 99:25;101:21;

 112:24;113:5,16,23;

 201:25

voting (7)

 49:23;95:17,18;

 96:21;101:5;111:24;

 125:21

W

Waisman (2)

 6:24;7:1

wait (16)

 28:13;31:25;32:24;

 46:12;49:22;57:24;

 78:8;88:1,2,23;90:20;

 99:8;110:9;119:5;

 138:8;167:1

waited (1)

 12:23

waive (1)

 140:17

waiver (1)

 89:25

waiving (2)

 140:16;141:2

wakeup (1)

 171:20

walked (1)

 71:14

Wall (1)

 16:3

wand (1)

 122:15

wants (8)

 20:17;21:7;84:23;

 86:8;90:18;131:10;

 173:5;178:13

warehouse (1)

 105:9

warn (1)

 48:16

waste (1)

 188:14

watch (1)

 69:21

watches (1)

 201:25

watching (1)

 201:25

way (57)

 8:8;9:17;10:8;16:5;

 17:20;20:16;25:4;

 33:20;34:25;35:1,2;

 38:21;42:21;43:16;

 48:25;52:14;62:23;

 73:2;76:5;79:21;94:14;

 96:25;98:10,10;

 100:24;101:16;103:12;

 104:25;110:19;117:8;

 126:10,24;127:22;

 136:15;137:9;142:14,

 16;150:24;151:6;

 152:15;155:17;162:19;

 163:11,14;168:22;

 172:3,10;175:3,17;

 178:1;183:11;186:17;

 187:3;198:22;199:14;

 200:14;203:11

ways (2)

 70:9;125:18

weaknesses (2)

 185:21;191:3

websites (2)

 17:7,11

WEDNESDAY (2)

 6:1;22:25

week (6)

 10:1;14:22;16:10;

 43:20;71:21;197:16

weeks (5)

 12:23;26:20;137:13;

 165:13;184:2

weigh (1)

 86:8

weighed (2)

 47:18;195:8

Weil (2)

 6:16;52:4

Weissberg (1)

 67:12

Weissmann (12)

 38:1,8,11;39:7;67:8,

 18;68:2,4,10,13,15;

 69:7

welcome (2)

 196:6,18

weren't (2)

 38:16;77:17

what's (30)

 13:14;19:19;22:1;

 47:25;48:13;49:20;

 57:23;58:19;62:20;

 72:1;84:24,24;99:15;

 101:14,15;107:9;

 110:13;121:9;142:10;

 144:15,15,25;157:22;

 160:15;166:13;176:9;

 179:15;186:17;192:11;

 203:25

whenever (1)

 120:25

whereas (1)

 202:10

Whereupon (1)

 204:8

whichever (1)

 162:19

white (1)

 104:6

whoever's (1)

 197:10

whole (2)

 17:6;194:2

whomever (1)

 54:7

who's (3)

 59:21;195:2;196:20

whose (1)

 189:6

wife (1)

 189:12

wildfire (43)

 7:8;11:21;17:8;23:6,

 18;30:24,25;31:11;

 32:7;33:9;37:3,11;

 45:17;46:8,10,15,22;

 47:7;50:8,10;53:4,20,

 21;54:2,3,16,21;55:12,

 13,14,17;68:20;69:10,

 11;87:22;88:10,16;

 89:6;105:8,11;108:21;

 114:5;171:19

wildfires (7)

 15:9;30:21;74:12;

 75:5,8,20;106:4

willing (2)

 73:2,2

willingness (1)

 161:19

Willke (1)

 72:11

Willkie (1)

 196:15

Willoughby (1)

 73:24

window (2)

 146:21;148:24

wishes (3)

 108:20;138:5,6

wishful (2)

 49:19;192:17

withdraw (2)

 42:15;46:7

withdrawing (1)

 117:5

within (10)

 18:24;25:23;26:20;

 127:9;174:17;175:9;

 176:14;177:24;178:2;

 179:16

without (13)

 31:16;74:24;81:1;

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PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

 128:4;135:19;137:8,8;

 140:15;141:2;155:2,4;

 158:10;175:19

wolf (1)

 25:22

wonder (2)

 74:20;194:1

woods (1)

 30:6

word (13)

 41:12;59:13;60:20;

 69:21;93:25;104:14;

 123:25;145:8;165:7;

 184:14,16;192:24;

 203:25

wording (1)

 92:24

words (19)

 32:15;34:16,18;35:2;

 37:24;42:4;46:12;47:3,

 15,16;49:3;56:9;65:18;

 82:8;115:1,9;142:14;

 146:22;150:8

work (29)

 58:7;72:9;106:17;

 120:14,16;123:18;

 124:5;136:21;146:9;

 158:10;165:12;174:22;

 175:18,18;176:15;

 177:20,22,24,25;178:8,

 19,20;179:2;185:21;

 197:12,19;198:4;

 199:19;201:14

worked (4)

 72:7;126:23;145:11;

 146:3

working (1)

 125:12

works (5)

 35:21;96:8;126:24;

 191:25;203:4

world (5)

 38:22;122:20;

 126:14;127:2;176:9

worms (1)

 9:18

worried (1)

 29:10

worry (1)

 86:11

worth (1)

 178:15

WR (1)

 153:4

write (1)

 59:20

written (1)

 34:25

wrong (3)

 64:12;100:9;126:24

wrongful (6)

 42:2,23;79:9,11,12;

 136:12

wrongly (1)

 47:22

wrote (1)

 34:17

Y

year (11)

 91:13;103:21;

 108:23,24;126:22;

 146:16,21,23;147:18;

 165:2;179:12

years (10)

 15:4;18:17,21,24;

 21:6;74:22;85:19;

 117:25;118:2;122:12

years' (1)

 152:23

year's (1)

 157:11

yellow (3)

 55:1,5;62:16

Yep (2)

 65:9;69:3

yesterday (12)

 7:4;9:12;54:18;

 77:17;105:12;110:13;

 124:17;161:7;166:24;

 169:14;180:23;190:22

York (1)

 22:17

YouTube (2)

 17:19;18:10

Z

Zell (1)

 84:12

zone (1)

 153:4

1

1 (9)

 22:12;23:1,4;53:23;

 55:24;56:8;99:13;

 102:9;108:9

1,000 (2)

 67:25;68:3

1,300 (1)

 16:22

1:53 (1)

 204:8

10 (1)

 45:14

100 (1)

 184:20

100,000 (2)

 174:14;175:16

11 (15)

 19:20;49:24;50:6,8;

 53:4;57:20;58:17;

 70:24;107:22;108:23;

 110:3;161:5;166:4;

 170:12,13

11:44 (1)

 107:6

11th (1)

 154:25

12 (9)

 41:19,25;52:25;79:2;

 80:4,19;81:11;82:9;

 107:5

12:01 (1)

 107:6

13 (1)

 52:18

15 (3)

 89:18;90:19;91:14

15th (7)

 26:21;27:4,5,11;

 39:10;115:20;203:19

16 (6)

 69:13;75:7;89:18;

 90:19,25;91:14

16th (2)

 24:6;25:1

17 (2)

 75:6;96:21

18 (2)

 52:25;75:6

19 (1)

 52:25

19th (2)

 8:25;116:18

1st (3)

 26:21;154:15;193:1

2

2 (5)

 30:21;56:8;74:10;

 75:6;194:7

2,000 (1)

 179:3

2.0 (2)

 130:25;135:24

2.3 (1)

 18:25

20 (1)

 26:5

2004 (6)

 162:25;163:1,11;

 185:22;186:14,15

2010 (1)

 147:6

2012 (1)

 147:17

2014 (3)

 74:14;75:1,3

2015 (1)

 75:6

2016 (7)

 30:22,23;57:6;68:22;

 74:11;75:9;105:6

2018 (5)

 123:12,14;125:13,

 19;165:9

2019 (4)

 6:1;65:6;77:23;

 165:10

2020 (8)

 109:1;125:1,14;

 126:4;157:18;192:14,

 16,17

2021 (1)

 110:4

20th (1)

 26:16

21 (6)

 24:16;112:9;116:6;

 183:7;184:2;203:13

21,500,000 (1)

 131:1

21,850,000 (1)

 131:2

21.5 (1)

 130:19

21st (15)

 12:12;21:14;24:8,18;

 25:1;115:15;158:19;

 160:1,4;166:17,20;

 188:21;190:19;202:21,

 25

22 (1)

 44:22

23,000 (1)

 178:2

25th (1)

 154:24

26 (2)

 6:1;53:1

2646- (1)

 99:12

26th (2)

 156:23,25

28 (2)

 135:23;184:2

28th (5)

 12:10;181:12,13;

 183:6,7

29 (3)

 76:22;80:5,24

29th (8)

 62:6;65:6;81:25;

 82:8,10,13,16;87:4

3

3 (6)

 28:14;29:1,2;57:5;

 66:21;67:1

3,000 (2)

 178:1;179:3

3003c2 (1)

 97:19

30th (4)

 42:6;108:23;109:1;

 111:3

31 (2)

 109:2;112:10

31st (7)

 12:9,12;125:6;126:4;

 175:15;183:8;193:2

35,000 (1)

 178:13

363b (1)

 192:6

3e (5)

 99:5,8,11,16;100:17

3O12 (1)

 76:10

4

4 (14)

 31:10;33:7;43:1,8;

 69:12;95:7,22,24;

 96:18;97:1,7,19;98:3,

 12

401 (1)

 67:5

410 (1)

 53:23

5

5 (8)

 34:7,17;88:17;92:8;

 93:8;94:11;99:12;

 169:13

5,000 (2)

 43:21;102:9

5.8 (1)

 15:14

500 (1)

 16:24

503b9 (1)

 39:23

51.95 (1)

 135:22

5th (1)

 192:12

6

6 (4)

 11:12;39:9;46:8;

 49:8

7

7 (11)

 39:18;40:6;49:19;

 96:15,20;97:1,18,18;

 98:12;99:17;101:19

75 (1)

 175:16

75,000 (2)

 174:14;179:16

7-B (1)

 31:12

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(27) wolf - 7-B Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 232

of 233
PG&E CORPORATION AND PACIFIC GAS 

AND ELECTRIC COMPANY

Case No. 19-30088; Chapter 11

June 26, 2019

8

8 (1)

 192:13

800-pound (1)

 161:12

8th (6)

 23:7;24:13;165:1,9,

 10;183:7

9

9 (6)

 41:16,17,19;43:1;

 50:7;53:3

9:54 (1)

 6:1

9014 (2)

 99:19;100:20

95 (1)

 15:15

98 (1)

 18:3

99 (1)

 18:14

9th (6)

 199:16,16;200:10,

 19;201:16,17

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(28) 8 - 9th Case: 19-30088 Doc# 2781 Filed: 06/27/19 Entered: 06/27/19 17:46:25 Page 233

of 233