1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

RICHARD A. MARSHACK, SBN 107291 

rmarshack@marshackhays.com 

DAVID A. WOOD, SBN 272406 

dwood@marshackhays.com 

LAILA MASUD, SBN 311731 

lmasud@marshackhays.com 

MARSHACK HAYS LLP 

870 Roosevelt, Irvine, CA 92620 

Tel: 949-333-7777 -/- Fax: 949-333-7778

GERALD SINGLETON, SBN 208783 

GARY LOCURTO, SBN 270372 

SINGLETON LAW FIRM, APC 

450 A Street, 5th Floor 

San Diego, CA 92101 

Tel. (619) 771-3473 

Email: gerald@slffirm.com 

 gary@slffirm.com 

Attorneys for SLF Fire Victim Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

In re 

PG&E CORPORATION, 

 and, 

PACIFIC GAS & ELECTRIC COMPANY, 

 Debtors. 

 

Affects: 

☐ PG&E Corporation 

☐ Pacific Gas & Electric Company 

☒ Both Debtors 

* All papers shall be filed in Lead Case, 

 No. 19-30088 (DM). 

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case Jointly Administered) 

JOINDER OF THE SLF FIRE VICTIMS 

CLAIMANTS TO THE STATEMENT OF 

THE OFFICIAL COMMITTEE OF TORT 

CLAIMANTS REGARDING AUGUST 27, 

2019 STATUS CONFERENCE ON 

ESTIMATION; DECLARATION OF JOHN 

F. MCGUIRE, JR., IN SUPPORT 

[Docket No. 3672] 

Hearing: 

Date: August 27, 2019 

Time: 9:30 a.m. 

Ctrm; 17, 16th Floor 

Place: United States Bankruptcy Court 

 San Francisco, CA 94102 

TO THE HONORABLE DENNIS MONTALI, UNITED STATES BANKRUPTCY COURT 

JUDGE, THE OFFICE OF THE UNITED STATES TRUSTEE AND ALL INTERESTED 

PARTIES: 

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 1 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

2 

4811-8952-2338, v. 1

 PLEASE TAKE NOTICE that the Singleton Law Firm (“SLF”) and Marshack Hays LLP, 

together with several other firms, represent approximately 5,500 victims of the fires started by 

PG&E in 2015 (“Butte Fire”), 2017 (the twenty fires generally referred to as the “North Bay” and 

“Wind Complex Fires”) and 2018 (“Camp Fire”).1

 

 The SLF Claimants join in the Statement of the Official Committee of Tort Claimants 

(“TCC”) Regarding August 27, 2019 Status Conference on Estimation, filed on August 23, 2019, as 

Docket No. 3672 (“Statement”). Moreover, SLF Claimants would like to make the following 

supplemental comments2: 

I. Participants 

 First, and as previously mentioned, the SLF Claimants contend the following parties 

should be able to participate in any estimation proceeding: 

1. Debtor; 

2. Tort Claimants Committee – including corresponding State Court fire litigation 

counsel (we understand this to include the Leadership in the state court JCCP for the 

North Bay Fires, JCCP Number 4955); 

3. SLF Claimants; and 

4. Anyone else who requests to participate within the deadline set by court and who the 

court further decides should be allowed to participate. 

SLF Claimants do not know if the Official Committee of Unsecured Creditors (“OCC”), or 

other creditors, intend to participate in the estimation proceeding. As such, SLF Claimants propose 

the Status Conference be continued for twenty (20) days so that during this time period other 

creditors may make a written request to participate if they wish to. Thereafter, the court can 

determine at the continued status conference whether to allow those creditors who filed request the 

opportunity to participate in the estimation proceedings. 

 

1

 The claimants are jointly referred to as the “SLF Claimants.” 

2

 SLF Claimants previously filed an objection to the Debtor’s Estimation Motion because we do 

not believe the estimation process can be done on the time table before the court without issues of 

due process. SLF Claimants maintain that position. 

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 2 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

3 

4811-8952-2338, v. 1

II. Discovery 

 Second, SLF Claimants agree that Debtors’ should expediently respond to the discovery 

noted in the TCC statement. Statement, p. 2, ¶1; p. 3, ¶3. That said, SLF Claimants note that we have 

not seen the letter requesting production of select documents by Debtors. As such, we are unaware of 

the scope and extent of the document production. To the extent it will aid the court, SLF Claimants 

have provided a detailed discovery outline as noted in the attached declaration of John McGuire, Jr. 

Moreover, discovery needs to be produced for all fires immediately, not just the 5 noted in 

the TCC’s Statement, with discovery for the others to follow at some unknown future date. In its 

Statement, TCC has emphasized the 5 fires (Tubbs, Camp, Atlas, Nuns Complex3 and Redwood) 

because, as counsel stated in Court on August 14, the TCC estimates that these 5 fires account for 

92% of the total wildfire damages at issue in this bankruptcy. Statement, p.4, ¶3. Whether not the 

92% number is accurate, there is no doubt that these 5 fires account for the vast majority of the 

wildfire damages. 

But, it is critical that the remaining fires not be ignored. SLF Claimants have over 2,000 fire 

victims from fires other than the ‘Big 5’ identified by the TCC. Two of these other fires, Cascade 

and Butte, involved multiple fatalities, and, together, the unpaid damages for these other fires – 

according to PG&E’s own calculations – is somewhere between $1.1 and $2.4 billion dollars.4

 

While SLF Claimants believe the actual amount of damages is substantially higher, there is no 

question that the victims of these other fires – which killed 6 people, left thousands homeless, and 

accounted for billions of dollars in damages – deserve to receive the same measure of due process as 

the victims of the ‘Big 5’ fires.5

 

3

 Although the TCC identifies the “Nuns Fire”, it appears the TCC is actually referring to the “Nuns 

Complex” of fires, which encompasses 6 separate fires: Nuns, Adobe, Norrbom, Oakmont/Pythian, 

Partrick, and Pressley. This is common mistake given the unfortunate fact that “Nuns” can refer to 

both a single fire and a complex of 6 separate fires. 

4

 PG&E’s financial disclosure statements, and the testimony of their CFO during the creditors 

hearing on April 29, estimated that the total damages for wildfire losses were $14 billion to in excess 

of $30 billion. A true and correct portion of the excerpts of the Debtors’ schedules wherein the range 

is listed is attached as Exhibit “1”, pg. 22. [Dk. No. 903]. 8% of this range ($14-30 billion) is $1.1-

2.4 billion. 

5

 One troubling aspect of the TCC is that its membership is dominated by victims of the Camp, 

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 3 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

4 

4811-8952-2338, v. 1

All parties must be included in discovery. Given the tight timeline, it is counterproductive for 

SLF Claimants not to receive the discovery requests and responses between the TCC and Debtors. 

SLF Claimants want to avoid duplicative discovery, therefore discovery should include all parties. 

In sum, SLF Claimants request: 

(1) That a structure for discovery be set up that allows for production of documents for 

all of 22 fires. Even if one assumes that that 5 fires purportedly account for 92% of the damages, the 

balance of the damages created by the remaining 17 fires exceeds $1 billion; a sum in and of itself 

that justifies equal treatment to all other discovery issues in the case; and 

(2) Further and, again, SLF Claimants request they be accorded equal access to 

participate in discovery including responding to PGE’s appropriate requests) as its interests not only 

include but go far beyond the “Big 5” that tend to get most of the attention. 

III. Mediation 

 Third, SLF Claimants agree with the TCC that there should an agreed set of mediators. 

Statement, p. 4; ¶4. However, to be effective mediation must include all major stakeholders. The 

SLF Claimants comprise over 5,500 fire victims. They deserve a seat at the table and to have their 

voices heard. The SLF Claimants should also be a party with the ability to propose, and vote on the 

agreed set of mediators alongside those parties mentioned in the Statement. 

 To that end, a fire litigation specialist should be included in the set of mediators. In the 

Butte Fire, the parties (PG&E and the plaintiffs’ lawyers, many of which are involved in this 

litigation) worked together to arrive at a mutually agreeable list of mediators. We believe this list 

should be the starting point for selecting mediators in this case, as these mediators have already been 

approved by PG&E in the context of mediating a wildfire case. Again, SLF Claimants would like to 

offer the idea of a type of binding mediation, as mentioned previous briefing with the Court. See, 

 

Atlas, and Tubbs Fires. Between the 11 members of the TCC only 3 fires are represented: Camp (5 

members); Atlas/Tubbs (4 members); Ghostship (2 members - which was not a utility fire and for 

which PG&E strongly disputes liability).The vast majority of the fires, including billion-dollar fires 

which resulted in fatalities (like Redwood, the Nuns Complex Fires and the Butte Fire) are not 

represented. See, Dk No. 530, Amended Appointment of the Official Committee of Tort Claimants, 

filed on February 21, 2019. 

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 4 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

5 

4811-8952-2338, v. 1

Docket No. 3451, pgs. 11-12 and 14-17. To reiterate, the SLF Claimants would like to offer the 

following example from the Butte Fire cases: 

 • In July 2017, the Singleton Butte Fire Plaintiffs reached an agreement with PG&E for 

a dispute resolution process that the parties termed “binding mediation.” This process was built on a 

similar “binding mediation” model process that PG&E and the Singleton Firm developed for use in 

the 2007 San Diego Fires; 

 • While the precise terms of the process are subject to the mediation privilege, the 

general terms of the process included; (1) PG&E did not contest liability; (2) victims did not seek 

punitive damages; and (3) the parties agreed to a basic framework regarding compensatory damages; 

 • Thereafter, the counsel for PG&E, Quinn Emanuel, and SLF negotiated each case 

individually in an attempt to reach an informal resolution; 

 • If we were unsuccessful, we could attend a “binding mediation” in which both parties 

would present their damages evidence to the mediator and attempt to resolve the case; 

 • Prior to attending the “binding mediation” the parties would agree on a range of 

potential damages (“high-low agreement”); 

 • If mediation was unsuccessful, then the mediator would become an arbitrator and 

decide on a final settlement amount within the high low agreement that would be binding on the 

parties. 

IV. Burden of Proof 

Fourth, a primary concern of SLF Claimants is with which party the burden of proof lies with 

respect to the estimation proceedings. In order for the estimation process to proceed smoothly and 

efficiently, the court should make it clear who has the burden of proof. Because Debtors are the 

movants, do they have the burden of proof? If, however, this were a state court trial, the plaintiffs 

would have the burden. SLF Claimants believe as specific hearing should be held after briefing to 

have these issues clearly resolved. As noted by the TCC in the Statement, parties participating in the 

estimation proceeding need to know from Debtors: (1) what the factual and legal issues are; (2) what 

Debtors’ specific theories are with respect to avoidance of liability; and (3) who needs to prove 

what with respect to which fire – e.g. do the Cal Fire Reports in fact play a burden shifting role or is 

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 5 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

6 

4811-8952-2338, v. 1

the law clear. Statement, p. 3, ln. 10-13. Without a clear of idea of what Debtors’ specific defenses 

are, it is difficult for any party to properly prepare for an estimation proceeding-let alone in the given 

time frame. Only after the Court determines these preliminary issues can the fire victim claimants, 

represented by their respective counsel, have an ability to put on their case. 

Lastly, to the extent that the general purpose of estimation is to determine the aggregate fire 

damage exposure of Debtors rather than estimation of individual claims, SLF would urge the Court 

that the starting point for estimation should be at the higher end of the fire damage range noted by 

Debtors’ COO at the 341(a) meeting of creditors as well as in Debtors’ schedules – $14 billion to 

$30 billion. Specifically, if all fire claimants are to be made whole, the starting point for estimation 

must be at the higher end of that range - $30 billion. 

Dated: August 26, 2019 MARSHACK HAYS LLP 

 

By:______________________________ 

RICHARD A. MARSHACK 

DAVID A. WOOD 

LAILA MASUD 

Attorneys for SLF CLAIMANTS 

Dated: August 26, 2019 SINGLETON LAW FIRM, APC 

 /s/ Gerald Singleton 

By:______________________________ 

GERALD SINGLETON 

GARY LOCURTO 

Attorneys for SLF CLAIMANTS 

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 6 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 7 

4811-8952-2338, v. 1

DECLARATION OF JOHN F. MCGUIRE, JR. 

I, John F. McGuire, Jr. declare:

1. I have personal knowledge of, and (if called as a witness) would competently testify 

to the following facts:

2. I am an attorney at law, licensed to practice before this Court. I have considerable 

experience representing plaintiffs in utility fire cases. I have been one of several trial counsel in wild 

fire cases, and I was selected to be co-lead trial counsel along with Terry Singleton (one of our cocounsel in this case) for the Witch/Guejito Fires in the SDG&E Fire case litigation, which ignited in 

2007 in San Diego County. That case was ultimately resolved shortly before the final scheduled trial 

date for several million dollars. 

3. Based on this experience, I am familiar with the discovery a plaintiff needs to prove 

utility fire case. 

4. Plaintiffs will need to conduct the following discovery, all of which is necessary to 

plaintiffs’ ability to prove that Pacific Gas & Electric (PG&E) is liable for the 2017 North Bay Fires.

Discovery Relevant to All Fires 

Discovery Device Specific Discovery Needed Estimated Time to 

Complete 

Requests for Production 

of Documents 

1. All SCADA data for each PG&E circuit 

involved in a fire two days prior to the 

ignition and two days after the ignition.

2. Circuit Maps for each relevant PG&E 

circuit in CAD format and which identify 

all equipment and protection.

3. PG&E system protection policies and 

corresponding documents.

4. PG&E vegetation management policies 

and corresponding documents.

5. PG&E pole inspection policies and 

corresponding documents. 

6. PG&E vegetation management inspection 

4 – 5 months for 

requests, 

objections, 

production.

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 7 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 8 

4811-8952-2338, v. 1

inventories, work requests, quality control 

records, quality assurance records for each 

fire’s relevant circuit.

7. PG&E customer refusal locations by 

address and circuit number, along with 

reasons for refusals for each fire’s relevant 

circuit.

8. PG&E Customer Restricted Access 

Locations by address and circuit map 

number, including reason for restricted 

access for each fire’s relevant circuit.

9. PG&E first responder audio 

communications with dispatch.

Depositions PG&E Witnesses 

1. PG&E Troublemen working on each 

circuit during the time that the fires 

ignited.

2. PG&E substation operators.

3. PG&E PMQ’s on interpreting SCADA 

data for each circuit.

4. PG&E PMQ’s on document and SCADA 

retention and custody.

5. PG&E PMQ on evidence collection. 

6. PG&E PMQ on vegetation management. 

7. PG&E PMQ on red flag warning 

operations, meteorology, and steps taken 

by PG&E to prepare for and react to 

weather conditions.

8. PG&E PMQ on pole inspections.

9. PG&E PMQ on quality assurance.

10. PG&E PMQ on quality control.

11. PG&E PMQ on system protection.

2 – 3 months but 

contingent on the 

production of 

relevant 

documents listed 

above.

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 8 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 9 

4811-8952-2338, v. 1

12. PG&E first responders for each fire.

Plaintiff Witnesses 

1. Vegetation Management Expert.

2. Pole Inspection Expert.

3. Metallurgist Expert.

4. Fire Origin and Cause Expert. 

Third Party Subpoenas 1. All un-redacted CalFire reports with 

attachments. Plaintiffs currently have 

unredacted reports for the following fires: 

(1) Cascade, (2) Cherokee, (3) LaPorte and 

(4) Redwood Valley. Plaintiffs still need 

unredacted reports with attachments for: 

(1) Adobe, (2) Atlas, (3) Blue, (4) Lobo, 

(5) Maacama, (6) McCourtney, (7) 

Norrbom, (8) Nuns, (9) Oakmont/Pythian, 

(10) Partrick, (11) Pocket, (12) Point, (13) 

Pressley, (14) Sullivan, (15) Sulphur and 

(16) Tubbs; (17) Camp 

2. Depositions of CalFire report investigators 

for each of the fires—including both the 

writer of the report and the CalFire 

investigators that collected 

3. Depositions of percipient witnesses 

referenced in CalFire reports for each fire. 

4. Depositions of third party contractors hired 

by PG&E on the following topics:

a. Vegetation Management; and

b. Pole Inspections.

5. Inspections of all physical evidence 

retained by CalFire from each fire’s area of 

origin.

4 – 5 months but 

contingent on the 

production of the 

unredacted 

CalFire reports 

and relevant 

PG&E documents 

describing the 

role of various 

contractors.

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 9 of

25
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

 10 

4811-8952-2338, v. 1

5. The above generally outlines the discovery needed for all fires. However, some 

deviation from the outline may be needed. For example, the Sulphur fire did not involve vegetation 

management issues, so some of the vegetation management discovery will not be needed. 

6. Given the scope of the discovery needed, estimation trials simply cannot be 

completed by [Judge suggested date]. Rather, the estimation trials should be set for [our suggested 

date] to ensure that Plaintiffs’ have enough time to prepare for each case.

7. The 2017 North Bay Fires were unlike anything California has ever seen. Each fire 

has specific liability issues, separate percipient witnesses, and unique facts. 

8. The “Estimated Time to Complete” does not take into account that Plaintiffs will 

need discovery on each and every fire in order to prove their case. An additional 3 – 4 months 

should be added to the above estimates to conduct discovery on factual and legal issues specific to 

each case.

I declare under penalty of perjury pursuant to the laws of the State of California that the 

foregoing is true and correct. Executed this 26th day of August 2019 at San Diego, California.

THORSNES BARTOLOTTA McGUIRE LLP

By:

JOHN F. MCGUIRE, JR.

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 10

of 25
$54,927,619,001

1. Schedule A/B: Assets–Real and Personal Property (Official Form 206A/B)

1a. Real property:

Copy line 88 from Schedule A/B ..................................................................................................................

$6,074,329,725

1b. Total personal property:

Copy line 91A from Schedule A/B ..............................................................................................................

$61,001,948,725

1c. Total of all property:

Copy line 92 from Schedule A/B ...............................................................................................................

Part 1: Summary of Assets

2. Schedule D: Creditors Who Have Claims Secured by Property (Official Form 206D)

Part 2: Summary of Liabilities

$0

3. Schedule E/F: Creditors Who Have Unsecured Claims (Official Form 206E/F)

3a. Total claim amounts of priority unsecured claims:

..................................................................................................................

$24,699,616,096

3b. Total amount of claims of nonpriority amount of unsecured claims:

..............................................................................................................

$2,809,790 Copy the total dollar amount listed in Column A, Amount of claim, from line 3 of Schedule D ..................................................................................................................

Copy the total claims from Part 1 from line 6a of Schedule E/F

Copy the total of the amount of claims from Part 2 from line 6b of Schedule E/F

4. Total liabilities

$24,702,425,886 Lines 2 + 3a + 3b ...................................................................................................................................................

+

+

Summary of Assets and Liabilities for Non-Individuals

Official Form 206Sum

12/15

 Debtor Name: Pacific Gas and Electric Company

 United States Bankruptcy Court for the: NORTHERN DISTRICT OF CALIFORNIA

 Case Number (if known): 19-30089 (DM)

Fill in this information to identify the case:

Check if this is an 

amended filing

Page 1 of 1 to Summary of Assets and Liabilities

Case: 19-30088 Doc# 903 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 1 of 1

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 11

EXHIBIT 1, PAGE 11

of 25
WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue

New York, NY 10153-0119 

Tel: 212 310 8000

Fax: 212 310 8007

KELLER & BENVENUTTI LLP

Tobias S. Keller (#151445)

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192)

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Proposed Attorneys for Debtors 

and Debtors in Possession

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC

COMPANY,

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case)

(Jointly Administered)

SCHEDULES OF ASSETS AND 

LIABILITIES FOR PACIFIC GAS AND 

Debtors. ELECTRIC COMPANY

 Affects PG&E Corporation 

 Affects Pacific Gas and Electric Company 

 Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 1

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 12

EXHIBIT 1, PAGE 12

of 25
GLOBAL NOTES AND STATEMENT OF LIMITATIONS, METHODOLOGY, AND 

DISCLAIMERS REGARDING DEBTORS’ SCHEDULES OF ASSETS AND LIABILITIES

On January 29, 2019 (the “Petition Date”), PG&E Corporation (“PG&E Corp.”) and Pacific Gas and 

Electric Company (the “Utility”), as debtors and debtors in possession (collectively, “PG&E” or the 

“Debtors”), each commenced a case under chapter 11 of title 11 of the United States Code (the 

“Bankruptcy Code”) in the United States Bankruptcy Court for the Norther District of California, 

San Francisco Division (the “Bankruptcy Court”). The Debtors are authorized to operate their 

businesses and manage their properties as debtors in possession, pursuant to sections 1107(a) and 1108 

of the Bankruptcy Code. The Debtors’ chapter 11 cases are being jointly administered for procedural 

purposes only under the Lead Case No. 19-30088 (DM) (the “Chapter 11 Cases”) pursuant to Rule 

1015(b) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”). 

OVERVIEW OF GLOBAL NOTES

Each of the Debtors has herewith filed separate Schedules of Assets and Liabilities (“Schedules”). 

These Global Notes and Statement of Limitations, Methodology, and Disclaimers Regarding Debtors’ 

Schedules of Assets and Liabilities (the “Global Notes”) relate to each Debtor’s Schedules and set 

forth the basis upon which the Schedules are presented. These Global Notes pertain to, are 

incorporated by reference in, and comprise an integral part of, the Schedules and should be 

referred to and considered in connection with any review of the Schedules. The Global Notes are 

in addition to any specific notes contained in either Debtor’s Schedules. Except as otherwise expressly 

set forth herein, information in the Schedules is presented as of the Petition Date and on an individual 

Debtor-by-Debtor basis. Disclosure of information in one Schedule, exhibit, or continuation sheet, 

even if incorrectly placed, shall be deemed to be disclosed in the correct Schedule, exhibit, or 

continuation sheet. 

The Schedules have been prepared by the Debtors’ management with the assistance of their advisors

and other professionals pursuant to section 521 of the Bankruptcy Code and Bankruptcy Rule 1007. 

The Schedules contain unaudited information, which is subject to further review and potential 

adjustment. Reasonable efforts have been made to provide accurate and complete information herein 

based upon information that was available at the time of preparation; however, subsequent information 

or discovery thereof may result in material changes to the Schedules and inadvertent errors or 

omissions may exist. 

The Schedules and Global Notes should not be relied upon by any persons for information 

relating to current or future financial conditions, events, or performance of either of the Debtors.

The Debtors and their agents, attorneys, and financial advisors expressly do not undertake any 

obligation to update, modify, revise, or re-categorize the information provided herein, or to notify any 

third party for any direct, indirect, incidental, consequential, or special damages (including, but not 

limited to, damages arising from the disallowance of a potential claim against the Debtors or damages 

to business reputation, lost business, or lost profits), whether foreseeable or not and however cause, 

even if the Debtors or their agents, attorneys, and financial advisors are advised of the possibility of 

such damages.

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 2

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 13

EXHIBIT 1, PAGE 13

of 25
The Debtors reserve all rights to amend, modify, or supplement the Schedules from time to time, in 

all respects, as may be necessary or appropriate, including, but not limited to, the right to dispute or 

otherwise assert offsets or defenses to any claim reflected on the Schedules as to amount, liability or 

classification, or to otherwise subsequently designate any claim as “disputed,” “contingent” or 

“unliquidated.” Furthermore, nothing contained in the Schedules shall constitute an admission of any 

claims or a waiver of either of the Debtor’s rights with respect to the Chapter 11 Cases, including with 

respect to any issues involving causes of action arising under the provisions of chapter 5 of the 

Bankruptcy Code and other relevant non-bankruptcy laws to recover assets or avoid transfers.

The Schedules for each Debtor have been signed by David Thomason, Chief Financial Officer for the 

Utility and Controller for PG&E Corp. In reviewing and signing the Schedules, Mr. Thomason 

necessarily relied upon the efforts, statements, and representations of various personnel employed by 

the Debtors and their advisors and other professionals. Mr. Thomason has not (and could not have) 

personally verified the accuracy of each such statement and representation, including, without 

limitation, statements and representations concerning amounts owed to creditors, classification of such 

amounts, and their addresses. 

Methodology and Limitations 

1. Basis of Presentation: Information contained in the Schedules has been derived from the

Debtors’ books and records and historical financial statements. The Schedules do not purport to 

represent financial statements prepared in accordance with United States Generally Accepted 

Accounting Principles (“GAAP”), nor are they intended to fully reconcile with the financial 

statements of each Debtor. 

2. Cash Management System: The Debtors use an integrated, centralized cash management

system to streamline collection, transfer, and disbursement of funds generated by their business 

operations (the “Cash Management System”). Although the Utility and PG&E Corp. each maintain 

separate systems, the Cash Management System is an integrated system. The Debtors describe the 

Cash Management System in detail in their Motion of Debtors Pursuant to 11 U.S.C. §§ 105(a), 

363(b), and 507 and Fed. R. Bankr. P. 6003 and 6004 for Interim and Final Authority to (i) (a) 

Continue Using Existing Cash Management System, (b) Honor Certain Prepetition Obligations 

Related to the Use Thereof, (c) Continue Intercompany Arrangements, (d) Continue to Honor 

Obligations Related to Joint Infrastructure Projects, and (e) Maintain Existing Bank Accounts and 

Business Forms, and (ii) Waiving the Requirements of 11 U.S.C. § 345(b) [Docket No. 7] (the “Cash 

Management Motion”). On March 14, 2019, the Court authorized the Debtors to continue using the 

Cash Management System on a final basis [Docket No. 881]. 

3. Valuation: The Debtors do not have current market valuations for all of their assets as it

would be prohibitively expensive, unduly burdensome, and an inefficient use of estate assets and 

resources for the Debtors to obtain current market valuations of all their assets. Accordingly, unless 

otherwise indicated herein, assets in the Schedules reflect net book values as of January 31, 2019. Net 

book values may vary, sometimes materially, from market values. Certain other assets, such as 

investments in subsidiaries, are listed as “unknown” or “undetermined” amounts. Additionally, 

amounts ultimately realized may differ materially from net book value (or whatever value was 

ascribed). Certain depreciable assets with a net book value of zero ($0) may also be included for 

completeness. 

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 3

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 14

EXHIBIT 1, PAGE 14

of 25
4. Liabilities: The Debtors have sought to allocate liabilities between the prepetition and

postpetition periods based on information and research that was conducted or available in connection 

with the preparation of the Schedules. As additional information becomes available and further 

research is conducted, the allocation of liabilities between prepetition and postpetition periods may 

change. The Debtors reserve all of the rights to amend, supplement, or otherwise modify the Schedules 

as they deem necessary or appropriate. 

The liabilities listed on the Schedules do not reflect any analysis of claims under section 503(b)(9) of 

the Bankruptcy Code. Accordingly, the Debtors reserve all rights to dispute or challenge the validity 

of any asserted claims under section 503(b)(9) of the Bankruptcy Code or the characterization of the 

structure of any such transaction or any document or instrument related to any creditor’s claim.

5. Excluded Assets and Liabilities: The Debtors have excluded the following items from their

Schedules, which may be included in their GAAP financial statements: certain accrued liabilities, 

including, without limitation, accrued salaries, employee benefit accruals, and certain other accruals, 

trusts, certain prepaid and other current assets considered to have no market value, certain contingent 

assets such as insurance recoveries, and deferred gains. 

The Utility records a regulatory balancing account asset or liability for differences between incurred 

costs and customer billings or authorized revenue meant to recover those costs, to the extent that these 

differences are probable of recovery or refund. The California Public Utilities Commission also has 

authorized the Utility to collect additional revenue requirements to recover costs that the Utility has 

been authorized to pass on to customers, including costs to purchase electricity and natural gas; and to 

fund public purpose, demand response, and customer energy efficiency programs. In general, the 

revenue recognition criteria for pass-through costs billed to customers are met at the time the costs are 

incurred. As these differences have no impact on net income, the Debtors have excluded balances with 

respect to regulatory balancing accounts and other accounts recognized for rate making purposes. 

Other immaterial assets and liabilities may also have been excluded. 

Various electricity suppliers filed claims in the Utility’s prior 2001 chapter 11 case (Case No. 01-

30923 (DM)) seeking payment for energy supplied to the Utility’s customers between May 2000 and 

June 2001. While proceedings are pending before the Federal Energy Regulatory Commission 

(“FERC”) and other judicial forums, the Utility pursued settlements with electricity suppliers and 

entered into a number of settlement agreements with various electricity suppliers to resolve some of 

these disputed claims and to resolve the Utility’s refund claims against these electricity suppliers. 

Under these settlement agreements, amounts payable by the parties, in some instances, would be 

subject to adjustment based on the outcome of the various refund offset and interest issues being 

considered by the FERC. Generally, any net refunds, claim offsets, or other credits that the Utility 

receives from electricity suppliers either through settlement or through the conclusion of the various 

FERC and judicial proceedings are refunded to customers through rates in future periods. Accordingly, 

such potential refund claims are not included in the Schedules. 

6. Guarantees and Other Secondary Liability Claims: The Debtors have used reasonable

efforts to locate and identify guarantees and other secondary liability claims (collectively, 

the “Guarantees”) in their executory contracts, unexpired leases, debt instruments, and other 

agreements. Where Guarantees have been identified, they have been included in the relevant 

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 4

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 15

EXHIBIT 1, PAGE 15

of 25
Schedules D, E/F, G and H for the affected Debtor. It is possible that certain Guarantees embedded 

in the Debtors’ executory contracts, unexpired leases, secured financings, debt instruments, and other 

such agreements may have been inadvertently omitted. The Debtors reserve all of their rights to

amend, supplement, or otherwise modify the Schedules to the extent additional Guarantees are 

identified. 

7. Leases: The Debtors may lease furniture, fixtures, and equipment from certain third party 

lessors. Any such leases are set forth in the Schedules. The Debtors have not included in the Schedules 

the future obligations of any capital or operating leases. However, assets under any capital leases have 

been included in the Schedules. Nothing in the Schedules is, or should be construed, as an admission 

as to the determination of the legal status of any lease (including whether any lease is a true lease or 

financing arrangement), and the Debtors reserve all rights with respect thereto.

In February 2016, the Financial Accounting Standard Board (the “FASB”) issued ASU No. 2016-02, 

Leases (Topic 842), which amends the existing guidance relating to the definition of a lease, 

recognition of lease assets and lease liabilities on the balance sheet, and the disclosure of key 

information about leasing arrangements. In November, 2017, the FASB tentatively decided to amend 

the new leasing guidance such that entities may elect not to restate their comparative periods in the 

period of adoption. Under the new standard, all lessees must recognize an asset and liability on the 

balance sheet. Operating leases were previously not recognized on the balance sheet. The ASU was

effective for PG&E Corp. and the Utility on January 1, 2019, with early adoption permitted. PG&E 

Corp. and the Utility plan to adopt this guidance in the first quarter of 2019. Therefore, the Schedules 

of assets and liabilities reflected herein do not include the asset or liability of those operating leases.

8. Intellectual Property Rights: Exclusion of certain intellectual property shall not be construed 

to be an admission that those intellectual property rights have been sold, abandoned, terminated, 

assigned, transferred, or otherwise have expired by their terms. Conversely, inclusion of certain 

intellectual property shall not be construed to be an admission that those intellectual property rights 

have not been sold, abandoned, terminated, assigned, transferred, or otherwise have not expired by 

their terms. Accordingly, the Debtors reserve all of their rights as to the legal status of all intellectual 

property rights.

9. Currency: Unless otherwise indicated, all amounts are reflected in U.S. dollars.

10. Property and Equipment: Unless otherwise indicated, owned property and equipment are 

stated at net book value. 

11. Intercompany Payables and Receivables: Prior to the Petition Date, the Debtors routinely 

engaged in intercompany transactions resulting in intercompany accounts payable and receivable. The 

intercompany transactions are described in the Cash Management Motion. The intercompany 

accounts payable and receivable are reported on each of the Debtor’s respective Schedules A/B or E/F 

as the net due-to or due-from based on invoiced intercompany charges assessed pursuant to various 

continuing services agreements. All intercompany assets and liabilities on Schedule A/B and 

elsewhere (if applicable) are reported as of January 31, 2019. 

The listing by the Debtors of any account between the Debtors or between a Debtor and a non-Debtor 

affiliate is a statement of what appears in a particular Debtor’s books and records and does not reflect 

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 5

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 16

EXHIBIT 1, PAGE 16

of 25
any admission or conclusion of the Debtors regarding the allowance, classification, characterization, 

validity, or priority of such account. The Debtors take no position in these Schedules as to whether 

such accounts would be allowed as claims, interests, or not allowed at all.

12. Causes of Action: The Debtors have not yet listed any causes of action or potential causes of

action against third parties as assets in their Schedules, including, without limitation, avoidance actions 

arising under chapter 5 of the Bankruptcy Code and actions under other relevant non-bankruptcy laws 

to recover assets. The Debtors reserve all of their rights for any claims, causes of action, or avoidance 

actions they may have, and neither these Global Notes nor the Schedules shall be deemed a waiver of 

any such claims, causes of actions, or avoidance actions or in any way prejudice or impair the assertion 

of such claims.

13. Classification: The Debtors have made reasonable efforts to correctly characterize, classify,

categorize, and designate assets, liabilities, executory contracts, unexpired leases, and other items 

reported in the Schedules. However, due to the complexity and size of the Debtors’ businesses and 

operations, the Debtors may have improperly characterized, classified, categorized, or designated 

certain items. The Debtors reserve all of their rights to re-characterize, reclassify, re-categorize, or redesignate items reported in the Schedules as necessary or appropriate as additional information 

becomes available.

14. Claim Description: Any failure to designate a claim in the Schedules as “contingent,”

“unliquidated,” or “disputed” does not constitute an admission by the Debtors that the claim or amount 

is not “contingent,” “unliquidated,” or “disputed.” The Debtors reserve all of their rights to dispute, 

or to assert offsets or defenses to, any claim reflected on their Schedules on any grounds, including, 

without limitation, amount, liability, priority, status, or classification, or to otherwise subsequently 

designate any claim as “contingent,” “unliquidated,” or “disputed.” Listing a claim on the Schedules 

as “secured” does not constitute an admission by the Debtors of the legal rights of the claimant, or a 

waiver of the Debtors’ rights to reclassify such claim or contract. Moreover, although the Debtors 

may have scheduled claims of various creditors as secured claims for informational purposes, no 

current valuation of the Debtors’ assets in which such creditors may have a lien has been undertaken. 

The Debtors reserve all of their rights to amend, supplement, or otherwise modify their Schedules as 

necessary and appropriate, including, modifying claim descriptions and designations. 

15. Executory Contracts and Unexpired Leases: The placing of a contract or lease onto the

Schedules shall not be deemed an admission that such contract is an executory contract or unexpired 

lease, or that it is necessarily a binding, valid, and enforceable agreement. The Debtors hereby 

expressly reserve the right to assert that any contract or lease listed on the Debtors’ Schedules does 

not constitute an executory contract or unexpired lease within the meaning of section 365 of the 

Bankruptcy Code.

16. Undetermined Amounts: Claim amounts that could not readily be quantified by the Debtors

are scheduled as “undetermined.” The description of an amount as “undetermined” is not intended to 

reflect upon the materiality of the amount. 

17. Payment of Prepetition Claims Pursuant to First Day Orders: On or about January 31,

2019, the Bankruptcy Court entered orders (the “First-Day Orders”) authorizing, but not directing, 

the Debtors to, among other things, pay certain prepetition claims relating to (a) certain safety, 

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 6

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 17

EXHIBIT 1, PAGE 17

of 25
reliability, outage, and nuclear facility suppliers; (b) shippers, warehousemen, and other lien 

claimants; (c) taxes; (d) employee wages, salaries, and other compensation and benefits; (e) customer 

programs, including public purpose programs; and (f) the continued use of the Debtors’ Cash 

Management System. Where the Schedules list creditors and set forth the amounts attributable to such 

claims, such scheduled amounts reflect balances owed as of the Petition Date. To the extent any 

adjustments are necessary to reflect any payments made on account of such claims following the 

commencement of these Chapter 11 Cases pursuant to the authority granted to the Debtors by the 

Bankruptcy Court under the First Day Orders, such adjustments have been included in the Schedules 

unless otherwise noted on the applicable Schedule. The Debtors reserve the right to update the 

Schedules to reflect payments made pursuant to the First-Day Orders. 

18. Confidentiality: There may be instances in the Schedules where the Debtors have deemed it

necessary and appropriate to redact or withhold from the public record information such as names, 

addresses, or amounts. Typically, the Debtors have used this approach because of an agreement 

between the Debtors and a third party, concerns of confidentiality, or concerns for the privacy of an 

individual. In addition, certain agreements may not have been included on the Schedules because 

publicly disclosing such agreements may violate the terms set forth therein. 

19. Totals: All totals that are included in the Schedules represent totals of all the known amounts

included in the Schedules and exclude items identified as “unknown” or “undetermined.” If there are 

unknown or undetermined amounts, the actual totals may be materially different from the listed totals.

Specific Notes with Respect to the Debtors’ Schedules

a. Schedule A/B – Real and Personal Property:

(i) Schedule A/B.3: The bank account balances listed are as of the Petition Date.

(ii) Schedule A/B.11: Credit is regularly extended to customers for utility service and

made in the ordinary course of business based upon the Debtors’ assessment of

creditworthiness. Accordingly, there is a significant amount of accounts receivable

owed to the Debtors as of the Petition Date which will be recouped or reimbursed in

the ordinary course of business. Receivables are reported as of January 31, 2019.

As part of the Debtors’ normal accounting practices, PG&E Corp. and the Utility

recognize an allowance for doubtful accounts to record uncollectable customer

accounts receivable at estimated net realizable value, including customer credits. The

allowance is determined based upon a variety of factors, including historical write-off

experience, aging of receivables, current economic conditions, and assessment of

customer collectability.

(iii) Schedule A/B.15: Equity interests in subsidiaries and affiliates primarily arise from

common stock ownership or member or partnership and joint venture interests. The

Debtors do not have current market valuations for all of their assets, including the

equity interests of all their subsidiaries and affiliates, as it would be prohibitively

expensive, unduly burdensome, and an inefficient use of estate assets and resources for

the Debtors to obtain current market valuations of all their assets. Accordingly, for

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 7

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 18

EXHIBIT 1, PAGE 18

of 25
purposes of these Schedules, the Debtors have listed the equity interests of all of their 

subsidiaries and affiliates as “unknown” or “undetermined” amounts.

(iv) Schedule A/B; Part 5: Inventories are carried at weighted-average cost and include

natural gas stored underground, nuclear fuel as well as materials and supplies. Stored

natural gas and nuclear fuel is recorded to inventory and then expensed as the gas is

withdrawn for distribution to customers or to be used as fuel for electric generation.

Materials and supplies are recorded to inventory when purchased and expensed or

capitalized to plant, as appropriate, when consumed or installed.

(v) Schedule A/B; Part 7, 8 and 9: Property, plant, and equipment are reported at

historical cost less accumulated depreciation. Historical costs include labor and

materials, construction overhead, and AFUDC. AFUDC represents the estimated costs

of debt (i.e., interest) and equity funds used to finance regulated plant additions before

they go into service and is capitalized as part of the cost of construction. The Debtors

depreciate property, plant, and equipment using the composite, or group, method of

depreciation, in which a single depreciation rate is applied to the gross investment

balance in a particular class of property. This method approximates the straight-line

method of depreciation over the useful lives of property, plant, and equipment.

Depreciation expense includes a component for the original cost of assets and a

component for estimated cost of future removal, net of any salvage value at retirement.

Upon retirement, the original cost of the retired assets, net of salvage value, is charged

against accumulated depreciation. The cost of repairs and maintenance, including

planned major maintenance activities and minor replacements of property, is charged

to operating and maintenance expense as incurred.

The Schedules do not include asset retirement obligations (“AROs”). The Debtors

account for an ARO at fair value in the period during which the legal obligation is

incurred if a reasonable estimate of fair value and its settlement date can be made. At

the time of recording an ARO, the associated asset retirement costs are capitalized as

part of the carrying amount of the related long-lived asset. To estimate its liability, the

Utility uses a discounted cash flow model based upon significant estimates and

assumptions about future decommissioning costs, inflation rates, and the estimated date

of decommissioning. The estimated future cash flows are discounted using a creditadjusted risk-free rate that reflects the risk associated with the decommissioning

obligation.

(vi) Schedule A/B.60, 61: The Debtors have not attempted to assign values to all of their

various intellectual property rights and licenses because doing so would be unduly

burdensome, and as a result, they are not included in Schedules.

(vii) Schedule A/B.74: Various electricity suppliers filed claims in the Utility’s prior 2001

chapter 11 case (Case No. 01-30923 (DM)) seeking payment for energy supplied to the

Utility’s customers between May 2000 and June 2001. While proceedings are pending

before FERC and other judicial forums, the Utility pursued settlements with electricity

suppliers and entered into a number of settlement agreements with various electricity

suppliers to resolve some of these disputed claims and to resolve the Utility’s refund

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 8

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 19

EXHIBIT 1, PAGE 19

of 25
claims against these electricity suppliers. Under these settlement agreements, amounts 

payable by the parties, in some instances, would be subject to adjustment based on the 

outcome of the various refund offset and interest issues being considered by the FERC. 

Generally, any net refunds, claim offsets, or other credits that the Utility receives from 

electricity suppliers either through settlement or through the conclusion of the various 

FERC and judicial proceedings are refunded to customers through rates in future 

periods. Accordingly, such potential refund claims are not included in the Schedules. 

(viii) Schedule A/B.75: In the ordinary course of business, the Debtors may have accrued,

or may in the future accrue, certain rights to counter-claims, cross-claims, setoffs,

and/or refunds with Debtors’ customers and suppliers, or potential warranty claims

against their suppliers. Additionally, either of the Debtors may be party to pending

litigation in which the Debtors have asserted, or may assert, claims as a plaintiff or

counter-claims and/or cross-claims as a defendant. Because such claims are unknown

to the Debtors and not quantifiable as of the Petition Date, they are not listed on

Schedule A/B.75.

(ix) Schedule A/B.77: The Utility uses both derivative and non-derivative contracts to

manage volatility in customer rates due to fluctuating commodity prices. Derivatives

include contracts, such as power purchase agreements, forwards, futures, swaps,

options, and congestion revenue rights. Derivatives are recorded at fair value and on a

net basis in accordance with master netting arrangements for each counterparty. The

fair value of derivative instruments is further offset by cash collateral paid or received

where the right of offset and the intention to offset exist. The Utility elects the normal

purchase and sale exception for eligible derivatives. Eligible derivatives are those that

require physical delivery in quantities that are expected to be used by the Utility over a

reasonable period in the normal course of business, and do not contain pricing

provisions unrelated to the commodity delivered. These items are not reflected in the

assets or liabilities at fair value. Eligible derivatives are accounted for under the accrual

method of accounting.

PG&E Corp. and the Utility record a receivable for insurance recoveries when it is

deemed probable that recovery of a recorded loss will occur. Through December 31,

2018, PG&E Corp. and the Utility recorded $1.38 billion for probable insurance

recoveries in connection with the 2018 Camp fire and $842 million for probable

insurance recoveries in connection with the 2017 Northern California wildfires. The

amount of the receivable is subject to change based on additional information.

b. Schedule D – Creditors Holding Secured Claims: The claims listed on Schedule D arose and

were incurred on various dates; a determination of the date upon which each claim arose or was

incurred would be unduly burdensome and cost prohibitive. Accordingly, not all such dates are

included for each claim. Except as otherwise agreed pursuant to a stipulation, agreed order, or

general order entered by the Bankruptcy Court, the Debtors reserve their right to dispute or

challenge the validity, perfection, or immunity from avoidance of any lien purported to be granted

or perfected in any specific asset to a creditor listed on Schedule D of either Debtor. Moreover,

although the Debtors may have scheduled claims of various creditors as secured claims, the

Debtors reserve all rights to dispute or challenge the secured nature of any such claim or the

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 9

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 20

EXHIBIT 1, PAGE 20

of 25
characterization of the structure of any such transaction or any document or instrument (including, 

without limitation, any intercompany agreement) related to such claim. The descriptions provided 

on Schedule D only are intended to be a summary. Reference to the applicable loan agreements 

and related documents is necessary for a complete description of the collateral and the nature, 

extent, and priority of any liens. 

In certain instances, a Debtor may be a co-obligor, co-mortgagor, or guarantor for a scheduled 

claim of another Debtor, and no claim on Schedule D of any Debtor is intended to acknowledge 

claims of creditors that are otherwise satisfied or discharged by other entities. Except as 

specifically stated herein, real property lessors, utility companies, and other parties that may hold 

security deposits have not been listed on Schedule D. Moreover, certain contracts listed on 

Schedule G may be secured by assets of the Debtors. The Debtors believe it would be unduly 

burdensome and costly to attempt to identify and list all such agreements on Schedule D. 

c. Schedule E/F – Creditors Holding Unsecured Claims: Reasonable efforts have been made to 

list all liabilities on Schedule E/F for both Debtors. Claims listed on Schedule E/F arose or were 

incurred on various dates. Although reasonable efforts have been made to list the date that each 

claim arose, determination of each date upon which such claim in Schedule E/F was incurred or 

arose would be unduly burdensome and cost prohibitive and, therefore, the Debtors do not list a 

date for each claim listed on Schedule E/F. 

As discussed above, the Bankruptcy Court entered a number of First-Day Orders granting authority 

to pay certain prepetition claims. Claims against the Debtors for prepetition amounts that have not 

been paid but for which authority has been received may be included in Schedule E/F. 

Accordingly, the Debtors reserve their rights to object to any listed claims on the ground that, 

among other things, they have already been satisfied. Listing a claim on Schedule E/F as priority 

does not constitute an admission by the Debtors of the claimant’s legal rights or a waiver of the 

Debtors’ right to recharacterize or reclassify the claim or contract. 

The Debtors believe that most of the employee prepetition claims entitled to priority under the 

Bankruptcy Code have been or will be paid pursuant to certain First-Day Orders that authorized 

the payment of such claims. Accordingly, except as otherwise noted therein, employee claims 

have been scheduled as “Undetermined” on Schedule E/F for each Debtor; however, for the 

avoidance of doubt, the Debtors have used reasonable efforts to include all employees on Schedule 

E/F that had prepetition claims as of the Petition Date. 

In the ordinary course of business, the Utility will require deposits from customers if they have 

had service discontinued in the past due to non-payment or if a customer has no previous service 

history with the Utility. The majority of these deposits would qualify as priority unsecured 

deposits under section 507(a)(7) of the Bankruptcy Code. The Debtors have received final

authority pursuant to the order approving their Motion of Debtors Pursuant to 11 U.S.C. §§ 105(a), 

363(b), and 507(a)(7) and Fed. R. Bankr. P. 6003 and 6004 for Interim and Final Orders (i) 

Authorizing Debtors to (a) Maintain and Administer Customer Programs, Including Public 

Purpose Programs, and (b) Honor any Prepetition Obligations Relating Thereto,; and (ii) 

Authorizing Financial Institutions to Honor and Process Related Checks and Transfers [Docket 

No. 16] (the “Customer Programs Motion”) to continue to refund or offer service credits to 

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 10

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 21

EXHIBIT 1, PAGE 21

of 25
customers with these deposits when the customer meets the appropriate credit worthiness criteria. 

Due to the number of customers with deposits, the relief granted in connection with the Customer 

Programs Motion, and the confidential nature of these deposits, the Debtors have not listed these 

customers on Schedule E/F – Priority Unsecured Claims.

Certain claims listed on Schedule E/F are claims owing to various taxing authorities to which the 

Debtors may potentially be liable. These claims may be the subject of ongoing audits and the 

Debtors may be unable to determine with certainty the amount of many, if not all, of the claims 

listed on Schedule E/F. Therefore, the Debtors listed all such claim amounts as “Undetermined” 

in amount, pending final resolution of ongoing audits or other outstanding issues. 

Schedule E/F contains information regarding pending litigation involving the Debtors. In certain 

instances, the identity of the Debtors that are the subject of the litigation is unclear or 

undetermined. However, if litigation involving a particular Debtor has been identified, that 

information is contained in the Schedule for that Debtor. The inclusion of any litigation in these 

Schedules does not constitute an admission by the Debtors of liability, the validity of any action, 

the availability of insurance coverage, or the amount or treatment of any claims, defenses, 

counterclaims, or cross-claims or the amount or treatment of any potential claim resulting from 

any current or future litigation. For the avoidance of doubt, the Debtors preserve all defenses with 

respect to any lawsuit listed on Schedule E/F, including, but not limited to, the right to dispute that 

any of the lawsuits listed were not properly filed or that Debtors were not properly served a 

complaint in accordance with applicable state or federal laws. The Debtors have generally 

excluded internal grievance claims to protect the privacy interests of the grieving party and because 

the majority of such claims generally will not result in actual litigation. In addition, certain 

litigation or claims covered by insurance policies maintained by the Debtors may be excluded from 

Schedule E/F.

As set forth in the Debtors’ Form 10-K for the fiscal year ended December 31, 2018, PG&E Corp. 

and the Utility face several uncertainties in connection with the 2018 Camp fire and 2017 Northern 

California wildfires, related to: the amount of possible loss related to third-party claims (in 2018, 

the Utility recorded total charges of $13.4 billion, which reflects the low end of the range of 

reasonably estimated losses and is subject to change based on additional information), which 

aggregate possible losses, if the Utility were found liable for certain or all of the costs, expenses

and other losses in connection with the 2018 Camp fire and 2017 Northern California wildfires 

(other than potential punitive damages, fines and penalties or damages related to future claims), 

could exceed $30 billion. The Debtors have not attributed these charges to the holder of any 

particular wildfire claim. Accordingly, the Debtors have listed the claim amounts as 

“Undetermined” in Schedule E/F.

In the ordinary course of business, the Debtors generally receive invoices for goods and services 

after the delivery of such goods or services. As of the filing of the Schedules, the Debtors had not 

received all invoices for payables, expenses, or liabilities that may have accrued before the Petition 

Date. Accordingly, the information contained in Schedules E/F may be incomplete. The Debtors 

reserve the right to amend, modify, or supplement Schedules E/F in the event they receive such 

invoices. The claims of individual creditors are generally listed at the amounts recorded on the 

Debtors’ books and records and may not reflect credits or allowances due from the creditor. The 

Debtors reserve all of their rights concerning credits or allowances.

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 11

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 22

EXHIBIT 1, PAGE 22

of 25
d. Schedule G – Executory Contracts: The business of the Debtors is large and complex. Although

reasonable efforts have been made to ensure the accuracy of Schedule G, inadvertent errors,

omissions, or overinclusion may have occurred. Nothing herein shall be construed as a concession

or evidence that any of the contracts, agreements, and leases identified on Schedule G: (i)

constitute an executory contract within the meaning of section 365 of the Bankruptcy Code and

other applicable law; or (ii) have not expired or been terminated or otherwise are not currently in

full force and effect. Moreover, omission of a contract or lease from Schedule G does not

constitute an admission that the contract or lease is not an executory contract or unexpired lease.

The Debtors reserve all of their rights, including their right to seek a later determination of these

issues and their right to dispute the validity, status, characterization, or enforceability of any

contract or lease in Schedule G.

Certain of these contracts or leases may have been modified, amended, or supplemented by various

amendments, restatements, statement of works, waivers, estoppel certificates, letters, improvement

initiatives, notices to proceed, field directives, side letters, commitment letters, and other

documents, instruments, and agreements that may not be listed, but are nonetheless incorporated

by this reference. Certain of the contracts and leases listed on Schedule G may have been entered

into by more than one of the Debtors. In addition, certain of the contracts and leases listed on

Schedule G may not have been memorialized or fully executed and could be subject to dispute.

In some cases, the same supplier or provider appears multiple times in Schedule G. This multiple

listing may reflect distinct agreements between the applicable Debtor and the supplier or provider.

Multiple purchase orders, repair orders, or agreements with the same supplier or provider may be

summarized and may not be listed on Schedule G individually.

The Debtors may have entered into various agreements in the ordinary course of their business,

such as easements, rights of way, subordinations, nondisturbance and attornment agreements,

supplemental agreements, amendments/letter agreements, title agreements, non-disclosure

agreements, confidentiality agreements, and similar such agreements. These documents also may

not be listed on Schedule G.

Terms and conditions governing purchase orders, sales orders, and similar agreements may be

referenced in an ancillary master services agreement (“MSA”) or other governing document.

Schedule G includes certain of such MSAs or other governing documents. By their inclusion in

this Schedule, the Debtors do not submit that any MSA is an executory contract and such MSAs

have been included in the Schedule out of an abundance of caution. The Debtors reserve all rights

with respect to such master service agreements, including the right to argue that they are executory

contracts.

e. Schedule H – Co-Debtors: Although the Debtors have made every effort to ensure the accuracy

of Schedule H, inadvertent errors, omissions, or inclusions may have occurred. The Debtors

hereby reserve all rights to dispute the validity, status, and enforceability of any obligations set

forth on Schedule H and to further amend or supplement such Schedule as necessary.

The Debtors further reserve all rights, claims, and causes of action with respect to the obligations

listed on Schedule H, including the right to dispute or challenge the characterization or the structure

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 12

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 23

EXHIBIT 1, PAGE 23

of 25
of any transaction, document, or instrument related to a creditor’s claim. The listing of a contract,

guarantee, or other obligation on Schedule H shall not be deemed an admission that such obligation 

is binding, valid, or enforceable. 

In the ordinary course of their business, the Debtors are involved in pending or threatened 

litigation, environmental matters and claims arising out of the conduct of their business. These 

matters may involve multiple plaintiffs and defendants, some or all of whom may assert crossclaims and counterclaims against other parties. Because such claims are listed elsewhere in the 

Statements and Schedules, they have not been set forth individually on Schedule H. 

The Debtors may not have identified certain guarantees that are embedded in the Debtors’ 

executory contracts, unexpired leases, debt instruments, and other such agreements. The Debtors 

reserve their right, but shall not be required, to amend the Schedules to the extent that additional 

guarantees are identified or such guarantees are discovered to have expired or are unenforceable. 

Case: 19-30088 Doc# 903-1 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 13

 of 13

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 24

EXHIBIT 1, PAGE 24

of 25
Case: 19-30088 Doc# 903-2 Filed: 03/14/19 Entered: 03/14/19 22:48:46 Page 1

 of 1

Case: 19-30088 Doc# 3688 Filed: 08/26/19 Entered: 08/26/19 10:08:16 Page 25

EXHIBIT 1, PAGE 25

of 25