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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

-oOoIn Re:

PG&E CORPORATION AND PACIFIC 

GAS AND ELECTRIC COMPANY

Debtor.

_____________________________

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Case No. 19-30088

Chapter 11

San Francisco, California

Wednesday, August 7, 2019

9:30 AM

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

TO COMPEL PRODUCTION OF 

THIRD-PARTY CONTRACTOR 

DOCUMENTS

STATUS CONFERENCE RE 

DISCOVERY

TRANSCRIPT OF PROCEEDINGS

BEFORE THE HONORABLE DENNIS MONTALI

UNITED STATES BANKRUPTCY JUDGE

APPEARANCES:

For the Debtors: KEVIN J. ORSINI, ESQ.

(Telephonically)

Cravath, Swaine & Moore LLP

825 Eighth Avenue

New York, NY 10019

(212)474-1596

For the Debtors: TOBIAS S. KELLER, ESQ.

JANE KIM, ESQ.

(Telephonically)

Keller & Benvenutti LLP

650 California Street

Suite 1900

San Francisco, CA 94108

(415)796-0709

For the Debtors: STEPHEN KAROTKIN, ESQ.

(Telephonically)

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153

(212) 310-8350

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For High Speed Rail 

Authority, California 

Resources Board, 

California Department of 

Toxic Control, et al.:

PAUL J. PASCUZZI, ESQ.

(Telephonically)

Felderstein Fitzgerald Willoughby 

& Pascuzzi LLP

500 Capitol Mall

Suite 2250

Sacramento, CA 95814

(916)329-7400

For State of California: ANNADEL ANGELINE ALMENDRAS, ESQ.

(Telephonically)

California Department of Justice

455 Golden Gate Avenue

Suite 11000

San Francisco, CA 94102

(415)510-3367

For California Department 

of Enforcement of Fire 

Protection:

TRACY LYNN WINSOR, ESQ.

(Telephonically)

California Department of Justice

1300 I Street

Suite 125

Sacramento, CA 95814

(916) 210-7796

For Travelers Insurance 

Company and Hartford 

Insurance Company:

MARK CHARLES BAUMAN, ESQ.

ADRIAN SCOTT LOEWE, ESQ.

(Telephonically)

765 East Bell Road

Suite 210

Scottsdale, AZ 85260

(480) 502-4664

For Liberty Mutual 

Insurance:

KEVIN DALE BUSH, ESQ.

(Telephonically)

Cozen & O'Connor

501 West Broadway #1610

San Diego, CA 92101

(619) 685-1716

For Becky Christensen: STEVEN M. CAMPORA, ESQ.

(Telephonically)

Dreyer Babich Buccola Wood 

Campora, LLP

20 Bicentennial Circle 

Sacramento, CA 95826

916-379-3500

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For Official Committee of 

Tort Claimants:

ERIC EVAN SAGERMAN, ESQ.

CECILY A. DUMAS, ESQ.

ROBERT A. JULIAN, ESQ.

KIMBERLY S. MORRIS, ESQ.

(Telephonically)

Baker & Hostetler LLP

11601 Wilshire Boulevard

Suite 1400

Los Angeles, CA 90025

(310) 820-8800

LARS TERENCE FULLER, ESQ.

(Telephonically)

Baker & Hostetler LLP

1801 California Street

Suite 4400

Denver, CO 80202

303.764.4114

KODY D. L. KLEBER, ESQ.

(Telephonically)

Baker & Hostetler LLP

811 Main Street, Suite 1100, 

Houston, TX 77002

(713) 751-1600

For Public Utilities 

Impacted by the Wildfires:

SANDER L. ESSERMAN, ESQ.

(Telephonically)

Stutzman, Bromberg, Esserman & 

Plifka

2323 Bryan Street

Suite 2200

Dallas, Texas 75201

(214) 969-4910

For California Public 

Utilities Commission:

BRIAN S. HERMANN, ESQ.

ALAN KORNBERG, ESQ.

(Telephonically)

Paul, Weiss, Rifkind, Wharton & 

Garrison LLP

1285 Avenue of the Americas

New York, NY 10019

(212) 373-3000

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For Severson & Werson: BERNARD JARON KORNBERG, ESQ.

(Telephonically)

Severson & Werson

1 Embarcadero Center

Suite 2600

San Francisco, CA 94111

(415) 398-3344

For Official Creditor's 

Committee:

ANDREW M. LEBLANC, ESQ.

(Telephonically)

Millbank LLP

1850 K Street, NW 

Suite 1100

Washington, DC 20006 

(202) 835-7500

For Court Claimants: RICHARD ALAN MARSHACK, ESQ.

(Telephonically)

Marshack Hays LLP

870 Roosevelt

Irvine, CA 92620

(949) 333.7777

For Ad Hoc Group of 

Subrogation Claimholders:

BENJAMIN P. MCCALLEN, ESQ.

(Telephonically)

Willkie Farr & Gallagher LLP

787 Seventh Avenue

New York, NY 10019

(212) 728 8182

Court Recorder: JOHN BOLTS

 United States Bankruptcy

Court

450 Golden Gate Avenue

16th Floor

San Francisco, CA 94102

Transcriber: JENNIFER HAMILTON

 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.

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SAN FRANCISCO, CALIFORNIA, WEDNESDAY, AUGUST 7, 2019, 9:32 AM

-oOo-

(Call to order of the Court.)

THE CLERK: Court is now in session, the Honorable 

Dennis Montali presiding. The matter of PG&E Corporation.

THE COURT: All right, good morning, counsel on the 

phone. I thought, with my invitation for a phone conference, 

that somebody would come to court, but here I have an empty 

courtroom, so what a cha -- what a deal.

Let me just double-check if my four invited guests are 

on the call.

Mr. Julian, are you there?

MR. JULIAN: Yes, Your Honor. And with me are 

Kimberly Morris and Kody Kleber, who are hand -- who are 

handling the discovery issues since they arose.

THE COURT: Okay, and Mr. Fuller, are you with us?

MR. FULLER: Yes, Your Honor. Good morning.

THE COURT: Good morning.

And Mr. Karotkin?

Mr. Karotkinon the call?

No? How about Mr. Orsini?

Well, that's not encouraging, those are the two people 

I wanted on the phone. I have Mr. Orsini's name on the call 

list. Our -- is anyone from Mr. Orsini's firm on the call?

Hm. Well, this is going to be a quick hearing.

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Mr. Julian, have you been in touch with either -- or

particularly Mr. Orsini about the discovery issues?

MR. ORSINI: Hello, Your Honor?

THE COURT: Yeah. Hello?

MR. ORSINI: Is anyone here?

THE COURT: All right, let's try again. Who was that 

who just spoke up? Was that Mr. Orsini?

MR. ORSINI: It is, Your Honor. I don't know why you 

were unable to hear me the first couple of times 

(indiscernible) my line, I apologize --

THE COURT: Okay.

MR. ORSINI: -- but I am here.

THE COURT: How about Mr. Karotkin?

No? Well, okay. Well, all right. I wanted -- the 

reason I asked Mr. Julian and Mr. Orsini, you were the 

principal counsel that were sort of in point position on these 

discovery issues. I realize that both of you are supported by 

lots of other lawyers or nonlawyers and, again, my purpose 

isn't to do anything other than to try to get the word out.

So let me just run through a short list of things, and 

then I'll see what I want to hear from any of you and any of 

the other counsel on the phone. There were a number of items 

on my list. The first one, there was, just again, one of these 

miscommunications that I want to avoid going forward. The TCC 

filed a motion to compel regarding third-party documents on 

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July 25th, and somehow it managed to get on the August 9th 

calendar before there was even a request for shortened time, or 

maybe that it was at the same time, and I was not that 

interested in having things on that August 9th calendar 

because, first of all, I have other matters, non PG&E matters, 

and that -- and then, secondly, that was the specific date 

reserved for any report back from CPUC and the Governor's 

Office and the continued hearing on the two contested motions 

pertaining to compensation matter. And so I just didn't want 

it to get on with the discovery -- any discovery issues, 

because of the congestions.

And so that's why, on the 29th of July, I issued the 

order that led to today's hearing, and said I would take up 

that motion to compel today, August 7th. Well, the very next 

day, the TCC set that motion to compel regarding third-party 

documents out to the end of August on the 27th, and I'm 

wondering: did they --

Wait, I have a correction here.

What?

(Court and clerk confer.)

THE COURT: Okay. Okay, Mr. Karotkin, you're on the 

call now?

MS. KIM: Actually, this is Jane Kim. I'm trying to 

get him conferenced in.

THE COURT: Okay, Okay. Well, let me go forward. I 

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want to move on.

So when the TCC then, a day after I said I wanted to 

hear the motion to compel today, and the TCC set it over for 

August 27th. I'm not going to make a big deal of it. I'm not 

going to take it up today, even though I said I was going to. 

But I want to make sure that everybody in this complicated case 

with so many lawyers in so many places dealing with it, just we 

be on the same page.

And so I'm going to ask again if I set something, 

please don't mess around with the schedule, unless you get --

clarify from me. So I don't need any discussion about it. I'm 

not going to take up the motion to compel because I'll write it 

off to a -- just a failure of communication and not any 

mischief. So I had -- and then I wanted to --

MR. KLEBER: Your --

THE COURT: -- I wanted to just -- oh, yes, sir, 

someone wanted to speak?

MR. KLEBER: Your Honor, this is Kody Kleber. First 

of all, we represent the TCC.

I apologize for any confusion with regard to that 

setting of the motion to compel. I just want to say that we 

interpreted your order as denying the motion to shorten time, 

and that's the reason why we set it for that later date. We 

are, of course, prepared to move forward and argue that today 

if we're permitted to do so.

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THE COURT: Well, I denied the shorten time, but set 

the time, and then the next day, it got set.

And Mr. Kleber, I'm not looking for an apology, I'm 

not mad at anybody, and I'm not even prepared to discuss the 

motion to compel today because I understood what was happening.

So but and further to the whole question of -- I just 

want to make sure we communicate both my chambers and my staff, 

and then all of the various counsel representing so many 

people, that we don't get at further cross-purposes.

So after this discussion back-and-forth about the 

motion, then on July 26th, I received a letter from other 

counsel from the TCC asking for a discovery conference 

regarding a number of matters that are on the subject -- you 

know, on the agenda for today. And again, my observation is 

simply that the ships are passing in the night slightly on 

matters that -- ships don't need to pass in the night, we need 

to make progress down on the -- on the voyage.

So I guess I'm going to encourage each firm and each 

constituency to make sure there's some sort of internal 

consistent coordination as to dates for requested hearings or 

discovery conference or anything that I or my staff or our 

responsibility falls.

So let's not -- let's not spend any more time on it. 

I'm not -- I'm not going to, and none of you need to.

Taking the matters that are left for today in kind of 

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an order of simplicity to more complex, they only thing that 

was an action item that I got from the official creditors' 

committee, not the fire -- not the TCC, but the official 

unsecured creditors committee is Mr. Leblanc's letter of August

1st. And Mr. Leblanc is asking for information about the 

BrownGreer portal, and I'm -- I can ask Mr. Leblanc to tell me 

where things stand on that.

But to the extent that it might be something that Mr. 

Orsini and the debtor is going to tell me about, generally, on 

what's ex -- what's expected from the debtor or from others is 

part of the suggestion that was in the statement from Weil, 

Gotshal that maybe there's been some resolution of all these 

matters.

So why don't I ask Mr. Orsini if you can help me on 

that broader subject? So I'm looking at the debtors' response 

that was filed to my order. It was filed on the 5th. It's 

docket 3371, and it's lengthy. And the first topic is what the 

debtor is waiting for from the TCC and the subrogation group. 

Instead of talking about that, let's go to the second topic, or 

the conclusion of that portion of the filing, that says that 

the debtors and the wildfire claimants are working on an 

agreement that wil provide some sort of a consensual 

resolution.

So Mr. Orsini, is there anything to report in a 

discovery context in that -- in that subject, or not?

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MR. ORSINI: Yes, Your Honor. Can you -- can you hear 

me now?

THE COURT: Yes, sure.

MR. ORSINI: Great. So we have been working -- the 

debtor has been working very hard, whereas some of the trial 

lawyers from the state court proceedings who have been managing 

the BrownGreer database. As Your Honor, will recall, the 

BrownGreer database was originally created through negotiations 

between us and those lawyers, and then was ultimately the 

subject of an order from the state court.

THE COURT: Um-hum.

MR. ORSINI: We have not yet finalized an agreement, 

but I'm happy to report that I believe both sides are of the 

view that we are very close to reaching an agreement. It still 

may not come to fruition, but where we are right now is I 

believe there are only a few terms that are still subject to 

discussion, and the general idea would be to allow access to 

the BrownGreer database; to come to a common understanding as 

to additional information, including documents and other data 

that could be provided through the BrownGreer database 

concerning the underlying damages claims of the various 

wildfire victims; that we would be able to use this mechanism 

to enable further discussions between the debtor and the 

wildfire claimant between now and the bar date, to see if we 

can get to a consensual resolution.

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As the Court knows, we haven't been able to do that 

yet, but data is very important to that effort and so we're 

working on this agreement to try to move those discussions 

forward and also permit the use of BrownGreer to bring a 

significant number of wildfire claims into the bankruptcy 

proceeding as quickly as possible to assist people in meeting 

their obligations under the bar date.

So we're not quite over the goal line yet. We have 

extended the return date on the subpoena we served on 

BrownGreer until August 9th with the goal of trying to wrap up 

the agreement by then. If we're unable to do so, then we'll 

need to come back to the Court and ask the Court to resolve the 

disputed issue of access to BrownGreer. I remain hopeful that 

we won't wind up there, but that's the current status.

THE COURT: Okay. Well, so I take it, then, Mr. 

Orsini, that to the extent that there are topics in your 

response, under Roman I, "Debtors' Request for TCC", that that 

covers much of that. And that's on hold, then, consistent with 

what you said; is that a fair statement?

MR. ORSINI: I think there are some issues that are 

separate and apart from the BrownGreer database that are listed 

in Section I. For example, informational support, the overall 

fifty-four billion dollar figure that --

THE COURT: Right. 

MR. ORSINI: -- the TCC has --

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THE COURT: No, I understand.

MR. ORSINI: -- put forward.

THE COURT: I understand.

MR. ORSINI: So I do think there will be some -- yeah. 

I do think even if we can secure the BrownGreer agreement, 

there might be some other discovery items we're seeking. We 

have requested to meet and confer with the TCC about those. We 

haven't yet been able to do that. But I don't think that 

there's anything ripe for discussion today, but it is all of a 

kind, which is trying to get to the bottom of what these claims 

are valued at, since that is the core (indiscernible).

THE COURT: Well, no, of course. I understand. And 

if you're satisfied, you, on behalf of the debtors, are 

satisfied at least where things stand and don't want me to act 

on paragraph I of your report, I won't. And therefore, no one 

else who was, perhaps, on the other side of that dispute needs 

to even be heard. I'm not going to interject myself in what's 

going forward, and so I'll leave it to you, Mr. Orsini. Should

we put this entire topic number I on hold, or not at this 

point?

MR. ORSINI: I think that would be -- no, I think that 

would be prudent, Your Honor. We will obviously not be shy 

about asking for your help if we need it, but let us continue 

the discussions and come back when they're ripe for 

adjudication.

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THE COURT: Okay. And Mr. Leblanc, are you with us on 

the call?

MR. LEBLANC: Yes.

THE COURT: And --

MR. LEBLANC: Yes, Your Honor, I am. I was just about 

to speak up.

THE COURT: Okay. Well, it was your letter that had 

this one issue, so --

MR. LEBLANC: Yeah.

THE COURT: -- are you comfortable with where things 

stand?

MR. LEBLANC: I am, Your Honor. We filed our letter

at the time that you had asked for those types of letters from 

other parties, so we wanted to make it clear that we had this 

open issue. 

We've been working -- Mr. Orsini has kept us involved 

and kept us in the loop and, in fact, the draft of the 

agreement provides access not only to the debtors, but also to 

the UCC and its professionals. And so we're satisfied with 

that, assuming that stays on course. Our issue can equally be 

tabled to let those discussions run to fruition.

THE COURT: Okay. That's fine. Again, same thing. 

I'm not going to interject myself into this. You gentlemen 

know what you're doing better than I do.

So before I go to open items from the TCC, let me go 

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to the Willkie Farr letter. And that's -- I'm sorry. Let me 

get the right document here. Too many documents come through 

the mail here. 

There was a short list of items that the subrogation 

committee has asked for, and I have managed to set aside what 

I'm looking for. Here it is. Well, I don't know where it is. 

So let me hear from the subrogation counsel. Are 

things stand -- where do things stand from what -- your request 

for information?

MR. MCCALLEN: Sure, Your Honor. This is Benjamin 

McCallen at Willkie Farr & Gallagher on behalf of the 

subrogation committee.

THE COURT: Right.

MR. MCCALLEN: Your Honor, since the TCC and the ad 

hoc subrogation group sent their letters to the Court, we've 

started a meet-and-confer process with the debtors. From our 

perspective, Your Honor, we want to do this as efficiently and 

quickly as possible, and I think there's some ways that we can 

do that. 

You know, the key issue, from our perspective, is 

getting access to the physical evidence that is in the debtors' 

possession and CAL FIRE's possession to conduct physical 

examinations. That was part of our meet-and-confer discussion 

with the debtors earlier this week. My understanding, and Mr. 

Orsini will correct me if I'm wrong, but he's generally 

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speaking in agreement that that's something that can and should 

move forward, provided that we can get an agreement in place to 

have all parties involved in that and to do it in a sensible

fashion going forward that everybody can participate in. 

And so I think, Your Honor, from my perspective, I 

think that the issues related to the physical evidence, I think 

we're going to be able to come to agreement on that. And I 

don't want to bring something to Your Honor prematurely if we 

can come to an agreement on our own. So I think for the time 

being, in the hope that we can reach an agreement with the 

debtors, we can take those issues off the table.

The one issue which I think could be dealt with today, 

Your Honor, because I don't want to bring issues prematurely to 

the Court, is that the TCC has obviously served a lot of 

discovery requests, and we'll get into those in a minute. And 

in particular, anything that the TCC is asking for that is 

relevant to wildfire claims is going to be equally relevant to 

our claims. And in fact, for the final request category we 

have in there, which is documents supporting estimates or 

projections of wildfire claim amounts as set forth in public 

and court filings by the debtors, and the debtors have 

responded saying that they have produced all nonprivileged 

documents to responsive to these requests of the TCC, but those 

productions have not been made to us.

And so I think, Your Honor, one issue that we could 

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address today -- and I don't know if any parties will have any 

objection to this because, frankly, we haven't had a chance to 

discuss it, but is an agreement that any materials that are 

produced to the TCC in response to their requests on the 

wildfire claims would come to us as well, which would allow us, 

I think, Your Honor, to streamline and focus our requests on 

supplemental or additional things the TCC hasn't already

requested.

THE COURT: Okay. Mr. McCallen, I'll ask Mr. Orsini 

or anyone else from the law firm to respond, but in one -- I 

located what I couldn't find a moment ago, and indeed, it was 

the filing that you made on the 1st, number 3352, and that was 

the one that had a list of about eight items. The first ones 

were the nondestructive examination of physical evidence, and 

I'm going to assume that the others on that list, policies and 

practices and procedures and the de-energizing and depositions 

and so on, that's under control for now.

Mr. Orsini, or someone on your side, do you have a 

problem with Mr. McCallen's request that whatever you give to 

the TCC can go to the subrogation group, at least in the way 

it's referred --

MR. ORSINI: Your --

THE COURT: -- referred to in his statement? 

Yes, go head.

MR. ORSINI: Yes, Your Honor, this is Kevin Orsini. 

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I, candidly, thought that they already had a copy of those, so 

I certainly have no objection to getting them a copy of those. 

I do think that it obviously makes sense for the ad hoc 

subrogation group to get any of the discovery that we are 

providing with respect to wildfire liability issues, since they 

have wildfire liability claims.

THE COURT: Okay.

MR. ORSINI: So I don't think there's any issue there.

THE COURT: Okay. Well, I'm glad you said that 

because it seemed to me that that's the sensible approach.

But Mr. Orsini, as long as I've got you speaking 

again, I want to go back to something that I'm unclear about 

that you said. And this is -- what I'm looking at now is the 

BakerHostetler -- that means signed by Mr. Julian -- letter of 

July 26th, and that was the letter that triggered my need, my 

sense that I better get moving on this discovery request. 

And Exhibit 2 to Mr. Julian's letter includes an email 

from you to Mr. Macon that I -- I guess I don't know who Mr. 

Macon is, but I can guess who he is. And what your statement 

concerned me in your letter, your email, was that since your 

group, meaning the subrogation group, has moved to lift the 

stay related to Tubbs, we think the Court needs to resolve the 

question of how these wildfires -- issues will be addressed in 

these proceedings before we embark on a path of discussing 

specific discovery demands. 

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I realize that that's a big question, but we can't put 

discovery on hold while we're dealing with the estimation 

matter that is coming back up on calendar next week. So did 

you mean something else in that statement, if you recall? And 

maybe the specific sentence doesn't pop up into your memory, 

but can you help me on that?

MR. ORSINI: I can, Your Honor. And I know exactly 

what you now are referring to. 

Just for a little bit of context, the letter to which 

I was responding was a fifteen to twenty-page letter from Mr. 

Macon, who is one of the subrogation trial lawyers for the 

state court proceedings, requesting that we open up 

discovery -- I think that his phrase says, that we lift the 

discovery stay and proceed with wildfire liability discovery. 

My response was sent prior to us getting our 

estimation motion on file. And the point that I was trying to 

make in my response was simply that we weren't going to consent 

to lifting the stay, because I wasn't even quite sure what that 

meant in this context, but that we do believe that estimation 

is going to require some form of liability discovery. 

As I'm sure Your Honor recalls, part of our estimation 

motion actually asks for an order directing all of us to get 

together and essentially do what we're doing right now, which 

is talk about how we're going to get the discovery in place for 

estimation.

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So just to state it very directly, so there's no 

ambiguity, it is not our position that liability discovery 

needs to be completely shut off for now until we resolve these 

issues. To the contrary, we completely agree that as part of 

the estimation process we propose, there will need to be some 

reasonable discovery into liability issues. 

I stated in a number of letters subsequent to the 

email Your Honor is citing that we are very amenable to having 

those conversations. As Mr. McCallen just reported, we've had 

meet-and-confers with the subrogation group on exactly some of 

those issues since, and we've made it clear to the TCC, 

generally speaking, we're ready. We do think discovery needs 

to move forward on the liability issues, and we're prepared to 

sit down and negotiate a protocol for that that makes sense to 

everybody, including the Court.

THE COURT: Okay. Again, Mr. Orsini, you're on a 

roll. You've given me the right answer because it seemed to 

me, we -- discovery is a fact. There are no facts that pertain 

only to a state court action rather than a bankruptcy action, 

so you're on the right path, and I won't discuss it further 

unless any other counsel want to raise it.

And come next week, when I deal with -- unless there's 

some change, I'll be dealing with both the relief from stay 

question again and the estimation motion. And by my 

calculation, a whole bunch of people are going to be filing a 

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whole bunch of things between now and then. 

So unless someone else on the phone has a different 

desire, I'm prepared to now go to the debtors' response to the 

TCC discovery and find out from Mr. Julian or any of his 

colleagues what needs action from me and what can we wait on.

So for purposes of tracking where we are, I'm now back 

to the debtor; I guess -- again, I guess Mr. Orsini bears his 

name on there, but it doesn't matter. It's the debtors' 

document 3371, beginning on page 4, "Responses to TCC 

Submission and Subrogation Submission". And there are numbers 

of them, and I see that some have been answered; some have not 

been answered. And I'm ready to have Mr. Julian, or whoever is 

going to speak for the TCC, go down the list and tell me where 

they're satisfied and where they're not satisfied. So let's 

proceed that way, unless someone wants to suggest a different 

approach.

MR. PASCUZZI: Your Honor, this is Paul Pascuzzi for 

CAL FIRE. Can I interject here, before we get into the weeds 

too much?

THE COURT: Absolutely. If you have something good to 

say. Sure, Mr. --

MR. PASCUZZI: Well, I think I do.

THE COURT: Yeah.

MR. PASCUZZI: I think I do, Your Honor. Paul 

Pascuzzi, Felderstein Fitzgerald Willoughby Pascuzzi & Rios, 

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for CAL FIRE. We're co-counsel with the Attorney General's 

Office. There are a couple of Attorney General lawyers on the 

phone, listening, as well.

As everybody has seen, CAL FIRE, I believe, is going 

to be prominently involved in the discovery process here. 

There's already a subpoena from the Singleton Law Firm; there's 

two subpoenas by the tort committee to CAL FIRE indirectly on 

the Camp Fire. And so I wanted to just interject and request 

that the parties kind of coordinate to eliminate duplication 

and overbroad requests and other issues that can arise from 

kind of a scattershot approach.

For example, the ad hoc subrogation committee pleading 

mentions just looking at evidence in CAL FIRE's possession. We 

have not been contacted about that. I assume parties will 

contact us and we'll be able to meet and confer. There are 

going to be some issues with respect to the Camp Fire with 

regard to investigative privilege because there are criminal 

investigation going on. 

So I just wanted to chime in here, just generally, let 

everybody know we're out here for CAL FIRE. We're looking to 

meet and confer and assist in good faith for an efficient 

process, and for the Court not to forget that CAL FIRE is out 

here. 

THE COURT: Okay. Thank you, Mr. Pascuzzi. I'll 

leave it to you to notify all counsel what you want to 

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coordinate. You'll be the center of gravity for that kind of 

coordination. That sounds helpful. That's not something that 

I was aware of, at least from the papers that I read today, but 

that's fine.

All right. Unless somebody else wants to be heard --

MR. PASCUZZI: Thank you.

THE COURT: -- let's go back to Mr. Julian, or 

whoever, if Mr. Julian wants to lead the discussion on what the 

TCC is expecting from the debtors. 

And I do note that, from what the debtors filed, there 

was a promise for a number of documents two days from now. So 

those of you who are waiting for something to happen by August 

9th, you don't have to tell me this morning that you expect it 

on August 9th; I'll assume you all expect it on August 9th, or 

the TCC.

So Mr. Julian, are you going to speak, or Mr. Kleber, 

or someone else in your department?

MR. JULIAN: Your Honor, it's Robert Julian for the 

TCC. And I wanted to divide my comments into two.

First, the seventy open requests that are in our 

response to your order will be addressed by Kim Morris. And 

what she has done is grouped them into four buckets. And she 

will have four common sense solutions for how the debtors, she, 

and the Court can resolve those.

But before she speaks on those seventy open items, 

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Your Honor, I would like to address Mr. Orsini's comments about 

my July 26th letter to you in which the TCC joined in the state 

court leadership counsels' and subrogation claimants' July 1 

letter requesting an opening of discovery for liability issues 

in both the bankruptcy and any relief from stay matter, with 

respect to the twenty fires listed in there.

And Mr. Orsini correctly stated the debtors' view that 

they would like to get together after August 14th to discuss a 

discovery protocol for how to handle those types of discovery 

requests with respect to liability for the twenty fires in 

which the TCC has joined. 

My point is whether or not the parties narrow the 

discovery or not, one thing is clear. We're looking at 

compressed discovery schedules. And that is the reason why the 

TCC joined with the North Bay fire groups in requesting an 

immediate opening of discovery on that. And obviously, the 

debtors can object to some of the request as narrow, but we 

think it's improper to simply say we're still not going to 

produce discovery. 

So we once again ask for discovery to be reopened, 

that those discovery requests be responded to that are in our 

letter. 

And I'd like to point out why we joined with the North 

Bay in subrogation group's request in their July 1 letter, and 

joining in my July 26th letter. The reason is, as you'll see 

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in our estimation brief that we're filing today, that under the 

mass tort procedures that bankruptcy judges and district judges 

have used to coordinate the pending state court litigation that 

has been brought in one way or another into the federal courts, 

either the district court or the bankruptcy court, is because 

the state court litigants have been litigating this stuff for 

two years. And the tort committee creditors' committee has to 

simply work in tandem with the state court trial for a couple 

of reasons.

First, as you've seen in the docket, the Cravath firm 

has been paid ninety million dollars to work up this case for 

two years for both liability and estimation. And we have not 

looked at any of that information, and we haven't spent any 

money at all on preparing because we don't have the 

information. The state court lawyers, on the other hand, have 

about half of the information, but not the rest of the half 

that the debtors have. 

And it's important to realize that in proving, as we 

will have to do, in either an estimation proceeding or a 

district court trial, or in the Tubbs trial, that PG&E 

negligently managed the trees, or the system, or failed to deenergize, that the documents that prove that are uniquely in 

PG&E's possession alone. They have them. They haven't given 

them up. They still haven't given them up. They want to have 

a discovery plan over that.

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Your Honor, we simply can't wait. And we ask for 

today that you simply acknowledge that the parties can go 

forward with that July 1 request and that the debtors be 

ordered to respond to it in some way. And I'd like to be heard 

on that. I'm done with that, but after this, Kim Morris can 

tell you about the four buckets --

THE COURT: Well, let's --

MR. JULIAN: -- that she has, and her four solutions 

for resolving them.

THE COURT: Well, let's come back to Ms. Morris in a 

minute. 

MR. JULIAN: Thank you.

THE COURT: Let me let Mr. Orsini respond to your 

statement that you just made.

MR. ORSINI: Yes. Thank you, Your Honor. So I don't 

quite understand Mr. Julian's statement that I've refused to 

provide discovery until after August 14th. I think I said the 

opposite just a few minutes ago, and I've told him repeatedly 

in letters and discussions over the previous couple of weeks

that we're ready. We're standing here, ready to embark upon 

this liability discovery.

All that we're suggesting is we ought to have an 

actual protocol in place that governs how that discovery is 

going to work: when requests are going to be served, when 

responses will be filed, how we'll address disputes, when 

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depositions can start. Basically, a discovery plan, like you 

have in every litigation with contested, factual issues.

And so I don't -- there's been no effort on our part 

to delay here. We've told them repeatedly we're ready to go 

when they want to sit down and have the protocol put in place. 

Mr. Julian had informed me in a letter last week that they were 

working on a protocol that covers those issues, and we were 

waiting to receive that protocol and provide responses to it. 

So again, I'll just say, we're prepared to move 

forward. We just think, particularly given the amount of 

parties, the number of parties, the compressed time schedule 

that we have by virtue of the June 30th deadline set by the 

legislature, that it just makes sense to have a plan in place 

to get us from where we are today to where we need to be for an 

estimation hearing.

THE COURT: Okay. But let's make sure we're on the 

same --

MR. ORSINI: Yep.

THE COURT: Mr. Orsini, from my point of view, I have 

to decide soon whether to grant relief from stay to two 

different motions -- on two different motions, but really, it's 

the same issue raised by two different moving parties. And if 

I were to do so, then presumably the discovery would be 

governed by the state court processes. If I deny the relief 

from stay and say we're going with estimation -- and I'm not 

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suggesting that it's either/or, but from my point of view, that 

is an option -- and so if we were -- for the moment, let's just

take relief from stay off the table. The debtor has admitted 

that its equipment caused all the fires except Tubbs -- and I'm 

not going to worry about Ghost Ship; that's a different set of 

issues -- so the wildfires, but that's all you've admitted.

And if I read correctly your arguments, and to some 

extent, what Mr. Karotkin argued, if I accept the debtors' 

contention about inverse condemnation, then to say your 

equipment caused the fire doesn't say much of anything, in 

terms of liability. And if, in fact, there's no proof of 

negligence -- there still has to be proof of negligence, 

correct, and no negligence if inverse condemnation applies. Do 

I got the basics right?

MR. ORSINI: A couple clarifying points, Your Honor. 

I think generally speaking, yes. 

Just to be clear on a couple of things, so the debtor 

has acknowledged causation --

THE COURT: Yes.

MR. ORSINI: -- for all purposes with respect to the 

Camp Fire. 

THE COURT: But causation means --

MR. ORSINI: With respect to the other fires --

THE COURT: Causation means my equipment caused the 

fire, right?

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MR. ORSINI: Correct.

THE COURT: But it doesn't mean I --

MR. ORSINI: Correct. And with respect --

THE COURT: It doesn't mean you were negligent?

MR. ORSINI: That's correct, Your Honor.

THE COURT: Okay.

MR. ORSINI: The one other point I want to clarify on 

that point is, with respect to the fires that are not Camp or 

Tubbs, what we have said is we will not contest causation in an 

estimation hearing. 

But Your Honor's absolutely right. If we move forward 

with the estimation process, there are questions of legal 

liability because factual causation does not equal legal 

liability.

THE COURT: I understand.

MR. ORSINI: And Your Honor's absolutely right.

THE COURT: Yeah. But the difference is --

MR. ORSINI: But Your Honor's absolutely right. 

The --

THE COURT: The difference between will not contest 

and admit is like a guilty plea and a nolo plea, right? "Will 

not contest" means the plaintiffs don't have to prove that PG&E 

equipment cause the Atlas Fire, or the -- I can't keep track of 

all the names, but we're putting Tubbs on a separate -- Tubbs 

and Ghost Ship are different. Your statement that will not 

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contest for purposes of an estimation trial means they don't 

have to prove that PG&E's equipment was the physical cause of 

the fire, right?

MR. ORSINI: In an estimation trial, that's correct. 

I'm simply just clarifying that if we somehow found ourselves 

in a different situation, let's say a state court trial because 

the motion to lift the stay on Atlas expires by tomorrow, that 

our agreement not to contest causation is limited to an 

estimation proceeding, not to any potential state court action.

THE COURT: Okay. Okay, that's fine. But if I were 

to grant relief from stay to any plaintiff for any fire, it's 

up to the court in that matter to deal with what do all these 

things mean. 

If I am presiding --

MR. ORSINI: Precisely.

THE COURT: If I am presiding over an estimation 

trial, or if a district judge is supposed to do it, if a 

federal judicial officer in the bankruptcy is doing it, you 

have made it clear that for these purposes, that's not 

contested.

But beyond that, I mean, there is a pretty broad range 

of discovery that's relevant, even for the estimation. Sounds 

to me you don't disagree with that?

MR. ORSINI: Not even a little bit, Your Honor. We 

completely agree with that proposition.

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THE COURT: Okay. Mr. Julian, I think that Mr. Orsini 

clarified it to my satisfaction. Are you -- still want to take 

him on for the way he responded to first your question, then my 

question?

MR. JULIAN: I understand what he's saying, and I have 

two requests that I think can help you see where we're coming 

from.

The first is, by way of background, the North Bay Fire 

litigation, which figures prominently in any estimation 

proceeding, had a bunch of documents produced that are in a 

database that we now have access to for the first time, as of 

last week. But on the eve of the bankruptcy, the debtors were 

ready to produce thousands of documents dealing with liability. 

They told the North Bay group that they were ready to be 

produced on February 15th.

Now, those had been bought and paid for via state 

money. They're in a database that the debtors have, that 

Cravath has. With the touch of a button, more or less, that 

could be produced to us because it was ready to be produced. 

It's already been produced. 

I request that the Court order the debtors to produce 

the discovery that was ready to be produced on February 15th, 

or whatever the date was -- it's already ready to go -- to the 

TCC, and secondly, that the 800 or so investigation reports and 

related documents that the debtors turned over to Judge Alsup 

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that we have not been a copy to be given to us, because they 

directly relate to their responsibility and their cover-up and 

destruction of evidence that is so key in any estimation 

proceeding.

And once again, with the touch of a button, those two 

items could be sent to us. And I'd like a ruling on that 

today, if I may, Your Honor.

THE COURT: Well, let's take the latter of those two. 

The first one, I understand the issue. The second one, when 

what was provided to Judge Alsup, does it relate to the 2010 

San Bruno matter, or does it relate to the wildfires?

MR. JULIAN: As we understand, it relates to primarily

Camp, but also any wildfire. And remember, the reason for 

that, Your Honor, is that the probation hearings have turned, 

now, from responsibility for the 2010 San Bruno gas explosion 

to a determination by Judge Alsup that a term of the probation 

dealing with not violating any other laws or complying with 

discovery disclosures means Judge Alsup is not going to let any 

more fires happen, and he's going to investigate what PG&E did 

with respect to the 2017 and 2018 fires. Those are the focus 

points of Judge Alsup's orders in 2019: responsibility for 

2017 and 2018 fires and the payment of dividends rather than 

putting it into wildfire mitigation. 

So yes, Your Honor. Our understanding is PG&E, in 

response to the 2017 and 2018 questions raised by Judge Alsup

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as to those fires, submitted inspection reports and related 

documentation with respect to their culpability to Judge Alsup.

And it's important to remember that this is so 

important to Judge Alsup and the TCC that Judge Alsup read in 

the Wall Street Journal --

THE COURT: Oh, I know that. I know.

MR. JULIAN: -- an article that said --

THE COURT: I'm aware of that. I've read his order --

MR. JULIAN: Yeah.

THE COURT: -- and I've read the response.

MR. JULIAN: And so yes, Your Honor. His order shows 

that he's focused on the 2017 and 2018 fires, and we want those 

inspection reports and related documents.

THE COURT: Okay. Mr. Orsini, you've taken Mr. Julian 

into two parts. The North Bay data that was going to be 

produced by February 15th, any reason why that shouldn't be 

available now? It seems like it's very relevant --

MR. ORSINI: Okay, Your Honor, I've got --

THE COURT: -- to the estimations. Pardon?

MR. ORSINI: So Your Honor, I need to correct some 

facts, because Mr. Julian's facts are incorrect. There was not 

a set of documents that were ready to go as of February 15th. 

There's no database for which at the touch of a button we could 

produce tens of thousands of pages of responsive materials.

What Mr. Julian is referring to, I believe, is there 

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was an extensive protocol in the North Bay fire cases 

concerning the collection of emails and other electronic 

documents from hundreds of custodians: over a hundred company 

employees, over a course of many years, going back in time. 

And those were then being reviewed and produced, subject to 

technology that was being negotiated between the parties to 

identify that which was responsive. 

There were many technological problems with getting 

that all done. The reality is, there's still months' worth of 

work to do with respect to going and getting those documents 

ready for production, with respect to pulling out the 

privileged information, with respect to preparing privilege 

logs. It's a massive amount of work, data, and documentation, 

the overwhelming majority of which is, frankly, overbroad, 

certainly for the purposes that we're addressing here.

So there's not a treasure trove of information that 

I've just got sitting in some database back at PG&E or Cravath 

where we could hit the button and produce it. 

And this brings me back to, if -- we agree 100 percent 

that we need to engage in some liability discovery. But we 

also need to be cognizant of the schedule we have, as well as 

the debtor resources, and formulate a plan that actually makes 

sense, given the current context. And the current context is 

not state court proceedings that could last for any number of 

years with no deadline in sight.

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So again, I have no objection to producing relevant, 

responsive information. My point is simply that we need to 

work together to put together a process that makes sense and is 

actually accomplishable -- if that's a word; I don't believe 

that it is -- that's actually feasible in the context of the 

proceedings that we have before us right now.

THE COURT: Well, what would have --

MR. ORSINI: That's point number 1.

THE COURT: What would have been produced on February 

15th, if there hadn't been a bankruptcy?

MR. ORSINI: My understanding is very little because 

there was still going to be a lot of work done over the ensuing 

couple of months. I've looked into this issue with my team, 

and there were significant amounts of work left to be done with 

respect to the production of these custodial documents.

THE COURT: And what's your quick response to --

MR. CAMPORA: Your Honor --

THE COURT: Wait. Let Mr. Orsini finish here.

Your quick response, Mr. Orsini, to the 800 or so 

reports that were delivered to Judge Alsup; why shouldn't the 

TCC have access to that? 

MR. ORSINI: I just need to go back and double check 

the facts there, Your Honor. My understanding -- and I'm 

involved in the Alsup proceedings, as I think Your Honor 

knows -- my understanding is everything that we submitted to 

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Judge Alsup was produced -- was submitted publicly. It was 

filed on PACER, publicly available, not subject to sealing

orders or anything like that. So I believe everything we gave 

to Judge Alsup they have access to.

I think what Mr. Julian is actually referring to is 

that there may be some documents that were referenced in some 

of the materials provided to Judge Alsup that we didn't 

actually give Judge Alsup copies of because it was just too 

much information. And if what Mr. Julian is saying is they 

would separately like discovery of those documents, I'm happy 

to review a discovery request, and I expect we would produce 

those.

THE COURT: Okay. Someone else started to speak, and 

I asked that person to wait. Who was that?

MR. CAMPORA: Your Honor, my name is Steve Campora, 

and I represent many individuals in the state court proceedings 

and also in the bankruptcy. And I wanted to comment about what 

Mr. Orsini just said about the document production that was due 

in February and also the documents that were filed under seal 

with Judge Alsup in December of 2018.

THE COURT: Okay.

MR. JULIAN: Yes, Your Honor, may I just supplement 

that? Mr. Campora represents the chair of the tort committee. 

And he does have relevant information, and thank you for 

hearing from him.

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THE COURT: Well, I'm happy to hear from him. 

Go ahead, Mr. Campora.

MR. CAMPORA: Your Honor, in the state court 

proceedings, we have been working with PG&E for this entire 

process to get documents produces for approximately a year. 

And the documents were to be done in February, and I'm happy to 

get copies of transcripts from our hearings before the judge 

and our correspondence on the items, but PG&E was supposed to 

be producing the documents from the prior proceeding by 

February. 

We have been waiting. They have excuse after excuse 

of why they haven't been done in nearly a year, but my 

recollection is, and I'm happy to get the transcript, is that 

there was an order that they be done in February. 

So for Mr. Orsini now to say it was months and months 

away is not accurate, and I'm happy to get those documents for 

you.

THE COURT: I don't want them.

MR. CAMPORA: So with --

THE COURT: I don't --

MR. CAMPORA: -- regard to the documents --

THE COURT: Mr. Campora, I don't want them. I can't 

process the volume of stuff. You need to make -- I take you at

your word, and Mr. Orsini has to figure out how he's going to 

accommodate you or tee up a ruling that I would say that he 

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doesn't have to. But for you to give me transcripts isn't 

efficient because I can't process all that.

MR. CAMPORA: Well --

THE COURT: So --

MR. CAMPORA: -- I'll tee it up however you'd like, 

Your Honor. But --

THE COURT: No, I'll take your word for it that you 

believe that there is some information that would have been 

available, and I'm going to tell Mr. Orsini to respond to that 

in some way. Again, I'm not taking sides here. I'm just 

trying to make the system go.

We all know that the best way to avoid a complaint 

that the debtor isn't providing information is for the debtor 

to provide information. And so Mr. Orsini knows that, and the 

bankruptcy lawyers with him know that. And that's what we're 

stuck with.

So Mr. Julian, I'm not going to make a ruling today, 

but I'm certainly going to -- I'm going to put this request of 

yours on the front burner and tell Mr. Orsini he's got to 

respond specifically and deal with this protocol issue sooner 

rather than later. And that's all I can hope for at this 

point.

MR. JULIAN: Your Honor, thank you for that. And may 

I ask Mr. Campora to explain to the 800 documents that PG&E 

filed under seal with Judge Alsup and are ready for production 

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to us?

THE COURT: Well, I thought --

MR. CAMPORA: Your Honor --

THE COURT: I thought Mr. Orsini said he didn't think 

it was under seal.

But yes, Mr. Campora, go ahead and say that.

MR. CAMPORA: Well, Your Honor, what we've been told 

is that there were 800 documents. There were inspection 

reports and other documents related to the Camp Fire which 

were, in fact, filed under seal or not made public at the time 

it was done in December of 2018. And so those documents are 

the ones we're requesting to be turned over.

THE COURT: Well, Mr. Orsini --

MR. ORSINI: Your Honor, this is --

THE COURT: -- you've got a response? 

Yes, sir. Go ahead.

MR. ORSINI: Yeah. No, I can just cut through this 

one, Your Honor, because I want to get back on a roll. 

As I said, I don't believe we filed anything under 

seal, but I make mistakes. I could be wrong about that. We'll 

go back and take a look, and if there was something that was 

filed under seal with Judge Alsup, those absolutely are readily 

available. And so if that set of documents exists, we'll 

produce them, subject to the confidentiality order here.

If I'm correct, that there was not something filed 

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under seal, then I believe what Mr. Campora and Mr. Julian are 

getting at are documents that were referenced in our 

submissions but not actually provided to Judge Alsup. And as I 

said, I'm also happy to speak to Mr. Julian, Mr. Campora, or 

anyone else about making those documents available to them as a 

separate production. And then the only thing --

MR. JULIAN: Let me rephrase. Let me rephrase; it's 

Julian here. Any documents given to Judge Alsup in camera, 

under seal, or otherwise that are not on the public record is 

what we're referring to and what the Wall Street Journal's 

referring to and what Judge Alsup's referring to.

THE COURT: Well, let me say this. I don't know what 

the procedure is in the criminal court -- in criminal matter 

pending before Judge Alsup. In our court, in the civil matter, 

in the bankruptcy court, if something's under seal, the docket 

will reflect that there is something under seal.

So although the docket, I'm sure, in the docket that 

Judge Alsup has before him is lengthy, there should be a docket 

entry that says there's something under seal.

Now, if, in fact, Judge Alsup did it in some other 

way, I can't know that. But Mr. Orsini said what he's willing 

to do, and certainly, if there was something that was under 

seal by a judge's order, then, as long as the debtors 

voluntarily turn it over, it should be turned over under the 

same kind of protections we have existing in this case for 

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various limited access.

And we don't want to read a sealed document in Alsup's 

court in the Daily Journal tomorrow and San Francisco 

newspaper. So it has to be treated in the same fashion. But

principle counsel for the TCC and the subrogation group would 

seem to me to be entitled to have that. And I'm not drawing a 

line between something other than lead counsel. I'm saying 

consistent with the discovery and the protective orders that 

are in place in our case, that's what I would assume.

Whether or not PG&E needs to get bogged down now in an 

estimation trial about how much was paid out to dividends, prepetition -- I'm not terribly sympathetic to that needing to be 

discovered because I don't think it's probative. But to the --

because they did what they did. And they told Judge Alsup, and 

the public, and the SEC filings what they did, and if the TCC 

wants to argue that that is somehow legally relevant to the 

estimation process, that's another argument that can be made.

But I don't want to have a discovery conference to get 

into a debate about whether details of pre-petition dividend 

distributions are standing in the way of what we're supposed to 

be doing in either the estimation -- well, I say the estimation 

trial because, I'll repeat again, if I'm persuaded to grant 

relief from stay, it seems to me there's less discovery issues 

that are left to worry about here. But that's for another day.

So Mr. Orsini, I'm going to not ask you to put your 

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responses to these issues on my record in this court. You are 

committing to me that you are going to look into one or more of 

these issues to Mr. Julian and Mr. Campora. If I'm pronouncing 

your name incorrectly, I'm sorry. But the principal lawyers 

that are looking for this information. And if you can satisfy 

them, then you will have satisfied me.

And so I won't dwell on it. But Mr. Julian, I won't 

make a ruling, either. I consider this as some progress.

So let's go to the four buckets that Ms. Morris -- can 

you take over, Ms. Morris? Are you there?

MS. MORRIS: Yes, I'm here. Thank you, Your Honor. 

Kimberly Morris of BakerHostetler for the TCC.

The documents in our submission to the Court that were 

numbered 1 through, I believe, 70, can be grouped into four 

separate buckets. One is the third-party contractor documents 

that were the subject of our motion to compel. And I 

understand Your Honor doesn't want to hear that today. We did, 

for clarity sake's, file a notice of hearing for today, and we 

are ready to proceed with that if Your Honor would like to hear 

it. The debtors' response --

THE COURT: Yeah, but you -- please, Ms. Morris. 

Please understand; I take some pride in preparing. But when 

you filed something that moves it over to later in the month, I 

don't prepare for it. So I will let you respond if the 

principal lawyers on the other side want to hear from you. I 

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wouldn't even know what you're talking about.

So have you communicated before this hearing with Mr. 

Orsini or others with him on your position on the third-party 

contractors?

MS. MORRIS: We have. We had communications with them 

and then it resulted in our motion to compel that was filed by 

my partner, Kody Kleber. And the debtors have responded that 

they have produced all of the relevant documents in their 

response to your order for this hearing. And so I believe the 

record is ripe for a discussion of this today if Your Honor is 

willing to take it up.

THE COURT: Okay. Go ahead. All right, so --

MS. MORRIS: Well, I'd first like to get through the 

list of the other topics, just so that you have clarity going 

into this, what those four topics are.

THE COURT: Okay.

MS. MORRIS: One is those third-party documents and 

contracts.

The second are insurance policies, and that made up a 

large section of our list. And those are obviously relevant 

because they're assets of the debtor, and it is important for 

the TCC to understand the coverages that are available for 

their claims -- for the tort victims' claims, as well as 

whether or not notices of claims and tenders of claims have 

been properly made to make sure those buckets of money are 

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available for claims such as this.

The third documents are what I'm going to call boardrelated documents. And these are documents that have been 

outstanding for almost five months now. And the debtors have 

responded that they've produced all -- or have not located or 

produced all nonprivileged documents.

Your Honor, we have not received a privilege log, so 

we're not able to evaluate that response sufficiently without a 

log. So with that request, that one's simple. We just ask 

Your Honor to order the debtors today to produce a privilege 

log for documents that are outstanding for almost five months 

now.

And the last, most important, I believe, for this 

call, for purposes of this call, are the claims estimations 

documents. And those documents, Your Honor, fit into two main 

buckets. They're the settlements relating to prior fire 

claims, so claims relating to the 2015 Butte fire and the 2010 

San Bruno fire, and all the information the debtors are using 

to estimate claims.

They've made many statements, both in financial 

filings as well as in this court and publicly, about the value 

of the liability for these tort claims. And the TCC has sought 

information upon which they're basing that because, as we know 

for financial filings, there has to be some reasonable basis 

for it.

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The debtors have been estimating their liabilities in 

connection with these public filings and public statements 

mainly in reliance upon the underlying settlement agreement. 

Yet in my meet-and-confer sessions with Mr. Orsini, he's saying 

that they're not able to turn over those settlement agreements 

and related documents and that they're producing their internal 

records relating to those settlements in redacted form because 

they contain privileged and work-product information.

Your Honor, bankruptcy courts consistently rely 

upon -- in estimating mass tort liabilities -- consistently 

rely upon prior settlement information, and it's why we cited 

to the Eagle-Picher case underneath our request for the 

settlement data. That case drives home the point that 

settlement data is the most reliable information that you can 

use to estimate claims because it's the direct information on 

how the debtors have handled claims that -- similar claims in 

the past that are being asserted against them now. And to 

ignore that information would be to ignore valuable 

experiential resource that the parties in the case could use to 

estimate those claims.

The debtors' internal records that have been produced 

show that they are relying upon those settlement agreements in 

their internal estimations of the claims here. They have 

produced many of those documents in heavily redacted form. And 

what they have produced is incomplete; we only have maybe less 

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than ten percent of the settlement data related to the Butte 

fire. And the debtors have refused to produce any information 

in connection with the San Bruno fire, claiming that it's a 

wholly different event. However, it is a fire event caused by 

PG&E that resulted in the exact same damages that are at issue 

here, the exact same types of claims. And so we claim that it 

is actually very relevant to look at that information as well.

And they're withholding this information from us 

either in redacted form or in withholding the settlement 

agreements and related documents themselves, claiming that 

they're subject to a mediation privilege and that they're 

subject to other privileges.

And with respect to the mediation privilege, Your 

Honor, they're relying upon California Evidence Code Section 

1119 that states that the documents are protected from 

disclosure. However, there are exceptions to that under 

California law, namely, Evidence Code Section 1123, that say 

that if the settlement agreements themselves contain language 

that they are enforceable or otherwise admissible, that they 

can be -- that they're not subject to the protections of the 

mediation privilege.

But more importantly, Your Honor, this is information 

that can be turned over confidentially to the tort claimants. 

In this case, we heavily negotiated a protective order. That 

protective order contains language saying that if a party has a 

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pre-existing obligation to third parties to treat information 

as confidential, that they can mark it as such, and it would be 

covered by the protective order.

And telling us -- the debtors have told us that we 

need the 1,500 or so underlying claimants that they settled 

those cases with to give their permission to turn over those 

documents. But we don't need that, Your Honor. We have the 

protections of the protective order here and, most importantly, 

the debtors themselves are relying upon this information. 

Bankruptcy courts expect that the parties will all rely upon 

this information, and the debtors are not providing it to us.

So in connection with our request for this 

information, Your Honor, we simply ask that the debtors be 

ordered to produce all settlement agreements and demands in 

connection with the 2015 Butte fire settlements and the 2010 

San Bruno fire settlements, that they be ordered to produce all 

of the internal reports that they're using to estimate claims 

which include their internal reports on these settlements in an 

unredacted form so we're all on a level playing field here as 

we seek to do the most important job which is estimate the 

massive amount of liability in connection with these cases. 

They've been doing it for months, and we'd like to get up to 

speed and be on the same level, fair playing field with them.

And then, lastly and specifically, that they be 

ordered to produce all the information that they're producing 

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to the SEC, in connection with the SEC's almost identical 

request to them -- that they produce information relating to 

their public disclosures and accounting for losses associated 

with the 2017 and '18 Northern California wildfires. 

So the SEC is seeking the same exact information that 

we are, yet the debtors are saying that they're not going to 

produce that in its entirety to us. So our requests are simply 

for those three items to be ordered to be produced today, Your 

Honor. 

THE COURT: Well, Ms. Morris, you did a nice summary 

of the four buckets for you, then proceeded to argue all the 

merits of bucket number four. 

So Mr. --

MS. MORRIS: I did, and --

THE COURT: That's all right. 

MS. MORRIS: I --

THE COURT: That's all right. 

MS. MORRIS: I'm happy to cover the other buckets now 

or just handle this one. 

THE COURT: Well, I'm going to ask Mr. Orsini to make 

my job simple about the privilege log for bucket number three. 

Mr. Orsini, is there some reason why you can't commit 

to a privilege log for what we're going to call bucket number 

three? 

MR. ORSINI: No reason at all, Your Honor. 

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THE COURT: All right. 

MR. ORSINI: We're happy to do that. 

THE COURT: Okay. When is that likely to be produced? 

MR. ORSINI: I will commit to Your Honor that we'll 

produce it as soon as we reasonably can. I'm a little reticent 

to just give you a date right now, because I don't know the 

scope of what's been done on that front and how many documents 

we're talking about. 

If it's acceptable to Your Honor, I will be in court 

next week on the other motions, and I'd be happy to report to 

the Court a deadline that is based upon actually looking into 

the work that's required. But I can commit that we'll do what 

we can in good faith to get it done as soon as possible. 

THE COURT: Well, okay. I'll tell you what. 

MS. MORRIS: Your Honor, if I may respond to that? 

THE COURT: Well, Ms. --

MS. MORRIS: If I may respond, those requests have 

been outstanding for five months. 

THE COURT: Ms. Morris --

MS. MORRIS: And so --

THE COURT: Ms. Morris --

MS. MORRIS: -- I think it --

THE COURT: Ms. Morris --

MS. MORRIS: Yes. 

THE COURT: I can only handle so many issues. And a 

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privilege log is important, but it's not as important as bucket 

four. So I'm going to let Mr. Orsini give either you a 

response on the merits or me a response as to when there'll be 

a response, next week at the hearing. So we have hearings on 

the 13th --

MS. MORRIS: Understood. 

THE COURT: -- and the 14th. So five months is a long 

time, but one more week isn't going to kill the deal. 

So Mr. Orsini, I'll take your word for what you'll 

give us. If Ms. Morris gets the response and she's satisfied 

with the timing, then you needn't come back to me on it. 

So Mr. Orsini, do you want to defer the third-party 

contractor issue, bucket one? Because I was prepared to do it 

because the debtor -- I mean, excuse me, the TCC had kicked 

that one out. What would you like to do about the third-party 

contractor information? 

MR. ORSINI: I can address it now, Your Honor, 

although I do think it would be beneficial to the Court for us 

to have the opportunity to put in a short written response, 

before we take it up. Ultimately, I think it's premised upon a 

misreading on their part of the request they actually 

submitted. We were preparing a response, but then had 

understood, based upon the various notices they filed, which 

confused us, that it wouldn't be taken up today. So I do think 

it would be better for the Court to have the benefit of a very 

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short written response --

THE COURT: Okay. 

MR. ORSINI: -- for us, and then we could take it 

up --

THE COURT: Okay. 

MR. ORSINI: -- at a later date. 

THE COURT: No, give your opponent a response. And if 

they're satisfied, I don't need a response. If they're not 

satisfied, then we'll deal with it on the calendar where it is.

I mean, to me, it's one thing -- as I said at the 

start, I'm not faulting anybody. It would have been better 

that we not have different people setting deadlines. But since 

the TCC's counsel was willing to put things out to the 27th, 

I'm putting them out to the 27th, but maybe we don't get there. 

Okay. So that leaves two buckets. Insurance 

policies, when she --

MR. KLEBER: Your Honor? 

THE COURT: Yes, sir? Yes? Who's that? 

MR. KLEBER: This is Kody Kleber again. 

THE COURT: Oh. 

MR. KLEBER: If I may again apologize for any 

confusion regarding the notice. But the motion to compel, 

regarding third party documents, is on calendar today. We did 

file an amended notice for the hearing today, and it is on the 

docket. We are prepared to speak to that at more length --

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THE COURT: I'm --

MR. KLEBER: -- but if you're inclined to give 

opposing counsel --

THE COURT: I'm not prepared. I didn't --

MR. KLEBER: -- the opportunity to respond, we can --

THE COURT: I'm not prepared. Did you withdraw 

your --

MR. KLEBER: Understood. 

THE COURT: -- setting of it on the 27th? 

Pardon? You did or didn't?

MR. KLEBER: Yes, Your Honor. We filed an amended 

notice setting it for today, in accordance with the Court's 

order --

THE COURT: When did you file that? 

MR. KLEBER: -- denying the motion to --

THE COURT: When did you file that? 

MR. KLEBER: On August 2nd, Your Honor. 

THE COURT: Okay. I just can't --

MR. KLEBER: On August 2nd, Your Honor. 

THE COURT: My staff and I can't keep up with the 

pace. This is going over to the 27th, but Mr. Orsini will be 

responding informally, Mr. Kleber, to you and Ms. Morris. And 

if that satisfies you, that's the end of it. If not, the 

motion will stay on calendar on the 27th, and that's where 

we'll be. 

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Okay. On the insurance policies, when I read the 

written responses on the debtors' filing, I thought that they 

were responding to most of the requests about the insurance 

policy. Ms. Morris doesn't feel that way. 

So Mr. Orsini, what's your response to that? 

MR. ORSINI: Well, I guess we're not quite sure what 

it is that they're looking for, Your Honor. A large number of 

the issues related to the insurance policies were raised with 

us for the first time in their submission to the Court. 

(Indiscernible) through the end. 

As we have set forth in our response, if there are 

specific issues they'd like to address with us, we're happy to 

look into those. More broadly, on the insurance issues, we 

either have provided or will provide everything that we've 

identified that we believe is responsive to their request. And 

some of those are the documents that, as Your Honor noted, we 

said we'd produce by August 9th. 

There are certain categories of policies that they're 

pushing for, in response to requests for insurance that could 

cover wildfire claims, that, after having reviewed them and 

consulted with the internal PG&E insurance experts, we don't 

believe are responsive because they don't cover wildfire 

claims, things like fiduciary coverage for employee benefit 

plans, things like property insurance coverage that covers 

PG&E's property itself. 

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So I think, really, this bucket falls into two 

sub-buckets: a bucket where I'm not sure exactly what it is 

they don't think we've given them, but we're happy to look into 

that; and then a bucket where we believe, based upon our work, 

we've actually satisfied the request, or will, in short order. 

THE COURT: Yeah. Ms. Morris, I, of course, looked at 

the items, the numbers all the way through number seventy, that 

you put there. And I don't know -- I can't tell what kind of 

policies they are. I mean, what's the relevance of a policy 

that might cover a direct loss of PG&E's own property or some 

other kind of thing that really has nothing to do with a fire? 

I mean, why do you want to go exploring things that clearly, on 

their face, aren't going to be relevant? 

MS. MORRIS: Well, Your Honor, it's because we don't 

believe that it's clear on its face that they are irrelevant. 

We have an insurance specialty team that has been reviewing 

these policies and that have worked with policies similar to 

this in the past. And without actually seeing the policies, 

it's not clear that they wouldn't cover claims like this. 

And the debtors are making blanket statements that 

they don't cover claims like this. However, my insurance 

experts are telling me that they could, in fact. And so all 

I'm asking is that the policies be produced and the TCC be 

allowed to make its own determination as to whether or not the 

policies would provide coverage for these claims and an 

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additional source of recovery for these claims, as an asset of 

the debtor. And so all the other lines of coverage for which 

we're seeking are specific to that request. 

THE COURT: Well, looking at your list, starting with 

number 27, that's an errors and omissions policy, and then it 

goes on. After that, there's an all-property insurance 

policies for various years. And in every case, the debtor 

says -- or for many of them, starting with, let's say, number 

32, it says, "Debtors produced this policy. Debtors need 

further information as to what's missing." Well, if the debtor 

produced the policy, isn't that enough for your expert to know 

what that policy insures?

MS. MORRIS: Yeah, my understanding, Your Honor, is 

that we have not received any policies that are specific to 

those lines of coverage. I believe the debtor is referring to 

the fact that their CGL policies or their general liability 

policies may cover some (indiscernible) information, but they 

also may have stand-alone policies in these particular coverage 

areas that may provide additional coverage. 

And so, Your Honor, we'd like to see those policies 

and make a determination for ourselves as to whether they do 

add additional pots of money to the wildfire claim and possible 

recovery. 

THE COURT: So let's again stick with the one that I 

started with, number 32. It's a general liability policy --

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MS. MORRIS: Um-hum. 

THE COURT: -- ACE Bermuda Limited, and I won't read 

the numbers. And your list says, "full policy not produced". 

But are you telling me that your experts need to look at the 

full policy; if they look at the face page or the coverage, 

that that's not going to tell them, by the way, this doesn't 

cover fires? It covers lost furniture or lost something or if 

a PG&E truck crashes into a plaintiff or something? I mean, 

how much information is enough information? I don't know the 

answer here. 

MS. MORRIS: I think I can clarify. When I was 

responding earlier, I was responding to the other lines of 

coverage. As to the specific policies where a policy number is 

referenced here, that's a little bit different. Those are 

either CGL, punitive, or D&O policies. The debtors have 

provided charts that say: here's all the policies within these 

buckets. 

And we've cross-referenced their productions in quite 

onerous detail to those charts, to make sure we have all of 

those policies. And for ones where we say the full policy is 

not produced, we only have maybe a declaration page or an 

endorsement page. We don't have the full policy. And without 

having the full policy, there's no way to tell if that 

coverage -- what the coverage terms are. 

And so I think this is a very easy one to handle. 

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Where we referenced a specific policy number, saying we either 

don't have it or that we don't have a full policy, my request 

is just that you order the debtors to go back and produce that 

full policy. If they don't have it, that we be allowed to take 

discovery from -- we'll serve discovery from their broker, 

Marsh, who undoubtedly has it. 

THE COURT: Isn't this getting a little bit 

attenuated? We're supposed to dealing with estimation of fire 

claims, and now you're telling me you're going to take the 

deposition of the broker to find out if some GLP -- general 

liability policy or D&O policy or some other thing might cover 

the fire losses? I mean, that seems to be such an extreme 

extension. I just don't know why I would permit it. It seems 

overly burdensome. 

And now, having said that, I don't know what any of 

these policies say. But it seems like -- it seems far broader 

than I'd be inclined to order, at this point. I mean, the 

thought of taking a deposition -- of having the TCC lawyers 

take the deposition of the insurance broker, to determine what 

is not evident on the first page of a policy seems like a waste 

of effort. 

I'm going to let the debtors -- I'm going to let you, 

Ms. Morris, tell Mr. Orsini or the debtors, in each of these 

instances where the debtor says, "need further information", 

that you give him a response per item. And if he can respond 

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and is willing to respond, that's fine. If not, I'll do my 

best to try to resolve it. 

But keep in mind, D&O policies don't cover third party 

fire losses the last time I checked, and it's hard for me to 

understand why that would be relevant to you. So I'll leave it 

at that. 

Let's come back to the big question, bucket four. Mr. 

Orsini, why don't we start with San Bruno. Why are you 

resisting giving them information about the San Bruno fire? 

MR. ORSINI: Well, Your Honor, I think there's a macro 

issue that relates to both San Bruno and the Butte fire case, 

that we have to get into first. As a quick response to your 

question, because we don't think the San Bruno fire, which was 

a gas pipeline explosion in a residential neighborhood nine 

years ago, in a circumstance where the company's insurance 

coverage covered all of the losses, is even remotely probative 

of the estimation of damages here. 

It's, as I was explaining to the TCC, not something 

the company has looked at, in any way, shape, or form. To try 

to estimate potential losses with respect to either the 2015 

Butte fire or the 2017/2018 fires, though Ms. Morris's argument 

about the work we've been doing and what the company's relying 

upon -- taking that argument at face value, our own approach, 

given our experience, has been San Bruno's just not part of the 

equation. We think it's a fundamentally different type of 

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event that is not remotely probative here. 

Now, I think the bigger issue that relates, Your 

Honor, to both the San Bruno fire and with respect to the 2015 

Butte settlement agreement that Ms. Morris sort of glided over, 

is there is a very strong, very specific mediation privilege in 

the state of California. And it prohibits either party to the 

mediation to turning over documents that were communicated as 

part of the mediation efforts -- exactly the type of documents 

that Ms. Morris is talking about -- the offers, the demands, 

the back-and-forth in a mediation, and ultimately the final 

settlement agreement. 

So absent an agreement from both sides to waive that 

mediation privilege, we don't believe the documents can be 

produced, given the clear California law. Now, what Ms. Morris 

also did not mention is that I have stated to her that the 

debtor is absolutely prepared on its part to waive the 

mediation privilege with respect to the 2015 Butte settlement. 

If the TCC has been arguing that they're entitled to, 

in total, fifty-four billion dollars in damages based upon some 

ratio analysis to the 2015 Butte settlement, as we've stated in 

the filings to Your Honor, we just believe that's flat wrong. 

The (indiscernible) believe that's flat wrong. And we frankly 

believe that analyzing the specifics and the trends of the 

Butte settlements will demonstrate why that was a different 

fire at a different time in a different place under a different 

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insurance regime. 

And so we are one hundred percent prepared to waive 

the mediation privilege with respect to the 2015 Butte fire and 

provide that information. The problem is we don't get to waive 

that ourselves. It's not a one-party waiver scenario. And so 

we asked the TCC almost a month ago whether they could talk to 

the trial lawyers who they're working with, including Mr. 

Campora, who the Court heard from earlier, to see if they would 

be willing to waive the privilege with respect to their part. 

We never got an answer back to that until after they 

had already told the Court that the issue was ripe for 

determination. We had a subsequent call, where I said we were 

still waiting for this, and they told us that the answer from 

the trial lawyers was it's too much work. It's too much work 

to go back and try to get this consent from 1,500 people. 

We don't have a whole lot of empathy for that 

position. But in the end of the day, from our perspective, 

we're stuck here, because we have California law that says we 

can't do this. We've said we're willing to waive this. 

They're here arguing to the Court that we're stonewalling and 

trying to hide this, but they're unwilling to make the effort 

to actually get the consent that would be needed to get access 

to the documents. 

The reference to confidentiality order solves nothing. 

The confidentiality order, as the Court well knows, is just 

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about exactly who can see a set of documents that are produced. 

But if the law says the documents can't be produced in the 

first instance -- and that's what the mediation language seems 

to say -- under California state law, the fact that you 

produced it subject to a confidentiality agreement doesn't 

change the fact that you've made an unlawful disclosure. 

THE COURT: Okay. Let me ask you this question.

MR. ORSINI: And so --

THE COURT: Mr. Orsini, I seem to recall there were a 

number of Butte County plaintiffs who settled and got paid and 

were home free, and a large number of others complained because 

the bankruptcy stopped them. Focusing on the latter group, the 

plaintiffs who settled with Butte on Butte fire but didn't get 

paid, they will either fish or cut bait. They will either file 

a claim, or they won't. Correct? And so if there --

MR. ORSINI: I would expect so, Your Honor. 

THE COURT: If there's a victim of the Butte fire who 

has a settlement agreement that says you're entitled to X 

dollars and that person doesn't file a claim, that person might 

be out of luck. If the person does file a claim, it would seem 

to me -- I don't know where there's a privilege or perhaps a 

privilege waived as to the final document. I'll leave aside 

the negotiations and the backs and forth. 

But at the end of the day, if there's a document that 

a claimant files to say, I settled for X dollars; here's my

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settlement agreement; this is my claim, it's hard for me to 

imagine that that document is privileged any longer. Do you 

think, Mr. Orsini, that's a correct, accurate statement or an 

inaccurate statement? 

MR. ORSINI: Well, to answer the question, Your Honor, 

I don't really know the answer to that, and that's part of what 

we're struggling with here, because I think the face of the 

mediation statement -- the mediation privilege -- would 

arguably say -- and I think, right on its four corners would 

say they can't disclose that settlement agreement in this 

context. Now --

THE COURT: But the claimant --

MR. ORSINI: -- as you just heard me say --

THE COURT: But the claimant can. If PG&E --

MR. ORSINI: Well, no. I don't think so, Your Honor. 

THE COURT: Wait a minute. If PG&E publicly states 

that it will waive a privilege for people they settled with --

MR. ORSINI: Yes, that's where I was going. 

THE COURT: -- and Mr. X --

MR. ORSINI: Yes. That is where I was going with 

that. 

THE COURT: -- settled, and he files his proof of 

claim, that sounds to me like a waiver of any privilege. 

Now, Ms. Morris --

MR. ORSINI: I think you're right, Your Honor. That's 

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where --

THE COURT: Okay. 

MR. ORSINI: Sorry. 

THE COURT: Ms. Morris, is that your understanding of 

the California law? If both sides to the settlement meet and 

waive the existence or the four corners of the settlement 

document, isn't that their prerogative? 

MS. MORRIS: I agree with you that the parties can waive the 

settlement privilege, Your Honor, but I don't think that that's 

the relevant analysis here. The analysis is the fact that it's 

not covered by the mediation privilege from the get-go because 

of the related evidence code Section 113 -- 1123 which says 

that they're not subject to the mediation privilege or 

protection if the policy includes language that is admissible 

or subject to disclosure, or words to that effect. Or if the 

agreement provides that it's enforceable or words to that 

effect.

So the protections are -- include specific additional 

provisions that would take them outside of the mediation 

privilege themselves. 

THE COURT: Well, I don't --

MS. MORRIS: And beyond that, Your Honor --

THE COURT: But again, how do I know that? How do I 

know what they actually say? I don't know. Who knows? 

MS. MORRIS: Well, that's the point. We have no 

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testimony or evidence before this Court that any of these 

documents are subject to the mediation privilege or are marked 

as such. 

THE COURT: Well, we have on your side of the debate 

here, the plaintiffs' lawyers. And they are in a position to 

express their opinions as to whether their own clients have 

waived a privilege. Again, that's not -- they didn't do 

anything wrong. The question is if there's a settlement 

agreement between Mr. X and PG&E and it has on it's face the 

kind of language you say, then why would anybody assert that 

it's privileged? But if the debtor says, we waive any claim of 

privilege, it seems to me the ball is in the TCC's court and 

the option to make those documents available freely and 

voluntarily. 

Remember the TCC and its bankruptcy lawyers want to 

put together all this information to come up with an estimation 

of the aggregate claims for purposes of confirmation of a plan. 

We are not talking an individual's particular rights. In fact, 

if there's been a settlement, I don't know that there's 

anything to talk about in terms about estimation. It's a done 

deal. It's not an unliquidated claim, it's not -- it's 

certainly not contingent, and it's not disputed. So it's the 

unliquidated claim that we're talking about.

So I guess what I'm saying --

MS. MORRIS: No, actually, Your Honor --

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THE COURT: Go ahead. Why isn't it --

MS. MORRIS: Sorry. 

THE COURT: Doesn't it -- why isn't it a liquidated 

claim and therefore isn't even up for estimation? 

MS. MORRIS: But we're not seeking the settlement 

agreement -- the 1,500 settlement agreements from Butte and the 

hundreds of settlement agreements from San Bruno, we're not 

seeking it for purposes of determining the value of those 

claims. We're seeking them, quite frankly, for the same reason 

that the debtors are using them. Because they provide a lot of 

useful data points from which the TCC and all the parties can 

use to estimate claims in this process. 

All of the debtors' documents that they've produced so 

far give reference to the fact that they are relying upon prior 

settlement data to analyze what the value of the future claims 

are worth. Because they're identical. They contain property 

losses. They contain nuisance claims. They contain zone of 

danger claims. They contain emotional distress claims and 

wrongful death claims. They're the exact type of claims under 

very similar circumstances as what we're trying to estimate now 

and the debtors recognize the relevance and importance of this 

because they're relying upon them in how they're approaching 

estimation.

And so the bankruptcy courts regularly recognize this 

and the Eagle-Picher case is probably the most prominent one on 

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point but all of the (indiscernible) cases do as well.

THE COURT: You know, it doesn't help -- Ms. Morris, 

it doesn't help for you to keep citing a bankruptcy court level 

case. It's not controlling doctrine. I will consider it but, 

on the fly, I can't. Okay? I prepared for a discovery 

dispute, not for a legal argument about the applicability about 

another bankruptcy court decision. 

And I know it's an important case but I don't -- I 

have to deal with it in this case. If to the extent -- you 

persuaded me that to the extent that the debtor is going to 

rely on this data for its part of the calculation to estimate, 

then indeed they -- you should be entitled to it also. I don't 

disagree with that. 

But I will say that if there is a claimant who settled 

and the only thing that happened is that -- well, one --

claimant A settled and got paid, claimant B settled and didn't 

get paid, those two claims may be relevant for various purposes 

but neither of them is disputed or unliquidated. Each is 

liquidated and each is undisputed.

Now, does that mean it's taken into account for 

purposes of the estimation? I don't have an answer. But I 

would think that the inquiry that the trier of fact has to make 

here for purposes of confirmation or -- well, for confirmation 

purposes at the moment, is that's not an unliquidated claim, 

it's not considered. Now, I -- you all and you, Ms. Morris, 

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specifically, have done much more research and learning on 

this. I have not. So you may believe that I have overstated 

or oversimplified and if so then I will hope to be educated 

when I have to. For now, I'm just dealing with it as a 

discovery dispute. 

And so I -- look, I'm looking for a solution for at 

least the Butte fire discovery question and it strikes me that 

maybe the answer is found in the plaintiffs' willingness to 

consent, at least, to the providing of the information that 

we've talked about.

Mr. Orsini, was that you about to speak or someone? 

MR. ORSINI: It was, Your Honor. I was going to 

offer, at least what I view is a constructive solution. One 

piece of it is what you just said which is that the easiest 

path here is for the plaintiffs' lawyers to get the consent of 

their clients and then we don't have an issue. Because 

ultimately, as I stated Your Honor, the debtors want to get 

this information into the TCC's possession and ultimately 

before the Court. What I can't do is advise my client to 

produce documents when I think we might be violating California 

state law. 

And so I think in the first instance, the easiest 

solution is the consent from the plaintiffs' counsel. And if 

we're unable to get that consent, frankly, it raises my concern 

about producing the documents because you don't hear them 

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saying that the documents can just be produced. And so we've 

got a legal question as to the ability if the debtor, my 

clients, turn them over. If we don't get the consent of the 

plaintiff's lawyers, maybe then we need to have a motion teed 

up for the Court, I hate to suggest more paper Your Honor but 

this is an important issue, we have a motion teed up for the 

Court, a motion to compel from the TCC, where they can set 

forth specifically why they believe we actually can produce the 

documents under California law. We can provide Your Honor with 

a counterargument and if Your Honor agrees with the TCC which, 

you know, frankly, would be the outcome we're looking for here, 

there would be an order that requires us to produce the 

documents. 

THE COURT: Well, Mr. Orsini --

MR. ORSINI: As we stand here --

THE COURT: Mr. Orsini, why can't you in the aggregate 

estimate -- why can't you say, what are the amounts and the 

number of claims settled and the number and the amount of money 

paid or committed to be paid to settle Butte? That doesn't 

disclose a specific --

MR. ORSINI: But we can, Your Honor.

THE COURT: I mean, when it comes to an estimate -- if 

we were having an estimation trial, we wouldn't be looking at 

individual documents, we'd be looking at the aggregate. And 

this goes back to my point about if the claims are liquidated 

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and no longer disputed, I don't even know they are relevant. 

But let's assume that it is. Certainly the debtor is able to 

say, we had X number of claims asserted against us in Butte and 

we settled for Y amount of dollars. And I would think that 

that might very well be probative in terms of, well, okay, what 

is the inference one might draw to estimate the claims for the 

Atlas fire or the -- some other fire, if there's a comparable 

of fires. There certainly might not be comparable fires but 

they're comparable of the kinds of damages that are asserted by 

the victims and what got them compromised and settled. 

MR. ORSINI: And to address that, Your Honor, I do 

believe we can disclose the aggregate number. We have 

disclosed that aggregate number. It's in the company's 

financial statements. The aggregate numbers are in the 

documents that have already been produced to the TCC. But this 

is where there could be significant prejudice to the debtors 

and other stakeholders if we're just talking about the 

aggregate number. 

A fire from 2015 that involves different geographies, 

different claims, different insurance law, we don't believe the 

aggregate number itself would fairly and accurately describe 

what an estimated liability would be for the current fires. 

THE COURT: But isn't that for your --

MR. ORSINI: And while the --

THE COURT: -- isn't that for your expert to say? In 

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other words, doesn't --

MR. ORSINI: It is, Your Honor. It absolutely is for 

our expert to say, but how can our expert do that and how can 

our expert do that with any level of confidence to present to 

Your Honor if the expert can't dig into what drove particular 

settlements. But why it -- you know, taking a sampling of the 

settlements, why did this amount of money get paid out for this 

type of claim?

THE COURT: But that -- Mr. Orsini, I --

MR. ORSINI: And how does that --

THE COURT: I think that's why estimation is 

different. In other words, if we were having a trial with a 

group of plaintiffs here each to prove his own case and it may 

be inappropriate to look to see the specifics of settlements of 

some prior claims of some prior people in comparable 

situations. But when there's an estimation, by definition it 

is an aggregate approach.

Now, I believe that an expert on one side or the other 

might try to say, well, why is the Butte fire different from 

the Camp fire, or the Tubbs fire, or any other fire? And 

indeed, I'm sure your experts would say, well, of course, the 

San Bruno fire is completely different and so was the Goshen 

fire. Because they are different. The question is whether 

they are relevant for purposes of making an estimation, and if 

an expert says, you know, whether it's Atlas or Camp or you 

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know whatever the other names of all the other fires, it's all 

part of the aggregate estimation of property damage, wrongful 

death, personal injury, et cetera. That's much different. 

So I guess what I'm saying is that I don't know why 

you can't provide enough detail that protects the privilege but 

is responsive to how do you, as PG&E's counsel go about your 

estimation of this component called the Butte 2015 fire. And 

it seems to me that could be shared with the plaintiffs. 

And I don't know this for sure but I'm pretty sure 

that the estimation process is unique to bankruptcy. I 

don't -- there may be similar processes in class actions and in 

multi -- mass tort litigation under state law or even under 

federal civil practice but in thinking about this case, as I 

have a lot lately also, and reading the briefs, I'm not sure 

I'm aware of any counterpart or corollary to the estimation 

process that has to be done under Section 502(C). 

So let's get back to work. Ms. Morris, I think --

MS. MORRIS: Your Honor, if I could respond to --

THE COURT: Well, I think --

MS. MORRIS: -- your comments and Mr. Orsini's? 

THE COURT: Well, yeah. But I think you're going to 

have to be -- give me more information before I can order what 

you want me to order at this point. And I -- including -- I'm 

really not at all of the view that the San Bruno fire is fair 

game for this one. 

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But go ahead, Ms. Morris. 

MS. MORRIS: Sure. Thank you.

I think Your Honor is exactly right on the relevance 

of this information. It's information that the debtors are 

relying upon in how they're estimating the tort claims here for 

'17 and '18. And it's relevant because it's the exact same 

types of causes of action and damages that were occurring in 

2015 are occurring here in '17 and '18. 

And the bigger picture is that we are looking at maybe 

a six-month window in which we need to estimate claims. The 

debtors have been looking at this data set for months and 

months. And they're using it to estimate claims and they're 

referring to it in public filings and internal documents as the 

source of how they're estimating the claims that they 

aggregate. And it's even broken down by different categories 

of losses, like, tree loss and emotional distress. These 

documents are extremely relevant. 

We are happy to brief the issue on the settlement 

agreements and related documents themselves. But at least for 

today -- and to put the TCC on the same footing as the debtors 

and looking -- and starting to estimate plans and look at how 

we're going to estimate claims in this expedited process, we 

would ask that you order, at a minimum, that the debtors be 

forced to produce their internal data spreadsheets -- and we 

know they have them because we have them for a hundred or so of 

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the Butte cases -- the internal spreadsheets that give the 

settlement amounts in the aggregate, as well as their 

allocation of those settlement amounts to various types of 

claims, like, property loss, tree loss, emotional distress, 

because that's exactly what they're referring to in their 

estimation-related documents, and we should be given access to 

the same thing. And then we can separately brief the issue, as 

Mr. Orsini suggested, on the actual settlement agreements and 

demands themselves, if Your Honor wishes. 

There's over 2,800 people who settled these claims in 

San Bruno and in Butte. Some of them are no longer living. 

The plaintiffs' lawyers do not represent all 2,800 and they 

can't consent on behalf of 2,800 people. 

So Mr. Orsini's suggestion that we have to go back to 

2,800 people is a nonstarter, and not only that, we contend 

that it's not necessary under the relevant California law, but 

we can brief that issue. 

But at least for purposes of today, we'd ask that Your 

Honor rule that they have to produce the spreadsheets that show 

the settlement amounts with the allocations to the various 

categories of the plan. 

THE COURT: Mr. Orsini, are you willing to continue 

your hat trick of roles here? Are you going to agree to that 

spreadsheet?

MR. ORSINI: I would love to, Your Honor, but I can't 

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because I don't believe it's a separate issue. It's the same 

mediation-protected information just taken out of one document 

and put into another. That doesn't change the fact that --

THE COURT: But what makes that document -- what makes 

that internally and generated aggregate document privileged? 

It's --

MR. ORSINI: Because the information contained in 

the -- the information from the mediation itself is what is 

protected from disclosure. 

THE COURT: Well, how are you --

MR. ORSINI: And so it's not --

THE COURT: Well, how are you going to produce it at 

trial? I mean, you're not going to have a trial --

MR. ORSINI: Well, Your Honor, that's where --

THE COURT: -- with only one side here, are you? No, 

I mean --

MR. ORSINI: Well, no, we don't want to have one, Your 

Honor. 

THE COURT: Mr. Orsini --

MR. ORSINI: And that's --

THE COURT: -- if you've got twenty -- forget --

again, I'm going to put San Bruno aside. So Ms. Morris said 

that there are 2,800 settlements. Let's assume there's some 

large number lower than 2,800. So that means that there are 

some numbers of settlement agreements. But all of those 

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settlement agreements are considered in the aggregate and put 

into a spreadsheet for you to say, our total exposure for 

personal injury was this, and tree damage was that, and 

property damage was that. What makes that spreadsheet or that 

work product privileged? It's not. 

MR. ORSINI: No, but there are two issues though, Your 

Honor. Number one, with the spreadsheets that Ms. Morris is 

talking about, we've provided aggregate numbers. But the 

spreadsheet that she's talking about is breaking it down into 

damages category, and then breaking it down further into 

individual settlements. And the individual settlement level 

information is protected by mediation privilege. 

THE COURT: Does the spreadsheet --

MR. ORSINI: And also (indiscernible) --

THE COURT: Wait, hold on. Does the spreadsheet name 

the claimants, the individuals?

MR. ORSINI: It does, Your Honor. It does, Your 

Honor. 

MS. MORRIS: Your Honor, if I could -- if I could 

interject. We have one of those spreadsheets already and 

they've redacted the identifying information for the claimant. 

They produced a spreadsheet related to the 2015 San Bruno fire 

and it redacts the --

THE COURT: No, 2015 --

MS. MORRIS: -- names of the claimants. 

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THE COURT: 2015 --

MS. MORRIS: I'm sorry. I'm sorry 2000- --

THE COURT: -- Butte fire. 

MS. MORRIS: Yeah, sorry. Thank you for the 

clarification. The 2015 Butte fire and it redacts the 

claimants' names but it's only for a hundred of those 2,800 

settlements. 

THE COURT: Okay. 

MS. MORRIS: The one thing that they did redact was 

their allocation of which amount goes to which bucket, which is 

absolutely necessary here for the claims estimation process. 

In addition, they've produced this information to the 

SEC as part of the SEC's investigation. And so we contend, 

Your Honor, that they can't selectively redact this information 

and rely upon it for estimation and selectively redact it. And 

so we've seen the version of the spreadsheet. Our request is 

that they produce it, not just for a hundred, that they produce 

it for all 2,800. 

THE COURT: Okay. Again --

MS. MORRIS: And that the redactions that are not 

identified redactions be removed. 

THE COURT: Ms. Morris, again, I'm --

MR. ORSINI: Your Honor, if I may?

THE COURT: -- I'm not rolling over on San Bruno. So 

I'm prepared, I think, to agree with you for Butte until Mr. 

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Orsini tries to persuade me otherwise. But it seems to me 

redacting the names of the individuals does not disclose what a 

particular individual's claim was or what you settled with that 

individual for because you don't tell who the individual is. 

So what's wrong with that reasoning?

MR. ORSINI: So Your Honor, that may very well be 

accurate reasoning, but I think that issue needs to be briefed 

because it's not clear to me that California law supports that 

outcome. And so all I'm asking is that the Court hear both --

THE COURT: But do you have any sense that why would 

California do it? In other words, did PG&E, did you breach the 

confidences of the mediation when you turned it over the SEC?

MR. ORSINI: No, Your Honor, because we did not 

provide anything to the SEC that were not already -- that we 

have not provided to the TCC in this context. They got the 

same version of this spreadsheet that the SEC received. 

THE COURT: Then give them --

MR. ORSINI: We made redactions --

THE COURT: Give them the same version of all the 

spreadsheets then for Butte. 

MR. ORSINI: We've said we will, Your Honor. We've 

said we will. 

THE COURT: Well. 

MR. ORSINI: The SEC was focused, Your Honor, on one 

particular -- or a couple of years' worth of disclosure. And 

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so the more recent versions of the spreadsheet that cover later 

years and more of the settlements, the SEC was not interested 

in receiving. 

So what we've said is, we will provide, in the same 

redacted form, the updated years to the TCC. We've already 

said we would do that. 

What the real dispute here, Your Honor, is, is with 

respect to the more detailed information with the offers, with 

the agreements, with the responses, and that's the one that I 

think Your Honor needs to be --

THE COURT: But I think I've --

MR. ORSINI: -- briefed, and there --

THE COURT: But I've agreed -- I'm agreeing with you 

on that. But that's --

MR. ORSINI: No, I understand, Your Honor. 

THE COURT: That's not relevant. 

MR. ORSINI: I just wanted to make sure --

THE COURT: That's not, to me, if we were at a trial 

and the issue -- look, for those of you that are not bankruptcy 

lawyers, let me just give you Bankruptcy 101 here. We could 

have an -- and leave aside whether it requires Article III or 

not, that's not my point for what I'm making. 

You could have an estimation trial with one claim. 

You could have one individual who was injured by someone in 

bankruptcy, but it's going to take years to determine the sum 

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total of that person's injuries. But you would have to 

estimate it to move under 502(c) -- for 502(c) to operate. 

And so you wouldn't have a trial, you would have 

something else, an estimation. What do you have to do to 

estimate this individual? The person lost a leg. Okay. What 

is the damages? This person suffered traumatic injury. What 

are the projections? Well, this person suffered crippling 

physical injury. What are the estimations? And it's an

estimation. 

So when we multiply it by thousands, obviously, it 

gets more complicated. But it's the same inquiry. It's not 

the trial, it's the estimation of the liability. 

So I'm inclined to -- of the opinion that, for 

openers, anything that relates to any of the fires that we're 

talking about, and the only thing we've talked about today in 

calendar year 2015 is the one fire about Butte in Butte County. 

I don't remember, going back to the hearing we had on the claim 

deadline, whether there's some other fires that I've forgotten, 

but you all know what fires are part of the aggregate label 

California Wildfires. And we know that Ghost Ship is in that 

label, San Bruno is not. And I'm not talking about the Ghost 

Ship issue today. 

So at least for today's purposes, without further 

briefing, I'm inclined to say that the debtor will have to 

produce, for the Butte 2015 fire, all the information that it's 

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given to the SEC. 

And for now, I'm not going to order them to produce 

anything about the San Bruno fire because I'm not persuaded 

that -- at this point, that the San Bruno fire explosion, and 

what happened there, would be legally relevant at an estimation 

trial for the 2015, '17, and '18 wildfires. That's not, and 

I'll keep an open mind about it, but I'm doing this on the fly 

today, and Ms. Morris, I'm not prepared to give that to you at 

this point. 

Now --

MS. MORRIS: Your Honor, could I just seek one 

clarification of your order?

THE COURT: Yes. 

MS. MORRIS: So Mr. Orsini said that the only 

information they gave to the SEC are these hundred cases, a 

spreadsheet that we already have. And it's a hundred of the 

over 2,000 settlements from 2015. 

I would request that you consider clarifying your 

order to include all of the 2015 Butte settlements and include

all of the allocations that PG&E used to put the total 

settlement amount into the different buckets of claims because 

that's how they're using it for purposes of estimation. 

THE COURT: Well, I --

MS. MORRIS: And to put everybody on the same playing 

field, that's how we'd like to use it. 

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THE COURT: Ms. Morris, I thought I was -- maybe you 

did a better job of restating it. That's what I had in mind.

So Mr. Orsini, that's what I intend by this ruling. 

MR. ORSINI: Your Honor, just to clarify, we have no 

objection to providing additional spreadsheets that provide the 

same level information that we provided to the SEC, which will 

cover additional settlements for additional years. 

What we do object to providing, on the basis of the 

mediation privilege and the point I was getting to, there's 

also attorney work product associated with it, the unredacting 

that which was redacted to the SEC, we don't believe is 

appropriate, and that needs to be further briefed if the 

Court's going to order that issue. 

THE COURT: No, I'm agreeing with you. I mean, I 

don't know what this spreadsheet looks like. But if the 

spreadsheet has Mr. X is the plaintiff, and you believe 

disclosing his status or his, as it is, and it's in any way 

relevant to -- I mean, it may be relevant -- it may be public 

knowledge, he may have been a coplaintiff, it doesn't matter. 

If it links up to something that PG&E has settled that should 

be privileged, then I'm not changing that at this point. 

But the allocation into the nature -- I mean, look, if 

you say whatever the number is, 2,200, 25, you know better than 

I the number of claims that are 2015 Butte fire settlements. 

There is a spreadsheet that one could look at and determine 

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lots of information, what kind of claims were settled and what 

were the aggregate amounts settled. It seems to me that is 

perfectly proper. And to me, the test here is, if you think 

you would have the -- you would be able to produce it at an 

estimation trial, clearly, they have to have it the same way. 

They, meaning TCC, but also the subrogation committee. 

And certainly, it goes without saying, that the 

information that's provided to the SEC has to be given to those 

two groups as well. And I'm not asking for attorney-client --

excuse me, attorney work product. I'm not asking for specific 

disclosures that are, at this point, on this record today, were 

part of a settlement agreement. 

If Ms. Morris is right that the settlement agreement 

on its face has an opening for disclosure elsewhere, let's find 

out. You've provided her, I take it, with specimens of 

settlement agreements, haven't you?

MS. MORRIS: No, we haven't Your Honor. 

MR. ORSINI: We have not. 

THE COURT: Well, but --

MR. ORSINI: But we can do that. We can do that.

THE COURT: You can blank out all the personal 

information on a settlement agreement and say this is the 

settlement agreement that was used, right? You could do that, 

can't you?

MR. ORSINI: Yes. I'm happy to share a specimen, 

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sample settlement agreement with them so they can understand 

what the language is, and we can talk with them about their 

argument. There is something on the face of that settlement 

agreement means it actually can be produced. 

THE COURT: And Ms. Morris, I take your word that 

there are a lot of victims of Butte fire who perhaps died, 

perhaps are not accounted for, perhaps are not represented by 

counsel. But you have access to a lot of those settlement 

agreements that the very lawyers who are working with you, I'm 

sure, can provide you with a check to look and compare what 

they hold for their clients, vis a vis what Mr. Orsini and his 

client makes available to you as the specimens. And the 

message is, he better provide specimens of things that are 

consistent with what have been produced. And I'm going to take 

his word that he's going to do that. All right. 

MS. MORRIS: Thank you, Your Honor. And I think that 

will help. And just one last clarification, Your Honor. And 

it may be that we don't even need to come back to you for the 

actual agreements and the demands. I'll hold that in reserve 

for further briefing if we get these spreadsheets in the manner 

that Your Honor is producing them. But I would like to make 

one clarification. 

There are two types of redactions on these 

spreadsheets. One is for claimant identifying information, 

like their names, and we are in agreement with the debtors and 

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with the Court that those should stay redacted. 

There's a separate type of redaction and they're 

redacting the allocation amounts. And I believe Mr. Orsini is 

claiming that they're subject to work product. 

And I would ask that Your Honor order that these be 

produced without those redactions. The allocations are the 

ones that say this claim settled at this dollar amount, and we 

take this amount that goes to the emotional distress component, 

this amount goes to the property loss component. Without that 

information, Your Honor, the total dollar amount of the 

settlement is no more information than we can get just from the 

debtors' report as to what their total liability is. 

THE COURT: Well --

MS. MORRIS: We absolutely need that information, and 

PG&E's internal records make it clear that they're relying upon 

that allocation and those specific dollar numbers to drive 

their estimation numbers. So it's critical that we get that, 

Your Honor. 

THE COURT: Well, Mr. Orsini --

MS. MORRIS: And it may negate the need for the 

settlement agreements themselves. 

THE COURT: Mr. Orsini, let me ask you a question 

since I presume -- were you personally involved in the 2015 

settlements, or are there some other lawyers in your firm?

MR. ORSINI: No, I was not personally involved, Your 

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Honor, and it's not my law firm. 

THE COURT: Well, then maybe you can't answer the 

question, but I'm sure you've seen them. So if you looked at a 

settlement agreement with one of the victims, does that show an 

allocation or does it have the usual --

MR. ORSINI: It does not. 

THE COURT: -- recitals about so and so was injured, 

or lost property and here's the settlement? So on the face of 

the document, like you'd see in any settlement agreement, there 

would be an assertion, you know, plaintiff contends A, B, C; 

defendant denies A, B, C, but the parties settle for one 

million dollars. It's probably more like that than a breakdown 

of how much for the dog, and how much for the car, and how much 

for the other components, right?

MR. ORSINI: You're right, Your Honor. I have looked 

at a number of these contracts, a number of these settlement 

agreements, and every one that I have seen has simply a lump 

sum settlement amount. And the amounts that are then, for 

internal purposes, allocated, including to inform further 

settlement discussions that the attorneys were having, that's 

done through an exercise of attorney work product. 

THE COURT: Yeah, but --

MR. ORSINI: Now, there are other documents that are 

subject to the mediation privilege that are exchanged between 

the mediating parties that actually do break it down. 

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THE COURT: No, but if --

MR. ORSINI: Claim demand letters --

THE COURT: But if there's a document that was used 

internally at PG&E, perhaps for the future settlements in 2015, 

I don't know why that would be privileged. In other words, I 

don't know why, if it's work product -- it might be work 

product, but it may be relevant here. I mean, does work 

product mean privileged? 

In other words, if somebody in your firm or the 

company took Mr. X's million dollars and did some internal 

calculation from other information and says, you know he had a 

new car, and he had an old cow, and he had a broken down fence, 

and he suffered crippling injuries, and these are the 

components, that's an internal allocation, but I don't know why 

it would be privileged. Why would it be privileged?

MR. ORSINI: Well, it's an internal allocation, Your 

Honor, that's being done by lawyers for the purpose of 

conducting further mediations and settlement discussions. So I 

think it is absolutely protected attorney work product. And to 

the extent that the Court is inclined to require the production 

of the internal work product, we would ask to be able to submit 

briefing on that issue. 

THE COURT: Well, you can --

MR. ORSINI: That's an important issue. 

THE COURT: -- have briefing on it, but again, we 

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start with if you think you're going to get it into evidence as 

part of your estimation, if your estimation is --

MR. ORSINI: I understand that part, Your Honor. 

THE COURT: You know, it's a lost argument here. All 

right. Let's defer on that one. Going back to --

MS. MORRIS: Your Honor, I would -- Your Honor, if I 

could just respond briefly? 

The debtors have already waived any privileges over 

this information by using it in connection with estimations 

that they're already doing in their SEC filings, and in 

estimating claims in the aggregate of thirty billion. They 

have to know how those settlement agreements break out between 

the different categories in order to use them to estimate 

claims. They intend to use those settlement agreements to 

estimate claims in this case, and they've waived any privileges 

associated with it. 

And not only that, to claim privilege over some of the 

information but not other information, to deny the tort 

claimant the ability to evaluate and estimate claims in the 

same exact manner that they've doing for months and months, is 

just unfair and the selective waiver law in the Ninth Circuit, 

I think should be factored in here. But they shouldn't be able 

to claim work product protection, yet pick which information 

they want to disclose and be able to use the redacted 

information themselves while denying us the ability to do so. 

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And so further briefing is going to further delay 

this. It's critical information that we need to start 

estimating these claims and to start the estimation 

proceedings, and I would ask that Your Honor consider ordering 

them to produce the charts that they've already agreed to 

produce, but with the allocation to the different components, 

as Your Honor stated before is absolutely relevant to 

understanding this, that they be ordered to produce it today. 

We can defer all arguments on San Bruno and on getting 

the actual settlement agreements until later, but this is 

critical information that we need to start looking at 

estimation and to be on the same level playing field as the 

debtors here. 

THE COURT: Mr. Orsini, I'll state it differently. I 

don't have to break it down into these elements. I'd say if 

PG&E, either in this court or publicly, or in press releases, 

or in SEC filings, or in filings before Judge Alsup or anywhere 

else has said, we think our estimate of liability for this 

particular fire or these fires is X, I think a fair 

interrogatory would be, how did you get to X? And if the 

answer is well, we can't tell you because it's privileged, 

that's not a winning argument. Because if you -- again, we're 

back to the point, if you're not going to explain it as a 

matter of discovery, I'm not going to let you show it as a 

matter of proof. 

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So I think I'm going to go with what Ms. Morris argues 

here, unless you believe this is a miscarriage of justice and 

needs immediate briefing, then you better brief it quickly. So 

let's leave that for now. 

And Ms. Morris, the last item that was on my list, 

when you were describing your buckets after we talked about 

settlements in 2015 Butte, you then went to what's included in 

the estimate. Generally, I presume, you're -- that means even 

beyond Butte. So much of the last hour -- or half-an-hour, 

we've been talking about, are things that, for reasons I 

(indiscernible), maybe aren't even any more estimated claims, 

they may be liquidated claims.

You want the same kind of information for the 2017 and 

2018 fires, which I think for almost probably one hundred 

percent are unliquidated except -- well, I presume they're 

unliquidated except maybe the public settlement that PG&E 

brought in with Butte County. That is one that's no longer 

unliquidated. But otherwise, for individual claimants, do I 

understand your argument correctly?

MS. MORRIS: No, I think the documents, specifically 

that we were looking for, they are -- the SEC has opened an 

investigation, that the debtors have disclosed in their public 

filings, and the purpose of that investigation, as reported by 

the debtors in their public filings, is that the SEC is seeking 

information relating to the debtors' public disclosures and 

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accounting for losses associated with the 2017 and 2018 wild 

fires and the 2015 Butte fire.

And our request is simply that they be obligated to 

produce the same information they're producing to the SEC to 

the tort claimants. They said, in their response to Your 

Honor's request for the pleadings that led to today's hearing, 

that they're only producing that information to the extent it's 

responsive to another request. And we would ask that Your 

Honor order the debtors to produce it all, and not just 

selectively pick what they want to produce as responsive to 

other requests, given that the narrow focus of the SEC 

investigation is exactly what we're talking here, which is 

estimation of the 2017 and '18 wildfire liability.

THE COURT: Well, when you were describing your four 

buckets, what I wrote down for number four, in your words -- I 

won't quote you verbatim -- but your words were, there are two 

sub-buckets and the first of the two was the settlement 2015 

and 2020 San Bruno. And then the second one, I wrote, what was 

used to estimate them, unless I misunderstood you. 

So I'm not sure what you want me to order the debtor 

to do now, beyond what we've just talked about. So I've stated 

again -- forget --

MS. MORRIS: I -- I'm --

THE COURT: -- 2015 --

MS. MORRIS: Sure.

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THE COURT: We're past that. If I asked you --

MS. MORRIS: Yes.

THE COURT: -- to describe specifically what you want 

me to tell Mr. Orsini he has to produce beyond that, just 

restate it so we're on the same page.

MS. MORRIS: Sure. Any information upon which the 

debtors rely to estimate fire claims exposure for 2017 and 

2018, which would include anything they produced to the SEC in 

response to their nearly identical requests for the debtors.

THE COURT: So it's, "which would include" which 

means, therefore, anything else?

MS. MORRIS: Yes.

THE COURT: Okay.

MS. MORRIS: So it's everything beyond the settlement 

agreements and documents that the debtors are using to estimate 

their liability in which they've relied upon in their SEC 

filings and other documents to estimate the aggregate of their 

liability for 2017 and 2018 fires.

THE COURT: Okay. But what about if Mr. Orsini tells 

me there's some privileged work product included there? What 

do I do about that? He's entitled to protect that, isn't he?

MS. MORRIS: If they use it in connection with 

estimating claims and public filings with the SEC or in public 

statements made with this Court, then I would argue that it's 

not privileged. And so I -- to the extent that it's their 

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expert work product or whatever, they can certainly put that on 

a privilege order for documents, produce a log identifying the 

documents or stating that it's an expert work product. But to 

the extent that they're relying upon that information to give a 

public disclosure about the extent of their liabilities, I 

would argue that that's not privileged or subject to any 

protection.

THE COURT: Okay.

Mr. Orsini, you got the message here?

MR. ORSINI: Don't miss the fact, Your Honor, could --

I think a couple of issues are being confused here. With 

respect to the SEC investigation, what we have told the TCC was 

that if there are documents we've produced to the SEC that 

relate to the estimates of liability for the 2017 and 2018 

fires -- which is exactly the coverage of the document request 

the TCC has already served -- we're producing them. So we're 

producing those documents by subject to privilege, subject to 

mediation confidentiality.

If there are other documents on other topics that we 

have produced for the SEC, we're not agreeing to just give them 

all of those documents because they've been given to the SEC. 

If they can articulate a need and relevance to any other 

documents on other topics, so be it; we can talk about those in 

the context of discovery requests.

So I don't think there's really a dispute with respect 

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to the SEC documents as Ms. Morris just articulated them. If 

it's a document we produced to the SEC that relates to the 2017 

and '18 wild fire claims liability estimates, those documents 

have already been provided to the TCC in the same format they 

were produced to the FCC.

Separately, with respect to documents that were 

flagged either mediation privileged or attorney work product, 

we have not produced those to the SEC, and we do not believe 

that those tenure should be produced to the TCC even if they 

were also used as part of public disclosure.

And that's an issue that, as I said, Your Honor, has 

not been briefed. We believe that we're correct in the 

California law, and we're happy to brief that quickly.

THE COURT: Well, Ms. Morris, I'm --

MS. MORRIS: Your Honor, that doesn't address the 

question --

THE COURT: All right. Go ahead. I'm having trouble 

keeping up with you.

MS. MORRIS: That doesn't --

THE COURT: Go ahead, Ms. Morris.

MS. MORRIS: That doesn't address the question of 

whether if the debtors used documentation to support the 

thirty-billion-dollar number that they put in their SEC filings 

as what they're expecting their disclosure could be, not 

inclusive of punitive damages and fines and other amounts. 

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Whatever documents they relied upon to come up with that 

number, they've waived the privilege over that.

So separate and apart from what they've produced to 

the SEC, and whatever they're claiming as protection for the 

SEC, they've waived any privilege when they relied upon those 

documents and put down that thirty-billion-dollar number in 

their SEC filing or to put that number in the filings they've 

made in this Court or in public statements.

THE COURT: Okay. So to state it differently, if Mr. 

Orsini said that you've been given what's been said to the SEC, 

what you're saying is, if you said to the SEC that the estimate 

is thirty million, what do you have to rely on making that 

statement; and he's saying -- and you're saying he hasn't 

produced that; is that correct, Ms. Morris? That is --

MS. MORRIS: That's right. We've gotten very limited 

productions in that regard. And --

THE COURT: Okay.

MS. MORRIS: And he said that he would produce some 

information, but he's also withholding a bunch of information 

on privileged ground, and I would argue that they're not 

privileged because he's relied upon them to make a public 

disclosure --

THE COURT: Okay. I --

MS. MORRIS: -- as you know.

THE COURT: I guess I don't have enough of a sense to 

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know that I -- which of you I agree with on whether there's a 

waiver of the privilege. But the question is -- well, I don't 

have an answer.

Mr. Orsini, is there -- you believe no waiver and 

privilege when you tell the SEC that we estimate our 

liabilities for the 2017 and '18 fires at thirty billion? I 

mean, that -- again, we're back to the simple interrogatory: 

what did you rely on to get the thirty billion? What's the 

answer? If the only answer is, attorney work product, if 

that's your answer, that's what I want to hear.

MR. ORSINI: Well, Your Honor, there are a lot of 

public documents that were relied upon in coming up with those 

figures. Those documents have been produced to the TCC. They 

were produced both by us as well as in connection with the 

whole Compass Lexecon STI issue that Your Honor probably 

remembers.

THE COURT: Yep.

MR. ORSINI: The way to resolve -- the way to -- the 

way that was resolved was an exchange of information -- public 

information; that was the stipulated resolution there. So the 

publicly available information, the documents, have been 

produced.

There is also work product that was done by our 

litigation consulting experts that further support the 

thirty-billion-dollar number, and it is absolutely our view 

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that that expert work product remains one hundred percent 

protected by the work product doctrine.

THE COURT: Well, but --

MS. MORRIS: Your Honor, maybe I can make this simple 

for you. Why don't we do this? the TCC is perfectly wiling to 

send the debtors a set of interrogatories asking them to 

identify each and every document that they relied upon to come 

up with those numbers. We would ask that they identify all 

those documents and whether or not they're claiming a privilege 

over those documents, and that Your Honor order them to respond 

to that on an expedited basis, so that we can get to the 

evidence matter, which is what are they withholding from us 

that they're not giving to us which we don't even know what 

that information is at this point.

THE COURT: Well, Ms. Morris, that might be the way to 

approach it.

Mr. Orsini, I take it your statement -- your last 

statement there was, you absolutely rely on the litigation 

consultant's expert as privileged; I understand that. But you 

could say -- you could name it on a privilege log, couldn't 

you?

MR. ORSINI: I could name it on a privilege log, and 

we can also identify, with specificity, the public documents 

that were actually used to do these calculations, all of which 

they already have.

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THE COURT: Okay. So it sounds to me that what your 

representation is, that the universe of data to get to that 

public -- I'm using the hypothetical thirty billion -- is a 

combination of what's already been produced plus what would be 

on the privilege log, but nothing else. Is that what I'm to 

assume? Because if there's --

MR. ORSINI: I think that's -- I think that's --

THE COURT: If there's something else --

MR. ORSINI: I that's generally right, Your Honor. 

(Indiscernible) --

THE COURT: If there's something else, then they're 

entitled to it. Okay.

MR. ORSINI: No, no, I think that's right. I mean, I 

would just state it slightly differently, which is that there 

were public documents that were relied upon for this. There 

was also expert work product by a litigation consultant to 

interpret those public documents -- just like they can, just 

like anybody else can. But the actual mechanism of doing that 

analysis is what we believe is work product and that was part 

of the agreed resolution of the Compass Lexecon issue.

And candidly, I wouldn't even know how to begin to log 

all of the materials and all of the work that was done by a 

litigation consultant; that would be highly unusual.

THE COURT: Well, I understand. It would be. I 

don't --

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MS. MORRIS: The point here, though, is that if 

they're -- regardless if they're using -- if they're using the 

same litigation consultant for purposes of estimation trials, 

and they're using the same litigation consultant for purposes 

of estimating for the SEC filings, there's no privilege because 

they're waiving the privilege by identifying that number in 

connection with their SEC filings. The underlying documents 

and analysis that they're using to come up with that 

thirty-billion-dollar number is not privileged.

THE COURT: Well, all right. Ms. Morris, you've said 

what you would inquire of. You make -- you'd expedite a 

written interrogatory. Mr. Orsini can respond, and if his 

response is all privileged, then that's the response.

And I'll -- I'm not going to make a decision without 

it being briefed a little bit on this subject. I think we're 

clear on the subject of mediation privileges different from 

something else here. And there may be some information that 

properly doesn't fall into what the expert has opined and what 

is filed with the SEC, and PG&E should at least explain what it 

is that might be in that category.

And I don't know what else I can do about it today. I 

can't make a decision on a matter of this importance today. 

I'd like to think we've made some progress in the last two 

hours. Hopefully, we have.

MS. MORRIS: Your Honor, if I could just ask for one 

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additional clarification? Our experience in working with the 

debtors on discovery is that unless there's a motion to compel 

or a deadline that is provided by Your Honor, that we don't get 

all the information. And so I would ask that the spreadsheet 

that Your Honor ordered earlier be produced in unredacted form, 

that we give the debtors a timeline by which to produce that 

information. We're fine with two weeks, and think that's 

reasonable and more than sufficient time, given that they're 

already relying upon this information, and ask that Your Honor 

order that be produced within that time frame.

THE COURT: Two weeks from today is August 21st, Mr. 

Orsini. Any problem with that?

MR. ORSINI: I obviously take exceptions -- I 

obviously take exceptions, Your Honor, to Ms. Morris's 

characterization of discovery history; I think that's 

fundamentally false. But I have no objection to agreeing to 

produce those spreadsheets within two weeks.

THE COURT: Okay.

Ms. Morris, your request is granted by your opponent.

All right. What else do we have --

MS. MORRIS: Thank you.

THE COURT: -- to deal with? All right. I'm going 

to -- if there are other parties on the call or want to be 

heard, I think I'm getting a little tired out, and my staff 

here is, and probably a lot of you are. And I do think we made 

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some progress, and if not, not.

So I will call it a day. I'm not going to try issue a 

formal order. I couldn't actually do it. If TCC or the debtor 

want to try to reduce this to a written order, I'll sign an 

order that opposing counsel has agreed to as to form. I like 

to think with the combination of the written transcript, the 

audio upload, and everybody paying attention to this, that's 

going to be adequate right now. If we have a disagreement and 

we have to have a further hearing with somebody, a he said/she 

said, then we have a record to rely on.

I want to thank you all for your time and effort and I 

look forward to seeing some of you on Friday and many of you 

next week. Thank you for your time today.

MR. ORSINI: Thank you, Your Honor.

MS. MORRIS: Thank you, Your Honor.

THE COURT: Thank you.

(Whereupon these proceedings were concluded at 11:43 PM)

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I N D E X

RULINGS: PAGE LINE

Debtors ordered to produce requested 99 19

discovery to TCC on or before August 24, 

2019.

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C E R T I F I C A T I O N

I, Jennifer Hamilton, certify that the foregoing transcript is 

a true and accurate record of the proceedings.

________________________________________ 

/s/ JENNIFER HAMILTON

eScribers

7227 N. 16th Street, Suite #207

Phoenix, AZ 85020

Date: August 8, 2019

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of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

A

ability (3)

 68:2;87:19,25

able (12)

 11:22;12:1;13:8;

 16:7;22:15;44:8;45:5;

 69:2;82:4;86:21;87:22,

 24

absent (1)

 59:12

Absolutely (13)

 21:20;29:11,16,18;

 39:22;59:16;70:2;

 76:11;84:14;86:19;

 88:7;95:25;96:18

accept (1)

 28:8

acceptable (1)

 49:9

access (11)

 11:17;12:13;14:18;

 15:21;31:11;35:21;

 36:4;41:1;60:22;73:6;

 83:8

accommodate (1)

 37:25

accomplishable (1)

 35:4

accordance (1)

 52:12

account (1)

 66:20

accounted (1)

 83:7

accounting (2)

 48:3;90:1

accurate (3)

 37:16;62:3;77:7

accurately (1)

 69:21

ACE (1)

 56:2

acknowledge (1)

 26:2

acknowledged (1)

 28:18

act (1)

 13:14

action (6)

 10:2;20:19,19;21:5;

 30:9;72:7

actions (1)

 71:11

actual (5)

 26:23;73:8;83:19;

 88:10;97:18

Actually (21)

 7:23;19:22;34:22;

 35:4,5;36:5,8;40:3;

 46:7;49:11;50:21;54:5,

 18;60:22;63:24;64:25;

 68:8;83:4;85:25;96:24;

 100:3

ad (3)

 15:14;18:3;22:12

add (1)

 55:22

addition (1)

 76:12

additional (10)

 11:19;17:7;55:1,19,

 22;63:18;81:5,7,7;99:1

address (8)

 17:1;24:1;26:25;

 50:17;53:12;69:11;

 93:15,21

addressed (2)

 18:23;23:21

addressing (1)

 34:15

adequate (1)

 100:8

adjudication (1)

 13:25

admissible (2)

 46:19;63:14

admit (1)

 29:21

admitted (2)

 28:3,6

advise (1)

 67:19

again (28)

 6:6,18,23;8:9;9:14;

 14:22;18:12;20:16,24;

 21:7;24:20;27:9;32:5;

 35:1;38:10;41:22;

 51:19,21;55:24;63:23;

 64:7;74:22;76:19,22;

 86:25;88:22;90:22;

 95:7

against (2)

 45:17;69:3

agenda (1)

 9:14

aggregate (19)

 64:17;68:16,24;

 69:12,13,14,18,21;

 70:17;71:2;72:15;73:2;

 74:5;75:1,8;79:19;

 82:2;87:11;91:17

ago (4)

 17:11;26:18;58:15;

 60:6

agree (7)

 20:4;30:25;34:19;

 63:8;73:23;76:25;95:1

agreed (4)

 78:13;88:5;97:20;

 100:5

agreeing (4)

 78:13;81:14;92:20;

 99:16

agreement (34)

 10:22;11:12,14;12:3,

 11;13:5;14:18;16:1,2,

 7,9,10;17:3;30:8;45:3;

 59:4,11,12;61:5,18;

 62:1,10;63:16;64:9;

 65:6;82:12,13,22,23;

 83:1,4,25;85:4,9

agreements (21)

 45:5,22;46:10,18;

 47:14;65:6,7;72:19;

 73:8;74:25;75:1;78:9;

 82:16;83:9,19;84:21;

 85:17;87:12,14;88:10;

 91:15

agrees (1)

 68:10

ahead (8)

 37:2;39:6,16;43:12;

 65:1;72:1;93:17,20

allocated (1)

 85:19

allocation (9)

 73:3;76:10;81:22;

 84:3,16;85:5;86:14,16;

 88:6

allocations (3)

 73:20;80:20;84:6

allow (2)

 11:17;17:5

allowed (2)

 54:24;57:4

all-property (1)

 55:6

almost (5)

 44:4,11;48:1;60:6;

 89:14

alone (1)

 25:23

Alsup (24)

 31:25;32:10,16,18,

 25;33:2,4,4;35:20,24;

 36:1,4,7,8,20;38:25;

 39:22;40:3,8,14,18,20;

 41:14;88:17

Alsup's (3)

 32:21;40:11;41:2

although (2)

 40:17;50:18

ambiguity (1)

 20:2

amenable (1)

 20:8

amended (2)

 51:24;52:11

amount (13)

 27:10;34:13;47:21;

 68:18;69:4;70:7;76:10;

 80:21;84:7,8,9,10;

 85:18

amounts (10)

 16:20;35:14;68:17;

 73:2,3,20;82:2;84:3;

 85:18;93:25

analysis (5)

 59:20;63:10,10;

 97:19;98:8

analyze (1)

 65:15

analyzing (1)

 59:23

answered (2)

 21:11,12

apart (2)

 12:21;94:3

apologize (3)

 6:10;8:20;51:21

apology (1)

 9:3

applicability (1)

 66:6

applies (1)

 28:13

approach (6)

 18:10;21:16;22:11;

 58:23;70:17;96:16

approaching (1)

 65:22

appropriate (1)

 81:12

approximately (1)

 37:5

areas (1)

 55:19

arguably (1)

 62:9

argue (6)

 8:24;41:16;48:11;

 91:24;92:6;94:20

argued (1)

 28:8

argues (1)

 89:1

arguing (2)

 59:18;60:20

argument (8)

 41:17;58:21,23;66:6;

 83:3;87:4;88:22;89:19

arguments (2)

 28:7;88:9

arise (1)

 22:10

arose (1)

 5:15

around (1)

 8:10

article (2)

 33:7;78:21

articulate (1)

 92:22

articulated (1)

 93:1

aside (4)

 15:5;61:22;74:22;

 78:21

assert (1)

 64:10

asserted (3)

 45:17;69:3,9

assertion (1)

 85:10

asset (1)

 55:1

assets (1)

 43:21

assist (2)

 12:6;22:21

associated (4)

 48:3;81:10;87:16;

 90:1

assume (7)

 17:15;22:14;23:14;

 41:9;69:2;74:23;97:6

assuming (1)

 14:20

Atlas (4)

 29:23;30:7;69:7;

 70:25

attention (1)

 100:7

attenuated (1)

 57:8

Attorney (8)

 22:1,2;81:10;82:10;

 85:21;86:19;93:7;95:9

attorney-client (1)

 82:9

attorneys (1)

 85:20

audio (1)

 100:7

AUGUST (18)

 5:1;7:1,4,14,16;8:4;

 10:4;12:10;23:12,14,

 14;24:8;26:17;52:17,

 19;53:17;99:11;101:4

available (10)

 33:17;36:2;38:9;

 39:23;40:5;43:22;44:1;

 64:13;83:12;95:21

avoid (2)

 6:24;38:12

aware (3)

 23:3;33:8;71:15

away (1)

 37:16

B

back (27)

 7:7;12:12;13:24;

 18:12;19:3;21:6;23:7;

 26:10;34:4,17,19;

 35:22;39:18,21;50:11;

 57:3;58:7;60:10,15;

 68:25;71:17;73:14;

 79:17;83:18;87:5;

 88:23;95:7

back-and-forth (2)

 9:10;59:10

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(1) ability - back-and-forth Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 103

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

background (1)

 31:8

backs (1)

 61:23

bait (1)

 61:14

BakerHostetler (2)

 18:14;42:12

ball (1)

 64:12

bankruptcy (22)

 12:5;20:19;24:5;

 25:2,5;30:18;31:12;

 35:10;36:17;38:15;

 40:15;45:9;47:10;

 61:12;64:15;65:24;

 66:3,7;71:10;78:19,20,

 25

bar (2)

 11:24;12:7

based (4)

 49:11;50:23;54:4;

 59:19

Basically (1)

 27:1

basics (1)

 28:14

basing (1)

 44:23

basis (3)

 44:24;81:8;96:11

Bay (6)

 24:15,24;31:8,14;

 33:15;34:1

bears (1)

 21:7

begin (1)

 97:21

beginning (1)

 21:9

behalf (3)

 13:13;15:11;73:13

beneficial (1)

 50:18

benefit (2)

 50:25;53:23

Benjamin (1)

 15:10

Bermuda (1)

 56:2

best (2)

 38:12;58:2

better (8)

 14:24;18:16;50:25;

 51:11;81:2,23;83:13;

 89:3

beyond (6)

 30:21;63:22;89:9;

 90:21;91:4,14

big (3)

 8:4;19:1;58:7

bigger (2)

 59:2;72:9

billion (6)

 12:23;59:19;87:11;

 95:6,8;97:3

bit (5)

 19:9;30:24;56:14;

 57:7;98:15

blank (1)

 82:21

blanket (1)

 54:20

board- (1)

 44:2

bogged (1)

 41:10

both (13)

 6:17;9:7;11:13;

 20:23;24:5;25:12;

 44:20;58:11;59:3,12;

 63:5;77:9;95:14

bottom (1)

 13:10

bought (1)

 31:16

breach (1)

 77:11

break (3)

 85:25;87:12;88:15

breakdown (1)

 85:12

breaking (2)

 75:9,10

brief (6)

 25:1;72:18;73:7,17;

 89:3;93:13

briefed (5)

 77:7;78:12;81:12;

 93:12;98:15

briefing (6)

 79:24;83:20;86:22,

 25;88:1;89:3

briefly (1)

 87:7

briefs (1)

 71:14

bring (3)

 12:4;16:8,13

brings (1)

 34:19

broad (1)

 30:21

broader (2)

 10:15;57:16

broadly (1)

 53:13

broken (2)

 72:15;86:12

broker (3)

 57:5,10,19

brought (2)

 25:4;89:17

BrownGreer (10)

 10:6;11:7,8,18,20;

 12:4,10,13,21;13:5

Bruno (22)

 32:11,15;44:18;46:3;

 47:16;58:8,9,11,13;

 59:3;65:7;70:22;71:24;

 73:11;74:22;75:22;

 76:24;79:21;80:3,4;

 88:9;90:18

Bruno's (1)

 58:24

bucket (10)

 48:12,21,23;50:1,13;

 54:1,2,4;58:7;76:10

buckets (13)

 23:22;26:6;42:9,15;

 43:25;44:16;48:11,18;

 51:15;56:17;80:21;

 89:6;90:15

bunch (4)

 20:25;21:1;31:10;

 94:19

burdensome (1)

 57:14

burner (1)

 38:19

Butte (36)

 44:17;46:1;47:15;

 58:11,21;59:4,17,20,

 24;60:3;61:10,13,13,

 17;65:6;67:7;68:19;

 69:3;70:19;71:7;73:1,

 11;76:3,5,25;77:20;

 79:16,16,25;80:19;

 81:24;83:6;89:7,9,17;

 90:2

button (4)

 31:18;32:5;33:23;

 34:18

C

CAL (8)

 15:22;21:18;22:1,4,

 7,13,20,22

calculation (3)

 20:25;66:11;86:11

calculations (1)

 96:24

calendar (7)

 7:2,4;19:3;51:9,23;

 52:24;79:16

CALIFORNIA (16)

 5:1;46:14,17;48:4;

 59:6,14;60:18;61:4;

 63:5;67:20;68:9;73:16;

 77:8,11;79:20;93:13

Call (14)

 5:3,11,20,23,24;

 7:22;14:2;44:2,14,14;

 48:23;60:12;99:23;

 100:2

called (1)

 71:7

camera (1)

 40:8

Camp (8)

 22:8,16;28:21;29:8;

 32:13;39:9;70:20,25

CAMPORA (19)

 35:17;36:15,15,23;

 37:2,3,19,21,22;38:3,5,

 24;39:3,6,7;40:1,4;

 42:3;60:8

can (81)

 10:6,14;11:1,1,25;

 13:5;14:20;15:18;16:1,

 2,4,9,10,11;17:20;

 18:19;19:6,7;21:5,18;

 22:10;23:24;24:17;

 26:2,5;27:1;31:6;

 38:21;39:17;41:17;

 42:5,9,14;45:14;46:20,

 23;47:2;49:5,12,13,25;

 50:17;52:5;56:11;

 57:25;59:13;61:1;

 62:14;63:8;65:11;68:1,

 7,8,9,21;69:12;70:3,3;

 71:22;73:7,17;82:20,

 20,21;83:1,2,4,10;

 84:11;86:23;88:9;92:1,

 22,23;96:4,11,23;

 97:17,18;98:12,21

candidly (2)

 18:1;97:21

car (2)

 85:13;86:12

case (17)

 8:6;25:11;40:25;

 41:9;45:12,13,19;

 46:24;55:7;58:11;

 65:25;66:4,8,9;70:13;

 71:13;87:15

cases (6)

 34:1;47:6,21;66:1;

 73:1;80:15

categories (4)

 53:18;72:15;73:21;

 87:13

category (3)

 16:18;75:10;98:20

causation (6)

 28:18,22,24;29:9,13;

 30:8

cause (2)

 29:23;30:2

caused (4)

 28:4,10,24;46:4

causes (1)

 72:7

center (1)

 23:1

certain (1)

 53:18

certainly (9)

 18:2;34:15;38:18;

 40:22;64:22;69:2,8;

 82:7;92:1

cetera (1)

 71:3

CGL (2)

 55:16;56:15

cha (1)

 5:9

chair (1)

 36:23

chambers (1)

 9:7

chance (1)

 17:2

change (3)

 20:23;61:6;74:3

changing (1)

 81:21

characterization (1)

 99:15

charts (3)

 56:16,19;88:5

check (2)

 35:22;83:10

checked (1)

 58:4

chime (1)

 22:19

Circuit (1)

 87:21

circumstance (1)

 58:15

circumstances (1)

 65:20

cited (1)

 45:11

citing (2)

 20:8;66:3

civil (2)

 40:14;71:13

claim (21)

 16:20;46:6;55:22;

 61:15,19,20;62:1,23;

 64:11,21,23;65:4;

 66:24;70:8;77:3;78:23;

 79:17;84:7;86:2;87:17,

 23

claimant (10)

 11:24;61:25;62:12,

 14;66:14,16,16;75:21;

 83:24;87:19

claimants (7)

 10:21;46:23;47:5;

 75:16,25;89:18;90:5

claimants' (2)

 24:3;76:6

claiming (5)

 46:3,10;84:4;94:4;

 96:9

claims (68)

 11:21;12:5;13:10;

 16:17,18;17:5;18:6;

 43:23,23,24,24;44:1,

 14,17,17,19,22;45:15,

 16,16,20,23;46:6;

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(2) background - claims Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 104

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

 47:17;53:20,23;54:19,

 21,25;55:1;57:9;64:17;

 65:9,12,15,17,18,18,19,

 19;66:17;68:18,25;

 69:3,6,20;70:15;72:5,

 10,12,14,22;73:4,10;

 76:11;80:21;81:24;

 82:1;87:11,14,15,19;

 88:3;89:11,12;91:7,23;

 93:3

clarification (5)

 76:5;80:12;83:17,22;

 99:1

clarified (1)

 31:2

clarify (4)

 8:11;29:7;56:11;

 81:4

clarifying (3)

 28:15;30:5;80:18

clarity (2)

 42:18;43:14

class (1)

 71:11

clear (11)

 14:14;20:11;24:13;

 28:17;30:19;54:15,19;

 59:14;77:8;84:15;

 98:16

clearly (2)

 54:12;82:5

CLERK (2)

 5:4;7:20

client (2)

 67:19;83:12

clients (4)

 64:6;67:16;68:3;

 83:11

close (1)

 11:14

co-counsel (1)

 22:1

Code (3)

 46:14,17;63:12

cognizant (1)

 34:21

colleagues (1)

 21:5

collection (1)

 34:2

combination (2)

 97:4;100:6

comfortable (1)

 14:10

coming (3)

 19:3;31:6;95:12

comment (1)

 36:17

comments (3)

 23:19;24:1;71:20

commit (3)

 48:22;49:4,12

committed (1)

 68:19

committee (10)

 10:3,4;15:5,12;22:7,

 12;25:7,7;36:23;82:6

committing (1)

 42:2

common (2)

 11:18;23:23

communicate (1)

 9:7

communicated (2)

 43:2;59:7

communication (1)

 8:13

communications (1)

 43:5

company (3)

 34:3;58:19;86:10

company's (3)

 58:15,22;69:13

comparable (4)

 69:7,8,9;70:15

compare (1)

 83:10

Compass (2)

 95:15;97:20

compel (12)

 6:25;7:14,15;8:3,12,

 21;9:5;42:16;43:6;

 51:22;68:7;99:2

compensation (1)

 7:9

complained (1)

 61:11

complaint (1)

 38:12

completely (4)

 20:3,4;30:25;70:22

complex (1)

 10:1

complicated (2)

 8:6;79:11

complying (1)

 32:17

component (3)

 71:7;84:8,9

components (3)

 85:14;86:14;88:6

compressed (2)

 24:14;27:11

compromised (1)

 69:10

concern (1)

 67:24

concerned (1)

 18:20

concerning (2)

 11:21;34:2

concluded (1)

 100:17

conclusion (1)

 10:20

condemnation (2)

 28:9,13

conduct (1)

 15:22

conducting (1)

 86:18

confer (4)

 7:20;13:7;22:15,21

conference (4)

 5:7;9:12,21;41:18

conferenced (1)

 7:24

confidence (1)

 70:4

confidences (1)

 77:12

confidential (1)

 47:2

confidentiality (5)

 39:24;60:24,25;61:5;

 92:18

confidentially (1)

 46:23

confirmation (3)

 64:17;66:23,23

confused (2)

 50:24;92:11

confusion (2)

 8:20;51:22

congestions (1)

 7:11

connection (10)

 45:2;46:3;47:12,15,

 21;48:1;87:9;91:22;

 95:14;98:7

consensual (2)

 10:22;11:25

consent (9)

 19:17;60:15,22;67:9,

 15,23,24;68:3;73:13

consider (4)

 42:8;66:4;80:18;

 88:4

considered (2)

 66:25;75:1

consistent (4)

 9:20;12:18;41:8;

 83:14

consistently (2)

 45:9,10

constituency (1)

 9:19

constructive (1)

 67:13

consultant (4)

 97:16,23;98:3,4

consultant's (1)

 96:19

consulted (1)

 53:21

consulting (1)

 95:24

contact (1)

 22:15

contacted (1)

 22:14

contain (6)

 45:8;46:18;65:16,17,

 17,18

contained (1)

 74:7

contains (1)

 46:25

contend (2)

 73:15;76:13

contends (1)

 85:10

contention (1)

 28:9

contest (5)

 29:9,20,22;30:1,8

contested (3)

 7:8;27:2;30:20

context (9)

 10:25;19:9,19;34:23,

 23;35:5;62:11;77:15;

 92:24

contingent (1)

 64:22

continue (2)

 13:23;73:22

continued (1)

 7:8

contractor (3)

 42:15;50:13,16

contractors (1)

 43:4

contracts (2)

 43:18;85:16

contrary (1)

 20:4

control (1)

 17:17

controlling (1)

 66:4

conversations (1)

 20:9

coordinate (3)

 22:9;23:1;25:3

coordination (2)

 9:20;23:2

copies (2)

 36:8;37:7

coplaintiff (1)

 81:19

copy (3)

 18:1,2;32:1

core (1)

 13:11

corners (2)

 62:9;63:6

corollary (1)

 71:15

Corporation (1)

 5:5

correction (1)

 7:18

correctly (3)

 24:7;28:7;89:19

correspondence (1)

 37:8

counsel (16)

 5:6;6:16,22;9:8,12;

 15:7;20:21;22:25;41:5,

 7;51:13;52:3;67:23;

 71:6;83:8;100:5

counsels' (1)

 24:3

counterargument (1)

 68:10

counterpart (1)

 71:15

County (3)

 61:10;79:16;89:17

couple (9)

 6:9;22:2;25:8;26:19;

 28:15,17;35:13;77:25;

 92:11

course (6)

 8:24;13:12;14:20;

 34:4;54:6;70:21

Court (265)

 5:3,4,6,8,16,18;6:4,6,

 11,13;7:20,21,25;8:16;

 9:1;11:3,6,10,11;12:1,

 12,12,15,24;13:1,3,12;

 14:1,4,7,10,22;15:13,

 15;16:14,21;17:9,23;

 18:7,9,22;19:12;20:15,

 16,19;21:20,23;22:22,

 24;23:7,24;24:3;25:3,

 5,5,6,8,15,20;26:7,10,

 13;27:16,19,24;28:19,

 22,24;29:2,4,6,15,17,

 20;30:6,9,10,12,16;

 31:1,21;32:8;33:6,8,10,

 14,19;34:24;35:7,9,16,

 18;36:13,16,21;37:1,3,

 18,20,22;38:4,7;39:2,4,

 13,15;40:12,13,14,15;

 41:3;42:1,13,21;43:12,

 16;44:21;48:10,15,17,

 20;49:1,3,9,11,14,16,

 19,21,23,25;50:7,18,

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 4,6,9,14,16,18,20;53:9;

 54:6;55:4,24;56:2;

 57:7;60:8,11,20,25;

 61:7,9,17;62:12,14,16,

 19,22;63:2,4,21,23;

 64:1,4,12;65:1,3;66:2,

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 22;69:23,25;70:9,11;

 71:19,21;73:22;74:4,

 10,12,15,19,21;75:13,

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 24;77:9,10,17,19,23;

 78:11,13,16,18;80:13,

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 83:5;84:1,13,19,22;

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(3) clarification - Court Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 105

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

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 90:14,24;91:1,3,10,13,

 19,24;92:8;93:14,17,

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courtroom (1)

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courts (4)

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Court's (2)

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cover (12)

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coverage (13)

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coverages (1)

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covered (3)

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covers (4)

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cover-up (1)

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cow (1)

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CPUC (1)

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crashes (1)

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Cravath (3)

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created (1)

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creditors (1)

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creditors' (2)

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criminal (3)

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crippling (2)

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critical (3)

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cross-purposes (1)

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cross-referenced (1)

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culpability (1)

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current (4)

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custodial (1)

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custodians (1)

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cut (2)

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D&O (3)

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Daily (1)

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damage (3)

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damages (9)

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data (13)

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date (8)

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day (7)

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days (1)

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de- (1)

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deadline (5)

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deadlines (1)

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deal (10)

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death (2)

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debate (2)

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debtors (60)

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December (2)

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decision (3)

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declaration (1)

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defendant (1)

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defer (3)

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definition (1)

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delay (2)

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delivered (1)

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demand (1)

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demands (5)

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denies (1)

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Dennis (1)

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deny (2)

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denying (3)

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department (1)

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deposition (3)

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depositions (2)

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describe (2)

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describing (2)

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desire (1)

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destruction (1)

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detail (2)

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detailed (1)

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details (1)

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determination (4)

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determining (1)

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died (1)

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difference (2)

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different (29)

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differently (3)

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dig (1)

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direct (2)

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directing (1)

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directly (2)

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disagree (2)

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disagreement (1)

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disclose (5)

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disclosed (2)

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disclosing (1)

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disclosure (10)

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disclosures (4)

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discovery (59)

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discussions (7)

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dispute (5)

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disputed (4)

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disputes (1)

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distress (4)

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distributions (1)

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district (4)

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divide (1)

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dividend (1)

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dividends (2)

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docket (7)

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doctrine (2)

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document (16)

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documentation (3)

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documents (96)

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of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

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 6,9,16,21;38:24;39:8,9,

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dog (1)

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dollar (4)

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dollars (7)

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done (18)

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double-check (1)

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down (13)

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draft (1)

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draw (1)

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drawing (1)

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drive (1)

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drives (1)

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drove (1)

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due (1)

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duplication (1)

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dwell (1)

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educated (1)

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effect (2)

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efficient (2)

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efficiently (1)

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effort (5)

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efforts (1)

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eight (1)

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either/or (1)

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electronic (1)

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elements (1)

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eliminate (1)

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email (3)

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emails (1)

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emotional (4)

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empathy (1)

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employee (1)

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employees (1)

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empty (1)

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enable (1)

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encourage (1)

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encouraging (1)

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end (5)

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endorsement (1)

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energize (1)

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enforceable (2)

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engage (1)

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enough (4)

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ensuing (1)

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entire (2)

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entirety (1)

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entitled (6)

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entry (1)

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equal (1)

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equally (2)

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equation (1)

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equipment (5)

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errors (1)

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estimate (29)

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estimates (3)

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estimating (8)

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estimation (56)

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estimation-related (1)

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estimations (5)

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event (3)

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everybody (7)

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evidence (11)

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evident (1)

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ex (1)

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exact (6)

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exactly (9)

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examinations (1)

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example (2)

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exceptions (3)

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exchange (1)

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exchanged (1)

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excuse (4)

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exercise (1)

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Exhibit (1)

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existence (1)

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existing (1)

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exists (1)

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expect (5)

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expected (1)

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expedite (1)

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expedited (2)

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experience (2)

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experiential (1)

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expert (14)

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experts (5)

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expires (1)

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explain (3)

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explaining (1)

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exploring (1)

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explosion (3)

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exposure (2)

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express (1)

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extended (1)

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extension (1)

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extensive (1)

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extent (10)

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extreme (1)

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extremely (1)

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F

face (9)

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(5) dog - face Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 107

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

fact (16)

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factored (1)

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facts (4)

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factual (2)

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failed (1)

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failure (1)

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fair (4)

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fairly (1)

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faith (2)

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fall (1)

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falls (2)

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false (1)

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far (2)

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Farr (2)

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fashion (2)

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faulting (1)

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FCC (1)

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feasible (1)

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February (9)

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federal (3)

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feel (1)

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Felderstein (1)

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fence (1)

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few (2)

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fiduciary (1)

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field (4)

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fifteen (1)

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fifty-four (2)

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figure (2)

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figures (2)

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file (8)

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filed (18)

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 23:10;26:25;36:2,19;

 38:25;39:10,19,22,25;

 42:23;43:6;50:23;

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files (2)

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filing (6)

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filings (18)

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final (3)

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finalized (1)

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financial (3)

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find (4)

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fine (5)

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fines (1)

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finish (1)

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fire (65)

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 30:3,11;31:8;34:1;

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fires (25)

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FIRE's (2)

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firm (8)

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first (19)

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 25:10;31:3,8,11;32:9;

 43:13;53:9;57:20;

 58:12;61:3;67:22;

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fish (1)

 61:14

fit (1)

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Fitzgerald (1)

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five (4)

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flagged (1)

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flat (2)

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fly (2)

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focus (3)

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focused (2)

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Focusing (1)

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footing (1)

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forced (1)

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forget (3)

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forgotten (1)

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form (9)

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 47:19;58:19;78:5;99:5;

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formal (1)

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format (1)

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formulate (1)

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forth (4)

 16:20;53:11;61:23;

 68:8

forward (13)

 6:24;7:25;8:24;12:4;

 13:2,18;16:2,4;20:13;

 26:3;27:10;29:11;

 100:12

found (2)

 30:5;67:8

four (16)

 5:10;23:22,23;26:6,

 8;42:9,14;43:15;48:11,

 12;50:2;58:7;62:9;

 63:6;90:14,15

frame (1)

 99:10

FRANCISCO (2)

 5:1;41:3

frankly (6)

 17:2;34:14;59:22;

 65:9;67:24;68:11

free (1)

 61:11

freely (1)

 64:13

Friday (1)

 100:12

front (2)

 38:19;49:7

fruition (2)

 11:15;14:21

full (7)

 56:3,5,20,22,23;57:2,

 4

Fuller (2)

 5:16,17

fundamentally (2)

 58:25;99:16

furniture (1)

 56:7

further (16)

 9:6,9;11:23;20:20;

 55:10;57:24;75:10;

 79:23;81:12;83:20;

 85:19;86:18;88:1,1;

 95:24;100:9

future (2)

 65:15;86:4

G

Gallagher (1)

 15:11

game (1)

 71:25

gas (2)

 32:15;58:14

gave (2)

 36:3;80:15

general (5)

 11:17;22:2;55:16,25;

 57:10

generally (7)

 10:9;15:25;20:12;

 22:19;28:16;89:8;97:9

General's (1)

 22:1

generated (1)

 74:5

gentlemen (1)

 14:23

geographies (1)

 69:19

get-go (1)

 63:11

gets (2)

 50:10;79:11

Ghost (4)

 28:5;29:25;79:20,21

given (17)

 20:17;25:23,24;

 27:10;32:1;34:23;40:8;

 54:3;58:24;59:14;73:6;

 80:1;82:8;90:11;92:21;

 94:10;99:8

giving (2)

 58:9;96:13

glad (1)

 18:9

glided (1)

 59:4

GLP (1)

 57:10

goal (2)

 12:8,10

goes (6)

 55:6;68:25;76:10;

 82:7;84:8,9

good (6)

 5:6,17,18;21:20;

 22:21;49:13

Goshen (1)

 70:22

Gotshal (1)

 10:12

governed (1)

 27:24

Governor's (1)

 7:7

governs (1)

 26:23

grant (3)

 27:20;30:11;41:22

granted (1)

 99:19

gravity (1)

 23:1

Great (1)

 11:4

ground (1)

 94:20

group (11)

 10:18;15:15;17:20;

 18:4,21,21;20:10;

 31:14;41:5;61:12;

 70:13

grouped (2)

 23:22;42:14

groups (2)

 24:15;82:9

group's (1)

 24:24

guess (9)

 9:18;18:18,19;21:7,

 7;53:6;64:24;71:4;

 94:25

guests (1)

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of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

 5:10

guilty (1)

 29:21

H

half (2)

 25:16,16

half-an-hour (1)

 89:9

hand (2)

 5:14;25:15

handle (4)

 24:9;48:19;49:25;

 56:25

handled (1)

 45:16

handling (1)

 5:15

happen (2)

 23:12;32:19

happened (2)

 66:15;80:5

happening (1)

 9:5

happy (15)

 11:13;36:10;37:1,6,

 13,16;40:4;48:18;49:2,

 10;53:12;54:3;72:18;

 82:25;93:13

hard (3)

 11:5;58:4;62:1

hat (1)

 73:23

hate (1)

 68:5

head (1)

 17:24

hear (12)

 6:9,21;8:3;11:1;

 15:7;37:1;42:17,19,25;

 67:25;77:9;95:10

heard (6)

 13:17;23:5;26:4;

 60:8;62:13;99:24

hearing (14)

 5:25;7:8,13;27:15;

 29:10;36:25;42:18;

 43:2,9;50:4;51:24;

 79:17;90:6;100:9

hearings (4)

 9:20;32:14;37:7;

 50:4

heavily (2)

 45:24;46:24

Hello (2)

 6:3,4

help (7)

 10:14;13:23;19:6;

 31:6;66:2,3;83:17

helpful (1)

 23:2

here's (3)

 56:16;61:25;85:8

hide (1)

 60:21

highly (1)

 97:23

history (1)

 99:15

hit (1)

 34:18

Hm (1)

 5:25

hoc (3)

 15:15;18:3;22:12

hold (6)

 12:18;13:19;19:2;

 75:15;83:11,19

home (2)

 45:13;61:11

Honor (148)

 5:13,17;6:3,8;8:18;

 11:1,7;13:22;14:5,12;

 15:10,14,17;16:5,8,13,

 25;17:6,25;19:7,21;

 20:8;21:17,24;23:18;

 24:1;26:1,15;28:15;

 29:5;30:24;32:7,14,24;

 33:11,18,20;35:17,23,

 24;36:15,22;37:3;38:6,

 23;39:3,7,14,18;42:11,

 17,19;43:10;44:7,10,

 15;45:9;46:14,22;47:7,

 13;48:9,25;49:4,9,15;

 50:17;51:17;52:11,17,

 19;53:7,16;54:14;

 55:13,20;58:10;59:3,

 21;61:16;62:5,15,25;

 63:9,22;64:25;67:12,

 17;68:5,9,10,21;69:11;

 70:2,5;71:18;72:3;

 73:9,19,25;74:14,18;

 75:7,17,18,19;76:14,

 23;77:6,13,21,24;78:7,

 10,15;80:11;81:4;

 82:17;83:16,17,21;

 84:5,10,18;85:1,15;

 86:17;87:3,6,6;88:4,7;

 90:9;92:10;93:11,15;

 95:11,15;96:4,10;97:9;

 98:25;99:3,5,9,14;

 100:14,15

Honorable (1)

 5:4

Honor's (4)

 29:11,16,18;90:6

hope (3)

 16:10;38:21;67:3

hopeful (1)

 12:13

Hopefully (1)

 98:24

hour (1)

 89:9

hours (1)

 98:24

hundred (9)

 34:3;60:2;72:25;

 76:6,17;80:15,16;

 89:14;96:1

hundreds (2)

 34:3;65:7

hypothetical (1)

 97:3

I

idea (1)

 11:17

identical (3)

 48:1;65:16;91:9

identified (2)

 53:15;76:21

identify (4)

 34:7;96:7,8,23

identifying (4)

 75:21;83:24;92:2;

 98:6

ignore (2)

 45:18,18

III (1)

 78:21

imagine (1)

 62:2

immediate (2)

 24:16;89:3

importance (2)

 65:21;98:22

important (12)

 12:2;25:18;33:3,4;

 43:21;44:13;47:20;

 50:1,1;66:8;68:6;86:24

importantly (2)

 46:22;47:8

improper (1)

 24:18

inaccurate (1)

 62:4

inappropriate (1)

 70:14

inclined (5)

 52:2;57:17;79:13,24;

 86:20

include (6)

 47:18;63:18;80:19,

 19;91:8,10

included (2)

 89:7;91:20

includes (2)

 18:17;63:14

including (5)

 11:19;20:15;60:7;

 71:23;85:19

inclusive (1)

 93:25

incomplete (1)

 45:25

incorrect (1)

 33:21

incorrectly (1)

 42:4

indeed (3)

 17:11;66:12;70:21

indirectly (1)

 22:7

indiscernible (9)

 6:10;13:11;53:10;

 55:17;59:22;66:1;

 75:14;89:11;97:10

individual (8)

 68:24;75:11,11;77:4,

 4;78:24;79:5;89:18

individuals (3)

 36:16;75:16;77:2

individual's (2)

 64:18;77:3

inference (1)

 69:6

inform (1)

 85:19

informally (1)

 52:22

information (89)

 10:5;11:19;15:9;

 25:13,15,16;34:12,16;

 35:2;36:9,24;38:8,13,

 14;42:5;44:18,23;45:8,

 11,14,15,18;46:2,7,8,

 22;47:1,9,11,13,25;

 48:2,5;50:16;55:10,17;

 56:9,9;57:24;58:9;

 60:4;64:16;67:9,18;

 71:22;72:4,4;74:2,7,8;

 75:12,21;76:12,14;

 78:8;79:25;80:15;81:6;

 82:1,8,22;83:24;84:10,

 11,14;86:11;87:9,18,

 18,23,25;88:2,11;

 89:13,25;90:4,7;91:6;

 92:4;94:19,19;95:19,

 20,21;96:14;98:17;

 99:4,7,9

informational (1)

 12:22

informed (1)

 27:6

injured (2)

 78:24;85:7

injuries (2)

 79:1;86:13

injury (4)

 71:3;75:3;79:6,8

inquire (1)

 98:11

inquiry (2)

 66:22;79:11

inspection (3)

 33:1,13;39:8

instance (2)

 61:3;67:22

instances (1)

 57:24

Instead (1)

 10:19

insurance (16)

 43:19;51:15;53:1,3,

 8,13,19,21,24;54:16,

 21;55:6;57:19;58:15;

 60:1;69:20

insures (1)

 55:12

intend (2)

 81:3;87:14

interested (2)

 7:4;78:2

interject (5)

 13:17;14:23;21:18;

 22:8;75:20

internal (16)

 9:19;45:6,21,23;

 47:17,18;53:21;72:13,

 24;73:1;84:15;85:19;

 86:10,14,16,21

internally (2)

 74:5;86:4

interpret (1)

 97:17

interpreted (1)

 8:22

interrogatories (1)

 96:6

interrogatory (3)

 88:20;95:7;98:12

into (35)

 12:5;14:23;16:15;

 19:5;20:6;21:18;23:19,

 22;25:4;32:23;33:15;

 35:13;41:19;42:2,14;

 43:15;44:15;49:11;

 53:13;54:1,3;56:8;

 58:12;66:20;67:18;

 70:5;74:3;75:2,9,10;

 80:21;81:22;87:1;

 88:15;98:18

inverse (2)

 28:9,13

investigate (1)

 32:19

investigation (7)

 22:18;31:24;76:13;

 89:22,23;90:12;92:12

investigative (1)

 22:17

invitation (1)

 5:7

invited (1)

 5:10

involved (6)

 14:16;16:3;22:5;

 35:24;84:23,25

involves (1)

 69:19

irrelevant (1)

 54:15

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(7) guilty - irrelevant Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 109

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

issue (33)

 12:13;14:8,15,20;

 15:20;16:12,25;18:8;

 27:22;32:9;35:13;

 38:20;46:5;50:13;

 58:11;59:2;60:11;

 67:16;68:6;72:18;73:7,

 17;74:1;77:7;78:19;

 79:22;81:13;86:22,24;

 93:11;95:15;97:20;

 100:2

issued (1)

 7:12

issues (29)

 5:15;6:2,17;7:10;

 12:20;16:6,11,13;18:5,

 23;20:4,6,11,13;22:10,

 16;24:4;27:2,7;28:6;

 41:23;42:1,3;49:25;

 53:8,12,13;75:6;92:11

item (3)

 10:2;57:25;89:5

items (10)

 6:22;13:6;14:25;

 15:4;17:13;23:25;32:6;

 37:8;48:8;54:7

J

Jane (1)

 7:23

job (3)

 47:20;48:21;81:2

joined (4)

 24:2,11,15,23

joining (1)

 24:25

Journal (2)

 33:5;41:3

Journal's (1)

 40:10

judge (27)

 30:17;31:25;32:10,

 16,18,21,25;33:2,4,4;

 35:20;36:1,4,7,8,20;

 37:7;38:25;39:22;40:3,

 8,11,14,18,20;41:14;

 88:17

judges (2)

 25:2,2

judge's (1)

 40:23

judicial (1)

 30:18

Julian (34)

 5:12,13;6:1,15;

 18:14;21:4,12;23:7,8,

 16,18,18;26:8,12;27:6;

 31:1,5;32:12;33:7,9,11,

 14,25;36:5,9,22;38:17,

 23;40:1,4,7,8;42:3,7

Julian's (3)

 18:17;26:16;33:21

July (9)

 7:1,12;9:11;18:15;

 24:2,3,24,25;26:3

June (1)

 27:12

justice (1)

 89:2

K

Karotkin (4)

 5:19;6:13;7:21;28:8

Karotkinon (1)

 5:20

keep (5)

 29:23;52:20;58:3;

 66:3;80:7

keeping (1)

 93:18

kept (2)

 14:16,17

Kevin (1)

 17:25

key (2)

 15:20;32:3

kicked (1)

 50:14

kill (1)

 50:8

Kim (4)

 7:23,23;23:21;26:5

Kimberly (2)

 5:14;42:12

kind (11)

 9:25;13:10;22:9,11;

 23:1;40:25;54:8,11;

 64:10;82:1;89:13

kinds (1)

 69:9

Kleber (19)

 5:14;8:15,18,18;9:3;

 23:16;43:7;51:17,19,

 19,21;52:2,5,8,11,15,

 17,19,22

knowledge (1)

 81:19

knows (5)

 12:1;35:25;38:14;

 60:25;63:24

Kody (4)

 5:14;8:18;43:7;

 51:19

L

label (2)

 79:19,21

language (6)

 46:18,25;61:3;63:14;

 64:10;83:2

large (4)

 43:20;53:7;61:11;

 74:24

last (10)

 27:6;31:12;34:24;

 44:13;58:4;83:17;89:5,

 9;96:17;98:23

lastly (1)

 47:24

lately (1)

 71:14

later (6)

 8:23;38:21;42:23;

 51:6;78:1;88:10

latter (2)

 32:8;61:12

law (17)

 17:10;22:6;46:17;

 59:14;60:18;61:2,4;

 63:5;67:21;68:9;69:20;

 71:12;73:16;77:8;85:1;

 87:21;93:13

laws (1)

 32:17

lawyers (22)

 6:18;8:7;11:6,9;

 19:11;22:2;25:15;

 38:15;42:4,25;57:18;

 60:7,14;64:5,15;67:15;

 68:4;73:12;78:20;83:9;

 84:24;86:17

lead (2)

 23:8;41:7

leadership (1)

 24:3

learning (1)

 67:1

least (10)

 13:14;17:20;23:3;

 67:7,9,13;72:19;73:18;

 79:23;98:19

leave (6)

 13:18;22:25;58:5;

 61:22;78:21;89:4

leaves (1)

 51:15

Leblanc (7)

 10:5,6;14:1,3,5,9,12

Leblanc's (1)

 10:4

led (2)

 7:13;90:6

left (3)

 9:25;35:14;41:24

leg (1)

 79:5

legal (4)

 29:12,13;66:6;68:2

legally (2)

 41:16;80:5

legislature (1)

 27:13

length (1)

 51:25

lengthy (2)

 10:17;40:18

less (3)

 31:18;41:23;45:25

letter (17)

 9:11;10:4;14:7,12;

 15:1;18:14,15,17,20;

 19:9,10;24:2,4,22,24,

 25;27:6

letters (5)

 14:13;15:15;20:7;

 26:19;86:2

level (7)

 47:19,23;66:3;70:4;

 75:11;81:6;88:12

Lexecon (2)

 95:15;97:20

liabilities (4)

 45:1,10;92:5;95:6

liability (30)

 18:5,6;19:14,20;

 20:2,6,13;24:4,10;

 25:12;26:21;28:11;

 29:13,14;31:13;34:20;

 44:22;47:21;55:16,25;

 57:11;69:22;79:12;

 84:12;88:18;90:13;

 91:16,18;92:14;93:3

lift (3)

 18:21;19:13;30:7

lifting (1)

 19:18

likely (1)

 49:3

limited (4)

 30:8;41:1;56:2;

 94:15

line (4)

 6:10;12:8;41:7;

 101:2

lines (3)

 55:2,15;56:12

links (1)

 81:20

liquidated (4)

 65:3;66:19;68:25;

 89:12

list (12)

 5:24;6:20,23;15:4;

 17:13,15;21:13;43:14,

 20;55:4;56:3;89:5

listed (2)

 12:21;24:6

listening (1)

 22:3

litigants (1)

 25:6

litigating (1)

 25:6

litigation (10)

 25:3;27:2;31:9;

 71:12;95:24;96:18;

 97:16,23;98:3,4

little (8)

 19:9;30:24;35:11;

 49:5;56:14;57:7;98:15;

 99:24

living (1)

 73:11

located (2)

 17:11;44:5

log (11)

 44:7,9,11;48:21,23;

 50:1;92:2;96:20,22;

 97:5,21

logs (1)

 34:13

long (3)

 18:11;40:23;50:7

longer (4)

 62:2;69:1;73:11;

 89:17

look (15)

 39:21;42:2;46:7;

 53:13;54:3;56:4,5;

 67:6;70:14;72:21;

 78:19;81:22,25;83:10;

 100:12

looked (6)

 25:13;35:13;54:6;

 58:19;85:3,15

looking (20)

 9:3;10:15;15:6;

 18:13;22:13,20;24:13;

 42:5;49:11;53:7;55:4;

 67:6;68:11,23,24;72:9,

 11,21;88:11;89:21

looks (1)

 81:15

loop (1)

 14:17

loss (5)

 54:10;72:16;73:4,4;

 84:9

losses (8)

 48:3;57:12;58:4,16,

 20;65:17;72:16;90:1

lost (5)

 56:7,7;79:5;85:8;

 87:4

lot (9)

 16:14;35:12;60:16;

 65:10;71:14;83:6,8;

 95:11;99:25

lots (2)

 6:18;82:1

love (1)

 73:25

lower (1)

 74:24

luck (1)

 61:20

lump (1)

 85:17

M

Macon (3)

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(8) issue - Macon Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 110

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

 18:18,19;19:11

macro (1)

 58:10

mad (1)

 9:4

mail (1)

 15:3

main (1)

 44:15

mainly (1)

 45:3

majority (1)

 34:14

makes (9)

 18:3;20:14;27:13;

 34:22;35:3;74:4,4;

 75:4;83:12

making (5)

 40:5;54:20;70:24;

 78:22;94:12

managed (3)

 7:1;15:5;25:21

managing (1)

 11:6

manner (2)

 83:20;87:20

many (13)

 8:7,7;9:8;15:2;34:4,

 8;36:16;44:20;45:24;

 49:7,25;55:8;100:12

mark (1)

 47:2

marked (1)

 64:2

Marsh (1)

 57:6

mass (3)

 25:2;45:10;71:12

massive (2)

 34:13;47:21

materials (4)

 17:3;33:24;36:7;

 97:22

matter (14)

 5:5;7:9;19:3;21:8;

 24:5;30:12;32:11;

 40:13,14;81:19;88:24,

 25;96:12;98:22

matters (6)

 7:5,5;9:13,16,25;

 10:13

may (25)

 11:15;32:7;36:6,22;

 38:23;49:15,17;51:21;

 55:17,18,19;66:17;

 67:2;70:13;71:11;

 76:23;77:6;81:18,18,

 19;83:18;84:20;86:7;

 89:12;98:17

maybe (14)

 7:3;10:12;19:5;

 45:25;51:14;56:21;

 67:8;68:4;72:9;81:1;

 85:2;89:11,16;96:4

MCCALLEN (5)

 15:10,11,14;17:9;

 20:9

McCallen's (1)

 17:19

mean (23)

 19:4;29:2,4;30:13,

 21;50:14;51:10;54:9,

 12;56:8;57:12,17;

 66:20;68:22;74:13,16;

 81:14,18,22;86:7,8;

 95:7;97:13

meaning (2)

 18:21;82:6

means (10)

 18:14;28:22,24;

 29:22;30:1;32:18;

 74:24;83:4;89:8;91:11

meant (1)

 19:19

mechanism (2)

 11:22;97:18

mediating (1)

 85:25

mediation (25)

 46:11,13,21;59:5,7,8,

 10,13,17;60:3;61:3;

 62:8,8;63:11,13,19;

 64:2;74:8;75:12;77:12;

 81:9;85:24;92:18;93:7;

 98:16

mediation-protected (1)

 74:2

mediations (1)

 86:18

meet (4)

 13:7;22:15,21;63:5

meet-and-confer (3)

 15:16,23;45:4

meet-and-confers (1)

 20:10

meeting (1)

 12:6

memory (1)

 19:5

mention (1)

 59:15

mentions (1)

 22:13

merits (2)

 48:12;50:3

mess (1)

 8:10

message (2)

 83:13;92:9

might (13)

 10:8;13:6;54:10;

 57:11;61:19;67:20;

 69:5,6,8;70:19;86:6;

 96:15;98:20

million (4)

 25:11;85:12;86:10;

 94:12

mind (3)

 58:3;80:7;81:2

minimum (1)

 72:23

minute (3)

 16:15;26:11;62:16

minutes (1)

 26:18

miscarriage (1)

 89:2

mischief (1)

 8:14

miscommunications (1)

 6:24

misreading (1)

 50:21

miss (1)

 92:10

missing (1)

 55:10

mistakes (1)

 39:20

misunderstood (1)

 90:19

mitigation (1)

 32:23

moment (3)

 17:11;28:2;66:24

money (6)

 25:14;31:17;43:25;

 55:22;68:18;70:7

Montali (1)

 5:5

month (2)

 42:23;60:6

months (12)

 35:13;37:15,15;44:4,

 11;47:22;49:18;50:7;

 72:11,12;87:20,20

months' (1)

 34:9

more (20)

 9:23;10:1;31:18;

 32:19;42:2;46:22;50:8;

 51:25;53:13;67:1;68:5;

 71:22;78:1,2,8;79:11;

 84:11;85:12;89:11;

 99:8

morning (4)

 5:6,17,18;23:13

Morris (101)

 5:14;23:21;26:5,10;

 42:9,10,11,12,21;43:5,

 13,17;48:10,14,16,18;

 49:15,17,19,20,21,22,

 23,24;50:6,10;52:22;

 53:4;54:6,14;55:13;

 56:1,11;57:23;59:4,9,

 14;62:24;63:4,8,22,25;

 64:25;65:2,5;66:2,25;

 71:17,18,20;72:1,2;

 74:22;75:7,19,25;76:2,

 4,9,20,22;80:8,11,14,

 24;81:1;82:13,17;83:5,

 16;84:14,20;87:6;89:1,

 5,20;90:23,25;91:2,6,

 12,14,22;93:1,14,15,

 19,20,21;94:14,15,18,

 24;96:4,15;98:1,10,25;

 99:19,21;100:15

Morris's (2)

 58:21;99:14

most (6)

 44:13;45:14;47:8,20;

 53:3;65:25

motion (22)

 6:25;7:14,15;8:3,12,

 21,22;9:5,11;19:16,22;

 20:24;30:7;42:16;43:6;

 51:22;52:15,24;68:4,6,

 7;99:2

motions (4)

 7:8;27:21,21;49:10

move (8)

 8:1,24;12:3;16:2;

 20:13;27:9;29:11;79:2

moved (1)

 18:21

moves (1)

 42:23

moving (2)

 18:16;27:22

much (14)

 12:18;21:19;28:10;

 36:9;41:11;56:9;60:14,

 14;67:1;71:3;85:13,13,

 13;89:9

multi (1)

 71:12

multiply (1)

 79:10

myself (2)

 13:17;14:23

N

name (7)

 5:23;21:8;36:15;

 42:4;75:15;96:20,22

namely (1)

 46:17

names (6)

 29:24;71:1;75:25;

 76:6;77:2;83:25

narrow (3)

 24:12,17;90:11

nature (1)

 81:22

nearly (2)

 37:12;91:9

necessary (2)

 73:16;76:11

need (29)

 8:11;9:16,16,24;

 12:12;13:23;18:15;

 20:5;27:14;33:20;

 34:20,21;35:2,22;

 37:23;47:5,7;51:8;

 55:9;56:4;57:24;68:4;

 72:10;83:18;84:14,20;

 88:2,11;92:22

needed (1)

 60:22

needing (1)

 41:12

needn't (1)

 50:11

needs (10)

 13:16;18:22;20:3,12;

 21:5;41:10;77:7;78:10;

 81:12;89:3

negate (1)

 84:20

negligence (3)

 28:12,12,13

negligent (1)

 29:4

negligently (1)

 25:21

negotiate (1)

 20:14

negotiated (2)

 34:6;46:24

negotiations (2)

 11:8;61:23

neighborhood (1)

 58:14

neither (1)

 66:18

new (1)

 86:12

newspaper (1)

 41:4

next (7)

 7:14;9:2;19:3;20:22;

 49:10;50:4;100:13

nice (1)

 48:10

night (2)

 9:15,16

nine (1)

 58:14

ninety (1)

 25:11

Ninth (1)

 87:21

nolo (1)

 29:21

non (1)

 7:5

nondestructive (1)

 17:14

none (1)

 9:24

nonlawyers (1)

 6:18

nonprivileged (2)

 16:22;44:6

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(9) macro - nonprivileged Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 111

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

nonstarter (1)

 73:15

North (6)

 24:15,23;31:8,14;

 33:15;34:1

Northern (1)

 48:4

note (1)

 23:10

noted (1)

 53:16

notice (4)

 42:18;51:22,24;

 52:12

notices (2)

 43:24;50:23

notify (1)

 22:25

nuisance (1)

 65:17

number (43)

 6:22;9:13;12:5;

 13:19;17:12;20:7;

 23:11;27:11;34:24;

 35:8;48:12,21,23;53:7;

 54:7;55:5,8,25;56:13;

 57:1;61:10,11;68:18,

 18;69:3,12,13,18,21;

 74:24;75:7;81:23,24;

 85:16,16;90:15;93:23;

 94:2,6,7;95:25;98:6,9

numbered (1)

 42:14

numbers (9)

 21:10;54:7;56:3;

 69:14;74:25;75:8;

 84:16,17;96:8

O

object (2)

 24:17;81:8

objection (5)

 17:2;18:2;35:1;81:5;

 99:16

obligated (1)

 90:3

obligation (1)

 47:1

obligations (1)

 12:7

observation (1)

 9:14

obviously (8)

 13:22;16:14;18:3;

 24:16;43:20;79:10;

 99:13,14

occurring (2)

 72:7,8

off (4)

 8:13;16:11;20:3;

 28:3

offer (1)

 67:13

offers (2)

 59:9;78:8

Office (2)

 7:8;22:2

officer (1)

 30:18

official (2)

 10:2,3

old (1)

 86:12

omissions (1)

 55:5

once (2)

 24:20;32:5

one (57)

 6:23,23;13:15;14:8;

 16:12,25;17:10,13;

 19:11;24:13;25:4;29:7;

 32:9,9;39:18;42:2,15;

 43:17;48:19;50:8,13,

 15;51:10;55:24;56:25;

 60:2;65:25;66:15;

 67:13;69:6;70:18;

 71:25;74:2,15,17;75:7,

 20;76:9;77:24;78:9,23,

 24;79:16;80:11;81:25;

 83:17,22,24;85:4,11,

 17;87:5;89:14,17;

 90:18;96:1;98:25

one-party (1)

 60:5

onerous (1)

 56:19

ones (4)

 17:13;39:12;56:20;

 84:7

one's (1)

 44:9

only (17)

 10:1;11:16;14:18;

 20:19;40:6;45:25;

 49:25;56:21;66:15;

 73:15;74:15;76:6;

 79:15;80:14;87:17;

 90:7;95:9

oOo- (1)

 5:2

open (6)

 14:15,25;19:12;

 23:20,25;80:7

opened (1)

 89:21

openers (1)

 79:14

opening (3)

 24:4,16;82:14

operate (1)

 79:2

opined (1)

 98:18

opinion (1)

 79:13

opinions (1)

 64:6

opponent (2)

 51:7;99:19

opportunity (2)

 50:19;52:5

opposing (2)

 52:3;100:5

opposite (1)

 26:18

option (2)

 28:2;64:13

order (44)

 5:3;7:13;8:22;10:1,

 16;11:10;19:22;23:21;

 31:21;33:8,11;37:14;

 39:24;40:23;43:9;

 44:10;46:24,25;47:3,8;

 52:13;54:5;57:3,17;

 60:24,25;68:12;71:22,

 23;72:23;80:2,12,19;

 81:13;84:5;87:13;90:9,

 20;92:2;96:10;99:10;

 100:3,4,5

ordered (8)

 26:4;47:14,16,25;

 48:8;88:8;99:5;101:3

ordering (1)

 88:4

orders (3)

 32:21;36:3;41:8

originally (1)

 11:8

Orsini (170)

 5:21;6:2,3,5,7,8,12,

 15;10:9,14,24;11:1,4,

 12;12:16,20,25;13:2,4,

 18,21;14:16;15:25;

 17:9,18,22,25,25;18:8,

 11;19:7;20:16;21:7;

 24:7;26:13,15;27:18,

 19;28:15,20,23;29:1,3,

 5,7,16,18;30:4,15,24;

 31:1;33:14,18,20;35:8,

 11,18,19,22;36:18;

 37:15,24;38:9,14,19;

 39:4,13,14,17;40:21;

 41:25;43:3;45:4;48:20,

 22,25;49:2,4;50:2,9,12,

 17;51:3,6;52:21;53:5,

 6;57:23;58:8,10;61:8,

 9,16;62:3,5,13,15,18,

 20,25;63:3;67:11,12;

 68:14,15,16,21;69:11,

 24;70:2,9,10;73:8,22,

 25;74:7,11,14,17,19,

 20;75:6,14,17;76:23;

 77:1,6,13,18,21,24;

 78:12,15,17;80:14;

 81:3,4;82:18,20,25;

 83:11;84:3,19,22,25;

 85:6,15,23;86:2,16,24;

 87:3;88:14;91:4,19;

 92:9,10;94:10;95:4,11,

 18;96:17,22;97:7,9,13;

 98:12;99:12,13;100:14

Orsini's (5)

 5:23,24;24:1;71:20;

 73:14

others (4)

 10:10;17:15;43:3;

 61:11

otherwise (4)

 40:9;46:19;77:1;

 89:18

ought (1)

 26:22

ourselves (3)

 30:5;55:21;60:5

out (20)

 6:19;7:16;21:4;

 22:20,22;24:23;34:11;

 37:24;41:11;50:15;

 51:13,14;57:10;61:20;

 70:7;74:2;82:15,21;

 87:12;99:24

outcome (2)

 68:11;77:9

outside (1)

 63:19

outstanding (3)

 44:4,11;49:18

over (29)

 8:3;12:8;25:25;

 26:19;30:16;31:25;

 34:3,4;35:12;39:12;

 40:24,24;42:10,23;

 45:5;46:23;47:6;52:21;

 59:4,7;68:3;73:10;

 76:24;77:12;80:17;

 87:8,17;94:2;96:10

overall (1)

 12:22

overbroad (2)

 22:10;34:14

overly (1)

 57:14

oversimplified (1)

 67:3

overstated (1)

 67:2

overwhelming (1)

 34:14

own (6)

 16:9;54:10,24;58:23;

 64:6;70:13

P

pace (1)

 52:21

PACER (1)

 36:2

page (8)

 8:8;21:9;56:5,21,22;

 57:20;91:5;101:2

pages (1)

 33:24

paid (10)

 25:11;31:16;41:11;

 61:10,14;66:16,17;

 68:19,19;70:7

paper (1)

 68:5

papers (1)

 23:3

paragraph (1)

 13:15

Pardon (2)

 33:19;52:10

part (20)

 10:11;15:23;19:21;

 20:4;27:3;50:21;58:24;

 59:8,16;60:9;62:6;

 66:11;71:2;76:13;

 79:19;82:12;87:2,3;

 93:10;97:19

participate (1)

 16:4

particular (7)

 16:16;55:18;64:18;

 70:5;77:3,25;88:19

particularly (2)

 6:2;27:10

parties (19)

 14:14;16:3;17:1;

 22:9,14;24:12;26:2;

 27:11,11,22;34:6;

 45:19;47:1,10;63:8;

 65:11;85:11,25;99:23

partner (1)

 43:7

parts (1)

 33:15

party (4)

 46:25;51:23;58:3;

 59:6

Pascuzzi (8)

 21:17,17,22,24,25,

 25;22:24;23:6

pass (1)

 9:16

passing (1)

 9:15

past (3)

 45:17;54:18;91:1

path (3)

 18:24;20:20;67:15

Paul (2)

 21:17,24

paying (1)

 100:7

payment (1)

 32:22

pending (2)

 25:3;40:14

people (11)

 5:22;9:9;12:6;20:25;

 51:12;60:15;62:17;

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(10) nonstarter - people Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 112

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

 70:15;73:10,13,15

per (1)

 57:25

percent (5)

 34:19;46:1;60:2;

 89:15;96:1

perfectly (2)

 82:3;96:5

perhaps (6)

 13:16;61:21;83:6,7,

 7;86:4

permission (1)

 47:6

permit (2)

 12:4;57:13

permitted (1)

 8:25

person (7)

 36:14;61:19,19,20;

 79:5,6,7

personal (3)

 71:3;75:3;82:21

personally (2)

 84:23,25

person's (1)

 79:1

perspective (4)

 15:17,20;16:5;60:17

persuade (1)

 77:1

persuaded (3)

 41:22;66:10;80:3

pertain (1)

 20:18

pertaining (1)

 7:9

petition (1)

 41:12

PG&E (24)

 5:5;7:5;25:20;29:22;

 32:19,24;34:17;37:4,8;

 38:24;41:10;46:5;

 53:21;56:8;62:14,16;

 64:9;77:11;80:20;

 81:20;86:4;88:16;

 89:16;98:19

PG&E's (6)

 25:23;30:2;53:25;

 54:10;71:6;84:15

phone (6)

 5:7,7,23;6:22;21:2;

 22:3

phrase (1)

 19:13

physical (6)

 15:21,22;16:6;17:14;

 30:2;79:8

pick (2)

 87:23;90:10

picture (1)

 72:9

piece (1)

 67:14

pipeline (1)

 58:14

place (7)

 16:2;19:24;26:23;

 27:5,13;41:9;59:25

places (1)

 8:7

plaintiff (4)

 30:11;56:8;81:16;

 85:10

plaintiffs (5)

 29:22;61:10,13;

 70:13;71:8

plaintiffs' (5)

 64:5;67:8,15,23;

 73:12

plaintiff's (1)

 68:4

plan (6)

 25:25;27:1,13;34:22;

 64:17;73:21

plans (2)

 53:24;72:21

playing (4)

 47:19,23;80:24;

 88:12

plea (2)

 29:21,21

pleading (1)

 22:12

pleadings (1)

 90:6

please (3)

 8:10;42:21,22

plus (1)

 97:4

PM (1)

 100:17

point (27)

 6:16;13:20;19:16;

 24:12,23;27:19;28:1;

 29:7,8;35:2,8;38:22;

 45:13;57:17;63:25;

 66:1;68:25;71:23;

 78:22;80:4,9;81:9,21;

 82:11;88:23;96:14;

 98:1

points (3)

 28:15;32:21;65:11

policies (24)

 17:15;43:19;51:16;

 53:1,8,18;54:9,17,17,

 18,23,25;55:7,14,16,

 17,18,20;56:13,15,16,

 20;57:16;58:3

policy (20)

 53:4;54:9;55:5,9,11,

 12,25;56:3,5,13,20,22,

 23;57:1,2,4,11,11,20;

 63:14

pop (1)

 19:5

portal (1)

 10:6

portion (1)

 10:20

position (5)

 6:16;20:2;43:3;

 60:17;64:5

possession (5)

 15:22,22;22:13;

 25:23;67:18

possible (4)

 12:6;15:18;49:13;

 55:22

potential (2)

 30:9;58:20

pots (1)

 55:22

practice (1)

 71:13

practices (1)

 17:16

pre- (1)

 41:11

Precisely (1)

 30:15

pre-existing (1)

 47:1

prejudice (1)

 69:16

prematurely (2)

 16:8,13

premised (1)

 50:20

prepare (1)

 42:24

prepared (14)

 8:24;9:4;20:13;21:3;

 27:9;50:13;51:25;52:4,

 6;59:16;60:2;66:5;

 76:25;80:8

preparing (4)

 25:14;34:12;42:22;

 50:22

pre-petition (1)

 41:19

prerogative (1)

 63:7

present (1)

 70:4

presiding (3)

 5:5;30:14,16

press (1)

 88:16

presumably (1)

 27:23

presume (3)

 84:23;89:8,15

pretty (2)

 30:21;71:9

previous (1)

 26:19

pride (1)

 42:22

primarily (1)

 32:12

principal (3)

 6:16;42:4,25

principle (1)

 41:5

prior (7)

 19:15;37:9;44:16;

 45:11;65:14;70:15,15

privilege (44)

 22:17;34:12;44:7,10;

 46:11,13,21;48:21,23;

 50:1;59:5,13,17;60:3,

 9;61:21,22;62:8,17,23;

 63:9,11,13,20;64:2,7,

 12;71:5;75:12;81:9;

 85:24;87:17;92:2,17;

 94:2,5;95:2,5;96:9,20,

 22;97:5;98:5,6

privileged (21)

 34:12;45:8;62:2;

 64:11;74:5;75:5;81:21;

 86:5,8,15,15;88:21;

 91:20,25;92:6;93:7;

 94:20,21;96:19;98:9,

 13

privileges (4)

 46:12;87:8,15;98:16

probably (5)

 65:25;85:12;89:14;

 95:15;99:25

probation (2)

 32:14,16

probative (4)

 41:13;58:16;59:1;

 69:5

problem (3)

 17:19;60:4;99:12

problems (1)

 34:8

procedure (1)

 40:13

procedures (2)

 17:16;25:2

proceed (3)

 19:14;21:15;42:19

proceeded (1)

 48:11

proceeding (6)

 12:6;25:19;30:9;

 31:10;32:4;37:9

proceedings (10)

 11:6;18:24;19:12;

 34:24;35:6,24;36:16;

 37:4;88:4;100:17

process (15)

 15:16;20:5;22:5,22;

 29:12;35:3;37:5,23;

 38:2;41:17;65:12;

 71:10,16;72:22;76:11

processes (2)

 27:24;71:11

produce (40)

 24:19;31:13,21;

 33:24;34:18;36:11;

 39:24;44:10;46:2;

 47:14,16,25;48:2,7;

 49:5;53:17;57:3;67:20;

 68:8,12;72:24;73:19;

 74:12;76:17,17;79:25;

 80:2;82:4;88:5,6,8;

 90:4,9,10;91:4;92:2;

 94:18;99:6,17;101:3

produced (52)

 16:22;17:4;31:10,15,

 19,19,20,22;33:16;

 34:5;35:9;36:1;43:8;

 44:5,6;45:21,24,25;

 48:8;49:3;54:23;55:9,

 11;56:3,21;59:14;61:1,

 2,5;65:13;68:1;69:15;

 75:22;76:12;83:4,14;

 84:6;91:8;92:13,20;

 93:2,5,8,9;94:3,14;

 95:13,14,22;97:4;99:5,

 10

produces (1)

 37:5

producing (10)

 35:1;37:9;45:6;

 47:25;67:25;83:21;

 90:4,7;92:16,17

product (21)

 75:5;81:10;82:10;

 84:4;85:21;86:6,7,8,19,

 21;87:23;91:20;92:1,3;

 93:7;95:9,23;96:1,2;

 97:16,19

production (6)

 34:11;35:15;36:18;

 38:25;40:6;86:20

productions (3)

 16:24;56:18;94:16

professionals (1)

 14:19

progress (4)

 9:17;42:8;98:23;

 100:1

prohibits (1)

 59:6

projections (2)

 16:20;79:7

prominent (1)

 65:25

prominently (2)

 22:5;31:9

promise (1)

 23:11

pronouncing (1)

 42:3

proof (4)

 28:11,12;62:22;

 88:25

proper (1)

 82:3

properly (2)

 43:25;98:18

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(11) per - properly Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 113

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

property (9)

 53:24,25;54:10;

 65:16;71:2;73:4;75:4;

 84:9;85:8

propose (1)

 20:5

proposition (1)

 30:25

protect (1)

 91:21

protected (5)

 46:15;74:9;75:12;

 86:19;96:2

protection (4)

 63:14;87:23;92:7;

 94:4

protections (4)

 40:25;46:20;47:8;

 63:18

protective (5)

 41:8;46:24,25;47:3,8

protects (1)

 71:5

protocol (8)

 20:14;24:9;26:23;

 27:5,7,8;34:1;38:20

prove (4)

 25:22;29:22;30:2;

 70:13

provide (16)

 10:22;26:17;27:8;

 38:14;53:14;54:25;

 55:19;60:4;65:10;68:9;

 71:5;77:14;78:4;81:5;

 83:10,13

provided (14)

 11:20;16:2;32:10;

 36:7;40:3;53:14;56:16;

 75:8;77:15;81:6;82:8,

 15;93:4;99:3

provides (2)

 14:18;63:16

providing (6)

 18:5;38:13;47:11;

 67:9;81:5,8

proving (1)

 25:18

provisions (1)

 63:19

prudent (1)

 13:22

public (25)

 16:20;39:10;40:9;

 41:15;45:2,2;48:3;

 72:13;81:18;89:16,22,

 24,25;91:23,23;92:5;

 93:10;94:8,21;95:12,

 19;96:23;97:3,15,17

publicly (6)

 36:1,2;44:21;62:16;

 88:16;95:21

pulling (1)

 34:11

punitive (2)

 56:15;93:25

purpose (3)

 6:18;86:17;89:23

purposes (19)

 21:6;28:20;30:1,19;

 34:15;44:14;64:17;

 65:8;66:17,21,23,24;

 70:24;73:18;79:23;

 80:22;85:19;98:3,4

pushing (1)

 53:19

put (21)

 13:2,19;19:1;27:5;

 35:3;38:18;41:25;

 50:19;51:13;54:8;

 64:16;72:20;74:3,22;

 75:1;80:20,24;92:1;

 93:23;94:6,7

putting (3)

 29:24;32:23;51:14

Q

quick (4)

 5:25;35:16,19;58:12

quickly (4)

 12:6;15:18;89:3;

 93:13

quite (6)

 12:8;19:18;26:16;

 53:6;56:18;65:9

quote (1)

 90:16

R

raise (1)

 20:21

raised (3)

 27:22;32:25;53:8

raises (1)

 67:24

range (1)

 30:21

rather (3)

 20:19;32:22;38:21

ratio (1)

 59:20

reach (1)

 16:10

reaching (1)

 11:14

read (8)

 23:3;28:7;33:4,8,10;

 41:2;53:1;56:2

readily (1)

 39:22

reading (1)

 71:14

ready (14)

 20:12;21:12;26:20,

 20;27:4;31:13,14,19,

 22,23;33:22;34:11;

 38:25;42:19

real (1)

 78:7

reality (1)

 34:9

realize (3)

 6:17;19:1;25:18

really (6)

 27:21;54:1,11;62:6;

 71:24;92:25

reason (9)

 6:15;8:23;24:14,25;

 32:13;33:16;48:22,25;

 65:9

reasonable (3)

 20:6;44:24;99:8

reasonably (1)

 49:5

reasoning (2)

 77:5,7

reasons (2)

 25:9;89:10

recall (3)

 11:7;19:4;61:9

recalls (1)

 19:21

receive (1)

 27:8

received (4)

 9:11;44:7;55:14;

 77:16

receiving (1)

 78:3

recent (1)

 78:1

recitals (1)

 85:7

recognize (2)

 65:21,24

recollection (1)

 37:13

record (5)

 40:9;42:1;43:10;

 82:11;100:10

records (3)

 45:7,21;84:15

recovery (2)

 55:1,23

redact (3)

 76:9,14,15

redacted (8)

 45:7,24;46:9;75:21;

 78:5;81:11;84:1;87:24

redacting (2)

 77:2;84:3

redaction (1)

 84:2

redactions (5)

 76:20,21;77:18;

 83:23;84:6

redacts (2)

 75:23;76:5

reduce (1)

 100:4

reference (2)

 60:24;65:14

referenced (4)

 36:6;40:2;56:14;

 57:1

referred (2)

 17:21,23

referring (9)

 19:8;33:25;36:5;

 40:10,11,11;55:15;

 72:13;73:5

reflect (1)

 40:16

refused (2)

 26:16;46:2

regard (4)

 8:20;22:17;37:21;

 94:16

regarding (5)

 6:25;7:15;9:13;

 51:22,23

regardless (1)

 98:2

regime (1)

 60:1

regularly (1)

 65:24

relate (4)

 32:2,10,11;92:14

related (14)

 16:6;18:22;31:25;

 33:1,13;39:9;44:3;

 45:6;46:1,10;53:8;

 63:12;72:19;75:22

relates (5)

 32:12;58:11;59:2;

 79:14;93:2

relating (5)

 44:16,17;45:7;48:2;

 89:25

releases (1)

 88:16

relevance (4)

 54:9;65:21;72:3;

 92:22

relevant (25)

 16:17,17;30:22;

 33:17;35:1;36:24;

 41:16;43:8,20;46:7;

 54:13;58:5;63:10;

 66:17;69:1;70:24;72:6,

 17;73:16;78:16;80:5;

 81:18,18;86:7;88:7

reliable (1)

 45:14

reliance (1)

 45:3

relied (7)

 91:16;94:1,5,21;

 95:12;96:7;97:15

relief (7)

 20:23;24:5;27:20,24;

 28:3;30:11;41:23

rely (10)

 45:9,11;47:10;66:11;

 76:15;91:7;94:12;95:8;

 96:18;100:10

relying (10)

 45:22;46:14;47:9;

 58:22;65:14,22;72:5;

 84:15;92:4;99:9

remain (1)

 12:13

remains (1)

 96:1

remember (4)

 32:13;33:3;64:15;

 79:17

remembers (1)

 95:16

remotely (2)

 58:16;59:1

removed (1)

 76:21

reopened (1)

 24:20

repeat (1)

 41:22

repeatedly (2)

 26:18;27:4

rephrase (2)

 40:7,7

report (6)

 7:7;10:24;11:13;

 13:15;49:10;84:12

reported (2)

 20:9;89:23

reports (7)

 31:24;33:1,13;35:20;

 39:9;47:17,18

represent (3)

 8:19;36:16;73:12

representation (1)

 97:2

represented (1)

 83:7

representing (1)

 9:8

represents (1)

 36:23

request (29)

 7:2;12:17;15:8;

 16:18;17:19;18:16;

 22:8;24:17,24;26:3;

 31:21;36:11;38:18;

 44:9;45:12;47:12;48:2;

 50:21;53:15;54:5;55:3;

 57:2;76:16;80:18;90:3,

 6,8;92:15;99:19

requested (4)

 9:20;13:7;17:8;

 101:3

requesting (4)

 19:12;24:4,15;39:12

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(12) property - requesting Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 114

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

requests (17)

 16:15,23;17:4,6;

 22:10;23:20;24:10,21;

 26:24;31:6;48:7;49:17;

 53:3,19;90:11;91:9;

 92:24

require (2)

 19:20;86:20

required (1)

 49:12

requires (2)

 68:12;78:21

research (1)

 67:1

reserve (1)

 83:19

reserved (1)

 7:7

residential (1)

 58:14

resisting (1)

 58:9

resolution (5)

 10:12,23;11:25;

 95:20;97:20

resolve (6)

 12:12;18:22;20:3;

 23:24;58:2;95:18

resolved (1)

 95:19

resolving (1)

 26:9

resource (1)

 45:19

resources (1)

 34:22

respect (24)

 18:5;22:16;24:6,10;

 28:20,23;29:3,8;32:20;

 33:2;34:10,11,12;

 35:15;46:13;58:20;

 59:3,17;60:3,9;78:8;

 92:12,25;93:6

respond (15)

 17:10;26:4,13;38:9,

 20;42:24;49:15,17;

 52:5;57:25;58:1;71:18;

 87:7;96:10;98:12

responded (5)

 16:22;24:21;31:3;

 43:7;44:5

responding (5)

 19:10;52:22;53:3;

 56:12,12

response (33)

 10:15;12:17;17:4;

 19:15,17;21:3;23:21;

 32:25;33:10;35:16,19;

 39:15;42:20;43:9;44:8;

 50:3,3,4,10,19,22;51:1,

 7,8;53:5,11,19;57:25;

 58:12;90:5;91:9;98:13,

 13

Responses (6)

 21:9;26:25;27:8;

 42:1;53:2;78:9

responsibility (4)

 9:22;32:2,15,21

responsive (9)

 16:23;33:24;34:7;

 35:2;53:15,22;71:6;

 90:8,10

rest (1)

 25:16

restate (1)

 91:5

restating (1)

 81:2

resulted (2)

 43:6;46:5

reticent (1)

 49:5

return (1)

 12:9

review (1)

 36:11

reviewed (2)

 34:5;53:20

reviewing (1)

 54:16

right (41)

 5:6;6:6,14;11:15;

 12:24;15:2,13;19:23;

 20:17,20;23:5;28:14,

 25;29:11,16,18,21;

 30:3;35:6;43:12;48:15,

 17;49:1,6;62:9,25;

 72:3;82:13,23;83:15;

 85:14,15;87:5;93:17;

 94:15;97:9,13;98:10;

 99:20,22;100:8

rights (1)

 64:18

Rios (1)

 21:25

ripe (4)

 13:9,24;43:10;60:11

Robert (1)

 23:18

roles (1)

 73:23

roll (2)

 20:17;39:18

rolling (1)

 76:24

Roman (1)

 12:17

rule (1)

 73:19

ruling (5)

 32:6;37:25;38:17;

 42:8;81:3

RULINGS (1)

 101:2

run (2)

 6:20;14:21

S

said/she (1)

 100:9

sake's (1)

 42:18

same (31)

 7:3;8:8;14:22;27:17,

 22;40:25;41:4;46:5,6;

 47:23;48:5;65:9;72:6,

 20;73:7;74:1;77:16,19;

 78:4;79:11;80:24;81:6;

 82:5;87:20;88:12;

 89:13;90:4;91:5;93:4;

 98:3,4

sample (1)

 83:1

sampling (1)

 70:6

SAN (25)

 5:1;32:11,15;41:3;

 44:18;46:3;47:16;58:8,

 9,11,13,24;59:3;65:7;

 70:22;71:24;73:11;

 74:22;75:22;76:24;

 79:21;80:3,4;88:9;

 90:18

satisfaction (1)

 31:2

satisfied (10)

 13:13,14;14:19;

 21:14,14;42:6;50:10;

 51:8,9;54:5

satisfies (1)

 52:23

satisfy (1)

 42:5

saying (15)

 16:22;31:5;36:9;

 41:7;45:4;46:25;48:6;

 57:1;64:24;68:1;71:4;

 82:7;94:11,13,13

scattershot (1)

 22:11

scenario (1)

 60:5

schedule (3)

 8:10;27:11;34:21

schedules (1)

 24:14

scope (1)

 49:7

seal (12)

 36:19;38:25;39:5,10,

 20,22;40:1,9,15,16,19,

 23

sealed (1)

 41:2

sealing (1)

 36:2

SEC (40)

 41:15;48:1,5;76:13;

 77:12,14,16,24;78:2;

 80:1,15;81:6,11;82:8;

 87:10;88:17;89:21,24;

 90:4,11;91:8,16,23;

 92:12,13,20,21;93:1,2,

 8,23;94:4,5,7,10,11;

 95:5;98:5,7,19

second (4)

 10:19;32:9;43:19;

 90:18

secondly (2)

 7:6;31:24

SEC's (2)

 48:1;76:13

Section (6)

 12:22;43:20;46:14,

 17;63:12;71:16

secure (1)

 13:5

seeing (2)

 54:18;100:12

seek (2)

 47:20;80:11

seeking (7)

 13:6;48:5;55:3;65:5,

 8,9;89:24

seem (3)

 41:6;61:9,20

seemed (2)

 18:10;20:17

seems (12)

 33:17;41:23;57:12,

 13,16,16,20;61:3;

 64:12;71:8;77:1;82:2

selective (1)

 87:21

selectively (3)

 76:14,15;90:10

send (1)

 96:6

sense (9)

 18:3,16;20:14;23:23;

 27:13;34:23;35:3;

 77:10;94:25

sensible (2)

 16:3;18:10

sent (3)

 15:15;19:15;32:6

sentence (1)

 19:5

separate (7)

 12:21;29:24;40:6;

 42:15;74:1;84:2;94:3

separately (3)

 36:10;73:7;93:6

serve (1)

 57:5

served (4)

 12:9;16:14;26:24;

 92:16

session (1)

 5:4

sessions (1)

 45:4

set (17)

 7:15;8:3,9,23;9:1,2;

 15:5;16:20;27:12;28:5;

 33:22;39:23;53:11;

 61:1;68:7;72:11;96:6

setting (4)

 8:21;51:12;52:9,12

settle (2)

 68:19;85:11

settled (18)

 47:5;61:10,13,25;

 62:17,22;66:14,16,16;

 68:18;69:4,10;73:10;

 77:3;81:20;82:1,2;84:7

settlement (58)

 45:3,5,11,13,14,22;

 46:1,9,18;47:14;59:4,

 11,17,20;61:18;62:1,

 10;63:5,6,9;64:8,19;

 65:5,6,7,15;72:18;73:2,

 3,8,20;74:25;75:1,11;

 80:21;82:12,13,16,22,

 23;83:1,3,8;84:11,21;

 85:4,8,9,16,18,20;

 86:18;87:12,14;88:10;

 89:16;90:17;91:14

settlements (20)

 44:16;45:7;47:15,16,

 18;59:24;70:6,7,14;

 74:23;75:11;76:7;78:2;

 80:17,19;81:7,24;

 84:24;86:4;89:7

seventy (3)

 23:20,25;54:7

shape (1)

 58:19

share (1)

 82:25

shared (1)

 71:8

Ship (4)

 28:5;29:25;79:20,22

ships (2)

 9:15,16

short (5)

 6:20;15:4;50:19;

 51:1;54:5

shorten (2)

 8:22;9:1

shortened (1)

 7:2

show (4)

 45:22;73:19;85:4;

 88:24

shows (1)

 33:11

shut (1)

 20:3

shy (1)

 13:22

side (6)

 13:16;17:18;42:25;

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(13) requests - side Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 115

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

 64:4;70:18;74:15

sides (4)

 11:13;38:10;59:12;

 63:5

sight (1)

 34:25

sign (1)

 100:4

signed (1)

 18:14

significant (3)

 12:5;35:14;69:16

similar (4)

 45:16;54:17;65:20;

 71:11

simple (4)

 44:9;48:21;95:7;

 96:4

simplicity (1)

 10:1

simply (12)

 9:15;19:17;24:18;

 25:8;26:1,2;30:5;35:2;

 47:13;48:7;85:17;90:3

Singleton (1)

 22:6

sit (2)

 20:14;27:5

sitting (1)

 34:17

situation (1)

 30:6

situations (1)

 70:16

six-month (1)

 72:10

slightly (2)

 9:15;97:14

solution (3)

 67:6,13,23

solutions (2)

 23:23;26:8

solves (1)

 60:24

somebody (4)

 5:8;23:5;86:9;100:9

somehow (3)

 7:1;30:5;41:16

someone (8)

 8:17;17:18;21:2,15;

 23:17;36:13;67:11;

 78:24

something's (1)

 40:15

soon (3)

 27:20;49:5,13

sooner (1)

 38:20

sorry (7)

 15:1;42:4;63:3;65:2;

 76:2,2,4

sort (4)

 6:16;9:19;10:22;

 59:4

sought (1)

 44:22

sounds (4)

 23:2;30:22;62:23;

 97:1

source (2)

 55:1;72:14

speak (8)

 8:17;14:6;21:13;

 23:16;36:13;40:4;

 51:25;67:11

speaking (4)

 16:1;18:11;20:12;

 28:16

speaks (1)

 23:25

specialty (1)

 54:16

specific (13)

 7:6;18:25;19:5;

 53:12;55:3,14;56:13;

 57:1;59:5;63:18;68:20;

 82:10;84:16

specifically (6)

 38:20;47:24;67:1;

 68:8;89:20;91:3

specificity (1)

 96:23

specifics (2)

 59:23;70:14

specimen (1)

 82:25

specimens (3)

 82:15;83:12,13

speed (1)

 47:23

spend (1)

 9:23

spent (1)

 25:13

spoke (1)

 6:7

spreadsheet (15)

 73:24;75:2,4,9,13,15,

 22;76:16;77:16;78:1;

 80:16;81:15,16,25;

 99:4

spreadsheets (10)

 72:24;73:1,19;75:7,

 20;77:20;81:5;83:20,

 24;99:17

staff (4)

 9:7,21;52:20;99:24

stakeholders (1)

 69:17

stand (6)

 10:7;13:14;14:11;

 15:8,8;68:15

stand-alone (1)

 55:18

standing (2)

 26:20;41:20

start (7)

 27:1;51:11;58:8;

 87:1;88:2,3,11

started (3)

 15:16;36:13;55:25

starting (3)

 55:4,8;72:21

state (24)

 11:6,10;19:12;20:1,

 19;24:2;25:3,6,8,15;

 27:24;30:6,9;31:16;

 34:24;36:16;37:3;59:6;

 61:4;67:21;71:12;

 88:14;94:9;97:14

stated (7)

 20:7;24:7;59:15,20;

 67:17;88:7;90:21

statement (14)

 10:11;12:19;17:23;

 18:19;19:4;26:14,16;

 29:25;62:3,4,8;94:13;

 96:17,18

statements (6)

 44:20;45:2;54:20;

 69:14;91:24;94:8

states (2)

 46:15;62:16

stating (1)

 92:3

status (2)

 12:14;81:17

stay (13)

 18:22;19:14,18;

 20:23;24:5;27:20,25;

 28:3;30:7,11;41:23;

 52:24;84:1

stays (1)

 14:20

Steve (1)

 36:15

STI (1)

 95:15

stick (1)

 55:24

still (9)

 11:14,16;24:18;

 25:24;28:12;31:2;34:9;

 35:12;60:13

stipulated (1)

 95:20

stonewalling (1)

 60:20

stopped (1)

 61:12

streamline (1)

 17:6

Street (2)

 33:5;40:10

strikes (1)

 67:7

strong (1)

 59:5

struggling (1)

 62:7

stuck (2)

 38:16;60:18

stuff (2)

 25:6;37:23

sub-buckets (2)

 54:2;90:17

subject (23)

 9:13;10:15,25;11:10,

 16;34:5;36:2;39:24;

 42:16;46:11,12,20;

 61:5;63:13,15;64:2;

 84:4;85:24;92:6,17,17;

 98:15,16

Submission (4)

 21:10,10;42:13;53:9

submissions (1)

 40:3

submit (1)

 86:21

submitted (4)

 33:1;35:25;36:1;

 50:22

subpoena (2)

 12:9;22:6

subpoenas (1)

 22:7

subrogation (16)

 10:18;15:4,7,12,15;

 17:20;18:4,21;19:11;

 20:10;21:10;22:12;

 24:3,24;41:5;82:6

subsequent (2)

 20:7;60:12

suffered (3)

 79:6,7;86:13

sufficient (1)

 99:8

sufficiently (1)

 44:8

suggest (2)

 21:15;68:5

suggested (1)

 73:8

suggesting (2)

 26:22;28:1

suggestion (2)

 10:11;73:14

sum (2)

 78:25;85:18

summary (1)

 48:10

supplement (1)

 36:22

supplemental (1)

 17:7

support (3)

 12:22;93:22;95:24

supported (1)

 6:17

supporting (1)

 16:19

supports (1)

 77:8

supposed (4)

 30:17;37:8;41:20;

 57:8

sure (25)

 8:6;9:7,19;11:3;

 15:10;19:18,21;21:21;

 27:16;40:17;43:25;

 53:6;54:2;56:19;70:21;

 71:9,9,14;72:2;78:17;

 83:10;85:3;90:20,25;

 91:6

sympathetic (1)

 41:12

system (2)

 25:21;38:11

T

table (2)

 16:11;28:3

tabled (1)

 14:21

talk (5)

 19:24;60:6;64:20;

 83:2;92:23

talked (4)

 67:10;79:15;89:6;

 90:21

talking (13)

 10:19;43:1;49:8;

 59:9;64:18,23;69:17;

 75:8,9;79:15,21;89:10;

 90:12

tandem (1)

 25:8

TCC (60)

 6:24;7:15;8:2,3,19;

 9:12;10:3,18;12:17,25;

 13:7;14:25;15:14;

 16:14,16,23;17:4,7,20;

 20:11;21:4,9,13;23:9,

 15,19;24:2,11,15;

 31:24;33:4;35:21;41:5,

 15;42:12;43:22;44:22;

 50:14;54:23;57:18;

 58:18;59:18;60:6;

 64:15;65:11;68:7,10;

 69:15;72:20;77:15;

 78:5;82:6;92:12,16;

 93:4,9;95:13;96:5;

 100:3;101:4

TCC's (3)

 51:13;64:12;67:18

team (2)

 35:13;54:16

technological (1)

 34:8

technology (1)

 34:6

tee (2)

 37:25;38:5

teed (2)

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of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

 68:4,6

telling (4)

 47:4;54:22;56:4;

 57:9

tells (1)

 91:19

ten (1)

 46:1

tenders (1)

 43:24

tens (1)

 33:24

tenure (1)

 93:9

term (1)

 32:16

terms (5)

 11:16;28:11;56:24;

 64:20;69:5

terribly (1)

 41:12

test (1)

 82:3

testimony (1)

 64:1

therefore (3)

 13:15;65:4;91:11

there'll (1)

 50:3

thinking (1)

 71:13

third (4)

 44:2;47:1;51:23;

 58:3

third-party (7)

 6:25;7:15;42:15;

 43:3,17;50:12,15

thirty (5)

 87:11;94:12;95:6,8;

 97:3

thirty-billion-dollar (4)

 93:23;94:6;95:25;

 98:9

though (4)

 8:5;58:21;75:6;98:1

thought (7)

 5:7;18:1;39:2,4;

 53:2;57:18;81:1

thousands (3)

 31:13;33:24;79:10

three (3)

 48:8,21,24

timeline (1)

 99:6

times (1)

 6:9

timing (1)

 50:11

tired (1)

 99:24

today (36)

 7:14;8:3,5,24;9:5,14,

 25;13:9;16:12;17:1;

 23:3;25:1;26:2;27:14;

 32:7;38:17;42:17,18;

 43:10;44:10;48:8;

 50:24;51:23,24;52:12;

 72:20;73:18;79:15,22;

 80:8;82:11;88:8;98:21,

 22;99:11;100:13

today's (3)

 7:13;79:23;90:6

together (5)

 19:23;24:8;35:3,3;

 64:16

told (9)

 26:18;27:4;31:14;

 39:7;41:14;47:4;60:11,

 13;92:12

tomorrow (2)

 30:7;41:3

took (1)

 86:10

topic (3)

 10:17,19;13:19

topics (5)

 12:16;43:14,15;

 92:19,23

tort (12)

 22:7;25:2,7;36:23;

 43:23;44:22;45:10;

 46:23;71:12;72:5;

 87:18;90:5

total (6)

 59:19;75:2;79:1;

 80:20;84:10,12

touch (4)

 6:1;31:18;32:5;

 33:23

track (1)

 29:23

tracking (1)

 21:6

transcript (2)

 37:13;100:6

transcripts (2)

 37:7;38:1

traumatic (1)

 79:6

treasure (1)

 34:16

treat (1)

 47:1

treated (1)

 41:4

tree (3)

 72:16;73:4;75:3

trees (1)

 25:21

trends (1)

 59:23

trial (23)

 11:5;19:11;25:8,20,

 20;30:1,4,6,17;41:11,

 22;60:7,14;68:23;

 70:12;74:13,13;78:18,

 23;79:3,12;80:6;82:5

trials (1)

 98:3

trick (1)

 73:23

trier (1)

 66:22

tries (1)

 77:1

triggered (1)

 18:15

trouble (1)

 93:17

trove (1)

 34:16

truck (1)

 56:8

try (9)

 6:6,19;12:3;58:2,19;

 60:15;70:19;100:2,4

trying (7)

 7:23;12:10;13:10;

 19:16;38:11;60:21;

 65:20

Tubbs (7)

 18:22;25:20;28:4;

 29:9,24,24;70:20

turn (4)

 40:24;45:5;47:6;

 68:3

turned (6)

 31:25;32:14;39:12;

 40:24;46:23;77:12

turning (1)

 59:7

twenty (3)

 24:6,10;74:21

twenty-page (1)

 19:10

two (27)

 5:22;7:8;22:7;23:11,

 19;25:7,12;27:20,21,

 22;31:6;32:5,8;33:15;

 44:15;51:15;54:1;

 66:17;75:6;82:9;83:23;

 90:16,17;98:23;99:7,

 11,17

type (5)

 58:25;59:8;65:19;

 70:8;84:2

types (6)

 14:13;24:9;46:6;

 72:7;73:3;83:23

U

UCC (1)

 14:19

ultimately (5)

 11:9;50:20;59:10;

 67:17,18

Um-hum (2)

 11:11;56:1

unable (3)

 6:9;12:11;67:24

unclear (1)

 18:12

under (27)

 12:7,17;17:17;25:1;

 36:19;38:25;39:5,10,

 19,22;40:1,9,15,16,19,

 22,24;46:16;59:25;

 61:4;65:19;68:9;71:12,

 12,16;73:16;79:2

underlying (4)

 11:21;45:3;47:5;

 98:7

underneath (1)

 45:12

understood (4)

 9:5;50:6,23;52:8

undisputed (1)

 66:19

undoubtedly (1)

 57:6

unfair (1)

 87:21

unique (1)

 71:10

uniquely (1)

 25:22

universe (1)

 97:2

unlawful (1)

 61:6

unless (9)

 8:10;20:21,22;21:2,

 15;23:5;89:2;90:19;

 99:2

unliquidated (7)

 64:21,23;66:18,24;

 89:15,16,18

unredacted (2)

 47:19;99:5

unredacting (1)

 81:10

unsecured (1)

 10:4

unusual (1)

 97:23

unwilling (1)

 60:21

up (33)

 6:7;7:13;8:5,12;

 12:10,14;14:6;19:3,5,

 12;25:11,24,24;30:12;

 37:25;38:5;43:11,19;

 47:22;50:20,24;51:4;

 52:20;64:16;65:4;68:5,

 6;81:20;93:18;94:1;

 95:12;96:8;98:8

updated (1)

 78:5

upload (1)

 100:7

upon (30)

 26:20;44:23;45:3,10,

 11,22;46:14;47:9,10;

 49:11;50:20,23;54:4;

 58:23;59:19;65:14,22;

 72:5;76:15;84:15;91:6,

 16;92:4;94:1,5,21;

 95:12;96:7;97:15;99:9

use (10)

 11:22;12:4;45:15,19;

 65:12;80:25;87:13,14,

 24;91:22

used (8)

 25:3;80:20;82:23;

 86:3;90:19;93:10,22;

 96:24

useful (1)

 65:11

using (12)

 44:18;47:17;65:10;

 72:12;80:22;87:9;

 91:15;97:3;98:2,2,4,8

usual (1)

 85:5

V

valuable (1)

 45:18

value (4)

 44:21;58:23;65:8,15

valued (1)

 13:11

various (8)

 9:8;11:21;41:1;

 50:23;55:7;66:17;73:3,

 20

verbatim (1)

 90:16

version (3)

 76:16;77:16,19

versions (1)

 78:1

via (1)

 31:16

victim (1)

 61:17

victims (4)

 11:22;69:10;83:6;

 85:4

victims' (1)

 43:23

view (7)

 11:14;24:7;27:19;

 28:1;67:13;71:24;

 95:25

violating (2)

 32:17;67:20

virtue (1)

 27:12

vis (2)

 83:11,11

volume (1)

 37:23

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(15) telling - volume Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 117

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

voluntarily (2)

 40:24;64:14

voyage (1)

 9:17

W

Wait (7)

 7:18;21:5;26:1;

 35:18;36:14;62:16;

 75:15

waiting (5)

 10:18;23:12;27:8;

 37:11;60:13

waive (10)

 59:12,16;60:2,4,9,

 19;62:17;63:6,8;64:11

waived (6)

 61:22;64:7;87:8,15;

 94:2,5

waiver (5)

 60:5;62:23;87:21;

 95:2,4

waiving (1)

 98:6

Wall (2)

 33:5;40:10

wants (4)

 21:15;23:5,8;41:16

waste (1)

 57:20

way (21)

 17:20;21:15;25:4;

 26:4;31:3,8;38:10,12;

 40:21;41:20;53:4;54:7;

 56:6,23;58:19;81:17;

 82:5;95:18,18,19;

 96:15

ways (1)

 15:18

WEDNESDAY (1)

 5:1

weeds (1)

 21:18

week (9)

 15:24;19:3;20:22;

 27:6;31:12;49:10;50:4,

 8;100:13

weeks (4)

 26:19;99:7,11,17

Weil (1)

 10:11

weren't (1)

 19:17

what's (13)

 10:10,10;13:17;

 35:16;49:7;53:5;54:9;

 55:10;77:5;89:7;94:10;

 95:8;97:4

whereas (1)

 11:5

Whereupon (1)

 100:17

whole (5)

 9:6;20:25;21:1;

 60:16;95:15

wholly (1)

 46:4

Who's (1)

 51:18

wil (1)

 10:22

wild (2)

 90:1;93:3

wildfire (16)

 10:21;11:22,24;12:5;

 16:17,20;17:5;18:5,6;

 19:14;32:13,23;53:20,

 22;55:22;90:13

wildfires (6)

 18:23;28:6;32:11;

 48:4;79:20;80:6

wiling (1)

 96:5

willing (7)

 40:21;43:11;51:13;

 58:1;60:9,19;73:22

willingness (1)

 67:8

Willkie (2)

 15:1,11

Willoughby (1)

 21:25

wind (1)

 12:14

window (1)

 72:10

winning (1)

 88:22

wishes (1)

 73:9

withdraw (1)

 52:6

withholding (4)

 46:8,9;94:19;96:12

within (3)

 56:16;99:10,17

without (8)

 44:8;54:18;56:22;

 79:23;82:7;84:6,9;

 98:14

wondering (1)

 7:17

word (7)

 6:19;35:4;37:24;

 38:7;50:9;83:5,15

words (9)

 63:15,16;70:1,12;

 77:11;86:5,9;90:15,16

work (36)

 25:8,11;26:24;34:10,

 13;35:3,12,14;49:12;

 54:4;58:22;60:14,14;

 71:17;75:5;81:10;

 82:10;84:4;85:21;86:6,

 6,7,19,21;87:23;91:20;

 92:1,3;93:7;95:9,23;

 96:1,2;97:16,19,22

worked (1)

 54:17

working (10)

 10:21;11:4,5;12:3;

 14:16;27:7;37:4;60:7;

 83:9;99:1

work-product (1)

 45:8

worry (2)

 28:5;41:24

worth (3)

 34:9;65:16;77:25

wrap (1)

 12:10

write (1)

 8:12

written (6)

 50:19;51:1;53:2;

 98:12;100:4,6

wrong (6)

 15:25;39:20;59:21,

 22;64:8;77:5

wrongful (2)

 65:19;71:2

wrote (2)

 90:15,18

X

X's (1)

 86:10

Y

year (3)

 37:5,12;79:16

years (10)

 25:7,12;34:4,25;

 55:7;58:15;78:2,5,25;

 81:7

years' (1)

 77:25

Yep (2)

 27:18;95:17

Z

zone (1)

 65:17

1

1 (5)

 24:3,24;26:3;35:8;

 42:14

1,500 (3)

 47:5;60:15;65:6

100 (1)

 34:19

101 (1)

 78:20

11:43 (1)

 100:17

1119 (1)

 46:15

1123 (2)

 46:17;63:12

113 (1)

 63:12

13th (1)

 50:5

14th (3)

 24:8;26:17;50:7

15th (5)

 31:15,22;33:16,22;

 35:10

17 (3)

 72:6,8;80:6

18 (7)

 48:4;72:6,8;80:6;

 90:13;93:3;95:6

19 (1)

 101:3

1st (2)

 10:5;17:12

2

2 (1)

 18:17

2,000 (1)

 80:17

2,200 (1)

 81:23

2,800 (8)

 73:10,12,13,15;

 74:23,24;76:6,18

2000- (1)

 76:2

2010 (4)

 32:10,15;44:17;

 47:15

2015 (26)

 44:17;47:15;58:20;

 59:3,17,20;60:3;69:19;

 71:7;72:8;75:22,24;

 76:1,5;79:16,25;80:6,

 17,19;81:24;84:23;

 86:4;89:7;90:2,17,24

2017 (13)

 32:20,22,25;33:12;

 48:4;89:13;90:1,13;

 91:7,18;92:14;93:2;

 95:6

2017/2018 (1)

 58:21

2018 (11)

 32:20,22,25;33:12;

 36:20;39:11;89:14;

 90:1;91:8,18;92:14

2019 (3)

 5:1;32:21;101:5

2020 (1)

 90:18

21st (1)

 99:11

24 (1)

 101:4

25 (1)

 81:23

25th (1)

 7:1

26th (4)

 9:11;18:15;24:2,25

27 (1)

 55:5

27th (7)

 7:16;8:4;51:13,14;

 52:9,21,24

29th (1)

 7:12

2nd (2)

 52:17,19

3

30th (1)

 27:12

32 (2)

 55:9,25

3352 (1)

 17:12

3371 (2)

 10:17;21:9

4

4 (1)

 21:9

5

502C (3)

 71:16;79:2,2

5th (1)

 10:16

7

7 (1)

 5:1

70 (1)

 42:14

7th (1)

 7:14

8

800 (4)

 31:24;35:19;38:24;

 39:8

9

9:32 (1)

 5:1

99 (1)

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(16) voluntarily - 99 Case: 19-30088 Doc# 3478 Filed: 08/08/19 Entered: 08/08/19 17:24:49 Page 118

of 119
PG&E CORPORATION AND 

PACIFIC GAS AND ELECTRIC COMPANY

Case No. 19-30088

August 7, 2019

 101:3

9th (7)

 7:1,4;12:10;23:13,

 14,14;53:17

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