Exhibit 1-K

E-Discovery Services

REDACTED VERSION OF EXHIBIT

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 1

of 13
Contract Work Authorization (CWA) - PG&E Law Dept. 

MATTER NO. 1807451 

(PG&E Law Department) 

TOTAL PAGE COUNT: Page 1 of 12 

CONSULTANT or PricewaterhouseCoopers, LLP 

CONTRACTOR LEGAL 3 Embarcadero Center 

NAME: 

San Francisco, CA 94111-4004 

ADDRESS: 

CONSULTANT Jane Allen Carlock 

REPRESENTATIVE NAME: 

PG&E CONTRACT Law Department Budget Group and Elizabeth Collier Jane Allen Carlock 

ADMINISTRATOR: 

PHONE: 415-973-4620 

PROJECT TITLE: 

PG&E WORK SUPERVISOR Elizabeth Collier 

PHONE 415-973-4620 

DATE PREPARED: 12/14/2018 

PREPARED BY: PG&E Law Department 

REQUIRED START DATE: December 17, 2018 

Contractor shall commence 

performance hereof when 

authorized to do so by PG&E 

REQUIRED COMPLETION March 30, 2019 

DATE: 

CWA PRICING; TOTAL: $250,000 

IE! NOT TO EXCEED 

• FIRM FIXED PRICE 

• 

Send Invoice to Submit Invoice Electronically via the Collaborati e-billing system. Please see the 

attached Exhibit B for billing codes. 

Collaborati Support for technical system and system usage: 

• Email: support@mitratech.com 

• Phone: 1-888-784-7224 or 512-382-7322 option 3 (7AM-7PM Central, 

Monday-Friday) 

PG&E's Billing Coordinator for billing process, inquires and requests: 

• Email: GenlCnslLawPavmentProcessinaGroup@Dae.com 

. Phone: 1-415-972-5673 

DESCRIPTION OF WORK Ail related work and Information associated with the project is detailed In Exhibit 1, Statement of 

SUMMARY: Work-

ALL WORK PERFORMED UNDER THIS CONTRACT IS AT THE DIRECTION OF 

THE PG&E LAW DEPARTMENT. ACCORDINGLY, ALL COMMUNICATIONS 

REGARDING THIS WORK ARE INTENDED TO BE PRIVILEGED AND 

CONFIDENTIAL ALL RESULTS PERTAINING TO WORK PERFORMED UNDER 

THIS CONTRACT SHALL BE SUBMITTED TO THE PG&E LAW DEPARTMENT. 

DESCRIPTION OF WORK: 

See Exhibit A - SCOPE OF WORK. The terms of Master Services Agreement 4400011341 between PG&E and Pricewaterhouse 

Coopers LLP are incorporated herein by reference. 

Page 1 of 2 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 2

of 13
Authorized by: For PG&E Accepted by: For Consultant or Contractor 

'±hljj£ 

Date 

Signature 

Jane Allen Cariock 

Partner 

Date 

Senior VP and Deputy General Counsel 

Type or Print Name Type or Print Name 

NOTE: ALL WORK PERFORMED UNDER THIS CONTRACT IS AT THE DIRECTION OF THE 

PG&E LAW DEPARTMENT. ACCORDINGLY, ALL COMMUNICATIONS REGARDING THIS 

WORK ARE INTENDED TO BE PRIVILEGED AND CONFIDENTIAL ALL RESULTS 

PERTAINING TO WORK PERFORMED UNDER THIS CONTRACT SHALL BE SUBMITTED 

TO THE PG&E LAW DEPARTMENT. 

Notwithstanding any other payment terms in Master Services Agreement 44000011341 between PG&E 

and Pricewaterhouse Coopers, LLP, all invoices for work performed hereunder shall be submitted directly 

to the PG&E Law Department for payment. 

Contractor shall ensure that it has complied with all applicable requirements for an alternate work 

schedule in accordance with California Labor Codes Please refer to California Department of Labor 

Relations located at www dir.ca.gov 

Page 2 of2 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 3

of 13
Contract Work Authorization 

This Contract Work Authorization ("CWA") dated January i, 2019 outlines the engagement between 

Pacific Gas and Electric Company ("PG&E" or "Client") with PricewaterhouseCoopers LLP ("PwC" or 

"Consultant") to perform the services described below (the "Services"). 

The governing Master Services Agreement ("MSA") for this work is MSA #4400011341 executed on 

January 17, 2017, as amended, and supersedes all other oral and written representations, 

understandings, or agreements relating to the subject matter hereof. 

I. Overview 

PG&E's Law Department has requested assistance from PwC to: (1) 

; and (2) transfer the collected forensic 

evidence maintaining chain of custody to PG&E's selected third party vendor for further filtering 

and/or processing in response to the Camp fire litigation. This work will be performed at the 

direction of PG&E's Law Department, and is subject to the attorney work product privilege. 

II. Scope of Services 

• The scope of the Services is as follows: 

o Prepare and transmit associated chain of custody logs and documentation from the 

collection site(s) 

JP, and document the chain of custody logs transmission to PG&E's third party 

vendor. 

o Upon request, conduct forensic analysis including, but not limited to, recovery of deleted 

data, USB device access/use, file transfer, log review, and other analysis as requested. 

In addition to the identified work activities for the above Services, PG&E may at times request 

additional support from Consultant specifically related to forensic acquisition of media (i.e., laptops, 

smaitphone, or other data storage devices). PG&E and PwC will discuss and agree upon the scope of 

any such additional activities, and the related estimated cost, which will be set forth in a Change 

Order to this CWA. 

The Services do not include the provision of legal advice, and PwC makes no representations regarding 

questions of legal interpretation. Client should consult with its attorneys with respect to any legal matters 

or items that require legal interpretation under federal, state, or any other type of law or regulation. 

Changes in the law and/or its interpretation may take place before PwCs advice is acted upon or may be 

retrospective in effect; PwC accepts no responsibility for changes in the law or its interpretation that may 

occur after the provision of the Services. 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 4

of 13
III. Deliverables 

• PwC's Deliverables will be limited to documentation related to the forensic data 

collection/evidence activities described herein, and related PwC branded chain of custody 

documentation. 

• Upon request, PwC may also provide oral advice based on our understanding of similar data 

collection and evidence gathering efforts and current industry practices. By "advise" or "provide 

advice," PwC means that it will share its industry experience, subject-matter knowledge and/or 

knowledge of current industry practices for Client's consideration in addressing Client's objectives 

and/or PwC will provide subject-matter advice in response to queries from Client management or 

based upon observations of Client's efforts. 

IV. Anticipated Timeframe 

• Consultant shall commence performance of the Services in coordination with and after obtaining 

authorization from PG&E. The Services are estimated to begin during the week of January 7, 

2019, and currently estimated to be completed on Friday, March 31, 2019. 

• Actual weekly staff resources may fluctuate to address Client's requests. The PG&E supervisor 

will coordinate with PwC to determine increases or decreases in actual PwC staff needs on a 

weekly basis. 

V. Key Assumptions 

• The Services will be performed at the direction of PG&E's Law Department. 

• PG&E and/or the PG&E Law Department will provide necessaiy and required access to all target 

devices. 

• PG&E will determine and identify the actual data collection site locations. 

• Any additional requests for assistance beyond the scope of Services described herein will be 

discussed and confirmed with PG&E's Law Department, and is not included in the cost and time 

estimates set forth in this CWA. 

• Any Target devices not available during the scheduled on-site collection times may not be imaged 

by PwC. 

• PwC will not conduct any filtering or further processing of the forensic data/evidence collected 

unless specifically requested by PG&E's Law Department. 

• PwC forensic staff will receive devices for the forensic data collection activities on a timely basis 

while onsite at the defined locations. Depending on the timing, amount of required time, and any 

restrictions related to the forensic data collection activities and the return of the related devices, 

the PwC team may charge Client for idle time to the extent that PwC is unable to perform other 

Services under this CWA during such periods of idle time. The Services described in this CWA will 

not be performed for devices that are not made available to PwC during the defined/scheduled 

times. 

• Site locations that are more than 1 hour's driving time from San Francisco will result in PwC 

charging for travel expenses, which will be invoiced to Client in accordance with the MSA terms. 

• PwC will take direction from PG&E and/or the PG&E Law Department regarding data retention 

requirements. PwC will also delete any copies of the data collected and within our possession 

upon written request from PG&E. 

VI. Team/Resource Description 

The key Consultant team members and roles are described below: 

• Principals Jane Allen and Sarah Nolton shall: (i) provide PwC project oversight and 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 5

of 13
guidance, (ii) coordinate staffing such that the required Consultant resources are available, 

(iii) provide quality control oversight and analysis, and (iv) provide strategic advice and highlevel recommendations as it relates to the forensic collection effort to PG&E, as requested. 

• Amol Dcshpande, Director, is the key point person for PG&E and PG&E Law Department 

personnel with regard to the Services performed under this CWA 

• Consultant shall provide additional team members with the necessary forensic data 

acquisition skills - primarily at the Senior Associate and Manager level resources who will 

perform the Services and provide the Deliverables in accordance with the specifications set 

forth in this CWA. 

VII. Professional Fees and Expenses 

PwC's fees are based on estimates of the time to be incurred under this CWA, which will be charged 

to Client on a time and materials basis, as required. 

PwC's fee estimate is subject to change due to a number of project factors, including: (i) potential 

changes to the specific PG&E custodian/employee schedules who will provide such devices to PwC, 

(ii) uncertainties related to the types of devices that will be analyzed, including the models and 

storage capacity of the devices, and (iii) other unforeseen technical challenges that are typically 

experienced when performing similar activities. 

PwC will provide a weekly updates regarding the approximate costs incurred to date. The total 

number of devices is unknown at this time, and represents one of several factors that will impact the 

amount of time required to complete the Services. PwC currently estimates a not-to-exceed amount 

of $250,000 for the collection of data related to 175 devices, excluding expenses. If PwC approaches 

this not-to-exceed amount it will discuss with, and obtain prior approval from, PG&E's Law 

Department before performing Services and incurring fees in excess of this not-to-exceed fee 

amount. 

Grade 

Rates 

(USD) 

Partner/Principal $499 

Director $404 

Manager $329 

Senior Associate $267 

Associate $172 

VIII. Other Items 

• The parties hereby agree that PwC may subcontract the Services to its wholly-owned 

subsidiary, PricewaterhouseCoopers Advisory Services LLC. 

• PwC's Materials and PwC's fees and fee structure are PwC's Confidential Information. 

• PG&E shall indemnify' and hold PwC harmless from and against any and all third party 

claims, losses, liabilities and damages arising from or relating to the Services or Deliverables 

under this CWA, except to the extent finally determined to have resulted from PwC's gross 

negligence or intentional misconduct relating to such Services and/or Deliverables. 

• If PwC is requested or authorized by PG&E or required by government regulation, regulatory 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 6

of 13
agency, subpoena, or other legal process to produce PwC's Deliverables, working papers or 

personnel for testimony or interview with respect to sendees PwC performed for PG&E, 

PG&E will reimburse PwC for PwC's and its counsels' expenses and professional time 

incurred in responding to such a request. 

• PwC understands that PG&E seeks to have the attorney work product doctrine, attorneyclient or other privilege apply to some or all of the Services and Deliverables. PG&E and its 

Law Department are solely responsible for determining whether or not the attorney work 

product doctrine, attorney-client or other privilege may apply and for managing the 

establishment and maintenance of any such privilege or protection. PwC makes no 

representation as to whether the attorney work product doctrine or the attorney-client 

privilege will apply, as the applicability of the doctrine and privilege are legal questions. 

However, PwC agrees to assist PG&E and its Law Department in preserving the 

confidentiality of the information received or provided in connection with the Services 

contemplated herein in a manner consistent with preserving an attorney-client privilege. 

• Client will be solely responsible for any and all communications required with Client's federal 

and state regulators and/or independent monitor(s) relating to these Services and 

Deliverables. PwC is not being engaged to interact or meet with third parties, including but 

not limited to Client's regulators and/or independent monitor(s). 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 7

of 13
Electronic Billing System. PG&E utilizes an electronic billing system. You agree to abide by the 

terms of use for such system. PG&E will only accept your invoices in electronic format, any mailed 

invoice will be returned unpaid. 

One Matter Per Statement. Unless otherwise directed by PG&E, you must bill separately for each 

case or matter assigned to you. Statements must be sent electronically on a monthly basis. Statements 

must be sent within thirty (30) days after the close of the month in which the services were rendered. 

Invoices will be paid within thirty (30) days of receipt. 

Invoice Requirements. In order to process your statements, PG&E requires that every monthly 

statement transmitted via Collaborati adhere to standard LEDES invoice requirements, including: 

• The case or matter name and PG&E's matter number; 

• The calendar month covered by the statement (each month of service must be separately 

submitted); 

• Name and job title (e.g., paralegal) of each timekeeper on each date work is done; 

• Time must be billed in increments required by Collaborati, for each date work is done; 

• Written description of work done on each date together with the corresponding ABA/ACCA taskbased billing codes sometimes known as the UTBMS (Uniform Task Based Management System) 

codes; 

• Hourly rates for each timekeeper; 

• Disbursements; and 

• Total amount billed. 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 8

of 13
EXHIBIT B 

PG&E Billing & Expense Codes 

Please utilize the following Codes for all invoicing. 

Bankruptcy Code Set: 

B110 Case Administration 

B120 Asset Analysis and Recovery 

B130 Asset Disposition 

B140 Relief from Stay/Adequate Protection 

B150 Meetings of and Communications with Creditors 

B160 Fee/Employment Applications 

B170 Fee/Employment Objections 

B180 Avoidance Action Analysis 

B185 Assumption/Rejection of Leases and Contracts 

B190 Other Contested Matters 

B195 Non-Working Travel 

B210 Business Operations 

B220 Employee Benefits/Pensions 

B230 Financing/Cash Collections 

B240 Tax Issues 

B250 Real Estate 

B260 Board of Directors Matters 

B310 Claims Administration and Objections 

B320 Plan and Disclosure Statement 

B410 General Bankruptcy Advice/Opinions 

B420 Restructurings 

Counseling Code Set: 

CI00 Fact Gathering 

C200 Researching Law 

C310 Client Counsel - Agreements 

C311 Client Counsel - Company Policy 

C312 Client Counsel - Stat/Reg/Judicial 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page 9

of 13
C320 Infringement/Validity/Survey Studies 

C330 Tort Reform/Lobbying/Govt Affairs 

C340 Situation Management 

C341 Business Disputes 

C350 Contract/Form Development 

C360 Legal Awareness Training 

C361 Policy/Program Development 

Project Code Set: 

PI00 Project Administration 

P210 Corporate Review 

P220Tax 

P230 Environmental 

P240 Real and Personal Property 

P250 Employee/Labor 

P260 Intellectual Property 

P270 Regulatory Reviews 

P280 Other 

P300 Structure/Strategy/Analysis 

P400 Initial Document Preparation/Filing 

P500 Negotiation/Revision/Responses 

P600 Completion/Closing 

P700 Post-Completion/Post-Closing 

P800 Maintenance and Renewal 

Litigation Code Set: 

LI 10 Fact Investigation/Development 

LI20 Analysis/Strategy 

L130 Experts/Consultants 

LI43 Discovery - Identification and Preservation 

LI60 Settlement/Non-Binding ADR 

L200 Pre-Trial Pleadings and Motions 

• Pleadings 

• Preliminary Injunctions/Provisional Remedies 

• Court Mandated Conferences 

• Dispositive Motions other than those listed below 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page

10 of 13
• Other Written Motions and Submissions 

• Class Action Certification and Notice 

L241 Motion to Dismiss: Preemption 

L242 Motion to Dismiss: Lack of Subject Matter Jurisdiction 

L243 Motion for Summary Judgment: Kongros 

L244 Motion for Summary Judgment: Causation 

L245 Motion for Summary Judgment: Employment 

L246 Motion for Summary Judgment: Recreational Use Immunity 

L310 Written Discovery 

• Drafting discovery requests 

• Drafting written responses, including objections, to discovery requests 

• Meeting and conferring with opposing parties 

• Drafting Electronically Stored Information (ESI) protocols, clawback agreements, and protective 

orders 

• Drafting mandatory written disclosures under FRCP 26 

L330 Depositions 

• Determining deponents, timing and sequences of depositions 

• Preparing deposition notices and subpoenas 

• Communicating with opposing parties regarding depositions 

• Planning for and preparing to take depositions 

• Preparing witnesses for deposition 

• Drafting deposition summaries 

L350 Discovery Motions 

• Developing, drafting, responding to, and arguing all discovery motions, including motions for 

protective orders and motions to quash 

L400 Trial Preparation and Trial 

• Fact Witnesses 

• Written Motions and Submissions 

• Other Trial Preparation and Support 

• Trial and Hearing Attendance 

• Post-Trial Motions and Submissions 

• Enforcement 

L500 Appeal 

• Appellate Motions and Submissions 

• Appellate Briefs 

• Oral Argument 

L600 Identification 

• Identifying potentially relevant information, where it is stored, and key players 

• Interviewing custodians and analyzing responses 

L610 Preservation 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page

11 of 13
• Developing and executing a preservation strategy and plan 

• Drafting and responding to preservation related communications, including legal holds and 

preservation demand letters 

• Overseeing quality assurance and control of preservation activities 

L620 Collection 

• Developing collection strategy and plan 

• Collecting potentially relevant information, including paper files, tangible items and 

electronically stored information 

• Overseeing quality assurance and control of collection activities 

L630 Processing 

• Developing a processing strategy and plan 

• Staging, preparing, and processing electronically stored information, or working with a vendor on 

the same activities 

• Analyzing and developing culling criteria, including date filters and key words 

• Performing early case assessments 

• Training a predictive coding system 

• Overseeing quality assurance and control of processing activities 

L650 Review 

• Developing a review strategy and plan 

• Preparing a review platform 

• Drafting review protocols 

• Training reviewers 

• Overseeing quality assurance and control of review activities 

L653 First Pass Document Review 

• Performing first pass document review such as determining relevancy, issue coding, tagging, and 

initial privileged detenninations 

L654 Second Pass Document Review 

• Performing second pass quality control of data and documents coded for relevancy, issue codes, 

tagging, and initial privileged determinations during first pass review 

L655 Privilege Review 

• Performing final privilege review 

• Preparing privilege logs 

L656 Redaction 

• Developing and implementing a redaction protocol 

• Performing redactions 

L670 Production 

• Preparing document productions 

• Overseeing quality assurance and control of production activities 

L671 Conversion of ESI to Production 

• Oversight of activities related to the TIFFing, bates stamping, endorsing, preparation of load files 

and deliverables to be provided as part of the production 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page

12 of 13
L680 Presentation 

• Preparing and displaying electronically stored information before audiences (at depositions, 

hearings, trials, etc.) 

L800 Experts/Consultants 

• Experts/Consultants 

• Expert Discovery 

• Expert Preparation for Trial 

L900 Settlement Process 

• Attendance at Mediations or other ADR conferences 

• Preparations for these conferences 

• Oral and written communications related to these conferences 

Expense Codes: 

El02 Outside printing 

E107 Delivery services/messengers 

El09 Local travel 

El 10 Out-of-town travel 

El 11 Meals 

E112 Court fees 

El 13 Subpoena fees 

El 14 Witness fees 

E115 Deposition transcripts 

El 16 Trial transcripts 

El 17 Trial exhibits 

E118 Litigation support vendors 

El 19 Experts 

El 21 Arbitrators/mediators 

E125 WMBE Sub-Contractor 

El26 WMBE Administration Costs 

Case: 19-30088 Doc# 1792-18 Filed: 05/01/19 Entered: 05/01/19 17:47:02 Page

13 of 13