EXHIBIT C

Case: 19-30088 Doc# 3436-3 Filed: 08/07/19 Entered: 08/07/19 16:13:52 Page 1

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SUPERIOR COURT OF CALIFORNIA 

COUNTY OF SAN FRANCISCO 

COORDINATION PROCEEDING 

SEP 2 4 2018 

BY~LE~a'c2 C?URT 

Deputy Clerk 

9 SPECIAL TITLE [RUL:g 3 .550] 

Judicial Council Coordination 

Proceeding No.: 4955 

10 California North Bay Fire Cases 

CASE MANAGEMENT ORDERNO. 3 

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I conducted a ca~e management conf~rence (CMC) September 21, 2018. 

The next CMC is set for October 19, 2018 at 10:30 a.m. The parties' joint CMC 

statement should reflect the results of their meet and cqnfer on these subjects: 

Trial setting. Tue parties shoul~ propose a trial with this detail, for each trial proposed: 

• Which fire (Tubbs, Atlas, etc.). Explain the choice, if the parties disagree. 

• Number of plaintiffs. 

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• Key characteristics of each plaintiff ( e.g. the case includes wrongful death, or type of 

damage ( e.g., agricultural); or presents a key issue [in which case this issue should be 

cited]; or plaintiff is selected randomly. 

o When and how each plaintiff will be identified, and if a series of backup 

plaintiffs whose cases present similar characteristics will be identified. 

• Estimated nwnber of witnesses, with very brief descriptions of their testimony ( e.g. 

expert on topic X, plaintiff on damages, PG&E witness on topic Z, etc.). 

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• Estimated number of days for trial, accounting for cross examination of witnesses by 

all counsel who would have reasons to do so.1 

• Proposed trial date. 

• Proposed county for trial. 

• While some parties have asked for trial in this Dept. 304, if the Department's trial 

calendar does not allow a trial in or around the date proposed, state alternative ( e.g., 

trial in different county; trial judge assigned by the Presiding Judge of this Court on 

the date of trial { master calendar approach}, etc.). 

Plaintiffs have explained that liability-only trials are not feasible because, among other 

things, punitive damages are sought. 

Discovery 

-Discovery cut off. Proposed dates for expert and percipient discovery cut off, given the 

proposed dates of trial' above. 

-PG&E ESL Does the end date of December 21, 2018 still appear feasible? Can 

plaintiffs commence corporate depositions before that date? Are there any remaining 

issues in accessing backups drives? 

-CAL Fire. Status of discussions to obtain access to evidence in the hands of Cal Fire. If 

the parties are unsatisfied with the response by CAL -Fire, state the options the parties are 

considering, how much time it will take to resolve, and the impact on the choice of which 

trial to handle first. 

-Plaintiff's CM0#2 compliance. Plaintiffs. agree to October 1, 2018. Are there any 

remaining issues? If so name the plaintiff law firms responsible. 

1 In Dept. 304, each trial day lasts about 4.1 to 4.2 hours per day exclusive of breaks (time is set aside in the morning 

(9-10 a.m.) and afternoon (4 p.m. and on) to handle the other cases in the Department). 

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-Are there topics where stipulations may be feasible? 

Procedures to refine issues. Aside from motions for summary judgment or adjudication, 

whether the parties contemplate other procedures to refine issue, such as (i) early in limine 

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motions to test the admissibility of significant evidence or expert testimony;2 (ii) early jury 

instruction conference to test what law will apply at trial; (iii) short, bifurcated jury or bench 

trials to resolve key fact or legal issues; (iv) motions under C.C.P 437c(t) to resolve a key legal 

issue. 

Mediation. Approximate dates when the parties will be ready for mediation. This must be 

in advance of any trial. 

Discovery disagreements. Once the parties have finally and completely finished their 

meet and confer on a discovery issue, they may call the clerk of this Department to arrange for 

an informal conference on the matter, with a short (usually no more than 2 pages) statement 

presenting the issue sent to the Clerk at least 24 business hours in advance. 

Dated: September 24, 2018 

Curtis E.A. Karn.ow 

Judge Of The Superior Court 

27 2 If expert testimony will be the subject of such an early motiony the parties will have to agree to conclude expert 

discovery earlier than provided by Code. 

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Case: 19-30088 Doc# 3436-3 Filed: 08/07/19 Entered: 08/07/19 16:13:52 Page 4

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CERTIFICATE OF ELECTRONIC SERVICE 

(CCP 1010.6(6) & CRC 2.260(g)) 

I, DANIAL LEMIRE, a Deputy Clerk of the Superior Court of the County of San 

Francisco, certify that I am not a party to the within action. 

On · SEP i 5 2018 , I electronically served THE ATTACHED DOCUMENT via 

File & ServeXpress on the recipients designated on the Transaction Receipt located on the File & 

ServeXpress website. 

Dated: 

SEP 25 2018 T.1~ Yuen,_ C 

By: V 

DANIAL LEMIRE, Deputy Clerk 

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