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BROWN RUDNICK LLP 

David J. Molton (SBN 262075) 

(DMolton@brownrudnick.com) 

Eric R. Goodman (admitted pro hac vice) 

(EGoodman@brownrudnick.com) 

Seven Times Square 

New York, New York 10036 

Telephone: (212) 209-4800 

Facsimile: (212) 209-4801 

BROWN RUDNICK LLP 

Joel S. Miliband (SBN 077438) 

(JMiliband@brownrudnick.com) 

2211 Michelson Drive, Seventh Floor 

Irvine, California 92612 

Telephone: (949) 752-7100 

Facsimile: (949) 252-1514 

Attorneys for Fire Victim Trustee

UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF CALIFORNIA 

In re: 

PG&E CORPORATION, 

-and- 

 Bankruptcy Case No. 3:19-bk-030088 DM 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

FIRE VICTIM TRUSTEE’S 

DISCLOURES DIRECTED BY 

SEPTEMBER 6, 2022 ORDER ON 

MOTION FOR RECONSIDERATION 

[No Hearing Requested] 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

 Affects PG&E Corporation 

 Affects Pacific Gas and Electric 

Company 

 Affects both Debtors 

*All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

 

Case: 19-30088 Doc# 12972 Filed: 09/16/22 Entered: 09/16/22 15:00:16 Page 1

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FIRE VICTIM TRUSTEE’S DISCLOURES DIRECTED BY 

SEPTEMBER 6, 2022 ORDER ON MOTION FOR RECONSIDERATION 

Cathy Yanni, in her capacity as the Trustee (the “Trustee”) of the PG&E Fire Victim Trust 

(the “Trust” or the “Fire Victim Trust,” and its beneficiaries, the “Fire Victims”), hereby submits 

the following responses as directed by the Court’s Order on Motion for Reconsideration [Docket 

No. 12929]. 

1. STATE SPECIFICALLY WHY IT IS NECESSARY TO REDACT THE NAME AND 

OTHER IDENTIFYING INFORMATION ABOUT THE FVT’S “AUTHORIZED 

AGENT” IN ANY OF THE RETENTION AGREEMENTS SUBMITTED IN 

CONNECTION WITH THIS MATTER 

The Trustee does not believe it is necessary to redact the name of the Authorized Agent, 

Patrick Kelly. There is no other identifying information regarding Mr. Kelly that has been redacted. 

2. FILE ANY AGREEMENT(S) BETWEEN THE FVT AND THE AUTHORIZED 

AGENT, INCLUDING ANY PROVISIONS FOR COMPENSATION OF THAT 

PERSON. 

The engagement letter between the Fire Victim Trust and Patrick Kelly (the “Engagement 

Letter”), redacted as requested in the Ex Parte Motion of the Fire Victim Trustee to Redact Personal 

Address from Engagement Letter to be Filed with the Court [Docket No. 12965] (the “Motion to 

Redact Address”) is attached hereto as Exhibit 1.1

 The Engagement Letter is the only agreement 

between the Trust and the Authorized Agent. 

DATED: September 16, 2022 

BROWN RUDNICK LLP 

/s/ Eric R. Goodman 

Eric R. Goodman (admitted pro hac vice) 

David J. Molton (SBN 262075) 

Joel S. Miliband (SBN 77438) 

Attorneys for the Fire Victim Trustee 

1

 Should the Court deny the Motion to Redact Address, the Trustee will file the Engagement letter in 

unredacted form. 

Case: 19-30088 Doc# 12972 Filed: 09/16/22 Entered: 09/16/22 15:00:16 Page 2

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64816918 v13-WorkSiteUS-035945/0008 

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EXHIBIT 1 

Case: 19-30088 Doc# 12972 Filed: 09/16/22 Entered: 09/16/22 15:00:16 Page 3

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