Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com)| 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and – 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case 

No. 19 -30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

SUPPLEMENTAL ORDER (A) 

APPROVING APPOINTMENT OF 

ADMINISTRATOR AND ESTABLISHING 

GUIDELINES FOR THE WILDFIRE 

ASSISTANCE PROGRAM AND (B) 

GRANTING RELATED RELIEF 

Related Docket Nos.: 1777 and 2223

Debtors.

 Affects PG&E Corporation 

 Affects Pacific Gas and Electric Company 

 Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

Signed and Filed: June 5, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

June 05, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 2409 Filed: 06/05/19 Entered: 06/05/19 16:07:16 Page 1 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Upon the Order entered by the Court on May 23, 2019 (the “Initial Order”) [Docket 

No. 2233] granting the Debtors’ Motion Pursuant to 11 U.S.C. §§ 105(a) and 363(b) and Fed. R. 

Bankr. P. 2002 and 6004(h) for an Order (a) Authorizing Debtors to Establish and Fund Program to 

Assist Wildfire Claimants with Alternative Living Expenses and Other Urgent Needs and (b) Granting 

Related Relief [Docket No. 1777] (the “Motion”)1 and requiring, among other things, the Debtors and 

the Committees to (i) select forthwith an Administrator for the Wildfire Assistance Program and (ii) 

confer with the selected Administrator forthwith on the terms of an order appointing the Administrator 

and the guidelines for the administration of the Wildfire Assistance Program; and the Debtors and the 

Committees having met and conferred and having agreed upon the selection of an Administrator; and 

upon the agreement of the Debtors, the Committees and the selected Administrator: and upon the 

record established in support of the Motion and the entry of the Initial Order, 

IT IS HEREBY ORDERED THAT: 

1. Cathy Yanni is appointed as Administrator of the Wildfire Assistance Program. 

2. The Debtors are authorized to deposit $105 million into a segregated account 

(the “Wildfire Assistance Fund”) to be controlled by the Administrator who shall be responsible for 

disbursing and administering the Wildfire Assistance Fund in accordance with the Program Terms (as 

defined below). The Debtors shall have no obligation to deposit any additional funds into the Wildfire 

Assistance Fund. 

3. The Administrator shall be responsible for developing the specific eligibility 

requirements and application procedures for the distribution of the Wildfire Assistance Fund to eligible 

Wildfire Claimants (the “Program Terms”) consistent with the following principles and guidelines: 

(1) Eligibility Criteria 

a) The Administrator shall determine the eligibility criteria for 

participation in and receipt of funds from the Wildfire Assistance 

 

1

 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such 

terms in the Motion. 

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Program, including the types of expenses Wildfire Claimants can obtain 

financial assistance for and the amount of assistance to be provided to 

each eligible Wildfire Claimant (the “Eligibility Criteria”). The 

Administrator shall consider the Committees’ reasonable input in 

determining the Eligibility Criteria, and may adopt, modify or reject the 

input in whole or in part. 

b) The Administrator shall consult with the Federal Emergency 

Management Agency (“FEMA”) as to the Eligibility Criteria to ensure 

eligible Wildfire Claimants do not receive funds from both FEMA and 

the Wildfire Assistance Program for the same expenses. 

c) In developing the Eligibility Criteria, the Administrator shall: 

i. ensure that the Wildfire Assistance Fund is distributed in a fair and 

equitable manner, and assistance is prioritized to those eligible 

Wildfire Claimants who are most in need, including those who are 

currently without adequate shelter (e.g., living in tents); and 

ii. ensure that only eligible Wildfire Claimants, being those who lost 

their homes in the 2017 and 2018 Wildfires2 receive distributions 

from the Wildfire Assistance Fund. 

d) The Administrator shall file a copy of the Eligibility Criteria with the 

Court. 

(2) The Administrator’s Authority and Obligations 

a) The Administrator shall be authorized to engage (i) a claims 

management firm, (ii) a legal advisor, (iii) an accounting firm, and (iv) 

in consultation with the Debtors and with the consent of the Committees 

or by further Court order, any other professional the Administrator 

deems necessary or appropriate to assist in administering the Wildfire 

Assistance Program in accordance with these principles and guidelines 

(collectively, the “Program Professionals”). The Administrator may 

also partner with local housing agencies and community organizations 

with relevant experience and expertise (the “Local Organizations”) to 

assist with the administration of the Wildfire Assistance Program. The 

costs of administering the Wildfire Assistance Program, including the 

Administrator’s fees, the fees of the Program Professionals and costs 

associated with partnering with Local Organizations (collectively, the 

 

2

 The 2017 and 2018 Wildfires are the Atlas, Adobe, Blue, Cascade, Cherokee, Honey, LaPorte, 

Lobo, Macaama, McCourtney, Nuns, Norrbom, Partrick, Pocket, Point, Pressley, Pythian, Redwood, 

Sulphur, Tubbs and 37 Fires in 2017, and the Camp Fire in 2018. 

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

“Fund Expenses”) shall be paid from the Wildfire Assistance Fund. 

The Fund Expenses shall not exceed $5 million in total. 

b) The Administrator shall prepare and, within 30 days after the end of a 

quarterly period (or such longer period as may be agreed to by the 

Administrator and the Committees or as authorized by Court order), file 

quarterly reports with the Court and serve such reports on counsel to the 

Debtors and the Committees. These reports shall include (i) the number 

of applications submitted to and processed by the Wildfire Assistance 

Program during the preceding quarter, and (ii) an account of the receipts 

and disbursements from the Wildfire Assistance Fund during the 

preceding quarter. 

c) The Administrator shall keep adequate administrative and financial 

records of the Wildfire Assistance Program, including a record of to 

whom disbursements from the Wildfire Assistance Fund are made and 

in what amounts. The Debtors and the Committees may inspect all the 

Wildfire Assistance Program’s records upon request. 

4. A Wildfire Claimant who receives a payment from the Wildfire Assistance 

Fund and who subsequently is entitled to receive a distribution from the Debtors in respect of a claim 

on account of the 2017 and 2018 Wildfires (a “Claim Distribution”) shall have the amount of such 

payment received from the Wildfire Assistance Fund deducted from such Claim Distribution. 

5. Nothing in the Initial Order, this Supplemental Order or the Motion is intended 

to be or shall be construed as (a) an admission as to the validity of any claim against the Debtors, (b) 

a waiver of the Debtors’ or any appropriate party in interest’s rights to dispute any claim, or (c) an 

approval or assumption of any agreement, contract, program, policy, or lease under section 365 of the 

Bankruptcy Code. Likewise any payment made in connection with the Motion, the Initial Order, this 

Supplemental Order or from the Wildfire Assistance Fund is not intended to be and shall not be 

construed as an admission as to the validity of any claim or a waiver of the Debtors’ rights to dispute 

such claim subsequently. 

6. Nothing in the Initial Order, this Supplemental Order or the Motion constitutes 

or shall be deemed to constitute an acknowledgement or admission by the Debtors of any liability or 

responsibility for any of the 2017 and 2018 Wildfires or for any claims related thereto. 

7. Notwithstanding entry of the Initial Order or this Supplemental Order, nothing 

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

herein shall create, nor is intended to create, any rights in favor of or enhance the status of any claim 

held by any party. 

8. This Supplemental Order shall be immediately effective and enforceable upon 

its entry. 

9. The Debtors and the Administrator are authorized to take all steps necessary or 

appropriate to carry out this Supplemental Order and effectuate the relief granted herein. 

10. This Court shall retain jurisdiction to hear and determine all matters arising 

from or related to the implementation, interpretation, or enforcement of this Supplemental Order. 

APPROVED AS TO FORM AND CONTENT: 

Dated: 3 June 2019 

MILBANK LLP 

By: _/s/ Thomas Kreller___________

Thomas Kreller 

 

Attorneys for Official Committee of Unsecured Creditors 

BAKER & HOSTETLER LLP 

By: _/s/ Robert Julian_______________

Robert Julian 

Attorneys for Official Committee of Tort Claimants 

 

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

CATHY YANNI 

By: /s/ Cathy Yanni_______________

Cathy Yanni 

Proposed Administrator of the Wildfire Assistance Program 

** END OF ORDER ** 

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