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LOCKE LORD LLP 

Meagan S. Tom (SBN 273489) 

meagan.tom@lockelord.com 

101 Montgomery Street, Suite 1950 

San Francisco, CA 94104 

Telephone: (415) 318-8810 

Fax: (415) 676-5816 

Bradley C. Knapp (admitted pro hac vice) 

bknapp@lockelord.com 

601 Poydras Street, Suite 2660 

New Orleans, Louisiana 70130 

Telephone: (504) 558-5210 

Fax: (504) 910-6847 

W. Steven Bryant (admitted pro hac vice) 

sbryant@lockelord.com 

600 Congress Street, Suite 2200 

Austin, Texas 78701 

Telephone: (512) 305-4700 

Fax: (512) 305-4800 

Attorneys for Creditor 

International Brotherhood of Electrical Workers Local Union 1245 

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 

_____ Affects Pacific Gas and Electric Company 

 X Affects both Debtors 

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CASE NO.: 19-30088 

Chapter 11 

(Lead Case) 

(JOINTLY ADMINISTERED) 

INTERNATIONAL 

BROTHERHOOD OF 

ELECTRICAL WORKERS, LOCAL 

UNION NO. 1245’S STATEMENT 

IN SUPPORT AND FURTHER 

RESPONSE REGARDING MOTION 

OF DEBTORS PURSUANT TO 11 

U.S.C. § 105(a) AND 363(b) AND 

FED. R. BANKR. P. 2002 AND 

6004(h) FOR AN ORDER (A) 

Case: 19-30088 Doc# 2018 Filed: 05/15/19 Entered: 05/15/19 15:55:11 Page 1 of

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AUTHORIZING DEBTORS TO 

ESTABLISH AND FUND 

PROGRAM TO ASSIST WILDFIRE 

CLAIMANTS WITH 

ALTERNATIVE LIVING 

EXPENSES AND (B) GRANTING 

RELATED RELIEF 

Date: May 22, 2019 

Time: 10:00 AM 

Place: Courtroom 17, U.S. Bankruptcy 

Court, 16th Floor, 450 Golden Gate 

Avenue, San Francisco, California 

The International Brotherhood of Electrical Workers Local Union 1245 (“IBEW”), files this 

Statement in Support and Further Response to the Motion of Debtors pursuant to 11 U.S.C. §§ 

105(a) and 363(b) and Federal Rules of Bankruptcy Procedure 2002 and 6004(h) for Entry of an 

Order (a) Authorizing the Debtors to Establish and Fund Program to Assist Wildfire Claimants with 

Alternative Living Expenses and Other Urgent Needs and (b) Granting Related Relief [Dkt. No. 

1777] (the “Motion”) and states as follows: 

I. Introduction 

The IBEW is a labor organization affiliated with the American Federal of Labor – Congress 

of Industrial Organizations. The IBEW represents approximately 20,000 gas and utility employees, 

including thousands of employees of Pacific Gas & Electric Company (“PG&E”), throughout 

California. IBEW members are responsible for building, maintaining and repairing PG&E’s electric 

distribution and transmission systems and are therefore critical to PG&E’s ability to supply power 

and gas to approximately 16 million California residents. The IBEW’s members live and work 

throughout the communities affected by the recent devastating wildfires. 

II. Statement 

The IBEW strongly supports the establishment of the fund contemplated by the Motion to 

provide necessary assistance to individuals affected by recent wildfires. While the IBEW is mindful 

that such a fund related to pre-petition claims is not typical in Chapter 11 cases, this is not a typical 

Case: 19-30088 Doc# 2018 Filed: 05/15/19 Entered: 05/15/19 15:55:11 Page 2 of

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Chapter 11 case. By most accounts, the reorganization process may take years and require 

coordinated action by a number of authorities including the California legislature, CPUC, and this 

Court. The victims affected by recent fires cannot wait for these processes to align and will benefit 

greatly from immediate access to assistance. 

The IBEW responds further that certain modifications to the program should be implemented 

to ensure its fairness in the context of the bankruptcy case. Specifically, the IBEW suggests that the 

program be modified as follows: 

 Individual claimants receiving funds through the program should see a reduction in their 

ultimate unsecured creditor recovery through the plan process to prevent double recoveries. 

 The program should have meaningful creditor and creditor committee oversight to ensure 

that program implementation fits the referenced need without prejudicing creditor recoveries 

through the eventual plan process. 

With these modifications, the IBEW asserts the Court should approve the Motion and 

authorize the requested relief to fire victims while the reorganization process moves forward. 

Dated: May 15, 2019 Respectfully submitted, 

LOCKE LORD LLP 

By: /s/ Meagan S. Tom 

Bradley C. Knapp 

W. Steven Bryant 

Meagan S. Tom 

Attorneys for Creditor 

International Brotherhood of Electrical Workers Local Union 1245 

Case: 19-30088 Doc# 2018 Filed: 05/15/19 Entered: 05/15/19 15:55:11 Page 3 of

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