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ATTORNEYS AT LAW SAN FRANCISCO

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Robert A. Julian (SBN 99469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8875 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

□ Affects PG& E Corporation 

□ Affects Pacific Gas and Electric Company 

■ Affects both Debtors 

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

EX PARTE APPLICATION OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS PURSUANT TO 

FEDERAL RULE OF BANKRUPTCY 

PROCEDURE 2004 FOR ORDERS 

AUTHORIZING PRODUCTION OF 

DOCUMENTS 

Date: 

Time: 4:00 p.m. (Pacific Time) 

Place: Robert Julian 

 Baker & Hostetler LLP 

 Levi’s Place 

 1160 Battery Street East, Ste. 100 

 San Francisco, CA 94111 

Case: 19-30088 Doc# 2449 Filed: 06/07/19 Entered: 06/07/19 11:57:00 Page 1 of

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

counsel, hereby submits this Ex Parte Application Pursuant to Bankruptcy Rule 2004 for Orders 

Authorizing Production of Documents (the “Application”) to secure orders requiring PG&E 

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

produce documents as set forth below.

The TCC represents the largest stakeholders in the case, the victims of the fires caused by 

the Debtors’ equipment and electrical system practices. The Debtors’ insurance coverage is a key 

source of payment of the fire claims. 

Bankruptcy Rule 2004 permits discovery of the acts, conduct, or property of the Debtors, 

or to any matter which may affect the administration of the estate, including the existence and 

extent of sources of recovery for the fire victims. By this 2004 Application, the TCC seeks copies 

of any insurance policies that may provide coverage for claims arising from the fires caused by 

Debtors. This discovery is proper and necessary for the TCC to fulfill its obligations to 

investigate and evaluate the insurance policies that the Debtors may use to pay fire claims in this 

case. 

LIST OF DOCUMENTS REQUESTED FOR PRODUCTION

1. Complete copies of all insurance policies (including any and all declarations, 

definitions, exhibits, endorsements, riders, exclusions and amendments) that have provided or 

may provide coverage for any claim against the Debtors arising from or concerning the Northern 

California Wildfires. “Northern California Wildfires” shall have the same meaning as used by the 

Debtors in the Bar Date Motion [Dkt # 1784], pp. 8-9. 

2. Complete copies of all insurance policies (including any and all declarations, 

definitions, exhibits, endorsements, riders, exclusions and amendments) that have provided or 

may provide coverage for any claim against the Debtors arising from or concerning the Ghost 

Ship Fire. “Ghost Ship Fire” shall mean the fire that occurred on December 2, 2016, at the 

building known as the “Ghost Ship,” located at 1315 31st Avenue in the City of Oakland, County 

of Alameda, State of California. 

Case: 19-30088 Doc# 2449 Filed: 06/07/19 Entered: 06/07/19 11:57:00 Page 2 of

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TIME AND PLACE FOR PRODUCTION 

The requested date of the document production is fifteen (15) days from entry of an order 

granting the Application. Bankruptcy Rule 2004(d) provides as follows: 

(d) Time and Place of Examination of Debtor. The court may for cause shown and 

on terms as it may impose order the debtor to be examined under this rule at any 

time or place it designates, whether within or without the district wherein the case 

is pending. 

These dates are a reasonable time after the anticipated date of entry. Service of the Application is 

effective via the Court’s electronic notice. 

NO PRIOR REQUEST FOR RELIEF 

No previous application for the relief sought herein has been made to this Court. The 

TCC reserves the right to conduct further depositions and other discovery, or otherwise, as 

appropriate. 

CONCLUSION 

Since March 5, 2019, Counsel for the TCC has made multiple informal requests for the 

insurance policies described above. But to date, Debtors have provided only summaries of a 

subset of the relevant policies. 

Accordingly, this Application is properly made on an ex parte basis under Local Rule 

2004-1(a) and the TCC respectfully requests this Court immediately take notice of the 

Application and enter an order in substantially the form attached hereto as Appendix A, granting 

the relief requested herein, and such other and further relief as may be just. 

Dated: June 7, 2019 

BAKER & HOSTETLER LLP 

By: /s/ Robert A. Julian

Robert Julian 

Attorneys for The Official Committee of Tort 

Claimants 

 

Case: 19-30088 Doc# 2449 Filed: 06/07/19 Entered: 06/07/19 11:57:00 Page 3 of

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APPENDIX A 

Case: 19-30088 Doc# 2449 Filed: 06/07/19 Entered: 06/07/19 11:57:00 Page 4 of

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BAKER 

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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 Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8875 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

□ Affects PG& E Corporation 

□ Affects Pacific Gas and Electric Company 

■ Affects both Debtors 

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

ORDER GRANTING THE EX PARTE 

APPLICATION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO FEDERAL RULE OF 

BANKRUPTCY PROCEDURE 2004 FOR 

ORDERS AUTHORIZING 

PRODUCTION OF DOCUMENTS 

The Court, having reviewed the Ex Parte Application of the Official Committee of Tort 

Claimants Pursuant to Bankruptcy Rule 2004 for Orders Authorizing Production of Documents 

filed on May 9, 2019, and after due deliberation and sufficient cause appearing therefor, 

Case: 19-30088 Doc# 2449 Filed: 06/07/19 Entered: 06/07/19 11:57:00 Page 5 of

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IT IS HEREBY ORDERED THAT: 

1. The Application is granted, as provided herein. 

2. The Debtors are directed to produce to the TCC the following documents and 

information, without service of a subpoena, fifteen (15) days from entry of this Order: 

a. Complete copies of all insurance policies (including any and all declarations, 

definitions, exhibits, endorsements, riders, exclusions and amendments) that have 

provided or may provide coverage for any claim against the Debtors arising from 

or concerning the Northern California Wildfires. “Northern California Wildfires” 

shall have the same meaning as used by the Debtors in the Bar Date Motion [Dkt 

# 1784], pp. 8-9. 

b. Complete copies of all insurance policies (including any and all declarations, 

definitions, exhibits, endorsements, riders, exclusions and amendments) that have 

 provided or may provide coverage for any claim against the Debtors arising 

from or concerning the Ghost Ship Fire. “Ghost Ship Fire” shall mean the fire 

that occurred on December 2, 2016, at the building known as the “Ghost Ship,” 

located at 1315 31st Avenue in the City of Oakland, County of Alameda, State of 

California. 

**END OF ORDER** 

 

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