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retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing

any of the Protected Material. Notwithstanding this provision, Outside Counsel are entitled to retain an

archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and

consultant and expert work product, even if such materials contain Protected Material. A Receiving

Party’s obligations under this paragraph shall not require the destruction or return of Confidential,

Highly Confidential or Professional Eyes Only Material by Outside Counsel that is stored on backup

storage or in archiving solutions made in accordance with regular data backup procedures for disaster

recovery or litigation hold, provided that Outside Counsel maintains the confidentiality thereof in

accordance with this Order. If a Receiving Party chooses to take all commercially reasonable steps to

destroy, rather than return, documents in accordance with this paragraph, that Receiving Party shall, if

requested by the Producing Party, verify such destruction in writing to counsel for the Producing Party.

Notwithstanding anything in this paragraph, to the extent that the information in the Discovery Material

remains confidential, the terms of this Order shall remain binding.

IT IS SO ORDERED.

DATED: ________________________ _________________________________________

Judge Dennis Montali

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EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, _____________________________ [print or type full name], of _________________ [print

or type full address], declare under penalty of perjury that I have read in its entirety and understand the

Confidentiality and Protective Order that was issued by the United States Bankruptcy Court for the

Northern District of California on [date] in In re PG&E Corp., et al., CASE NO. 3:19-bk-30088 (the

“Order”). I agree to comply with and to be bound by all the terms of the Order and I understand and

acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of

contempt. I solemnly promise that I will not disclose in any manner any information or item that is

subject to the Order to any person or entity except in strict compliance with the provisions of the

Order.

I further agree to submit to the jurisdiction of the United States Bankruptcy Court for the

Northern District of California for the purpose of enforcing the terms of this Confidentiality and

Protective Order, even if such enforcement proceedings occur after termination of this action.

I hereby appoint __________________________ [print or type full name] of

_______________________________________ [print or type full address and telephone number] as

my California agent for service of process in connection with this action or any proceedings related to

enforcement of the Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: __________________________________

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