1

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

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

-oOoIn Re:

PG&E CORPORATION AND PACIFIC 

GAS AND ELECTRIC COMPANY,

Debtors.

_____________________________

)

)

)

)

)

)

)

Case No. 19-30088

Chapter 11

San Francisco, California

Tuesday, September 13, 2022

10:00 AM

REORGANIZED DEBTORS' SEVENTYNINTH OMNIBUS OBJECTION TO 

CLAIMS (BOOKS AND RECORDS 

CLAIMS) FILED BY PG&E 

CORPORATION [10673]

MOTION OF WILLIAM B. ABRAMS 

PURSUANT TO FEDERAL RULE OF 

BANKRUPTCY FOR 2004 

EXAMINATION FOR ENTRY OF AN 

ORDER AUTHORIZING DISCOVERY 

AND HEARINGS REGARDING THE 

ACTS AND CONDUCT OF JAMS 

NEUTRALS GIVEN NEW EVIDENCE. 

FILED BY WILLIAM ABRAMS 

[12766]

TRANSCRIPT OF PROCEEDINGS

BEFORE THE HONORABLE DENNIS MONTALI

UNITED STATES BANKRUPTCY JUDGE

APPEARANCES (All present by video or telephone):

For the Reorganized 

Debtors:

THOMAS B. RUPP, ESQ.

Keller Benvenutti Kim LLP

650 California Street

Suite 1900

San Francisco, CA 94018

(415)469-6723

For David P. Addington: RON OLINER, ESQ.

Duane Morris LLP

1 Market Spear Tower

Suite 2200

San Francisco, CA 94105

(415)957-3000

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 1

of 72
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

For Fire Victim Trust and 

Cathy Yanni, in her 

capacity as the Trustee of 

the Fire Victim Trust:

DAVID J. MOLTON, ESQ.

Brown Rudnick LLP

7 Times Square

New York, NY 10036

(212)209-4800

For Fire Claimants Majesti 

Mai Bagorio, etc.:

MATTHEW P. FRENCH, ESQ.

Baum Hedlund Aristei & Goldman PC

10940 Wilshire Boulevard

Suite 1600

Los Angeles, CA 90024

(310)207-3233

Also Appearing: William B. Abrams, Movant

Court Recorder: LORENA PARADA/ANKEY THOMAS

 United States Bankruptcy Court

450 Golden Gate Avenue

San Francisco, CA 94102

Transcriber: ELLEN S. KOLMAN

 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.

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 2

of 72
3

PG&E Corporation and Pacific Gas and Electric Company

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

SAN FRANCISCO, CALIFORNIA, TUESDAY, SEPTEMBER 13, 2022, 

10:00 AM

-oOo-

(Call to order of the Court.)

THE CLERK: Court is now in session. The Honorable 

Dennis Montali presiding. 

Calling the matter of PG&E Corporation. And I will 

bring in counsel now, Your Honor. 

THE COURT: Morning, Mr. Oliner. Nice to see you. 

Can you state your appearance, please? 

MR. OLINER: Good morning, Your Honor. Ron Oliner, 

Dwayne Morris, counsel to Mr. Addington. 

THE COURT: Mr. Rupp?

MR. RUPP: Good morning, Your Honor. Thomas Rupp of 

Keller, Benvenutti Kim on behalf of the reorganized debtors. 

THE COURT: So Mr. Rupp, I got fooled into letting you 

file something at the last minute, but I did read what you 

filed last evening. 

Mr. Oliner, what's your response there? What's your 

pleasure that -- what we do next?

MR. OLINER: Well, I'm not -- I don't have a lot of 

pleasure after receiving after hours eighteen pages. What I 

would like to do is to push things out. And let me explain 

why, I guess compelled or wouldn't agree to just kicking this 

entire hearing out after I received late, I guess just before 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 3

of 72
4

PG&E Corporation and Pacific Gas and Electric Company

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

Labor Day, a request to push out the dates on your calendar. I 

may go a little long here so you can just give me the hook if 

you need to, Your Honor. 

I got retained in June and contacted Mr. Rupp in early 

June, long before the new deadline to file the amended claim 

was filed and tried to see if we could resolve it in a 

mediation. I also requested that the debtor turn over their 

files on the Addington property in Piedmont because of their 

position that in order to fix the property, we needed to 

proceed by a PG&E-approved engineering plan. 

Mr. Rupp has been polite and professional throughout, 

but came back to me after I requested it again to say that PG&E 

wouldn't give us their files on our property until we had a 

contested matter. 

So I dutifully -- we dutifully filed an amended claim 

on time, a little early, and sent it to Mr. Rupp who

acknowledged receiving it, and then tried to get this thing 

back into a mediation, because this needs to be solved and it 

doesn't need to be litigated. 

After that, some exchanges, although I couldn't get 

much information, Mr. Rupp's -- the debtors' position was they 

still wouldn't give us our files until we had a contested 

matter. And we don't have a contested matter until they file 

an objection. 

And then, as I say, late a week or so ago, I think it 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 4

of 72
5

PG&E Corporation and Pacific Gas and Electric Company

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

was on September 1st, two weeks ago, I got an urgent request to 

kick out this thing. And so I said, all right. As a 

professional courtesy, file your objection later if you need 

to, but I wanted this date on as a holding date. And now I 

read, and I got it after hours as Your Honor did. I know 

you're an avid reader of everything that's filed, and I did my 

best to read it this morning, a filing, which is really in the 

nature of let's go, let's go. You now -- having shifted the 

burden, it's now incumbent on you, Mr. Addington, to further 

explain, et cetera, et cetera.

I invoked the rules in any contested matter. And now, 

since PG&E will not cooperate or give us access to their files 

on our property, the Rules 9014, the rules to treat this as a 

contested matter, and if I can't get Mr. Rupp's client to give 

us their files, I need to engage in discovery. 

It's sad that we're here, but they won't mediate. 

They won't give us their files. And now I see a pleading which 

says we're going to jam you up and you Mr. Oliner, and get to 

file some supplemental thing in two more weeks time. I'm out 

of town in the next two weeks, so that doesn't work for me. 

But that's where we are.

I would like this in summation to be put out. I need 

to engage in discovery because I don't think Mr. Rupp's client 

is going to cooperate with us in any way, shape, or form. I'm 

not prepared to set a date to try this. I've tried innumerable 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 5

of 72
6

PG&E Corporation and Pacific Gas and Electric Company

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

claim objections, but this is nowhere near that because of 

where we are and the way PG&E has treated us. Thank you, Your 

Honor. 

THE COURT: Mr. Rupp, what's your pleasure? 

MR. RUPP: Thank you, Your Honor. 

I just, again, want to back up from the perspective of 

the debtors. This goes back to the hearing on May 10th, where 

Your Honor allowed Mr. Addington to file an amended claim. And 

at the hearing when prompted, Mr. Addington estimated his claim 

to be about 100,000 dollars. And again, we don't have to hold 

him to it. Your Honor certainly said you would not be holding 

him to it, but the claim we received was an order of magnitude 

larger and none of it had to do, really, with -- seemed to have 

to do with fixing Mr. Addington's property. 

So from PG&E's perspective and from the perspective, I 

would say, of anyone trying to settle this, which I am also of 

that persuasion, I would also like to see this settled, it just 

seems like we've been moving backwards on this. And the proof 

of claim that we have just doesn't give us a whole lot, and it 

doesn't give us a whole lot from what Mr. Addington had tried 

to present back in the spring. 

And it's not that we're philosophically opposed to --

against discovery or in favor of jamming anybody, it's just 

that we want to be on a level playing field here where we know

where Mr. Addington wants to prove and what the theory is about 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 6

of 72
7

PG&E Corporation and Pacific Gas and Electric Company

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

liability so that we can prepare for discovery, we can 

determine what, or discuss with Mr. Oliner what the scope of 

discovery is reasonable and, if possible, take our own 

discovery from Mr. Addington. 

And I do want to --

THE COURT: And that's all fine, but why not share the 

file then? I mean, Mr. Addington was a tenacious advocate, but 

Mr. Oliner's presence as an experienced practitioner seems to 

me a good result from your point of view, and not to take it --

not to criticize Mr. Addington, I don't criticize him. But 

here we have an experienced lawyer on the other side who says, 

I'd like to see the file. What's wrong with that? 

MR. RUPP: Well, Your Honor, I -- the file is -- 

THE COURT: I've made a ruling that there was no 

termination of the easement, and I've made a ruling that there 

was a settlement in whatever year it was in a certain amount, 

and after Mr. Addington was paid a certain amount so. Mr. 

Oliner can't dig himself out of those two positions unless 

there's some revisiting. 

So whether he has a right to assert a claim for 

100,000 or 900,000, if he has a right to assert a claim, it 

seems to me that you start with show me your file. And if 

there's something in the file that might have been different if 

there hadn't been these prior rulings, then so be it. But you 

won those rounds, right? And no one's going back, no one's 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 7

of 72
8

PG&E Corporation and Pacific Gas and Electric Company

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

asking me to set aside the ruling that I made. So I guess I'm 

having trouble understanding why it's constructive to say we're 

happy to mediate, but we won't show our file to the other side. 

So you got to get me past that one first. 

MR. RUPP: Your Honor, I guess the way I can get past 

that is just saying that we're entitled to a little bit more as 

far as what the theory of liability is here. 

THE COURT: Well, but you made a comment in your paper 

that, I guess, technically I agree with that Rule 12(b) doesn't 

apply. But Rule 56 applies, and you could file a motion for 

summary judgment.

If you believe that the amended proof of claim doesn't 

state a claim, file a summary judgment. Summary judgment is 

proper on a claim objection. And if you did that and you said 

there's no liability, blah, blah, blah, Mr. Oliner would say 

well, I got to get some more facts, give me your file. So 

you'd show him your file. And then he would, perhaps, oppose 

the motion for summary judgment, and maybe he'd lose or maybe 

he'd win. But the point is the issue would be framed. 

So you say that we shouldn't give him the file because 

we want something in return, what do you want in return? 

MR. RUPP: I guess, Your Honor, we're -- what we're 

looking for is the theory of liability here and the specific 

facts. 

THE COURT: But Mr. Rupp, if there's no theory 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 8

of 72
9

PG&E Corporation and Pacific Gas and Electric Company

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

articulated, make a motion for judgment. In other words, if 

12(b)(6) isn't available, which is what you would do in a 

traditional adversary proceeding, you'd say there's no state of 

claim -- doesn't state a claim under 12(b)(6). And of course, 

as you know, and most lawyers know, half the 12(b)(6) motions 

end up being treated like summary judgment motions anyway 

because people bring in facts. 

So one of the facts you would bring in is Mr. 

Addington settled this case back in 20-whatever-it-was, and got 

paid 50,000 bucks. So therefore, he can't complain about what 

happened in the past. 

So all -- and all we're doing now is trying to see has 

he made a case for any additional damages after that 

settlement, which was what the underpinning of my ruling was. 

And if he -- your argument is he hasn't proven it, then you're 

going to get a summary judgment.

Anyway -- well, okay. So Mr. Rupp, I won't pin you 

down any further. Procedurally, what do you want me to do 

today, because Mr. Oliner wants more time. And I -- this case 

has taken quite a while, but what would you like me to do? 

MR. RUPP: Your Honor, again, we -- we're happy to 

give more time. We're happy to put this out. We don't --

setting a trial today or any fixed discovery deadlines is, I 

would say, premature, and I think Mr. Olinger would agree. 

But --

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 9

of 72
10

PG&E Corporation and Pacific Gas and Electric Company

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

THE COURT: Well, there wasn't -- there was a prior 

mediation that was unsuccessful. Are you willing to try again? 

As you know, your firm coordinates a whole panel of other 

counsel and people available to mediate. If the parties get 

together and pick someone from that panel and try to resolve 

it, fine. That would seem to be constructive. 

One of the things that I would wonder is the mediator 

might say, well, what are the damage claims? But anyway, do 

you want to explore that? 

MR. RUPP: Your Honor?

THE COURT: Are you prepared to commit and go to that 

level on the mediation? 

MR. RUPP: I'm sorry, Your Honor. I didn't quite 

catch that. What -- what level on the mediation?

THE COURT: No, I said I -- are you -- is the company 

willing to do for this case what it's done for many others? 

Again, you've been on the principal lawyer role in many that 

have gone to mediation. I can think of over the past couple of 

years, all the ones that have gone to third-party mediators.

And Mr. Oliner, I don't know if you're aware of this, 

but the company has paid for a mediators from --

MR. OLINER: I am.

THE COURT: -- that it maintains, this is not related 

to the fire claims, and it's -- but it's ad hoc and it -- some 

have been successful and some have not. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 10

of 72
11

PG&E Corporation and Pacific Gas and Electric Company

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

And Mr. Rupp, I would assume the company would still 

be willing to undermine that -- support that effort, right?. 

MR. RUPP: You're -- that's right, Your Honor. I 

mean, we've enjoyed a lot of success with mediation in other 

claims. Right now, I'm not sure if mediation would be a good 

route at this time based on what's been filed so far. I mean, 

we --

THE COURT: Because the mediator would say why haven't 

you given them your file? 

MR. RUPP: Well, we filed a claim objection, Your 

Honor. And just the way the scheduling came out, Mr. Oliner 

did want to have this hearing today. But we do think we --

that Mr. Oliner should have to respond to our objection at some 

point before we can proceed. If --

THE COURT: Mr. Rupp, that's not a good enough answer. 

Because the Addington claim was tossed, because it was four 

million dollars, because Mr. Addington believed that the 

easement had been terminated. And I said, no, I'm sorry, Mr. 

Addington, that it hasn't been terminated. But if you had 

damages that didn't get dealt with because they are postsettlement, prove your claim. And whether Mr. Addington could 

have filed a claim for 5 dollars or 100,000, he filed a claim 

for just under a million. And you believe that that claim 

is -- can't even -- you can't even put your arms around it. 

But that's the claim he filed. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 11

of 72
12

PG&E Corporation and Pacific Gas and Electric Company

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

And so to tell him to amend the claim, that you won't 

give them access to the file voluntarily is -- it's silly.

So I could just say, well, let's go to trial, put on 

your case. And Mr. Oliner would probably ask for discovery and 

you would have to provide. 

So all I'm getting at is, why don't you just say 

you'll make the file available and take up with your client 

whether they agree again to support, perhaps, a new mediator on 

the scene under the same procedure that has worked before, and 

we'd take another look at it in thirty days or forty-five days? 

Maybe there'll be progress. Maybe there won't. But I can't --

look, I can't tell Mr. Oliner the other side says you don't 

have a case, but we'll have a trial, well, you have to prove 

your case. When he says but I can't prove my case because I 

can't get access to the files that I'm entitled to under formal 

discovery. That's not efficient. 

MR. OLINER: I don't -- I just want to add that we 

previously indicated in writing our willingness, in fact, I 

suggested it, to go to mediation. We will maintain that 

position provided we receive PG&E's files. 

I've conferred with my client about that. If there's 

something there which increasingly feels like there might be 

that's useful to us to prosecute the claim, then why -- maybe 

that's the reticence. But just give us our stuff, because it's 

far easier for us to see what there is and to go and mediate 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 12

of 72
13

PG&E Corporation and Pacific Gas and Electric Company

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

this in good faith. 

And Mr. Addington is a lot of things. He is 

tenacious, and he also listens to me. And so I think -- I'm 

confident that we -- I'm sure we should take a shot at 

resolving it before I engage in defending SJ and converting it 

to a long, drawn-out discovery process. 

PG&E can try to steamroll us. And they've got the 

assets, but that's not practical or efficient. 

THE COURT: But Mr. Oliner, I have to say --

MR. OLINER: So let's get this to mediation. 

THE COURT: Mr. Oliner, I have to say this, though 

lest I -- lest you make -- think I'm putting Mr. Rupp on the 

defensive completely. One of the things that struck me as 

strange is well, why does Mr. Addington need discovery? Mr. 

Addington settled the case four years ago, and claims to have 

suffered damages since then and he has to prove it. 

So what will he find in PG&E's files that proves his 

damages? Now, come on, one of his damages is his attorneys'

fees. You won't find that in PG&E's file. Another one is his 

own time, won't find that in there. Another one is the loss of 

value in his property, won't find that in there. So I'm not 

sure what in a practical sense you're going to do if you accept 

that there is a rule in this case that he settled -- he 

settled four years ago. 

MR. OLINER: I'm aware. I don't know what's in the 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 13

of 72
14

PG&E Corporation and Pacific Gas and Electric Company

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

file. I know this, that my client has been warned repeatedly 

that he has no authority without their approved engineering 

plan to fix the gradient in his backyard. I don't know what's 

in the file and Mr. Rupp won't tell me because his client won't 

let him tell me. So I'm not -- it's not a fishing expedition 

so much as my trying to get my arms around what my -- what I've 

got in PG&E's files. 

Mr. Addington can't landscape or fix this gradient 

without figuring out what's -- what PG&E requires. What do 

they know? 

And another further sideshow is a month or so ago, Mr. 

Addington received an urgent demand for access to his property 

by PG&E's vendors. Must absolutely happen tomorrow, which was 

a Sunday, no alternative date. So I contacted Mr. Rupp, and 

suddenly that urgent need for PG&E to get on the property went 

away. I don't know what's going on. I just want to see the 

file, turn over the file, which shouldn't have anything sexy or 

exciting in it, at least per Mr. Rupp's implication. We will 

go to mediation and I will drag Mr. Addington there in good 

faith to try to solve his claim. That's the way we (audio 

interference). 

THE COURT: It seems to me that there's a 

miscommunication here. Mr. Addington may want to make some 

corrections on his property, and PG&E may have the right to 

insist that any such corrections be consistent with its needs, 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 14

of 72
15

PG&E Corporation and Pacific Gas and Electric Company

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

but that has nothing to do with this proof of claim. 

In other words, he might want to build a, you know, a 

tower there as his choice, and maybe he can do it and maybe he 

can't. But that has to do with the nature of the relationship

and the easement. It has nothing to do with his proof of claim 

in the bankruptcy case. 

So I think -- I find this to be a confusion between 

what Mr. Addington may want to do versus what is the basis for 

him to have a provable claim against PG&E for any damages that 

he's suffered from. See the difference? 

MR. OLINER: I do, and you may be right, and I'm not 

going to suggest that you're wrong at the moment. But --

THE COURT: Well, but the point it is if there were no 

bankruptcy, if there were no dispute here, and Mr. Addington 

wanted to do something with his property, whether it's rebuild 

the tennis court or put in a pool or something, whether he 

could do it or not is -- has nothing to do with the bankruptcy. 

It has to do with the nature of the relationship between the 

two tenements, the dominant tenement, PG&E, and the servient 

one, Addington here. And that's a matter of law and has 

nothing to do with proofs of claim. 

So I think what I'm trying to avoid here is getting 

into a fight on a contested matter of a claim objection with 

what Mr. Addington would like to do, even if it's at his 

expense. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 15

of 72
16

PG&E Corporation and Pacific Gas and Electric Company

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

All he's entitled to do in this bankruptcy case is to 

prove up money damages that PG&E owes him for the situation 

that persists after and since his settlement with them. 

MR. OLINER: Well, I -- your points are again well 

taken. I don't know what's in the file. It should be very --

this is not rocket science. Give us the file. What 

engineering studies have you done? I'm focusing post-agreement 

for those purposes. I just got to have the file, and I want to 

go to mediation, and I will drag Mr. Addington there. I know 

he's willing to do so. 

THE COURT: You said that -- you said that before, and 

I accept that. But that's not the point. I mean, I --

MR. OLINER: Well --

THE COURT: Listen, the mediation will be a complete 

failure if Mr. Addington says here I am, I want ten -- a 

million dollars, and Mr. Rupp's client says we're ready --

prepared to pay you 10,000 dollars. I mean, that's not going 

to be successful, you know that. So --

MR. OLINER: I know that very, very well. 

THE COURT: Mr. Rupp, it seems to me that -- again, 

I -- maybe I'm conflating issues and maybe you don't agree with 

the way I have -- or maybe I should say maybe you are 

conflating them and I'm separating. But don't you agree that 

to the extent that Mr. Addington wants to prove his damage 

claim in this bankruptcy, he does have the right to a certain 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 16

of 72
17

PG&E Corporation and Pacific Gas and Electric Company

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

kind of discovery as a general matter, right?

MR. RUPP: Your Honor, yes. Ultimately, if we --

we're not expecting anyone to put a trial on without taking the 

discovery they're entitled to. 

Again, not to sound like a broken record, but we did

state in our claim objection that PG&E has provided an 

engineering report to Mr. Addington, and it provided the report 

from the contractor that did the work. But I think more 

importantly is -- if there's some discovery to be done, I've 

been to enough hearings before Your Honor and viewed enough 

hearings before Your Honor that discovery disputes are not Your 

Honor's pleasure, and you expect competent counsel to work 

these issues out.

So you know what the -- what keeps troubling me is 

that we keep using the phrase the file. And you know, it's --

but I understand that's a good enough term for right now. But,

perhaps, Mr. Oliner and I can meet and confer and come to some 

kind of agreement on what exactly Mr. Addington is looking for 

and what should be turned over. 

MR. OLINER: I'm sure --

THE COURT: But if Mr. Addington wants to do something 

with his property, is it your view that PG&E doesn't have to 

provide him whatever it would insist upon be done no matter 

what? Again, even if there were no bankruptcy? 

In other words, if there were no bankruptcy and Mr. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 17

of 72
18

PG&E Corporation and Pacific Gas and Electric Company

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

Addington calls up PG&E and says I want to install a swimming 

pool on my lot, and PG&E may have a way, under the easement 

rules, to prohibit him from, or limit his ability to do that. 

Is that what we're talking about? Is this a question of a 

dispute over what Mr. Addington may want to do wholly apart 

from whether he has a proof of claim for damages? 

MR. RUPP: You know, again, Your Honor, I think we're 

getting a little over our -- over our skis here. I'm not 

exactly sure what Mr. Addington wants to do to the property. 

I'm not a civil engineer. And we don't -- I don't think we 

have anyone on this call to know what's safe. 

What I do know is that these towers are important to 

PG&E and PG&E has an easement for them and that comes first,

that those towers need to remain upright and remain in good 

condition and Mr. Addington's desires for his lawn comes

second. 

THE COURT: No, that's true. Again, I don't think 

there's any -- that's not the issue and that's my point, 

though. 

The only relevance, it seems to me, to any of this, is 

what -- does Mr. Addington have to prove his claim? And if Mr. 

Addington threw in the towel and withdrew his proof of claim, 

that would be the end of this Court and your personal and maybe 

Mr. Oliner's involvement. But the next day, if Mr. Addington 

wanted to do something on the property, he'd have to -- he'd 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 18

of 72
19

PG&E Corporation and Pacific Gas and Electric Company

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

have to comply with whatever rules pertain to the servient 

tenants' rights under the easement. So -- and that's what I'm 

trying to make sure we don't lose focus on. And I'm asking Mr. 

Oliner to focus on it too.

What Mr. Addington wants to happen on his property is 

not the same as what Mr. Addington is entitled to as 

compensation for a damage claim that he is asserting against 

PG&E. At least I don't think there -- they overlap. I think 

they are two separate issues. 

I'll tell you what, I will just remind you again, Mr. 

Rupp, you're correct; I hate discovery disputes. I don't know 

of a single federal judge who loves -- likes them, but I will 

put this over one more time, a month or so, and expect as a 

consensual matter that there'll be an exchange of information.

If Mr. Oliner is frustrated and believes that he 

should be getting more than you're willing to make available to 

him, then I guess that will require a more formal motion,

because if he wants stuff that is irrelevant to the proof of 

claim dispute, and he's not going to get it. 

But the fact of the matter is, I don't have much 

choice but to set in motion the claims resolution. 

So there's a claim for just under a million dollars 

that's a hundred percent contested. And Mr. Oliner and his 

client have the burden of proof, and they have to be put to 

that proof. But traditional discovery rules say they can have 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 19

of 72
20

PG&E Corporation and Pacific Gas and Electric Company

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

some access to the evidence before they are required to do it. 

And PG&E in turn, can file a motion for summary 

judgment to say on this record, there is no liability for the 

following reasons, A, B, C. And if PG&E wins that argument, 

they'll be done with this dispute and -- but in the meantime 

Mr. Addington and his counsel should at least have access to 

the information, whatever information is that's relevant to 

resolving that dispute. And if it's more than that that he 

wants because of his own desires to do something on the

property, because it is his property, no question about that, 

then to the extent that PG&E's willing to cooperate and do so 

provide it consensually, it may facilitate a consensual 

resolution through a mediation process. 

So I will assume that PG&E, if it wants to, will make 

one of the panel mediators available at its expense the way 

it's done otherwise. And Mr. Addington and his counsel can 

take advantage of that process. But alternatively, if 

there's --- if the discovery or the informal discovery becomes 

unworkable, then I think the burden will be on Mr. Oliner to 

initiate some formal discovery. 

And I'll just put this over -- Mr. Oliner, you say 

you're going to be away for two weeks? 

MR. OLINER: I'm going to be in New York, and Eugene, 

Oregon for a football game in the next two weeks. 

THE COURT: You might consider going to South Bend, 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 20

of 72
21

PG&E Corporation and Pacific Gas and Electric Company

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

Indiana and watch Notre Dame beat Cal next Saturday. In the 

meantime --

MR. OLINER: Does Notre Dame --

MR. RUPP: Your Honor --

MR. OLINER: -- have a football team? 

THE COURT: Huh? What, Mr. Rupp? 

MR. RUPP: Your Honor, you've been hard enough on me 

already today. I think that was undeserved. 

THE COURT: I get it. 

MR. OLINER: Your Honor, the -- that's terrific. I 

think your comments are guiding us. Mr. Rupp and I have a good 

rapport. I'm a little mad at his client, but that's just how I 

am. 

I will proceed in good faith in the effort to get what 

we've called the file, and Mr. Rupp correctly calls it his 

stuff that's relevant to the claim and try to resolve it that 

way. 

I don't intend to proceed with formal discovery before 

this to-be-set-next hearing. But if we can't get what we need 

and we're still fighting about basics there, that's what I'm 

going to be talking about at the next hearing. 

THE COURT: Yeah, but the point is, if you're going to 

be out of town for a good part of two weeks, then I want you to 

be productively back on duty here to deal with these matters --

MR. OLINER: Yes.

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 21

of 72
22

PG&E Corporation and Pacific Gas and Electric Company

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

THE COURT: -- and so I don't want to have a hearing 

two days after your schedule lets you back.

So Ms. Parada, what are our -- what's our PG&E date 

out about a month? Mr. Rupp probably knows the dates, but I 

don't know. 

MR. RUPP: I believe it's the 11th, Your Honor.

THE CLERK: Yes. That's the only date available in 

October. 

THE COURT: What's the next one after that? 

THE CLERK: That would be sometime in November. 

November 2nd, 15th, and 30th. 

THE COURT: Mr. Oliner, November --

MR. OLINER: November 2 is fine, Your Honor. I'm 

already in court on the 11th in another case. So November 2 

would be terrific. And that's plenty of time for Mr. Rupp and 

I to try to get -- be on the same page. 

THE COURT: Okay. But gentlemen, on November 2nd, if 

there hasn't been a resolution or either a resolution as to the 

procedure, like scheduling a mediation or scheduling some 

discovery, I'm going to set a schedule for either trial on the 

contested claim or any motion that Mr. Rupp or either side 

wants to make that might be dispositive. 

And we won't call it a 12(b)(6) motion, because it 

isn't. It could be a summary judgment motion. But I'll wish 

you good luck in trying to make some progress. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 22

of 72
23

PG&E Corporation and Pacific Gas and Electric Company

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

So I'm continuing the Addington claim objection to 

November 2nd at 10 o'clock and I'm not going to fix any 

deadlines. I'll assume that you'll file some sort of a joint 

status conference before that, but I'm not going to fix 

anything that's required. Okay?

MR. RUPP: We will. 

MR. OLINER: Thank you very much for your time today, 

Your Honor. 

MR. RUPP: Thank you, Your Honor.

THE COURT: Thank you, Mr. Oliner.

MR. RUPP: Before we quit, I did want to repay the 

compliment from Mr. Oliner earlier and thank him for agreeing 

to the extension and for his professionalism. 

THE COURT: Yeah. Okay, great. And are you staying 

on for the next matter, Mr. Rupp, or is that someone else?

MR. RUPP: I will retire to the gallery, Your Honor, 

but --

THE COURT: Okay. 

MR. RUPP: -- some of my co-counsel may be listening 

in as well and may wish to be heard. 

THE COURT: Okay. Thank you very much. 

MR. RUPP: Thank you. 

THE COURT: We'll proceed with Mr. Abrams' matter. 

All right. Good morning, Mr. Abrams. Please state 

your appearance, please. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 23

of 72
24

PG&E Corporation and Pacific Gas and Electric Company

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

MR. ABRAMS: Good morning, Your Honor. Will Abrams. 

THE COURT: Ms. Parada, who is appearing for the Fire 

Trustee today? 

THE CLERK: Mr. Molton is joining now, Your Honor. He 

raised a hand. 

THE COURT: Okay. Is Mr. -- Ms. Parada, is there 

anyone else who has asked to be heard on this matter today? 

THE CLERK: Mr. Matthew French has raised a hand. 

Would you like me to bring him in, Your Honor? 

THE COURT: I'm sorry. What's the person's name? 

THE CLERK: Matthew French. 

THE COURT: Yes. Okay. 

All right. Mr. Molton, would you state your 

appearance, please? Mr. Molton, are you there? I can't hear 

you. Nope, still can't hear you. 

Mr. French, do you wish to be heard? 

MR. FRENCH: Sure, Your Honor. Matthew French for 

creditors Majesti Mai Bagorio, et al. I joined Mr. Abrams' 

motion. 

THE COURT: Oh, okay. Thank you, Mr. French. 

Mr. Molton, until I can hear you, I can't do much. 

Ms. Parada, you can't hear him, can you?

THE CLERK: I cannot, Your Honor. 

THE COURT: Mr. Molton, I -- you got a -- you've got 

some sort of a muting thing on your microphone. You want to 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 24

of 72
25

PG&E Corporation and Pacific Gas and Electric Company

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

log out and come back in again? All right. Go ahead and do 

that. We'll just wait. 

(Pause.)

MR. MOLTON: Can you hear me now, Your Honor? 

THE COURT: There you go. Good morning, Mr. Molton. 

MR. MOLTON: I'm so sorry, Judge. I had to get off of 

another machine and onto my Apple. So I don't want to give 

them a another thumbs up, but they always seem to work. 

THE COURT: Okay. Just state your appearance for the 

record. 

MR. MOLTON: Your Honor, David Molton, Brown Rudnick 

LLP, for the Fire Victim Trust and the Fire Victim Trustee 

Cathy Yanni, in that capacity. 

THE COURT: So when Mr. Abrams filed this motion, his 

prior motion that was directed more specifically to Justice 

Trotter and the Fire Trust, I set a preliminary hearing and 

didn't ask for a response from you. When I looked at this 

motion, which we'll call his JAMS motion, for lack of a better 

term, it was much broader in scope, and I frankly wasn't quite 

clear whether and who would be respondents on the motion. So 

I, simply adopted the same procedure to kind of let's find out 

if people want to be heard on this. 

Well, I did expect the Fire Trustee as their counsel 

now has appeared, and I -- and to some extent, that's what I 

wanted too. And now I've come to realize that it's not even 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 25

of 72
26

PG&E Corporation and Pacific Gas and Electric Company

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

clear who might be respondents on this motion. 

And I don't want to turn this into a debate with Mr. 

Abrams, and I want to say that one of the things that I need to 

do is to figure out who are the likely respondents on this 

motion and what did they want to say. 

So Mr. Molton, what I'd like to ask you if you have 

any indication or clue other than your client, Ms. Yanni -- and 

I don't know whether you're going to be acting on behalf of 

Justice Trotter also -- but are you aware of people or parties 

other than you and your client who are going to want to be 

opposing this or heard on this motion? 

MR. MOLTON: Judge, I had some remarks, and I was 

going to go into that very point because, as Your Honor knows 

from reading Mr. Abrams' motion, most of it is directed to 

matters that preceded the Trust or other cases that have 

nothing to do with the Trust. 

He mentions a lot of names in there, Your Honor, 

including in addition to former trustee and former Justice 

Trotter and Cathy Yanni, our present trustee, he mentions Mr. 

Skikos, a member of the TOC. He mentions Judge Newsome, who is 

a court-appointed mediator in this case. Jay Gandhi, another 

mediator in this case. Both of their mediations that Mr. 

Abrams referred to, of course, concern issues that preceded the 

Trust. 

He mentions a number of people that I don't know of, 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 26

of 72
27

PG&E Corporation and Pacific Gas and Electric Company

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

but arguably, according to Mr. Abrams, are JAMS panelists: 

retired Judge Carvill, retired Judge Gallagher, Ms. Gillette, 

retired Judge Kawaichi, Judge Pichon, Viggo Boserup who is the 

appeals officer for -- in our appeals regime under our claims 

procedure, and JAMS in full. 

And one of the things, Your Honor, I was going to ask 

is it's our feeling, Your Honor, that based on the fact that we 

don't believe there's any good cause to proceed for various 

reasons, including the fact that all we have are allegations 

and innuendo based on newspaper articles and whatnot, and I can 

go into some remarks on that as well. But at the very least, 

Your Honor, notice and opportunity to be heard should be given 

to anyone impacted by Mr. Abrams' request for discovery. 

Mr. Abrams, as Your Honor would know in his papers,

even defines this request as a very broad request. And if Your 

Honor looks at his proposed discovery, which includes lots of 

interrogatories and document requests that go well beyond the 

people I represent or the entities I represent, I think it only 

fair, Your Honor, that this Court give those folks notice and

opportunity. 

I do note, Your Honor, that in doing what you did, 

which is exactly what you did the prior time, you asked for us 

to come forward, meaning the Trust, and be prepared to indicate 

how and when it, us, the Trust intends to respond or otherwise 

deal with the motion. And for folks who may be mentioned in 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 27

of 72
28

PG&E Corporation and Pacific Gas and Electric Company

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

Mr. Abrams' pleadings, we're reading Your Honor's directive, I

don't think that gave them clear indication that they were 

expected either to be here today or to have anything on the 

record. Indeed, Your Honor in Your Honor's order, asks us not 

to file anything, which we didn't. 

So my view, Judge, is that at the very least, clearly 

that those folk who are mentioned or impacted by Mr. Abrams'

requests be given an opportunity to come in. 

I don't know, Judge, and I can't tell you right now 

whether they will or won't, but certainly they weren't expected 

to, based on the pleadings to date, and they should be given 

that opportunity. So I hope that answers your question. 

THE COURT: Well, no, it does. Can you clarify 

whether you speak today for Justice Trotter also or --

MR. MOLTON: No, Judge. I -- one of the things that I 

wanted to say in my opening remark is I'm here for the Fire 

Victim Trustee, Cathy Yanni in her capacity as such, as well as 

for the Fire Victim Trust.

THE COURT: Right. 

MR. MOLTON: The allegations that have been made 

against Justice Trotter, which were derived, I understand, from 

a Los Angeles Times article, concern events and issues that 

precede the Trust. So at the present time, I am not here for 

him with respect to those issues. 

THE COURT: Okay. But I'm not surprised at your 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 28

of 72
29

PG&E Corporation and Pacific Gas and Electric Company

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

response, but at least that focuses the question at the minimum

Justice Trotter, personally, or in his former capacity, may be 

considered a respondent, and he hasn't been noticed. And Ms. 

Yanni, of course, in her capacity as the current trustee and 

her counsel on that trust are. And it seems to me that all the 

other people that you've identified -- and I believe there's at 

least one other person you didn't mention who was a former 

judge who was actually appointed, I believe that's Judge 

James -- 

MR. MOLTON: Yes, I forgot Judge James. 

THE COURT: -- I actually issued an order during the 

case to authorize her role, as I did with Judge Newsom. But 

whether either of those or any other person should even be a 

respondent is one of the uncertainties in my mind about this 

motion. And I, as I say, I didn't insist that they be 

respond -- served or response, and I didn't know whether they 

would respond or not. And my instincts told me maybe someone 

would be responding by saying, I oppose this. 

When I saw Mr. French's name, I didn't recognize his 

name, and I thought, well, there is at least one lawyer who 

might be here for one of the respondents. Obviously, Mr. 

French, who stated his appearance, is not in that camp. He's 

in the roll call in the Abrams' camp, I'm sure. And Mr. 

French, I'll give you a chance to speak in a moment. 

I'm just saying that unlike the original, what I'll

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 29

of 72
30

PG&E Corporation and Pacific Gas and Electric Company

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

call the original Abrams' discovery motion, where there was a 

very clear focus on who the respondent would be, I nevertheless 

saw fit to depart from the normal process in Rule 2004. 

I mean, 2004 is, to the extent that they -- that rule 

is available and we don't have to go there again, I've made a 

decision previously about that. And there's a whole -- there's 

a whole body of practice in our court in this district on how 

2004 requests are processed. But there's never been a case of 

this nature where Mr. Abrams in his role as -- whatever his 

role is, is bringing something that is broader than in my 

experience, has ever been dealt with before. 

So -- but Mr. Molton, before I conclude my comments to 

you, I still believe it's appropriate for you to file a formal 

response, and I want to move this more quickly than I, perhaps,

did in the other time -- the other motion. So make me a 

proposal. I assume you can respond within a reasonably short 

period of time. 

MR. MOLTON: Judge, I was ready for that, Your Honor, 

and I've got a date to suggest. And that date, Your Honor, is 

October 3rd. And that's a date also, as Your Honor may recall, 

that is the disclosure date of the director and officer --

THE COURT: Right. 

MR. MOLTON: -- settlement agreement that was the 

subject of the joint motion by PG&E and the Fire Victim Trust. 

THE COURT: Well, yes. And you did say that's coming. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 30

of 72
31

PG&E Corporation and Pacific Gas and Electric Company

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

And so that's still on track. And just as an aside, is that 

going to be noticed out, or is it going to be on a scream or 

die? What will be the mechanism to bring that before the 

Court? 

MR. MOLTON: Judge, I'm going to have to look at Your 

Honor's order today for that application. I think we -- I 

think that the -- that is the date by which the settlement will 

be disclosed. And I think PG&E -- and I don't know if they're 

in the room or listening, but I think that they need to be 

moving the Court with respect to certain aspects of that 

settlement agreement or issues related to. And --

THE COURT: And I'm assuming --

MR. MOLTON: Yes.

THE COURT: -- yes, Mr. Molton, I'm assuming that that 

it's a complex settlement that involves the district court 

litigation, the state court litigation by the trustee, the 

class plaintiffs, the debtor, the Fire Trustee, and lots of 

other folks. And I don't -- and Mr. Abrams or any other party 

in the case, whether a fire claimant or a nonfire claimant, 

might want to be heard. I don't think that the approval and 

the consummation of that settlement should be at all involved 

with the current discovery requests that are done here. And 

just a coincidence that you're proposing a date that coincides 

with --

MR. MOLTON: Yes.

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 31

of 72
32

PG&E Corporation and Pacific Gas and Electric Company

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

THE COURT: -- that date. But beyond that's the 

only -- 

MR. MOLTON: There's no interconnection. And I'm not 

asking you to make any, Your Honor.

THE COURT: Okay. 

MR. MOLTON: We're just using that as a useful date 

for getting a response in here, allowing, as I suggested, after 

proper notice, other interested parties should they want to, to 

file a response as well as on a very -- on a separate matter, 

wholly independent of this, there will be other activity as 

well. 

THE COURT: Mr. Abrams, I'm inclined to give the Fire 

Trustee, Mr. Molton, for his client, the Trust and the current 

trustee, a date of October 3rd to respond. And as to all these 

other people, from Justice Trotter to JAMS as an institution,

to the individuals, there's nothing procedurally on the line. 

You haven't even demonstrated any kind of formal 

notice to those parties. And I'm not inclined to do anything 

except decide on your motion and the trustee's response what to 

do next. 

Now, what to do next might be a reply from you. It 

might be a hearing. It might be an order to give notice to 

others. I simply want to see what happens on October 3rd, and 

that's what I'm inclined to do, and I'll give you a chance to 

respond. But my inclination is to let Mr. Molton have a 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 32

of 72
33

PG&E Corporation and Pacific Gas and Electric Company

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

response date. Whether it should have been a little later or a 

little earlier, it's not a big deal, it's not very long from 

now, and take the matter under advisement and decide what to do 

then. So go ahead and respond if you wish to. 

MR. ABRAMS: Thank you, Your Honor.

Certainly, I agree with what Your Honor stated and 

what Mr. Molton reiterated that getting this done sooner rather 

than later is very important, certainly very important to 

victims. And I just wanted to make sure that the Court 

understood that I did follow as best as I could, the procedures 

and noticed everyone on the service list who was --

THE COURT: Did you serve any of them? Did you serve 

any of them by original service? 

MR. ABRAMS: I served all of them via email. 

THE COURT: I asked you if you served any of them by 

original service. I guess the answer is no. 

MR. ABRAMS: The answer is no, Your Honor, and I --

and look, Your Honor knows that I am not a practicing attorney, 

and I'm following the procedures as best I can. If the Court 

is correcting me, I stand corrected and I will certainly 

provide written notice via certified mail to whomever I should 

be providing that to. 

I think it is a correct point that because of the 

pattern associated with JAMS and Justice Trotter that's been 

demonstrated, of course the parties who are associated with 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 33

of 72
34

PG&E Corporation and Pacific Gas and Electric Company

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

that are broader than they might have been. But that is not a 

function of me putting forward a motion. That's a function of 

the pattern that's been demonstrated that is before the Court. 

THE COURT: Mr. Abrams?

MR. ABRAMS: For me as a messenger --

THE COURT: Mr. Abrams? Mr. Abrams, excuse me. What 

you call a pattern that has been demonstrated, I call a 

newspaper report with no foundation. So you may assume that 

all those other judges, and that JAMS itself as an entity and 

Justice Trotter and Ms. Yanni have all done bad things, but I 

make no determination and no pattern has been established 

except your reporting of what the LA Times reported about a 

major catastrophe and scandal in another unrelated bankruptcy. 

MR. ABRAMS: Understood, Your Honor. And look --

THE COURT: It's that simple. 

MR. ABRAMS: And look, Your Honor, and I made it very 

clear in my motion that I am not accusing anyone of a crime. 

But the basis here, as I read it, is good cause. And I'm 

certainly not reliant upon any outside reporting. I'm 

demonstrating a pattern that says, yes, there's good cause.

Your Honor, if this was -- in a lot of ways, the way 

that I see the role of the trustee is for providing security 

for the Trust, making sure that the Trust has integrity. 

And so if there was an example of a bank that -- that 

somebody had security over that bank, and it turned out that 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 34

of 72
35

PG&E Corporation and Pacific Gas and Electric Company

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

some other parties were taking money from that bank, and then 

there was a pattern of money being taken out of banks, and then 

we're in charge of -- and then is in charge of a new bank for 

13.5 billion dollars, and all the money isn't there, there 

would, of course, be good cause for asking questions about are 

they taking prudent steps for security of that bank? 

And so similarly, I certainly feel that there is good 

cause in this case to be asking is the current and past trustee 

and JAMS in general providing security for the Trust, or have 

they been operating in ways that are not in good faith? And I 

think that that's just good cause.

I'm not -- again, I am not accusing anyone of a crime. 

I'm not reliant on the press. I am providing information to 

the Court that wasn't before the Court before to demonstrate 

good cause for reasonable discovery. 

THE COURT: Okay. Thank you. 

Mr. French, do you wish to be heard? 

MR. FRENCH: Morning, Your Honor. 

Fundamentally, I agree with Mr. Abrams as to good 

cause. I think that this reported pattern of behavior is 

sufficient. 

THE COURT: But what you see as a pattern of behavior?

MR. FRENCH: Well --

THE COURT: Let's assume the Girardi case is a major 

disaster for lots of people in the Girardi world. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 35

of 72
36

PG&E Corporation and Pacific Gas and Electric Company

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

MR. FRENCH: Certainly.

THE COURT: So where is there a pattern beyond that? 

MR. FRENCH: Well, the article does not implicate 

Justice Trotter to be clear and neither am I. But it does 

indicate that he was trustee of two different bankruptcy trusts 

from which Mr. Girardi misappropriated funds. And to my mind 

that is sufficient good cause to just make sure that we don't 

have any of the same issues here. 

THE COURT: Okay. 

MR. FRENCH: I agree with Your Honor that the breadth 

of the motion is perhaps not as narrow as is necessary to 

answer that question. To my mind, though, in terms of notice, 

which I agree there's a problem with notice, is that the first 

step would be the Trust sort of making an accounting for who 

has a contractual relationship with the Trust that's related to 

JAMS or what contracts exist between the Trust and JAMS, and 

that that would be a starting point, in which case the notice 

could be issued and we could sort of set the parameters for,

perhaps, different categories of people as to what would be 

discoverable or not. 

THE COURT: Well, I can ask Mr. Molton if there is any 

contract between the Trust and JAMS, and he probably could 

answer that in one syllable, yes or no, probably. And I'm not 

going to ask him that now unless he wants to volunteer it. But 

I mean, the pattern, what if he says no, first of all, and 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 36

of 72
37

PG&E Corporation and Pacific Gas and Electric Company

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

let's assume that Mr. Molton isn't going to make it up, isn't 

that the end of the inquiry? I mean, what's the next step if 

on a final formal basis I ask Mr. Molton does the Trust have a 

contract with JAMS and he says no. Then what? What's the next 

question? 

MR. FRENCH: Disclosure of prior relationships among 

Trust employees with JAMS. 

THE COURT: I mean, like what, for example? Somebody 

that's a data processor who used to work as a clerk at JAMS? I 

mean, if you want me to know if there's any member of the --

well, first of all, there is only one trustee. The fact that 

Ms. Yanni may have done work through JAMS sometime in the past, 

I don't know what the relationship of any JAMS entity is. I'm 

assuming, but I don't know this personally, that they're 

independent contractors. I mean, it's my experience with real 

estate brokers and, perhaps, I think mediators elsewhere, I 

believe generally they are independent contractors. 

So if I'm an independent contractor, or if you, Mr. 

French, are -- if you go do a gig through JAMS and you're an 

independent contractor, does that mean, therefore, JAMS is 

implicated in any mischief that you might be involved with? 

Again, I'm going to assume the answer is, of course, it 

doesn't. The question is what to do about it in the context of 

a 2004 exam. 

I'll accept Mr. Abrams' goal here is to -- and you're 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 37

of 72
38

PG&E Corporation and Pacific Gas and Electric Company

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

sharing this notion of good cause. I'm still going to do it in 

little steps. 

Mr. Abrams, I'm not directing, in fact, I do not 

expect you to go out and serve a bunch of entities or former 

judges or retired judges or anyone else with something in the 

next couple weeks. I'm going to let Mr. Molton file a response 

by the date he said, and then I'm going to decide what to do. 

And I may decide that, perhaps, Justice Trotter should be 

expected to respond as the former trustee. But that doesn't 

mean that I'm going to say, therefore, JAMS as an entity --

again, what does it mean to say JAMS as a corporate entity if 

some other person or retired judge or a lawyer has had a 

relationship with JAMS? Does that implicate JAMS or not? 

This is Mr. Abrams trying to protect his interest as a 

claimant in this bankruptcy case. It is not the chief justice 

of the California Supreme Court deciding that the legislature 

ought to fix the world of private judging. It is deciding 

whether the interests of the Fire Victims Trust, which is the 

goal of this proceeding, are in any kind of jeopardy or need to 

be dug into more thoroughly than has happened so far. 

And I'm not prepared at this point to make a decision 

on it, but I'm just raising the question is that -- well, let 

me say this. 

Mr. Molton, I believe it would be appropriate when you 

file your response to at least answer that question through Ms. 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 38

of 72
39

PG&E Corporation and Pacific Gas and Electric Company

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

Yanni, and I do think it's appropriate for you at least to, in 

your written response, to indicate -- well, I'm going to 

assume -- I assume that your response will not be on behalf of 

Justice Trotter personally or as a former trustee, and that 

until he's directed to respond -- and I won't expect him to --

but the fact is, I might give you a heads-up. I might be 

inclined to ask Justice Trotter or direct Justice Trotter to 

respond that I think it is only Justice Trotter because he is 

the only prior trustee in this trust. We have a prior trustee 

and an existing trustee, and the existing trustee is 

represented in her capacity as trustee through counsel. 

And I would say, Mr. Molton, if Justice Trotter or any 

counsel for him were inclined to file a response by the same 

deadline, that might be constructive, but I'm not going to 

order it at this point. I'll just leave it as an open 

question. 

So I'm going to expect a response by the Fire Victim 

Trustee through Mr. Molton by October 3rd, and the matter is 

going to stand submitted at that point. If I want further 

briefing from Mr. Abrams or from anyone else, I will so advise 

the parties after I've considered the response.

Any questions, Mr. Abrams? 

MR. ABRAMS: Yes, Your Honor. I did have one 

question. 

I had three other points of order that I was hoping to 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 39

of 72
40

PG&E Corporation and Pacific Gas and Electric Company

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

bring before the Court. The first just a clarification, Your 

Honor. What is clear is that these representatives of JAMS are 

also shareholders. 

THE COURT: No, it's not clear. That's not clear to 

me. If it's clear to you, provide some competent evidence that 

it's true. 

MR. ABRAMS: So the competent evidence is that from 

Justice Trotter's own mouth, he said he's still a shareholder 

in JAMS. 

THE COURT: Okay. That's one person. 

MR. ABRAMS: But again, it's --

THE COURT: Mr. Abrams, that's one person. You 

haven't named anyone else who's a shareholder. 

MR. ABRAMS: Absolutely. Which is why I think it's 

good cause and certainly appropriate to ask if Justice Trotter 

is a shareholder, wouldn't the chairman of the board, Mr. --

who's now the appeals coordinator, also be a shareholder? 

THE COURT: Okay. That's a fair question. 

MR. ABRAMS: Who's the others? And so it's just good 

cause to ask the question. If it turns out and they say, no, 

we're not shareholders, then I agree with Your Honor. If they 

say we are shareholders, then of course, the question is to 

what degree are they acting as shareholders to try to increase 

the corporation's assets, and to what degree are they acting on 

behalf of victims and other parties that they represent within 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 40

of 72
41

PG&E Corporation and Pacific Gas and Electric Company

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

the case? 

THE COURT: Mr. Abrams, that's a fair point, and I 

believe if Mr. Trot -- Justice Trotter has -- and I think you 

have quoted as his saying, he is a shareholder, and at that 

point, I'll take that as in the record somewhere, and I've 

already asked that Justice Trotter be prepared to respond, if 

he is so inclined, and if not, I may choose to direct that he 

do so. I'm not going to require that of anyone else at this 

point.

MR. ABRAMS: I --

THE COURT: Again, I'm -- Mr. Abrams, so you 

understand, to me, it's fair game perhaps to ask of conduct of 

the trustee when he was the trustee and therefore prior --

therefore, he, as the prior trustee -- all these other people, 

I have no evidence at this point about it, and I'm not going to 

turn this into an evidentiary point at this point.

What's the second question you -- you had three points 

of order.

MR. ABRAMS: Sure. The second point, Your Honor, is 

that I appreciate that we're trying to put this, perhaps, on a 

faster track to get things filed, but I just wanted to 

understand because what's been happening recently regarding the 

motions for discovery is that there's been a very fast 

expectation from the trustee that their motions to be quickly 

decided upon and then fast tracked, and then when a motion is 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 41

of 72
42

PG&E Corporation and Pacific Gas and Electric Company

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

put forward on discovery for me, that that is then provided a 

very long time, and it seems that, perhaps, that's an effort of 

the trustee, and perhaps, now the debtor to be able to push 

this off as long as possible so that none of this information 

comes out and impacts the case.

So I just ask in future -- maybe some of this is 

because I'm unaware as a pro se claimant, but that they put --

that the trustee puts a response deadline so that myself or 

other victims or other parties that would want to respond and 

weigh in to provide the Court with more context have the 

opportunity to do so. So that's my --

THE COURT: Mr. Abrams, I'm the one that makes the 

rules on these deadlines. I gave you an opportunity to respond 

to your first motion. I did not -- and to the extent that you 

are upset that I didn't give you a response on the motions to 

seal, that was my decision. It was not the trustee's secret 

plan to cut you off, or the debtor's.

I know you believe, perhaps, the right to respond is a 

denial of due process. I don't believe that's true. Lots of 

courts around this land don't even give moving parties time to 

respond. Our district generally does, but there is no 

Constitutional right to a hearing or to even a response at this 

point. So to the extent that you feel wronged that certain 

things like decisions on sealing were decided quickly, blame 

me. Don't blame Mr. Molton or the trustee, and if I believe 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 42

of 72
43

PG&E Corporation and Pacific Gas and Electric Company

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

it's necessary to give you an opportunity to respond to what 

Mr. Molton files, I will do so, and if I disagree, then you can 

blame me if I don't give you that opportunity.

MR. ABRAMS: I appreciate it, Your Honor. It's not 

about blame. I just wanted to make that point, but I 

appreciate Your Honor's context, and I certainly appreciate 

that and will follow it.

THE COURT: Mr. Abrams --

MR. ABRAMS: I just --

THE COURT: Mr. Abrams, you're very verbose and 

prolix, and you articulate and express yourself extremely well, 

and as the old saying, if you can't say it in your opening 

brief, you don't say it. So your briefs are thorough, and it 

doesn't follow that you therefore must therefore reply to 

everything. One of the things that drives me crazy about 

lawyers is they say the same thing in their reply that they 

said in their opening brief. If you did that, I'd run out of 

paper.

MR. ABRAMS: Understood. And that's not my goal, and 

believe me, as individual, I certainly want to cut down on my 

workload, not add to it, but again, it's just in contrast to 

the larger length of time that's given, but I understood. I 

take Your Honor's point.

I did have, again, two other just minor points that I 

wanted to make sure I brought up. One, Your Honor, is that I 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 43

of 72
44

PG&E Corporation and Pacific Gas and Electric Company

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

just want to make clear because what's been happening is with 

the last preliminary hearing was that there was a preliminary 

hearing where it was stated that I do not have the opportunity 

to argue my case in the preliminary hearing, which I 

understand, but then after the preliminary hearing, it was 

stated by both Mr. Molton and within the Court order that I was 

given the opportunity to argue my case, which I wasn't, and I 

just want to make sure that I understand -- and this is for my 

own understanding, Your Honor, that I understand that this is a 

preliminary hearing, not to argue my case and that Your Honor 

will decide if I'm given an opportunity to argue my case, but I 

just don't want to have it be the case where I'm given a 

preliminary hearing where I can't argue my case, and then later 

parties are able to state, well, I had my preliminary hearing, 

and I was able to argue fully my case, which is -- which isn't 

(indiscernible)--

THE COURT: We're getting hung up on labels. You made 

a motion. I chose to have a preliminary hearing. I could have 

simply directed Mr. Molton to respond and then decide it. I 

chose because of the history, frankly, the history of your 

earlier motion, but now with the incredible breadth of this 

motion, I didn't want to have JAMS or Judges X, Y, and Z and 

all the other people you named feel that they had to do 

something under a procedure that is almost unprecedented. You 

have decided to file a thing called your 2004 motion and name 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 44

of 72
45

PG&E Corporation and Pacific Gas and Electric Company

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

all these people who have nothing to do with the Court in a 

technical sense, in a sense of active parties and didn't even 

serve them correctly.

So I was not about to start to put out rules that 

says, Judge So and So, whether it be Judge Newsome or Judge 

James or Judge -- any one of the other people that Mr. Molton 

named have to respond because I don't know that they have to 

respond. So I made the rules because of the unusual procedure 

that you took. And Mr. Abrams, that goes to the very heart of 

it, whether there's even proper to be using Rule 2004 in this 

context the way you have tried -- wished to do it on what we'll 

call the JAMS motion, much different, in my opinion, from the 

prior motion that was focused and directed or at least in the 

way that I dealt with it with the fire trustee. So --

MR. ABRAMS: I'm just -- Your Honor, I just --

THE COURT: I will leave it with that. Go ahead with 

your final point. You had one more point.

MR. ABRAMS: Thank you, Your Honor. I just, the last 

point, Your Honor, is that I want to make sure that it is --

and that I'm following this correctly, is that there was a 

protective order that was modified by the trustee, and that's 

docket 8662, and within that, they really have, in addition to 

their exculpations and other protections that they negotiated, 

have a protective order to make sure that any discovery that 

comes out cannot be used, and I certainly would look for a 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 45

of 72
46

PG&E Corporation and Pacific Gas and Electric Company

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

modification to that.

Certainly, I've stated and I believe and I hope that 

there's nothing here that reveals bad-faith actions, but if 

there are things that come out that do reveal bad-faith 

actions, I don't want to have a prior negotiated protective 

order precluding remedies that the Court may want to take or 

other courts may want to take, and so I would just ask that the 

Court consider a modification to that order and to whatever 

degree I need to research that and figure out how to do it, I 

will, but I just wanted to bring that point up as well.

THE COURT: Mr. Abrams, as you know, there are, what, 

13,000 items on this docket and counting, and I don't remember 

docket number 8662, but if it was a protective order that was 

entered some time in the past, I'm not about to do anything 

about that order until the proponents of that order and people 

impacted by that order are given an opportunity to be heard on 

the subject of it.

So the answer is if there's a protective order in 

place, it's in place, and if somebody believes there should be 

some relief from it, they should -- they need to make a proper 

motion and deal with it. Again, I don't even want to go there 

today because that raises all sorts of post-confirmation 

jurisdiction. I have no clue of the merits of what you refer 

to. I made a note in my pad here that it's 8662, but that's 

all I know about it, and it's not an action item today.

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 46

of 72
47

PG&E Corporation and Pacific Gas and Electric Company

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

We're back to the point when I get Mr. Molton's 

filing, I will review it and decide what to do next. If I 

decide to give you some relief as requested, perhaps, the next 

step will be, well, what happens after that? If I don't give 

you the relief you want, then it may be academic at least, 

unless my decision is vacated at some point going forward. So 

it's just premature for me even to speculate. You've made 

it -- you've preserved it. You've preserved your position on 

it, and it's noted.

MR. ABRAMS: And Your Honor, last point -- and I 

promise it's my last point. Just the one thing I also did just 

want to state that's clear is that the individuals that I --

that are contracted with or employed by JAMS are holding very 

central roles within this case, and so I'm not going beyond the 

case when I'm listing those individuals. Unfortunately, 

there's a long list of those peoples, all from JAMS. That 

isn't my doing. That is just a fact associated with this case, 

and my purpose of providing a context of the prior case with 

Ms. Yanni and where Mr. Skikos was involved was to be able to 

demonstrate when one corporation has an inordinate role behind 

closed doors with confidentiality agreements. And as we've 

seen in the Girardi case, unfortunately that creates an 

environment where bad things can happen.

And so it was to provide that context and to really 

try to list those things, and within the redacted agreements 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 47

of 72
48

PG&E Corporation and Pacific Gas and Electric Company

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

that were filed with the Court, I should also note that 

completely redacted from that are who's doing the mediation. 

So we don't even know even beyond this if there are other 

mediators that are core to this case who are from JAMS, Inc. --

THE COURT: Wait. What are you referring to? What 

mediator is being -- I mean, what document redacts out who was 

a mediator?

MR. ABRAMS: So in the derivative cases, Your Honor, 

where they provided the agreements around the derivative cases, 

there's a section called --

THE COURT: You mean, in the retention agreements.

MR. ABRAMS: In the retention agreements. I'm sorry, 

Your Honor, yes. There is a whole section about mediation, and 

all of that is redacted. Only the title of that section is 

kept in. So again, I don't know what's behind the black marks. 

I don't -- and again, it's just demonstrating that JAMS, Inc., 

has had an inordinate role within this case, and given the 

patterns that were identified within my motion --

THE COURT: But how do you know --

MR. ABRAMS: -- that's what I'm relying on.

THE COURT: How do you know that JAMS, Inc., is in the 

redacted language?

MR. ABRAMS: Like I said, Your Honor, I don't know, 

but we know that JAMS, Inc., is covering I think it was close 

to twenty-five other key points within this case, and so --

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 48

of 72
49

PG&E Corporation and Pacific Gas and Electric Company

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

THE COURT: But your pending --

MR. ABRAMS: -- it's not out of the ordinary --

THE COURT: Mr. Abrams?

MR. ABRAMS: Yeah.

THE COURT: First of all, I reviewed the unredacted 

documents. So you can, again, blame it on me because I did, I 

reviewed every word of every redacted document, and I made a 

decision that they would stay redacted, and so that's one 

thing.

Secondly, you paint with a very broad brush, and I am 

not prepared on your say-so to paint or taint -- paint or 

taint, pick your word, JAMS or anyone else with the sins of Mr. 

Girardi and what has come out in that case. Simply not --

we're not going there, and that is -- I agree with you if 

somehow this Fire Victim Trust, or through any of its 

representatives, has been tainted by misconduct, then there are 

consequences, perhaps. I agree with you. But I'm not about to 

say, Mr. Girardi and all of his failures, his personal, 

disastrous occasion for so many people, is not going to be 

imported and infused into this case because somehow Justice 

Trotter, who was selected in this case was also involved in 

some matter that involved Mr. Girardi, that the LA Times wants 

to make -- draw inferences about. I am not drawing inferences 

about it.

MR. ABRAMS: I'm not drawing inferences either --

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 49

of 72
50

PG&E Corporation and Pacific Gas and Electric Company

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

THE COURT: Okay. Well you're --

MR. ABRAMS: I'm just --

THE COURT: You're painting a picture that I haven't 

painted, but I'm going to leave it at that. You've made your 

comments and I've noted it and I will do this in the steps that 

I agreed to with you and assured you that I'm going to go 

there.

Mr. French, did you have a final comment?

MR. FRENCH: I just wanted to clarify my position. So 

my thought was that the names, aside from Justice Trotter's, in 

the motion were examples of some of the issues with JAMS. I 

was not imagining necessarily doing some investigation on each 

of those individuals. My thought was to have the Trust report 

back what its relationships are with JAMS or people who have 

these relationships with JAMS. So just so that we understand 

where those connections are, so that then, if there's a need 

for further analysis based upon that, that we have the 

information necessary to go forward.

THE COURT: Mr. --

MR. FRENCH: Just understanding those relationships 

is --

THE COURT: Okay. Mr. Molton, to the extent that 

you're able and in a position to clarify the trust's role, that 

would be helpful. I'll just leave it to you to make what you 

believe is an appropriate disclosure. At this point, I'm not 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 50

of 72
51

PG&E Corporation and Pacific Gas and Electric Company

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

going to order it. Justice Trotter has been quoted as saying 

he is or was a shareholder. To the extent that he is or was, 

it might be helpful, and if Ms. Yanni, I know had some prior, 

if not current, affiliation with JAMS, but she can certainly 

make a disclosure and should make a disclosure in this context 

for her as the Fire Victim Trustee, but I'll leave it at that 

at this point.

MR. MOLTON: Judge, instead of speaking off the cuff, 

what I'd like to do is save those for our response so we're 

completely accurate, but if I might, I'd like to just say a few 

things in closing, if I might, Your Honor?

THE COURT: Yes, sir. Yes, sir.

MR. MOLTON: I want to reiterate because I think it's 

important because a lot of things have been said that aren't 

based on evidence or proof or even credible allegations. 

There's not a single allegation in the papers submitted that 

anything wrong has actually occurred at the Trust or in 

connection with the Trust.

THE COURT: Right.

MR. MOLTON: As Your Honor knows, every April, we file 

an audited financial statement with an opinion from an auditor, 

BDO, once a year, which sets forth the trust finances and 

claims history for that year.

Number 2, what we have here -- one example, and we'll 

deal with this more -- Mr. Abrams likes to take what he reads 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 51

of 72
52

PG&E Corporation and Pacific Gas and Electric Company

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

in the newspaper and put it in a fashion that can be used here. 

He cites the LA Times, and he basically misquotes that article 

in his pleading, page 2 of 39 at 12766, he says that discovery 

request should be expanded "to ensure that the multifaceted 

victimization of injured people referred to by the chief 

justice" -- and I'm going to butcher her name. So I'm not 

going to say it, but her name is there -- "regarding the 

influence of JAMS has not undermined the well-intentioned 

efforts of this court to ensure fair and just outcomes." The 

actual quote, Your Honor, the actual quote from that paper was 

from the chief judge in the article cited by Mr. Abrams has 

nothing to do with JAMS or anyone involved with the Fire Victim 

Trust. It says, the chief justice lamented the multifaceted 

victimization of injured people in the Girardi case. So that's 

what we're dealing with here, Judge. We're dealing with all of 

these innuendos, and arguably, misstatements.

Number two, Judge -- so there's no evidence or 

allegation of wrongdoing at the Trust. Number two -- and you 

know, we'll deal with this in our response, but I think it's a 

good example, Mr. Abrams cites to Mr. Boserup, who is the 

appeals officer, what does an appeal officer do? Well, if you 

read our constitutional documents, the appeal officer reviews 

and assigns an appeal to either a complex or noncomplex panel. 

That's it. Not involved in claims administration. Then, 

there's a random of neutrals, of a neutral, as a result of that 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 52

of 72
53

PG&E Corporation and Pacific Gas and Electric Company

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

categorization either to the complex or noncomplex panel. And 

many of what Mr. Abrams refers to as the panel of neutrals 

refers to appeals.

I want to give Your Honor -- because we're very proud 

of the work we do, and will put it in our pleading -- Judge, 

we've had 36,000 submitted claims questionnaires to date. 

36,000. We've had -- eighty percent of those have had 

determination notices. I know that Justice Trotter, when he 

was trustee, and Ms. Yanni now, is fully engaged in pushing 

that number up by year-end as well. It's important to note 

that of that eighty percent of the 36,000, less than two-thirds 

of a percent -- I'm going to say that again. Two-thirds of a 

percent or .67 percent have invoked an appeal. 99.33 percent 

of all determinations notices have been resolved without 

appeal. That means -- and I'm going to cut more to the 

chase -- that's 155 appeals, Judge, that have gone to the JAMS 

neutrals in any event. So that's a little bit of what we're 

having to deal with in terms of broad allegations that have 

nothing to do with the facts.

Judge, with respect to the protective order, I agree. 

I don't know what Mr. Abrams is referring to. We'll take a 

look at it. The low number of it suggests to me that it might 

even precede the existence of the Trust, the low docket entry 

number, but we'll take a look at it. And again, I want to 

reiterate, Your Honor, that we're looking forward to 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 53

of 72
54

PG&E Corporation and Pacific Gas and Electric Company

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

responding, and we'll respond in-kind and address the issues 

that Your Honor suggested we do so.

THE COURT: Okay.

MR. ABRAMS: Your Honor, there was a few allegations 

there that I just would like to be able to have respond to that 

Mr. Molton put forward.

THE COURT: Go ahead.

MR. ABRAMS: So first of all, Mr. Molton's 

characterization that there was an audit done so that's all the 

financial reporting we need to do, I think is very 

disingenuous. The fact of the matter is that my prior motion 

stated that it is very important for victims to understand the 

costs that are being incurred by the Trust, the financial 

incentive structures, all of which were redacted. I'm not 

blaming anyone, but then to say, look, you know, we've fully 

disclosed all the financial information that we need to, I 

think is inappropriate.

The second point, Your Honor, is that Mr. Molton 

listed a number of different folks that he feels should have 

nothing to do with this, including the appeals officer and the 

people that are sitting on this complex or simple panel for 

appeals. Every single one of them comes from JAMS, Inc.

THE COURT: How do you know that? How do you know 

that?

MR. ABRAMS: Because I looked at --

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 54

of 72
55

PG&E Corporation and Pacific Gas and Electric Company

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

THE COURT: How do you know that? First of all, what 

does come from mean?

MR. ABRAMS: That they are employed by or contracted 

with JAMS, Inc. --

THE COURT: Okay.

MR. ABRAMS: -- all of them.

THE COURT: Contracted with is not the same as comes 

from, but okay. Let's suppose --

MR. ABRAMS: I --

THE COURT: -- appeal -- let's suppose Appeal Officer 

X also has done work as a JAMS neutral, therefore, what? What 

does that have to do with financial incentives? If the 

litigants have availed themselves to the appeal and the appeal 

was assigned to retired Judge X, and retired Judge X decides 

the merits of the appeal, what's the prob -- what's wrong with 

that?

MR. ABRAMS: So Your Honor --

THE COURT: The fact that that person used to -- has 

also a relationship with JAMS, therefore, what?

MR. ABRAMS: Those are great questions, Your Honor, 

and that's why there's good cause for discovery. If Your 

Honor, all these people are all shareholders and they are all 

employees of JAMS working in their capacity as employees of 

JAMS, then of course they have the goal as a shareholder to 

increase return for the corporation. Those interests may be 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 55

of 72
56

PG&E Corporation and Pacific Gas and Electric Company

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

very adverse to the interest of victims within this case and 

the equitable patterns associated with the trustee --

THE COURT: What if --

MR. ABRAMS: -- neutral position of them, and so all 

of that is relevant with the proper discovery, but just saying, 

look, we're not going to provide any of that information and we 

want you just to assume that none of them are shareholders when 

Justice Trotter stated specifically that he was, I don't think 

is a prudent path either.

THE COURT: Okay.

MR. ABRAMS: And the last -- and also, Your Honor, the 

point of this as well is every victim is subjected to this 

process to put money in their pocket to rebuild their house, to 

get compensation for their lives, and I know Your Honor knows 

that, but this is essential to the dollars that are in victims' 

pockets, and there are very few victims, as the Court knows and 

as Mr. Molton knows, that were provided judicial review. So 

even if they proved it --

THE COURT: Mr. Abrams --

MR. ABRAMS: -- that --

THE COURT: -- I don't want to revisit that because 

they all were given a chance, and five of them chose to. It 

wasn't something arbitrary. It wasn't the luck of the draw. 

Those five people came -- they squawked, and they were heard. 

So what's the -- therefore, what?

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 56

of 72
57

PG&E Corporation and Pacific Gas and Electric Company

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

MR. ABRAMS: Your Honor, I --

THE COURT: What do you want me to do about that?

MR. ABRAMS: Well, one of the remedies that I think 

should be considered by the Court -- and I'll save this for my 

reply -- is that given all these things that the Trust isn't 

going to be forthcoming and fully disclose what all these 

financial incentives are for these people in these appeals 

process, then victims should have a judicial review process, so 

that if they have perceived injustices with their settlement, 

that they can also come to the Court, and say, look, Your 

Honor, this was unjustly settled. I deserve a million dollars. 

These appeals coordinators only provided 500,000 dollars, and 

here's that justification, but to fact --

THE COURT: Wait a minute --

MR. ABRAMS: -- to have this unequal system --

THE COURT: -- Mr. Abrams --

MR. ABRAMS: -- where these appeals -- yes, Your 

Honor?

THE COURT: Mr. Abrams, the appeals coordinator sent 

the matter to an appeal. The appeals coordinator from what I'm 

told didn't make the decision. So if --

MR. ABRAMS: But --

THE COURT: -- the appeal coordinator says here, your 

appeal is going over to so and so --

MR. ABRAMS: But it's the same -- but again, Your 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 57

of 72
58

PG&E Corporation and Pacific Gas and Electric Company

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

Honor, to whatever extent this is the same corporation and that 

these neutrals have conflicting duties to JAMS, Inc., that are 

interfering with their neutral capacity and/or might be 

favoring certain attorneys who are going to give them future 

work in future cases where they could hire JAMS and other 

attorneys who are less prominent, that they don't care whether 

they're going to -- that won't have the ability to rehire JAMS 

in a future case, all of these are biases that should be 

understood.

The degree to which one particular neutral has acted 

on those biases is a different story, and they may or may not 

have acted on those biases, but until we know that information, 

we can't come to a conclusion on these matters. Again, if 

they're not going to be forthcoming with this information, 

then, yes. I do feel that opening up judicial review is really 

important to do. I hope it -- I hope that we are given 

information that shows that these neutrals are indeed neutral.

THE COURT: Okay. Your petition is noted.

MR. MOLTON: May I --

THE COURT: No --

MR. MOLTON: Your Honor --

THE COURT: I'm going to -- that's enough. I'm going 

around in circles here. I'm going to stick with the schedule 

that we have. I'll wait to hear from Mr. Molton, and Mr. 

French and Mr. Abrams, you'll be -- you'll hear my decision at 

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 58

of 72
59

PG&E Corporation and Pacific Gas and Electric Company

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

that point, and as I say, it might very well invite a reply or 

further information. I'm going to wait and see what the 

trustee provides for all of us. So with that, I'm going to 

include the hearing, and thank you all for your time.

IN UNISON: Thank you, Your Honor.

THE COURT: And I'm going to -- Ms. Parada, I'm going 

to turn off my camera, but not log off because after all the 

attendees exit, I want to talk to you and the rest of the staff 

on to. Thank you all for your time.

THE CLERK: Yes, Your Honor.

MR. ABRAMS: Thank you, Judge.

(Whereupon these proceedings were concluded at 11:29 AM)

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 59

of 72
60

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

C E R T I F I C A T I O N

I, Ellen S. Kolman, certify that the foregoing transcript is a 

true and accurate record of the proceedings.

________________________________________ 

/s/ ELLEN S. KOLMAN, CET-568

eScribers

7227 N. 16th Street, Suite #207

Phoenix, AZ 85020

Date: September 14, 2022

Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 60

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

A

ability (2)

 18:3;58:7

able (6)

 42:3;44:14,15;47:19;

 50:23;54:5

Abrams (82)

 23:24;24:1,1;25:14;

 26:3,23;27:1,14;30:9;

 31:18;32:12;33:5,14,

 17;34:4,5,6,6,14,16;

 35:19;38:3,14;39:20,

 22,23;40:7,11,12,14,

 19;41:2,10,11,19;

 42:12;43:4,8,9,10,19;

 45:9,15,18;46:11;

 47:10;48:8,12,20,23;

 49:2,3,4,25;50:2;

 51:25;52:11,20;53:2,

 21;54:4,8,25;55:3,6,9,

 17,20;56:4,11,19,20;

 57:1,3,15,16,17,19,22,

 25;58:25;59:11

Abrams' (9)

 23:23;24:18;26:14;

 27:13;28:1,7;29:23;

 30:1;37:25

absolutely (2)

 14:13;40:14

academic (1)

 47:5

accept (3)

 13:22;16:12;37:25

access (6)

 5:12;12:2,15;14:12;

 20:1,6

according (1)

 27:1

accounting (1)

 36:14

accurate (1)

 51:10

accusing (2)

 34:17;35:12

acknowledged (1)

 4:17

acted (2)

 58:10,12

acting (3)

 26:8;40:23,24

action (1)

 46:25

actions (2)

 46:3,5

active (1)

 45:2

activity (1)

 32:10

actual (2)

 52:10,10

actually (3)

 29:8,11;51:17

ad (1)

 10:24

add (2)

 12:17;43:21

Addington (44)

 3:12;4:8;5:9;6:8,9,

 20,25;7:4,7,10,17;9:9;

 11:16,17,19,21;13:2,

 14,15;14:8,12,19,23;

 15:8,14,20,24;16:9,15,

 24;17:7,18,21;18:1,5,9,

 21,22,24;19:5,6;20:6,

 16;23:1

Addington's (2)

 6:14;18:15

addition (2)

 26:18;45:22

additional (1)

 9:13

address (1)

 54:1

administration (1)

 52:24

adopted (1)

 25:21

advantage (1)

 20:17

adversary (1)

 9:3

adverse (1)

 56:1

advise (1)

 39:20

advisement (1)

 33:3

advocate (1)

 7:7

affiliation (1)

 51:4

again (31)

 4:12;6:6,10;9:21;

 10:2,17;12:8;16:4,20;

 17:5,24;18:7,17;19:10;

 25:1;30:5;35:12;37:22;

 38:11;40:11;41:11;

 43:21,24;46:21;48:15,

 16;49:6;53:12,24;

 57:25;58:13

against (4)

 6:23;15:9;19:7;

 28:21

ago (5)

 4:25;5:1;13:15,24;

 14:11

agree (14)

 3:24;8:9;9:24;12:8;

 16:21,23;33:6;35:19;

 36:10,13;40:21;49:14,

 17;53:20

agreed (1)

 50:6

agreeing (1)

 23:12

agreement (3)

 17:18;30:23;31:11

agreements (5)

 47:21,25;48:9,11,12

ahead (4)

 25:1;33:4;45:16;

 54:7

al (1)

 24:18

allegation (2)

 51:16;52:18

allegations (5)

 27:9;28:20;51:15;

 53:18;54:4

allowed (1)

 6:8

allowing (1)

 32:7

almost (1)

 44:24

alternative (1)

 14:14

alternatively (1)

 20:17

although (1)

 4:20

always (1)

 25:8

amend (1)

 12:1

amended (4)

 4:5,15;6:8;8:12

among (1)

 37:6

amount (2)

 7:16,17

analysis (1)

 50:17

and/or (1)

 58:3

Angeles (1)

 28:22

apart (1)

 18:5

appeal (13)

 52:21,22,23;53:13,

 15;55:10,10,13,13,15;

 57:20,23,24

appeals (13)

 27:4,4;40:17;52:21;

 53:3,16;54:20,22;57:7,

 12,17,19,20

appearance (5)

 3:10;23:25;24:14;

 25:9;29:22

appeared (1)

 25:24

appearing (1)

 24:2

Apple (1)

 25:7

application (1)

 31:6

applies (1)

 8:10

apply (1)

 8:10

appointed (1)

 29:8

appreciate (4)

 41:20;43:4,6,6

appropriate (5)

 30:13;38:24;39:1;

 40:15;50:25

approval (1)

 31:20

approved (1)

 14:2

April (1)

 51:20

arbitrary (1)

 56:23

arguably (2)

 27:1;52:16

argue (6)

 44:4,7,10,11,13,15

argument (2)

 9:15;20:4

arms (2)

 11:24;14:6

around (5)

 11:24;14:6;42:20;

 48:9;58:23

article (4)

 28:22;36:3;52:2,11

articles (1)

 27:10

articulate (1)

 43:11

articulated (1)

 9:1

aside (3)

 8:1;31:1;50:10

aspects (1)

 31:10

assert (2)

 7:20,21

asserting (1)

 19:7

assets (2)

 13:8;40:24

assigned (1)

 55:14

assigns (1)

 52:23

associated (4)

 33:24,25;47:17;56:2

assume (11)

 11:1;20:14;23:3;

 30:16;34:8;35:24;37:1,

 22;39:3,3;56:7

assuming (3)

 31:12,14;37:14

assured (1)

 50:6

attendees (1)

 59:8

attorney (1)

 33:18

attorneys (2)

 58:4,6

attorneys' (1)

 13:18

audio (1)

 14:20

audit (1)

 54:9

audited (1)

 51:21

auditor (1)

 51:21

authority (1)

 14:2

authorize (1)

 29:12

available (7)

 9:2;10:4;12:7;19:16;

 20:15;22:7;30:5

availed (1)

 55:13

avid (1)

 5:6

avoid (1)

 15:22

aware (3)

 10:20;13:25;26:9

away (2)

 14:16;20:22

B

back (12)

 4:12,18;6:6,7,21;

 7:25;9:9;21:24;22:2;

 25:1;47:1;50:14

backwards (1)

 6:18

backyard (1)

 14:3

bad (2)

 34:10;47:23

bad-faith (2)

 46:3,4

Bagorio (1)

 24:18

bank (5)

 34:24,25;35:1,3,6

bankruptcy (10)

 15:6,14,17;16:1,25;

 17:24,25;34:13;36:5;

 38:15

banks (1)

 35:2

based (6)

 11:6;27:7,10;28:11;

 50:17;51:15

basically (1)

 52:2

Min-U-Script® eScribers, LLC

www.escribers.net

(1) ability - basically Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 61

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

basics (1)

 21:20

basis (3)

 15:8;34:18;37:3

BDO (1)

 51:22

beat (1)

 21:1

becomes (1)

 20:18

behalf (4)

 3:15;26:8;39:3;

 40:25

behavior (2)

 35:20,22

behind (2)

 47:20;48:15

believes (2)

 19:15;46:19

Bend (1)

 20:25

Benvenutti (1)

 3:15

best (3)

 5:7;33:10,19

better (1)

 25:18

beyond (5)

 27:17;32:1;36:2;

 47:14;48:3

biases (3)

 58:8,11,12

big (1)

 33:2

billion (1)

 35:4

bit (2)

 8:6;53:17

black (1)

 48:15

blah (3)

 8:15,15,15

blame (5)

 42:24,25;43:3,5;49:6

blaming (1)

 54:15

board (1)

 40:16

body (1)

 30:7

Boserup (2)

 27:3;52:20

Both (2)

 26:22;44:6

breadth (2)

 36:10;44:21

brief (2)

 43:13,17

briefing (1)

 39:20

briefs (1)

 43:13

bring (7)

 3:8;9:7,8;24:9;31:3;

 40:1;46:10

bringing (1)

 30:10

broad (3)

 27:15;49:10;53:18

broader (3)

 25:19;30:10;34:1

broken (1)

 17:5

brokers (1)

 37:16

brought (1)

 43:25

Brown (1)

 25:11

brush (1)

 49:10

bucks (1)

 9:10

build (1)

 15:2

bunch (1)

 38:4

burden (3)

 5:9;19:24;20:19

butcher (1)

 52:6

C

Cal (1)

 21:1

calendar (1)

 4:1

CALIFORNIA (2)

 3:1;38:16

Call (9)

 3:4;18:11;22:23;

 25:18;29:23;30:1;34:7,

 7;45:12

called (3)

 21:15;44:25;48:10

Calling (1)

 3:7

calls (2)

 18:1;21:15

came (3)

 4:12;11:11;56:24

camera (1)

 59:7

camp (2)

 29:22,23

Can (27)

 3:10;4:2;7:1,1;8:5;

 10:18;11:14;13:7;15:3;

 17:17;19:25;20:2,16;

 24:21,22;25:4;27:10;

 28:13;30:16;33:19;

 36:21;43:2;47:23;49:6;

 51:4;52:1;57:10

capacity (7)

 25:13;28:17;29:2,4;

 39:11;55:23;58:3

care (1)

 58:6

Carvill (1)

 27:2

case (45)

 9:9,13,19;10:16;

 12:4,13,14,14;13:15,

 23;15:6;16:1;22:14;

 26:21,22;29:12;30:8;

 31:19;35:8,24;36:17;

 38:15;41:1;42:5;44:4,

 7,10,11,12,13,15;

 47:14,15,17,18,22;

 48:4,17,25;49:13,20,

 21;52:14;56:1;58:8

cases (4)

 26:15;48:8,9;58:5

catastrophe (1)

 34:13

catch (1)

 10:14

categories (1)

 36:19

categorization (1)

 53:1

Cathy (3)

 25:13;26:19;28:17

cause (13)

 27:8;34:18,20;35:5,

 8,11,15,20;36:7;38:1;

 40:15,20;55:21

central (1)

 47:14

certain (6)

 7:16,17;16:25;31:10;

 42:23;58:4

certainly (14)

 6:11;28:10;33:6,8,

 20;34:19;35:7;36:1;

 40:15;43:6,20;45:25;

 46:2;51:4

certified (1)

 33:21

cetera (2)

 5:10,10

chairman (1)

 40:16

chance (3)

 29:24;32:24;56:22

characterization (1)

 54:9

charge (2)

 35:3,3

chase (1)

 53:16

chief (4)

 38:15;52:5,11,13

choice (2)

 15:3;19:21

choose (1)

 41:7

chose (3)

 44:18,20;56:22

circles (1)

 58:23

cited (1)

 52:11

cites (2)

 52:2,20

civil (1)

 18:10

claim (40)

 4:5,15;6:1,8,9,12,19;

 7:20,21;8:12,13,14;9:4,

 4;11:10,16,21,22,22,

 23,25;12:1,23;14:20;

 15:1,5,9,21,23;16:25;

 17:6;18:6,21,22;19:7,

 19,22;21:16;22:21;

 23:1

claimant (4)

 31:19,19;38:15;42:7

claims (9)

 10:8,24;11:5;13:15;

 19:21;27:4;51:23;

 52:24;53:6

clarification (1)

 40:1

clarify (3)

 28:13;50:9,23

class (1)

 31:17

clear (12)

 25:20;26:1;28:2;

 30:2;34:17;36:4;40:2,

 4,4,5;44:1;47:12

clearly (1)

 28:6

CLERK (9)

 3:5;22:7,10;24:4,8,

 11,23;37:9;59:10

client (12)

 5:14,23;12:7,21;

 14:1,4;16:16;19:24;

 21:12;26:7,10;32:13

close (1)

 48:24

closed (1)

 47:21

closing (1)

 51:11

clue (2)

 26:7;46:23

co-counsel (1)

 23:19

coincidence (1)

 31:23

coincides (1)

 31:23

coming (1)

 30:25

comment (2)

 8:8;50:8

comments (3)

 21:11;30:12;50:5

commit (1)

 10:11

company (3)

 10:15,21;11:1

compelled (1)

 3:24

compensation (2)

 19:7;56:14

competent (3)

 17:12;40:5,7

complain (1)

 9:10

complete (1)

 16:14

completely (3)

 13:13;48:2;51:10

complex (4)

 31:15;52:23;53:1;

 54:21

compliment (1)

 23:12

comply (1)

 19:1

concern (2)

 26:23;28:22

conclude (1)

 30:12

concluded (1)

 59:12

conclusion (1)

 58:13

condition (1)

 18:15

conduct (1)

 41:12

confer (1)

 17:17

conference (1)

 23:4

conferred (1)

 12:21

confident (1)

 13:4

confidentiality (1)

 47:21

conflating (2)

 16:21,23

conflicting (1)

 58:2

confusion (1)

 15:7

connection (1)

 51:18

connections (1)

 50:16

consensual (2)

 19:14;20:12

consensually (1)

 20:12

consequences (1)

 49:17

consider (2)

 20:25;46:8

Min-U-Script® eScribers, LLC

www.escribers.net

(2) basics - consider Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 62

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

considered (3)

 29:3;39:21;57:4

consistent (1)

 14:25

Constitutional (2)

 42:22;52:22

constructive (3)

 8:2;10:6;39:14

consummation (1)

 31:21

contacted (2)

 4:4;14:14

contested (8)

 4:14,22,23;5:11,14;

 15:23;19:23;22:21

context (7)

 37:23;42:10;43:6;

 45:11;47:18,24;51:5

continuing (1)

 23:1

contract (2)

 36:22;37:4

contracted (3)

 47:13;55:3,7

contractor (3)

 17:8;37:18,20

contractors (2)

 37:15,17

contracts (1)

 36:16

contractual (1)

 36:15

contrast (1)

 43:21

converting (1)

 13:5

cooperate (3)

 5:12,24;20:11

coordinates (1)

 10:3

coordinator (4)

 40:17;57:19,20,23

coordinators (1)

 57:12

core (1)

 48:4

corporate (1)

 38:11

Corporation (4)

 3:7;47:20;55:25;

 58:1

corporation's (1)

 40:24

corrected (1)

 33:20

correcting (1)

 33:20

corrections (2)

 14:24,25

correctly (3)

 21:15;45:3,20

costs (1)

 54:13

counsel (10)

 3:8,12;10:4;17:12;

 20:6,16;25:23;29:5;

 39:11,13

counting (1)

 46:12

couple (2)

 10:18;38:6

course (8)

 9:4;26:23;29:4;

 33:25;35:5;37:22;

 40:22;55:24

Court (142)

 3:4,5,9,13,16;6:4;

 7:6,14;8:8,25;10:1,11,

 15,23;11:8,15;13:9,11;

 14:22;15:13,16;16:11,

 14,20;17:21;18:17,23;

 20:25;21:6,9,22;22:1,9,

 12,14,17;23:10,14,18,

 21,23;24:2,6,10,12,20,

 24;25:5,9,14;27:19;

 28:13,19,25;29:11;

 30:7,22,25;31:4,10,12,

 14,15,16;32:1,5,12;

 33:9,12,15,19;34:3,4,6,

 15;35:14,14,16,22,24;

 36:2,9,21;37:8;38:16;

 40:1,4,10,12,18;41:2,

 11;42:10,12;43:8,10;

 44:6,17;45:1,16;46:6,8,

 11;48:1,5,11,19,21;

 49:1,3,5;50:1,3,19,22;

 51:12,19;52:9;54:3,7,

 23;55:1,5,7,10,18;56:3,

 10,16,19,21;57:2,4,10,

 14,16,19,23;58:18,20,

 22;59:6

court-appointed (1)

 26:21

courtesy (1)

 5:3

courts (2)

 42:20;46:7

covering (1)

 48:24

crazy (1)

 43:15

creates (1)

 47:22

credible (1)

 51:15

creditors (1)

 24:18

crime (2)

 34:17;35:12

criticize (2)

 7:10,10

cuff (1)

 51:8

current (5)

 29:4;31:22;32:13;

 35:8;51:4

cut (3)

 42:17;43:20;53:15

D

damage (3)

 10:8;16:24;19:7

damages (8)

 9:13;11:20;13:16,18,

 18;15:9;16:2;18:6

Dame (2)

 21:1,3

data (1)

 37:9

date (19)

 5:4,4,25;14:14;22:3,

 7;28:11;30:19,19,20,

 21;31:7,23;32:1,6,14;

 33:1;38:7;53:6

dates (2)

 4:1;22:4

David (1)

 25:11

Day (2)

 4:1;18:24

days (3)

 12:10,10;22:2

deadline (3)

 4:5;39:14;42:8

deadlines (3)

 9:23;23:3;42:13

deal (7)

 21:24;27:25;33:2;

 46:21;51:25;52:19;

 53:18

dealing (2)

 52:15,15

dealt (3)

 11:20;30:11;45:14

debate (1)

 26:2

debtor (3)

 4:7;31:17;42:3

debtors (2)

 3:15;6:7

debtors' (1)

 4:21

debtor's (1)

 42:17

decide (8)

 32:19;33:3;38:7,8;

 44:11,19;47:2,3

decided (3)

 41:25;42:24;44:25

decides (1)

 55:14

deciding (2)

 38:16,17

decision (7)

 30:6;38:21;42:16;

 47:6;49:8;57:21;58:25

decisions (1)

 42:24

defending (1)

 13:5

defensive (1)

 13:13

defines (1)

 27:15

degree (4)

 40:23,24;46:9;58:10

demand (1)

 14:12

demonstrate (2)

 35:14;47:20

demonstrated (4)

 32:17;33:25;34:3,7

demonstrating (2)

 34:20;48:16

denial (1)

 42:19

Dennis (1)

 3:6

depart (1)

 30:3

derivative (2)

 48:8,9

derived (1)

 28:21

deserve (1)

 57:11

desires (2)

 18:15;20:9

determination (2)

 34:11;53:8

determinations (1)

 53:14

determine (1)

 7:2

die (1)

 31:3

difference (1)

 15:10

different (6)

 7:23;36:5,19;45:12;

 54:19;58:11

dig (1)

 7:18

direct (2)

 39:7;41:7

directed (5)

 25:15;26:14;39:5;

 44:19;45:13

directing (1)

 38:3

directive (1)

 28:1

director (1)

 30:21

disagree (1)

 43:2

disaster (1)

 35:25

disastrous (1)

 49:19

disclose (1)

 57:6

disclosed (2)

 31:8;54:16

disclosure (5)

 30:21;37:6;50:25;

 51:5,5

discoverable (1)

 36:20

discovery (33)

 5:15,23;6:23;7:1,3,4;

 9:23;12:4,16;13:6,14;

 17:1,4,9,11;19:11,25;

 20:18,18,20;21:18;

 22:20;27:13,16;30:1;

 31:22;35:15;41:23;

 42:1;45:24;52:3;55:21;

 56:5

discuss (1)

 7:2

disingenuous (1)

 54:11

dispositive (1)

 22:22

dispute (5)

 15:14;18:5;19:19;

 20:5,8

disputes (2)

 17:11;19:11

district (3)

 30:7;31:15;42:21

docket (4)

 45:22;46:12,13;

 53:23

document (3)

 27:17;48:6;49:7

documents (2)

 49:6;52:22

dollars (10)

 6:10;11:17,22;16:16,

 17;19:22;35:4;56:15;

 57:11,12

dominant (1)

 15:19

done (12)

 10:16;16:7;17:9,23;

 20:5,16;31:22;33:7;

 34:10;37:12;54:9;

 55:11

doors (1)

 47:21

down (2)

 9:18;43:20

drag (2)

 14:19;16:9

draw (2)

 49:23;56:23

drawing (2)

 49:23,25

drawn-out (1)

 13:6

drives (1)

 43:15

due (1)

Min-U-Script® eScribers, LLC

www.escribers.net

(3) considered - due Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 63

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

 42:19

dug (1)

 38:20

during (1)

 29:11

duties (1)

 58:2

dutifully (2)

 4:15,15

duty (1)

 21:24

Dwayne (1)

 3:12

E

earlier (3)

 23:12;33:2;44:21

early (2)

 4:4,16

easement (6)

 7:15;11:18;15:5;

 18:2,13;19:2

easier (1)

 12:25

efficient (2)

 12:16;13:8

effort (3)

 11:2;21:14;42:2

efforts (1)

 52:9

eighteen (1)

 3:22

eighty (2)

 53:7,11

either (9)

 22:18,20,21;28:3;

 29:13;49:25;52:23;

 53:1;56:9

else (7)

 23:15;24:7;38:5;

 39:20;40:13;41:8;

 49:12

elsewhere (1)

 37:16

email (1)

 33:14

employed (2)

 47:13;55:3

employees (3)

 37:7;55:23,23

end (3)

 9:6;18:23;37:2

engage (3)

 5:15,23;13:5

engaged (1)

 53:9

engineer (1)

 18:10

engineering (4)

 4:10;14:2;16:7;17:7

enjoyed (1)

 11:4

enough (6)

 11:15;17:10,10,16;

 21:7;58:22

ensure (2)

 52:4,9

entered (1)

 46:14

entire (1)

 3:25

entities (2)

 27:18;38:4

entitled (5)

 8:6;12:15;16:1;17:4;

 19:6

entity (4)

 34:9;37:13;38:10,11

entry (1)

 53:23

environment (1)

 47:23

equitable (1)

 56:2

essential (1)

 56:15

established (1)

 34:11

estate (1)

 37:16

estimated (1)

 6:9

et (3)

 5:10,10;24:18

Eugene (1)

 20:23

even (19)

 11:24,24;15:24;

 17:24;25:25;27:15;

 29:13;32:17;42:20,22;

 45:2,10;46:21;47:7;

 48:3,3;51:15;53:23;

 56:18

evening (1)

 3:18

event (1)

 53:17

events (1)

 28:22

everyone (1)

 33:11

evidence (6)

 20:1;40:5,7;41:15;

 51:15;52:17

evidentiary (1)

 41:16

exactly (3)

 17:18;18:9;27:22

exam (1)

 37:24

example (4)

 34:24;37:8;51:24;

 52:20

examples (1)

 50:11

except (2)

 32:19;34:12

exchange (1)

 19:14

exchanges (1)

 4:20

exciting (1)

 14:18

exculpations (1)

 45:23

excuse (1)

 34:6

exist (1)

 36:16

existence (1)

 53:23

existing (2)

 39:10,10

exit (1)

 59:8

expanded (1)

 52:4

expect (6)

 17:12;19:13;25:23;

 38:4;39:5,17

expectation (1)

 41:24

expected (3)

 28:3,10;38:9

expecting (1)

 17:3

expedition (1)

 14:5

expense (2)

 15:25;20:15

experience (2)

 30:11;37:15

experienced (2)

 7:8,11

explain (2)

 3:23;5:10

explore (1)

 10:9

express (1)

 43:11

extension (1)

 23:13

extent (9)

 16:24;20:11;25:24;

 30:4;42:14,23;50:22;

 51:2;58:1

extremely (1)

 43:11

F

facilitate (1)

 20:12

fact (11)

 12:18;19:20;27:7,9;

 37:11;38:3;39:6;47:17;

 54:11;55:18;57:13

facts (5)

 8:16,24;9:7,8;53:19

failure (1)

 16:15

failures (1)

 49:18

fair (5)

 27:19;40:18;41:2,12;

 52:9

faith (4)

 13:1;14:20;21:14;

 35:10

far (4)

 8:7;11:6;12:25;

 38:20

fashion (1)

 52:1

fast (2)

 41:23,25

faster (1)

 41:21

favor (1)

 6:23

favoring (1)

 58:4

federal (1)

 19:12

feel (4)

 35:7;42:23;44:23;

 58:15

feeling (1)

 27:7

feels (2)

 12:22;54:19

fees (1)

 13:19

few (3)

 51:10;54:4;56:16

field (1)

 6:24

fight (1)

 15:23

fighting (1)

 21:20

figure (2)

 26:4;46:9

figuring (1)

 14:9

file (40)

 3:17;4:5,23;5:3,19;

 6:8;7:7,12,13,22,23;

 8:3,10,13,16,17,20;

 11:9;12:2,7;13:19;

 14:1,4,17,17;16:5,6,8;

 17:15;20:2;21:15;23:3;

 28:5;30:13;32:9;38:6,

 25;39:13;44:25;51:20

filed (12)

 3:18;4:6,15;5:6;11:6,

 10,22,22,25;25:14;

 41:21;48:1

files (11)

 4:8,13,22;5:12,15,

 17;12:15,20;13:17;

 14:7;43:2

filing (2)

 5:7;47:2

final (3)

 37:3;45:17;50:8

finances (1)

 51:22

financial (6)

 51:21;54:10,13,16;

 55:12;57:7

find (6)

 13:17,19,20,21;15:7;

 25:21

fine (3)

 7:6;10:6;22:13

fire (18)

 10:24;24:2;25:12,12,

 16,23;28:16,18;30:24;

 31:17,19;32:12;38:18;

 39:17;45:14;49:15;

 51:6;52:12

firm (1)

 10:3

first (10)

 8:4;18:13;36:13,25;

 37:11;40:1;42:14;49:5;

 54:8;55:1

fishing (1)

 14:5

fit (1)

 30:3

five (2)

 56:22,24

fix (6)

 4:9;14:3,8;23:2,4;

 38:17

fixed (1)

 9:23

fixing (1)

 6:14

focus (3)

 19:3,4;30:2

focused (1)

 45:13

focuses (1)

 29:1

focusing (1)

 16:7

folk (1)

 28:7

folks (4)

 27:19,25;31:18;

 54:19

follow (3)

 33:10;43:7,14

following (3)

 20:4;33:19;45:20

fooled (1)

 3:16

football (2)

 20:24;21:5

forgot (1)

 29:10

Min-U-Script® eScribers, LLC

www.escribers.net

(4) dug - forgot Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 64

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

form (1)

 5:24

formal (7)

 12:15;19:17;20:20;

 21:18;30:13;32:17;

 37:3

former (7)

 26:18,18;29:2,7;

 38:4,9;39:4

forth (1)

 51:22

forthcoming (2)

 57:6;58:14

forty-five (1)

 12:10

forward (7)

 27:23;34:2;42:1;

 47:6;50:18;53:25;54:6

foundation (1)

 34:8

four (3)

 11:16;13:15,24

framed (1)

 8:19

FRANCISCO (1)

 3:1

frankly (2)

 25:19;44:20

French (20)

 24:8,11,16,17,17,20;

 29:22,24;35:17,18,23;

 36:1,3,10;37:6,19;50:8,

 9,20;58:25

French's (1)

 29:19

frustrated (1)

 19:15

full (1)

 27:5

fully (4)

 44:15;53:9;54:15;

 57:6

function (2)

 34:2,2

Fundamentally (1)

 35:19

funds (1)

 36:6

further (6)

 5:9;9:18;14:11;

 39:19;50:17;59:2

future (4)

 42:6;58:4,5,8

G

Gallagher (1)

 27:2

gallery (1)

 23:16

game (2)

 20:24;41:12

Gandhi (1)

 26:21

gave (2)

 28:2;42:13

general (2)

 17:1;35:9

generally (2)

 37:17;42:21

gentlemen (1)

 22:17

gig (1)

 37:19

Gillette (1)

 27:2

Girardi (8)

 35:24,25;36:6;47:22;

 49:13,18,22;52:14

given (13)

 11:9;27:12;28:8,11;

 43:22;44:7,11,12;

 46:16;48:17;56:22;

 57:5;58:16

goal (4)

 37:25;38:19;43:19;

 55:24

goes (2)

 6:7;45:9

Good (31)

 3:11,14;7:9;11:5,15;

 13:1;14:19;17:16;

 18:14;21:11,14,23;

 22:25;23:24;24:1;25:5;

 27:8;34:18,20;35:5,7,

 10,11,15,19;36:7;38:1;

 40:15,19;52:20;55:21

gradient (2)

 14:3,8

great (2)

 23:14;55:20

guess (8)

 3:24,25;8:1,5,9,22;

 19:17;33:16

guiding (1)

 21:11

H

half (1)

 9:5

hand (2)

 24:5,8

happen (3)

 14:13;19:5;47:23

happened (2)

 9:11;38:20

happening (2)

 41:22;44:1

happens (2)

 32:23;47:4

happy (3)

 8:3;9:21,22

hard (1)

 21:7

hate (1)

 19:11

heads-up (1)

 39:6

hear (7)

 24:14,15,21,22;25:4;

 58:24,25

heard (10)

 23:20;24:7,16;25:22;

 26:11;27:12;31:20;

 35:17;46:16;56:24

hearing (19)

 3:25;6:7,9;11:12;

 21:19,21;22:1;25:16;

 32:22;42:22;44:2,3,4,5,

 10,13,14,18;59:4

hearings (2)

 17:10,11

heart (1)

 45:9

helpful (2)

 50:24;51:3

here's (1)

 57:13

himself (1)

 7:18

hire (1)

 58:5

history (3)

 44:20,20;51:23

hoc (1)

 10:24

hold (1)

 6:10

holding (3)

 5:4;6:11;47:13

Honor (94)

 3:8,11,14;4:3;5:5;

 6:3,5,8,11;7:13;8:5,22;

 9:21;10:10,13;11:3,11;

 17:2,10,11;18:7;21:4,7,

 10;22:6,13;23:8,9,16;

 24:1,4,9,17,23;25:4,11;

 26:13,17;27:6,7,12,14,

 16,19,21;28:4;30:18,

 19,20;32:4;33:5,6,17,

 18;34:14,16,21;35:18;

 36:10;39:23;40:2,21;

 41:19;43:4,25;44:9,10;

 45:15,18,19;47:10;

 48:8,13,23;51:11,20;

 52:10;53:4,25;54:2,4,

 18;55:17,20,22;56:11,

 14;57:1,11,18;58:1,21;

 59:5,10

Honorable (1)

 3:5

Honor's (6)

 17:12;28:1,4;31:6;

 43:6,23

hook (1)

 4:2

hope (4)

 28:12;46:2;58:16,16

hoping (1)

 39:25

hours (2)

 3:22;5:5

house (1)

 56:13

Huh (1)

 21:6

hundred (1)

 19:23

hung (1)

 44:17

I

identified (2)

 29:6;48:18

imagining (1)

 50:12

impacted (3)

 27:13;28:7;46:16

impacts (1)

 42:5

implicate (2)

 36:3;38:13

implicated (1)

 37:21

implication (1)

 14:18

important (7)

 18:12;33:8,8;51:14;

 53:10;54:12;58:16

importantly (1)

 17:9

imported (1)

 49:20

inappropriate (1)

 54:17

Inc (7)

 48:4,16,21,24;54:22;

 55:4;58:2

incentive (1)

 54:14

incentives (2)

 55:12;57:7

inclination (1)

 32:25

inclined (6)

 32:12,18,24;39:7,13;

 41:7

include (1)

 59:4

includes (1)

 27:16

including (3)

 26:18;27:9;54:20

increase (2)

 40:23;55:25

increasingly (1)

 12:22

incredible (1)

 44:21

incumbent (1)

 5:9

incurred (1)

 54:13

Indeed (2)

 28:4;58:17

independent (5)

 32:10;37:15,17,18,

 20

Indiana (1)

 21:1

indicate (3)

 27:23;36:5;39:2

indicated (1)

 12:18

indication (2)

 26:7;28:2

indiscernible- (1)

 44:16

individual (1)

 43:20

individuals (4)

 32:16;47:12,15;

 50:13

inferences (3)

 49:23,23,25

influence (1)

 52:8

informal (1)

 20:18

information (13)

 4:21;19:14;20:7,7;

 35:13;42:4;50:18;

 54:16;56:6;58:12,14,

 17;59:2

infused (1)

 49:20

initiate (1)

 20:20

injured (2)

 52:5,14

injustices (1)

 57:9

in-kind (1)

 54:1

innuendo (1)

 27:10

innuendos (1)

 52:16

innumerable (1)

 5:25

inordinate (2)

 47:20;48:17

inquiry (1)

 37:2

insist (3)

 14:25;17:23;29:15

install (1)

 18:1

instead (1)

 51:8

instincts (1)

 29:17

institution (1)

Min-U-Script® eScribers, LLC

www.escribers.net

(5) form - institution Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 65

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

 32:15

integrity (1)

 34:23

intend (1)

 21:18

intends (1)

 27:24

interconnection (1)

 32:3

interest (2)

 38:14;56:1

interested (1)

 32:8

interests (2)

 38:18;55:25

interference (1)

 14:21

interfering (1)

 58:3

interrogatories (1)

 27:17

into (9)

 3:16;4:18;15:23;

 26:2,13;27:11;38:20;

 41:16;49:20

investigation (1)

 50:12

invite (1)

 59:1

invoked (2)

 5:11;53:13

involved (7)

 31:21;37:21;47:19;

 49:21,22;52:12,24

involvement (1)

 18:24

involves (1)

 31:15

irrelevant (1)

 19:18

issue (2)

 8:19;18:18

issued (2)

 29:11;36:18

issues (10)

 16:21;17:13;19:9;

 26:23;28:22,24;31:11;

 36:8;50:11;54:1

item (1)

 46:25

items (1)

 46:12

J

jam (1)

 5:18

James (3)

 29:9,10;45:6

jamming (1)

 6:23

JAMS (48)

 25:18;27:1,5;32:15;

 33:24;34:9;35:9;36:16,

 16,22;37:4,7,9,12,13,

 19,20;38:10,11,13,13;

 40:2,9;44:22;45:12;

 47:13,16;48:4,16,21,

 24;49:12;50:11,14,15;

 51:4;52:8,12;53:16;

 54:22;55:4,11,19,23,

 24;58:2,5,7

Jay (1)

 26:21

jeopardy (1)

 38:19

joined (1)

 24:18

joining (1)

 24:4

joint (2)

 23:3;30:24

judge (32)

 19:12;25:6;26:12,20;

 27:2,2,3,3;28:6,9,15;

 29:8,8,10,12;30:18;

 31:5;38:12;45:5,5,5,6;

 51:8;52:11,15,17;53:5,

 16,20;55:14,14;59:11

judges (4)

 34:9;38:5,5;44:22

judging (1)

 38:17

judgment (9)

 8:11,13,13,18;9:1,6,

 16;20:3;22:24

judicial (3)

 56:17;57:8;58:15

June (2)

 4:4,5

jurisdiction (1)

 46:23

Justice (28)

 25:15;26:9,18;28:14,

 21;29:2;32:15;33:24;

 34:10;36:4;38:8,15;

 39:4,7,7,8,12;40:8,15;

 41:3,6;49:20;50:10;

 51:1;52:6,13;53:8;56:8

justification (1)

 57:13

K

Kawaichi (1)

 27:3

keep (1)

 17:15

keeps (1)

 17:14

Keller (1)

 3:15

kept (1)

 48:15

key (1)

 48:25

kick (1)

 5:2

kicking (1)

 3:24

Kim (1)

 3:15

kind (5)

 17:1,18;25:21;32:17;

 38:19

knows (7)

 22:4;26:13;33:18;

 51:20;56:14,16,17

L

LA (3)

 34:12;49:22;52:2

labels (1)

 44:17

Labor (1)

 4:1

lack (1)

 25:18

lamented (1)

 52:13

land (1)

 42:20

landscape (1)

 14:8

language (1)

 48:22

larger (2)

 6:13;43:22

last (7)

 3:17,18;44:2;45:18;

 47:10,11;56:11

late (2)

 3:25;4:25

later (4)

 5:3;33:1,8;44:13

law (1)

 15:20

lawn (1)

 18:15

lawyer (4)

 7:11;10:17;29:20;

 38:12

lawyers (2)

 9:5;43:16

least (12)

 14:18;19:8;20:6;

 27:11;28:6;29:1,7,20;

 38:25;39:1;45:13;47:5

leave (5)

 39:15;45:16;50:4,24;

 51:6

legislature (1)

 38:16

length (1)

 43:22

less (2)

 53:11;58:6

lest (2)

 13:12,12

lets (1)

 22:2

letting (1)

 3:16

level (3)

 6:24;10:12,14

liability (5)

 7:1;8:7,15,23;20:3

likely (1)

 26:4

likes (2)

 19:12;51:25

limit (1)

 18:3

line (1)

 32:16

list (3)

 33:11;47:16,25

listed (1)

 54:19

Listen (1)

 16:14

listening (2)

 23:19;31:9

listens (1)

 13:3

listing (1)

 47:15

litigants (1)

 55:13

litigated (1)

 4:19

litigation (2)

 31:16,16

little (9)

 4:2,16;8:6;18:8;

 21:12;33:1,2;38:2;

 53:17

lives (1)

 56:14

LLP (1)

 25:12

log (2)

 25:1;59:7

long (7)

 4:2,5;13:6;33:2;42:2,

 4;47:16

look (12)

 12:10,12;31:5;33:18;

 34:14,16;45:25;53:22,

 24;54:15;56:6;57:10

looked (2)

 25:17;54:25

looking (3)

 8:23;17:18;53:25

looks (1)

 27:16

Los (1)

 28:22

lose (2)

 8:18;19:3

loss (1)

 13:20

lot (9)

 3:21;6:19,20;11:4;

 13:2;18:2;26:17;34:21;

 51:14

lots (4)

 27:16;31:17;35:25;

 42:19

loves (1)

 19:12

low (2)

 53:22,23

luck (2)

 22:25;56:23

M

machine (1)

 25:7

mad (1)

 21:12

magnitude (1)

 6:12

Mai (1)

 24:18

mail (1)

 33:21

maintain (1)

 12:19

maintains (1)

 10:23

Majesti (1)

 24:18

major (2)

 34:13;35:24

makes (1)

 42:12

making (2)

 34:23;36:14

many (4)

 10:16,17;49:19;53:2

marks (1)

 48:15

matter (21)

 3:7;4:14,23,23;5:11,

 14;15:20,23;17:1,23;

 19:14,20;23:15,23;

 24:7;32:9;33:3;39:18;

 49:22;54:11;57:20

matters (3)

 21:24;26:15;58:13

Matthew (3)

 24:8,11,17

may (25)

 4:2;6:7;14:23,24;

 15:8,11;18:2,5;20:12;

 23:19,20;27:25;29:2;

 30:20;34:8;37:12;38:8;

 41:7;46:6,7;47:5;

 55:25;58:11,11,19

maybe (14)

 8:18,18;12:11,11,23;

 15:3,3;16:21,21,22,22;

Min-U-Script® eScribers, LLC

www.escribers.net

(6) integrity - maybe Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 66

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

 18:23;29:17;42:6

mean (17)

 7:7;11:4,6;16:12,17;

 30:4;36:25;37:2,8,10,

 15,20;38:10,11;48:6,

 11;55:2

meaning (1)

 27:23

means (1)

 53:15

meantime (2)

 20:5;21:2

mechanism (1)

 31:3

mediate (4)

 5:16;8:3;10:4;12:25

mediation (17)

 4:7,18;10:2,12,14,

 18;11:4,5;12:19;13:10;

 14:19;16:9,14;20:13;

 22:19;48:2,13

mediations (1)

 26:22

mediator (7)

 10:7;11:8;12:8;

 26:21,22;48:6,7

mediators (5)

 10:19,21;20:15;

 37:16;48:4

meet (1)

 17:17

member (2)

 26:20;37:10

mention (1)

 29:7

mentioned (2)

 27:25;28:7

mentions (4)

 26:17,19,20,25

merits (2)

 46:23;55:15

messenger (1)

 34:5

microphone (1)

 24:25

might (23)

 7:23;10:8;12:22;

 15:2;20:25;22:22;26:1;

 29:21;31:20;32:21,22,

 22;34:1;37:21;39:6,6,

 14;51:3,10,11;53:22;

 58:3;59:1

million (5)

 11:17,23;16:16;

 19:22;57:11

mind (3)

 29:14;36:6,12

minimum (1)

 29:1

minor (1)

 43:24

minute (2)

 3:17;57:14

misappropriated (1)

 36:6

mischief (1)

 37:21

miscommunication (1)

 14:23

misconduct (1)

 49:16

misquotes (1)

 52:2

misstatements (1)

 52:16

modification (2)

 46:1,8

modified (1)

 45:21

Molton (49)

 24:4,13,14,21,24;

 25:4,5,6,11,11;26:6,12;

 28:15,20;29:10;30:12,

 18,23;31:5,13,14,25;

 32:3,6,13,25;33:7;

 36:21;37:1,3;38:6,24;

 39:12,18;42:25;43:2;

 44:6,19;45:6;50:22;

 51:8,13,20;54:6,18;

 56:17;58:19,21,24

Molton's (2)

 47:1;54:8

moment (2)

 15:12;29:24

money (5)

 16:2;35:1,2,4;56:13

Montali (1)

 3:6

month (3)

 14:11;19:13;22:4

more (17)

 5:19;8:6,16;9:19,22;

 17:8;19:13,16,17;20:8;

 25:15;30:14;38:20;

 42:10;45:17;51:25;

 53:15

Morning (8)

 3:9,11,14;5:7;23:24;

 24:1;25:5;35:18

Morris (1)

 3:12

most (2)

 9:5;26:14

motion (40)

 8:10,18;9:1;19:17,

 21;20:2;22:21,23,24;

 24:19;25:14,15,18,18,

 20;26:1,5,11,14;27:25;

 29:15;30:1,15,24;

 32:19;34:2,17;36:11;

 41:25;42:14;44:18,21,

 22,25;45:12,13;46:21;

 48:18;50:11;54:11

motions (5)

 9:5,6;41:23,24;42:15

mouth (1)

 40:8

move (1)

 30:14

moving (3)

 6:18;31:10;42:20

much (8)

 4:21;14:6;19:20;

 23:7,21;24:21;25:19;

 45:12

multifaceted (2)

 52:4,13

Must (2)

 14:13;43:14

muting (1)

 24:25

myself (1)

 42:8

N

name (6)

 24:10;29:19,20;

 44:25;52:6,7

named (3)

 40:13;44:23;45:7

names (2)

 26:17;50:10

narrow (1)

 36:11

nature (4)

 5:8;15:4,18;30:9

near (1)

 6:1

necessarily (1)

 50:12

necessary (3)

 36:11;43:1;50:18

need (17)

 4:3,19;5:3,15,22;

 13:14;14:15;18:14;

 21:19;26:3;31:9;38:19;

 46:9,20;50:16;54:10,

 16

needed (1)

 4:9

needs (2)

 4:18;14:25

negotiated (2)

 45:23;46:5

neither (1)

 36:4

neutral (6)

 52:25;55:11;56:4;

 58:3,10,17

neutrals (5)

 52:25;53:2,17;58:2,

 17

nevertheless (1)

 30:2

new (4)

 4:5;12:8;20:23;35:3

Newsom (1)

 29:12

Newsome (2)

 26:20;45:5

newspaper (3)

 27:10;34:8;52:1

next (15)

 3:20;5:20;18:24;

 20:24;21:1,21;22:9;

 23:15;32:20,21;37:2,4;

 38:6;47:2,3

Nice (1)

 3:9

noncomplex (2)

 52:23;53:1

none (3)

 6:13;42:4;56:7

nonfire (1)

 31:19

Nope (1)

 24:15

normal (1)

 30:3

note (4)

 27:21;46:24;48:1;

 53:10

noted (3)

 47:9;50:5;58:18

notice (9)

 27:12,19;32:8,18,22;

 33:21;36:12,13,17

noticed (3)

 29:3;31:2;33:11

notices (2)

 53:8,14

notion (1)

 38:1

Notre (2)

 21:1,3

November (7)

 22:10,11,12,13,14,

 17;23:2

nowhere (1)

 6:1

number (9)

 26:25;46:13;51:24;

 52:17,18;53:10,22,24;

 54:19

O

objection (8)

 4:24;5:3;8:14;11:10,

 13;15:23;17:6;23:1

objections (1)

 6:1

Obviously (1)

 29:21

occasion (1)

 49:19

occurred (1)

 51:17

o'clock (1)

 23:2

October (5)

 22:8;30:20;32:14,23;

 39:18

off (6)

 25:6;42:4,17;51:8;

 59:7,7

officer (7)

 27:4;30:21;52:21,21,

 22;54:20;55:10

old (1)

 43:12

Oliner (42)

 3:9,11,11,19,21;

 5:18;7:2,18;8:15;9:19;

 10:20,22;11:11,13;

 12:4,12,17;13:9,10,11,

 25;15:11;16:4,13,19;

 17:17,20;19:4,15,23;

 20:19,21,23;21:3,5,10,

 25;22:12,13;23:7,10,12

Oliner's (2)

 7:8;18:24

Olinger (1)

 9:24

once (1)

 51:22

one (35)

 8:4;9:8;10:7;13:13,

 18,19,20;15:20;19:13;

 20:15;22:9;26:3;27:6;

 28:15;29:7,14,20,21;

 36:23;37:11;39:23;

 40:10,12;42:12;43:15,

 25;45:6,17;47:11,20;

 49:8;51:24;54:22;57:3;

 58:10

ones (1)

 10:19

one's (2)

 7:25,25

only (9)

 18:20;22:7;27:18;

 32:2;37:11;39:8,9;

 48:14;57:12

onto (1)

 25:7

oOo- (1)

 3:3

open (1)

 39:15

opening (4)

 28:16;43:12,17;

 58:15

operating (1)

 35:10

opinion (2)

 45:12;51:21

opportunity (12)

 27:12,20;28:8,12;

 42:11,13;43:1,3;44:3,7,

 11;46:16

oppose (2)

 8:17;29:18

opposed (1)

Min-U-Script® eScribers, LLC

www.escribers.net

(7) mean - opposed Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 67

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

 6:22

opposing (1)

 26:11

order (22)

 3:4;4:9;6:12;28:4;

 29:11;31:6;32:22;

 39:15,25;41:18;44:6;

 45:21,24;46:6,8,13,15,

 15,16,18;51:1;53:20

ordinary (1)

 49:2

Oregon (1)

 20:24

original (4)

 29:25;30:1;33:13,16

others (3)

 10:16;32:23;40:19

otherwise (2)

 20:16;27:24

ought (1)

 38:17

out (30)

 3:23,25;4:1;5:2,19,

 22;7:18;9:22;11:11;

 14:9;17:13;21:23;22:4;

 25:1,21;26:4;31:2;

 34:25;35:2;38:4;40:20;

 42:5;43:17;45:4,25;

 46:4,9;48:6;49:2,13

outcomes (1)

 52:9

outside (1)

 34:19

over (11)

 4:7;10:18;14:17;

 17:19;18:5,8,8;19:13;

 20:21;34:25;57:24

overlap (1)

 19:8

owes (1)

 16:2

own (5)

 7:3;13:20;20:9;40:8;

 44:9

P

pad (1)

 46:24

page (2)

 22:16;52:3

pages (1)

 3:22

paid (3)

 7:17;9:10;10:21

paint (3)

 49:10,11,11

painted (1)

 50:4

painting (1)

 50:3

panel (7)

 10:3,5;20:15;52:23;

 53:1,2;54:21

panelists (1)

 27:1

paper (3)

 8:8;43:18;52:10

papers (2)

 27:14;51:16

Parada (5)

 22:3;24:2,6,22;59:6

parameters (1)

 36:18

part (1)

 21:23

particular (1)

 58:10

parties (12)

 10:4;26:9;32:8,18;

 33:25;35:1;39:21;

 40:25;42:9,20;44:14;

 45:2

party (1)

 31:18

past (7)

 8:4,5;9:11;10:18;

 35:8;37:12;46:14

path (1)

 56:9

pattern (10)

 33:24;34:3,7,11,20;

 35:2,20,22;36:2,25

patterns (2)

 48:18;56:2

Pause (1)

 25:3

pay (1)

 16:17

pending (1)

 49:1

people (23)

 9:7;10:4;25:22;26:9,

 25;27:18;29:6;32:15;

 35:25;36:19;41:14;

 44:23;45:1,6;46:15;

 49:19;50:14;52:5,14;

 54:21;55:22;56:24;

 57:7

peoples (1)

 47:16

per (1)

 14:18

perceived (1)

 57:9

percent (7)

 19:23;53:7,11,12,13,

 13,13

perhaps (15)

 8:17;12:8;17:17;

 30:14;36:11,19;37:16;

 38:8;41:12,20;42:2,3,

 18;47:3;49:17

period (1)

 30:17

persists (1)

 16:3

person (6)

 29:7,13;38:12;40:10,

 12;55:18

personal (2)

 18:23;49:18

personally (3)

 29:2;37:14;39:4

person's (1)

 24:10

perspective (3)

 6:6,15,15

persuasion (1)

 6:17

pertain (1)

 19:1

petition (1)

 58:18

PG&E (24)

 3:7;4:12;5:12;6:2;

 13:7;14:9,15,24;15:9,

 19;16:2;17:6,22;18:1,

 2,13,13;19:8;20:2,4,14;

 22:3;30:24;31:8

PG&E-approved (1)

 4:10

PG&E's (7)

 6:15;12:20;13:17,19;

 14:7,13;20:11

philosophically (1)

 6:22

phrase (1)

 17:15

Pichon (1)

 27:3

pick (2)

 10:5;49:12

picture (1)

 50:3

Piedmont (1)

 4:8

pin (1)

 9:17

place (2)

 46:19,19

plaintiffs (1)

 31:17

plan (3)

 4:10;14:3;42:17

playing (1)

 6:24

pleading (3)

 5:17;52:3;53:5

pleadings (2)

 28:1,11

please (4)

 3:10;23:24,25;24:14

pleasure (4)

 3:20,22;6:4;17:12

plenty (1)

 22:15

pocket (1)

 56:13

pockets (1)

 56:16

point (36)

 7:9;8:19;11:14;

 15:13;16:12;18:18;

 21:22;26:13;33:23;

 36:17;38:21;39:15,19;

 41:2,5,9,15,16,16,19;

 42:23;43:5,23;45:17,

 17,19;46:10;47:1,6,10,

 11;50:25;51:7;54:18;

 56:12;59:1

points (5)

 16:4;39:25;41:17;

 43:24;48:25

polite (1)

 4:11

pool (2)

 15:16;18:2

position (7)

 4:9,21;12:20;47:8;

 50:9,23;56:4

positions (1)

 7:18

possible (2)

 7:3;42:4

post- (1)

 11:20

post-agreement (1)

 16:7

post-confirmation (1)

 46:22

practical (2)

 13:8,22

practice (1)

 30:7

practicing (1)

 33:18

practitioner (1)

 7:8

precede (2)

 28:23;53:23

preceded (2)

 26:15,23

precluding (1)

 46:6

preliminary (9)

 25:16;44:2,2,4,5,10,

 13,14,18

premature (2)

 9:24;47:7

prepare (1)

 7:1

prepared (7)

 5:25;10:11;16:17;

 27:23;38:21;41:6;

 49:11

presence (1)

 7:8

present (3)

 6:21;26:19;28:23

preserved (2)

 47:8,8

presiding (1)

 3:6

press (1)

 35:13

previously (2)

 12:18;30:6

principal (1)

 10:17

prior (14)

 7:24;10:1;25:15;

 27:22;37:6;39:9,9;

 41:13,14;45:13;46:5;

 47:18;51:3;54:11

private (1)

 38:17

pro (1)

 42:7

prob (1)

 55:15

probably (4)

 12:4;22:4;36:22,23

problem (1)

 36:13

Procedurally (2)

 9:18;32:16

procedure (6)

 12:9;22:19;25:21;

 27:5;44:24;45:8

procedures (2)

 33:10,19

proceed (6)

 4:10;11:14;21:14,18;

 23:23;27:8

proceeding (2)

 9:3;38:19

proceedings (1)

 59:12

process (8)

 13:6;20:13,17;30:3;

 42:19;56:13;57:8,8

processed (1)

 30:8

processor (1)

 37:9

productively (1)

 21:24

professional (2)

 4:11;5:3

professionalism (1)

 23:13

progress (2)

 12:11;22:25

prohibit (1)

 18:3

prolix (1)

 43:11

prominent (1)

 58:6

promise (1)

 47:11

prompted (1)

 6:9

proof (10)

Min-U-Script® eScribers, LLC

www.escribers.net

(8) opposing - proof Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 68

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

 6:18;8:12;15:1,5;

 18:6,22;19:18,24,25;

 51:15

proofs (1)

 15:21

proper (5)

 8:14;32:8;45:10;

 46:20;56:5

property (16)

 4:8,9,13;5:13;6:14;

 13:21;14:12,15,24;

 15:15;17:22;18:9,25;

 19:5;20:10,10

proponents (1)

 46:15

proposal (1)

 30:16

proposed (1)

 27:16

proposing (1)

 31:23

prosecute (1)

 12:23

protect (1)

 38:14

protections (1)

 45:23

protective (6)

 45:21,24;46:5,13,18;

 53:20

proud (1)

 53:4

provable (1)

 15:9

prove (8)

 6:25;11:21;12:13,14;

 13:16;16:2,24;18:21

proved (1)

 56:18

proven (1)

 9:15

proves (1)

 13:17

provide (8)

 12:5;17:23;20:12;

 33:21;40:5;42:10;

 47:24;56:6

provided (7)

 12:20;17:6,7;42:1;

 48:9;56:17;57:12

provides (1)

 59:3

providing (5)

 33:22;34:22;35:9,13;

 47:18

prudent (2)

 35:6;56:9

purpose (1)

 47:18

purposes (1)

 16:8

push (3)

 3:23;4:1;42:3

pushing (1)

 53:9

put (17)

 5:22;9:22;11:24;

 12:3;15:16;17:3;19:13,

 24;20:21;41:20;42:1,7;

 45:4;52:1;53:5;54:6;

 56:13

puts (1)

 42:8

putting (2)

 13:12;34:2

Q

questionnaires (1)

 53:6

quickly (3)

 30:14;41:24;42:24

quit (1)

 23:11

quite (3)

 9:20;10:13;25:19

quote (2)

 52:10,10

quoted (2)

 41:4;51:1

R

raised (2)

 24:5,8

raises (1)

 46:22

raising (1)

 38:22

random (1)

 52:25

rapport (1)

 21:12

rather (1)

 33:7

read (5)

 3:17;5:5,7;34:18;

 52:22

reader (1)

 5:6

reading (2)

 26:14;28:1

reads (1)

 51:25

ready (2)

 16:16;30:18

real (1)

 37:15

realize (1)

 25:25

really (5)

 5:7;6:13;45:22;

 47:24;58:15

reasonable (2)

 7:3;35:15

reasonably (1)

 30:16

reasons (2)

 20:4;27:9

rebuild (2)

 15:15;56:13

recall (1)

 30:20

receive (1)

 12:20

received (3)

 3:25;6:12;14:12

receiving (2)

 3:22;4:17

recently (1)

 41:22

recognize (1)

 29:19

record (5)

 17:5;20:3;25:10;

 28:4;41:5

redacted (7)

 47:25;48:2,14,22;

 49:7,8;54:14

redacts (1)

 48:6

refer (1)

 46:23

referred (2)

 26:23;52:5

referring (2)

 48:5;53:21

refers (2)

 53:2,3

regarding (2)

 41:22;52:7

regime (1)

 27:4

rehire (1)

 58:7

reiterate (2)

 51:13;53:25

reiterated (1)

 33:7

related (3)

 10:23;31:11;36:15

relationship (6)

 15:4,18;36:15;37:13;

 38:13;55:19

relationships (4)

 37:6;50:14,15,20

relevance (1)

 18:20

relevant (3)

 20:7;21:16;56:5

reliant (2)

 34:19;35:13

relief (3)

 46:20;47:3,5

relying (1)

 48:20

remain (2)

 18:14,14

remark (1)

 28:16

remarks (2)

 26:12;27:11

remedies (2)

 46:6;57:3

remember (1)

 46:12

remind (1)

 19:10

reorganized (1)

 3:15

repay (1)

 23:11

repeatedly (1)

 14:1

reply (5)

 32:21;43:14,16;57:5;

 59:1

report (4)

 17:7,7;34:8;50:13

reported (2)

 34:12;35:20

reporting (3)

 34:12,19;54:10

represent (3)

 27:18,18;40:25

representatives (2)

 40:2;49:16

represented (1)

 39:11

request (6)

 4:1;5:1;27:13,15,15;

 52:4

requested (3)

 4:7,12;47:3

requests (4)

 27:17;28:8;30:8;

 31:22

require (2)

 19:17;41:8

required (2)

 20:1;23:5

requires (1)

 14:9

research (1)

 46:9

resolution (4)

 19:21;20:13;22:18,

 18

resolve (3)

 4:6;10:5;21:16

resolved (1)

 53:14

resolving (2)

 13:5;20:8

respect (3)

 28:24;31:10;53:20

respond (22)

 11:13;27:24;29:16,

 17;30:16;32:14,25;

 33:4;38:9;39:5,8;41:6;

 42:9,13,18,21;43:1;

 44:19;45:7,8;54:1,5

respondent (3)

 29:3,14;30:2

respondents (4)

 25:20;26:1,4;29:21

responding (2)

 29:18;54:1

response (21)

 3:19;25:17;29:1,16;

 30:14;32:7,9,19;33:1;

 38:6,25;39:2,3,13,17,

 21;42:8,15,22;51:9;

 52:19

rest (1)

 59:8

result (2)

 7:9;52:25

retained (1)

 4:4

retention (2)

 48:11,12

reticence (1)

 12:24

retire (1)

 23:16

retired (7)

 27:2,2,3;38:5,12;

 55:14,14

return (3)

 8:21,21;55:25

reveal (1)

 46:4

reveals (1)

 46:3

review (4)

 47:2;56:17;57:8;

 58:15

reviewed (2)

 49:5,7

reviews (1)

 52:22

revisit (1)

 56:21

revisiting (1)

 7:19

right (21)

 5:2;7:20,21,25;11:2,

 3,5;14:24;15:11;16:25;

 17:1,16;23:24;24:13;

 25:1;28:9,19;30:22;

 42:18,22;51:19

rights (1)

 19:2

rocket (1)

 16:6

role (8)

 10:17;29:12;30:9,10;

 34:22;47:20;48:17;

 50:23

roles (1)

 47:14

roll (1)

 29:23

Ron (1)

Min-U-Script® eScribers, LLC

www.escribers.net

(9) proofs - Ron Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 69

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

 3:11

room (1)

 31:9

rounds (1)

 7:25

route (1)

 11:6

Rudnick (1)

 25:11

Rule (6)

 8:9,10;13:23;30:3,4;

 45:10

rules (9)

 5:11,13,13;18:3;

 19:1,25;42:13;45:4,8

ruling (4)

 7:14,15;8:1;9:14

rulings (1)

 7:24

run (1)

 43:17

Rupp (44)

 3:13,14,14,16;4:4,11,

 16;6:4,5;7:13;8:5,22,

 25;9:17,21;10:10,13;

 11:1,3,10,15;13:12;

 14:4,14;16:20;17:2;

 18:7;19:11;21:4,6,7,11,

 15;22:4,6,15,21;23:6,9,

 11,15,16,19,22

Rupp's (5)

 4:21;5:14,23;14:18;

 16:16

S

sad (1)

 5:16

safe (1)

 18:11

same (10)

 12:9;19:6;22:16;

 25:21;36:8;39:13;

 43:16;55:7;57:25;58:1

SAN (1)

 3:1

Saturday (1)

 21:1

save (2)

 51:9;57:4

saw (2)

 29:19;30:3

saying (7)

 8:6;29:18,25;41:4;

 43:12;51:1;56:5

say-so (1)

 49:11

scandal (1)

 34:13

scene (1)

 12:9

schedule (3)

 22:2,20;58:23

scheduling (3)

 11:11;22:19,19

science (1)

 16:6

scope (2)

 7:2;25:19

scream (1)

 31:2

se (1)

 42:7

seal (1)

 42:16

sealing (1)

 42:24

second (4)

 18:16;41:17,19;

 54:18

Secondly (1)

 49:10

secret (1)

 42:16

section (3)

 48:10,13,14

security (4)

 34:22,25;35:6,9

seem (2)

 10:6;25:8

seemed (1)

 6:13

seems (8)

 6:18;7:8,22;14:22;

 16:20;18:20;29:5;42:2

selected (1)

 49:21

sense (3)

 13:22;45:2,2

sent (2)

 4:16;57:19

separate (2)

 19:9;32:9

separating (1)

 16:23

SEPTEMBER (2)

 3:1;5:1

serve (4)

 33:12,12;38:4;45:3

served (3)

 29:16;33:14,15

service (3)

 33:11,13,16

servient (2)

 15:19;19:1

session (1)

 3:5

set (6)

 5:25;8:1;19:21;

 22:20;25:16;36:18

sets (1)

 51:22

setting (1)

 9:23

settle (1)

 6:16

settled (6)

 6:17;9:9;13:15,23,

 24;57:11

settlement (10)

 7:16;9:14;11:21;

 16:3;30:23;31:7,11,15,

 21;57:9

sexy (1)

 14:17

shape (1)

 5:24

share (1)

 7:6

shareholder (7)

 40:8,13,16,17;41:4;

 51:2;55:24

shareholders (6)

 40:3,21,22,23;55:22;

 56:7

sharing (1)

 38:1

shifted (1)

 5:8

short (1)

 30:16

shot (1)

 13:4

show (3)

 7:22;8:3,17

shows (1)

 58:17

side (4)

 7:11;8:3;12:12;

 22:21

sideshow (1)

 14:11

silly (1)

 12:2

similarly (1)

 35:7

simple (2)

 34:15;54:21

simply (4)

 25:21;32:23;44:19;

 49:13

single (3)

 19:12;51:16;54:22

sins (1)

 49:12

sitting (1)

 54:21

situation (1)

 16:2

SJ (1)

 13:5

Skikos (2)

 26:20;47:19

skis (1)

 18:8

solve (1)

 14:20

solved (1)

 4:18

somebody (3)

 34:25;37:8;46:19

somehow (2)

 49:15,20

someone (3)

 10:5;23:15;29:17

sometime (2)

 22:10;37:12

somewhere (1)

 41:5

sooner (1)

 33:7

sorry (5)

 10:13;11:18;24:10;

 25:6;48:12

sort (4)

 23:3;24:25;36:14,18

sorts (1)

 46:22

sound (1)

 17:5

South (1)

 20:25

speak (2)

 28:14;29:24

speaking (1)

 51:8

specific (1)

 8:23

specifically (2)

 25:15;56:8

speculate (1)

 47:7

spring (1)

 6:21

squawked (1)

 56:24

staff (1)

 59:8

stand (2)

 33:20;39:19

start (2)

 7:22;45:4

starting (1)

 36:17

state (11)

 3:10;8:13;9:3,4;

 17:6;23:24;24:13;25:9;

 31:16;44:14;47:12

stated (7)

 29:22;33:6;44:3,6;

 46:2;54:12;56:8

statement (1)

 51:21

status (1)

 23:4

stay (1)

 49:8

staying (1)

 23:14

steamroll (1)

 13:7

step (3)

 36:14;37:2;47:4

steps (3)

 35:6;38:2;50:5

stick (1)

 58:23

still (8)

 4:22;11:1;21:20;

 24:15;30:13;31:1;38:1;

 40:8

story (1)

 58:11

strange (1)

 13:14

struck (1)

 13:13

structures (1)

 54:14

studies (1)

 16:7

stuff (3)

 12:24;19:18;21:16

subject (2)

 30:24;46:17

subjected (1)

 56:12

submitted (3)

 39:19;51:16;53:6

success (1)

 11:4

successful (2)

 10:25;16:18

suddenly (1)

 14:15

suffered (2)

 13:16;15:10

sufficient (2)

 35:21;36:7

suggest (2)

 15:12;30:19

suggested (3)

 12:19;32:7;54:2

suggests (1)

 53:22

summary (8)

 8:11,13,13,18;9:6,

 16;20:2;22:24

summation (1)

 5:22

Sunday (1)

 14:14

supplemental (1)

 5:19

support (2)

 11:2;12:8

suppose (2)

 55:8,10

Supreme (1)

 38:16

sure (16)

 11:5;13:4,22;17:20;

 18:9;19:3;24:17;29:23;

 33:9;34:23;36:7;41:19;

 43:25;44:8;45:19,24

Min-U-Script® eScribers, LLC

www.escribers.net

(10) room - sure Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 70

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

surprised (1)

 28:25

swimming (1)

 18:1

syllable (1)

 36:23

system (1)

 57:15

T

taint (2)

 49:11,12

tainted (1)

 49:16

talk (1)

 59:8

talking (2)

 18:4;21:21

team (1)

 21:5

technical (1)

 45:2

technically (1)

 8:9

ten (1)

 16:15

tenacious (2)

 7:7;13:3

tenants' (1)

 19:2

tenement (1)

 15:19

tenements (1)

 15:19

tennis (1)

 15:16

term (2)

 17:16;25:19

terminated (2)

 11:18,19

termination (1)

 7:15

terms (2)

 36:12;53:18

terrific (2)

 21:10;22:15

theory (4)

 6:25;8:7,23,25

therefore (10)

 9:10;37:20;38:10;

 41:13,14;43:14,14;

 55:11,19;56:25

there'll (2)

 12:11;19:14

third-party (1)

 10:19

thirty (1)

 12:10

Thomas (1)

 3:14

thorough (1)

 43:13

thoroughly (1)

 38:20

though (3)

 13:11;18:19;36:12

thought (3)

 29:20;50:10,13

three (2)

 39:25;41:17

threw (1)

 18:22

throughout (1)

 4:11

thumbs (1)

 25:8

Times (4)

 28:22;34:12;49:22;

 52:2

title (1)

 48:14

to-be-set-next (1)

 21:19

TOC (1)

 26:20

today (12)

 9:19,23;11:12;21:8;

 23:7;24:3,7;28:3,14;

 31:6;46:22,25

together (1)

 10:5

told (2)

 29:17;57:21

tomorrow (1)

 14:13

took (1)

 45:9

tossed (1)

 11:16

towel (1)

 18:22

tower (1)

 15:3

towers (2)

 18:12,14

town (2)

 5:20;21:23

track (2)

 31:1;41:21

tracked (1)

 41:25

traditional (2)

 9:3;19:25

treat (1)

 5:13

treated (2)

 6:2;9:6

trial (5)

 9:23;12:3,13;17:3;

 22:20

tried (5)

 4:6,17;5:25;6:20;

 45:11

Trot (1)

 41:3

Trotter (23)

 25:16;26:9,19;28:14,

 21;29:2;32:15;33:24;

 34:10;36:4;38:8;39:4,

 7,7,8,12;40:15;41:3,6;

 49:21;51:1;53:8;56:8

Trotter's (2)

 40:8;50:10

trouble (1)

 8:2

troubling (1)

 17:14

true (3)

 18:17;40:6;42:19

Trust (33)

 25:12,16;26:15,16,

 24;27:23,24;28:18,23;

 29:5;30:24;32:13;

 34:23,23;35:9;36:14,

 15,16,22;37:3,7;38:18;

 39:9;49:15;50:13;

 51:17,18,22;52:13,18;

 53:23;54:13;57:5

Trustee (36)

 24:3;25:12,23;26:18,

 19;28:17;29:4;31:16,

 17;32:13,14;34:22;

 35:8;36:5;37:11;38:9;

 39:4,9,9,10,10,11,18;

 41:13,13,14,24;42:3,8,

 25;45:14,21;51:6;53:9;

 56:2;59:3

trustee's (2)

 32:19;42:16

trusts (1)

 36:5

trust's (1)

 50:23

try (9)

 5:25;10:2,5;13:7;

 14:20;21:16;22:16;

 40:23;47:25

trying (8)

 6:16;9:12;14:6;

 15:22;19:3;22:25;

 38:14;41:20

TUESDAY (1)

 3:1

turn (6)

 4:7;14:17;20:2;26:2;

 41:16;59:7

turned (2)

 17:19;34:25

turns (1)

 40:20

twenty-five (1)

 48:25

two (14)

 5:1,19,20;7:18;

 15:19;19:9;20:22,24;

 21:23;22:2;36:5;43:24;

 52:17,18

two-thirds (2)

 53:11,12

U

Ultimately (1)

 17:2

unaware (1)

 42:7

uncertainties (1)

 29:14

under (10)

 9:4;11:23;12:9,15;

 18:2;19:2,22;27:4;

 33:3;44:24

undermine (1)

 11:2

undermined (1)

 52:8

underpinning (1)

 9:14

understood (5)

 33:10;34:14;43:19,

 22;58:9

undeserved (1)

 21:8

unequal (1)

 57:15

Unfortunately (2)

 47:15,22

UNISON (1)

 59:5

unjustly (1)

 57:11

unless (3)

 7:18;36:24;47:6

unlike (1)

 29:25

unprecedented (1)

 44:24

unredacted (1)

 49:5

unrelated (1)

 34:13

unsuccessful (1)

 10:2

unusual (1)

 45:8

unworkable (1)

 20:19

up (13)

 5:18;6:6;9:6;12:7;

 16:2;18:1;25:8;37:1;

 43:25;44:17;46:10;

 53:10;58:15

upon (4)

 17:23;34:19;41:25;

 50:17

upright (1)

 18:14

upset (1)

 42:15

urgent (3)

 5:1;14:12,15

used (4)

 37:9;45:25;52:1;

 55:18

useful (2)

 12:23;32:6

using (3)

 17:15;32:6;45:10

V

vacated (1)

 47:6

value (1)

 13:21

various (1)

 27:8

vendors (1)

 14:13

verbose (1)

 43:10

versus (1)

 15:8

via (2)

 33:14,21

Victim (10)

 25:12,12;28:17,18;

 30:24;39:17;49:15;

 51:6;52:12;56:12

victimization (2)

 52:5,14

victims (8)

 33:9;38:18;40:25;

 42:9;54:12;56:1,16;

 57:8

victims' (1)

 56:15

view (3)

 7:9;17:22;28:6

viewed (1)

 17:10

Viggo (1)

 27:3

voluntarily (1)

 12:2

volunteer (1)

 36:24

W

wait (5)

 25:2;48:5;57:14;

 58:24;59:2

wants (12)

 6:25;9:19;16:24;

 17:21;18:9;19:5,18;

 20:9,14;22:22;36:24;

 49:22

warned (1)

 14:1

watch (1)

 21:1

way (12)

 5:24;6:2;8:5;11:11;

Min-U-Script® eScribers, LLC

www.escribers.net

(11) surprised - way Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 71

of 72
PG&E Corporation and Pacific Gas 

and Electric Company

Case No. 19-30088

September 13, 2022

 14:20;16:22;18:2;

 20:15;21:17;34:21;

 45:11,14

ways (2)

 34:21;35:10

week (1)

 4:25

weeks (7)

 5:1,19,20;20:22,24;

 21:23;38:6

weigh (1)

 42:10

well-intentioned (1)

 52:8

weren't (1)

 28:10

whatnot (1)

 27:10

What's (23)

 3:19,19;6:4;7:12;

 11:6;13:25;14:3,9,16;

 16:5;18:11;22:3,9;

 24:10;37:2,4;41:17,22;

 44:1;48:15;55:15,15;

 56:25

Whereupon (1)

 59:12

whole (6)

 6:19,20;10:3;30:6,7;

 48:13

wholly (2)

 18:5;32:10

whomever (1)

 33:21

who's (4)

 40:13,17,19;48:2

willing (6)

 10:2,16;11:2;16:10;

 19:16;20:11

willingness (1)

 12:18

win (1)

 8:19

wins (1)

 20:4

wish (5)

 22:24;23:20;24:16;

 33:4;35:17

wished (1)

 45:11

withdrew (1)

 18:22

within (10)

 30:16;40:25;44:6;

 45:22;47:14,25;48:17,

 18,25;56:1

without (4)

 14:2,9;17:3;53:14

won (1)

 7:25

wonder (1)

 10:7

word (2)

 49:7,12

words (3)

 9:1;15:2;17:25

work (9)

 5:20;17:8,12;25:8;

 37:9,12;53:5;55:11;

 58:5

worked (1)

 12:9

working (1)

 55:23

workload (1)

 43:21

world (2)

 35:25;38:17

writing (1)

 12:18

written (2)

 33:21;39:2

wrong (4)

 7:12;15:12;51:17;

 55:15

wrongdoing (1)

 52:18

wronged (1)

 42:23

Y

Yanni (11)

 25:13;26:7,19;28:17;

 29:4;34:10;37:12;39:1;

 47:19;51:3;53:9

year (3)

 7:16;51:22,23

year-end (1)

 53:10

years (3)

 10:19;13:15,24

York (1)

 20:23

1

10 (1)

 23:2

10,000 (1)

 16:17

100,000 (3)

 6:10;7:21;11:22

10th (1)

 6:7

11:29 (1)

 59:12

11th (2)

 22:6,14

12766 (1)

 52:3

12b (1)

 8:9

12b6 (4)

 9:2,4,5;22:23

13 (1)

 3:1

13,000 (1)

 46:12

13.5 (1)

 35:4

155 (1)

 53:16

15th (1)

 22:11

1st (1)

 5:1

2

2 (4)

 22:13,14;51:24;52:3

2004 (6)

 30:3,4,8;37:24;

 44:25;45:10

2022 (1)

 3:1

20-whatever-it-was (1)

 9:9

2nd (3)

 22:11,17;23:2

3

30th (1)

 22:11

36,000 (3)

 53:6,7,11

39 (1)

 52:3

3rd (4)

 30:20;32:14,23;

 39:18

5

5 (1)

 11:22

50,000 (1)

 9:10

500,000 (1)

 57:12

56 (1)

 8:10

6

67 (1)

 53:13

8

8662 (3)

 45:22;46:13,24

9

900,000 (1)

 7:21

9014 (1)

 5:13

99.33 (1)

 53:13

Min-U-Script® eScribers, LLC

www.escribers.net

(12) ways - 99.33 Case: 19-30088 Doc# 12954 Filed: 09/14/22 Entered: 09/14/22 11:09:32 Page 72

of 72