1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

1 

Robert A. Julian (SBN 99469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Boulevard, Suite 1400 

Los Angeles, CA 90025 

Telephone: 310.820.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

□ Affects PG&E Corporation 

□ Affects Pacific Gas and Electric Company 

■ Affects both Debtors 

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

NOTICE OF MOTION OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS FOR ENTRY OF A 

PROTECTIVE ORDER 

Date: June 26, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: June 19, 2019, 4:00 

p.m. (Pacific Time)

 

Case: 19-30088 Doc# 2421 Filed: 06/05/19 Entered: 06/05/19 20:13:53 Page 1 of

2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

2 

PLEASE TAKE NOTICE that on January 29, 2019 (the “Petition Date”), PG&E 

Corporation and Pacific Gas and Electric Company, as debtors and debtors in possession 

(the “Debtors”) in the above-captioned chapter 11 cases (the “Chapter 11 Cases”), each filed a 

voluntary petition for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy 

Code”) with the United States Bankruptcy Court for the Northern District of California (San 

Francisco Division) (the “Bankruptcy Court”). 

PLEASE TAKE FURTHER NOTICE that the Bankruptcy Court will hold a hearing on 

June 26, 2019 at 9:30 a.m. (Pacific Time) (the “Omnibus Hearing”) in the courtroom of the 

Honorable Dennis Montali, United States Bankruptcy Judge, Courtroom 17, 16th Floor, 450 

Golden Gate Avenue, San Francisco, California 94102. 

PLEASE TAKE FURTHER NOTICE that, in addition to any other matters scheduled for 

the Omnibus Hearing, the Bankruptcy Court is scheduled to hear the Motion of the Official 

Committee of Tort Claimants for Entry of a Protective Order, which was filed on June 5, 2019 (the 

“Motion”). 

PLEASE TAKE FURTHER NOTICE that any oppositions or responses to the Motion 

must be in writing, filed with the Bankruptcy Court, and served on the counsel for the Official 

Committee of Tort Claimants at the above-referenced addresses so as to be received by no later 

than 4:00 p.m. (Pacific Time) on June 19, 2019. Any oppositions or responses must be filed and 

served on all “Standard Parties” as defined in, and in accordance with, the Second Amended Order 

Implementing Certain Notice and Case Management Procedures entered on May 14, 2019 (ECF 

No. 1996) (the “Case Management Order”). Any relief requested in the Motion may be 

granted without a hearing if no opposition is timely filed and served in accordance with the 

Case Management Order. In deciding the Motion, the Court may consider any other document 

filed in these Chapter 11 Cases and related Adversary Proceedings. 

PLEASE TAKE FURTHER NOTICE that copies of the Motion and its supporting papers 

can be viewed and/or obtained: (i) by accessing the Court’s website at 

http://www.canb.uscourts.gov, (ii) by contacting the Office of the Clerk of the Court at 450 Golden 

Gate Avenue, San Francisco, CA 94102, or (iii) from the Debtors’ notice and claims agent, Prime 

Clerk LLC, at http://restructuring.primeclerk.com/pge or by calling (844) 339-4217 (toll free) for 

U.S.-based parties; or +1 (929) 333-8977 for International parties or by e-mail at: 

pginfo@primeclerk.com. Note that a PACER password is needed to access documents on the 

Bankruptcy Court’s website. 

Dated: June 5, 2019 BAKER & HOSTETLER LLP

By: /s/ Robert Julian 

Counsel for The Official Committee of Tort 

Claimants

Case: 19-30088 Doc# 2421 Filed: 06/05/19 Entered: 06/05/19 20:13:53 Page 2 of

2