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Exhibit 3 

(Enforcement Order Notice)

 

Case: 19-30088 Doc# 13685-3 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 1

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[Caption] 

NOTICE OF BANKRUPTCY COURT ORDER 

PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the “Utility”), by 

and through their undersigned counsel, respectfully submit this Notice of Bankruptcy Court Order, and 

state as follows: 

On January 29, 2019, PG&E Corporation and Pacific Gas and Electric Company (collectively, 

the “Debtors” or “Reorganized Debtors”) filed voluntary cases for relief under chapter 11 of title 11 

of the United States Code (the “Bankruptcy Code”) in the United States Bankruptcy Court for the 

Northern District of California (the “Bankruptcy Court”). PG&E’s chapter 11 cases are being jointly 

administered as case number 19-30088 (DM). 

On June 20, 2020, the Bankruptcy Court entered its Order Confirming Debtors’ and Shareholder 

Proponents’ Joint Chapter 11 Plan of Reorganization Dated June 19, 2020 [Docket No. 8053] 

(the “Confirmation Order”) approving the terms of the Debtors’ and Shareholder Proponents’ Joint 

Chapter 11 Plan of Reorganization Dated June 19, 2020 [Docket No. 8048] (together with any exhibits 

or schedules thereto, the “Plan”). The Plan became effective on July 1, 2020 (the “Effective Date”) 

[Docket No. 8252]. 

The Plan and Confirmation Order contain discharge and injunction provisions that expressly 

provide that the holders of all Fire Victim Claims1 against the Debtors “shall have no recourse to or 

Claims whatsoever against the Debtors or the Reorganized Debtors or their assets and properties” and 

are permanently enjoined from “commencing, conducting, or continuing, in any manner, whether 

directly or indirectly, any suit, action, or other proceeding of any kind in any forum with respect to any 

such Fire Claim, against or affecting any Debtor or Reorganized Debtor, or any property or interests in 

property of any Debtor or Reorganized Debtor with respect to any such Fire Claim.” 

On [Date], the Bankruptcy Court entered the attached Order Enforcing Discharge and Injunction 

Provisions of Plan and Confirmation Order Against Certain Pending Actions (the “Enforcement 

Order”) which (i) orders [State Court Plaintiff] to take all appropriate actions within fourteen days of 

entry of the Enforcement Order to dismiss this action and otherwise comply with the discharge and 

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injunction provisions of the Plan and the Confirmation Order, including but not limited to filing a 

Request for Dismissal in this action, (ii) permits the Reorganized Debtors to request an order from the 

Bankruptcy Court holding [State Court Plaintiff] in contempt of the Bankruptcy Court for violating the 

terms of the Enforcement Order and the discharge and injunction provisions of the Plan and the 

Confirmation Order, and (iii) permits the Reorganized Debtors to seek sanctions against [State Court 

Plaintiff] in the Bankruptcy Court for reasonable fees and costs incurred by the Reorganized Debtors in 

connection with further enforcement of the discharge and injunction provisions of the Plan and the 

Confirmation Order after the fourteen-day period in part (i) has elapsed. 

Respectfully submitted this day of , 2023. 

1

 A “Fire Victim Claim” is defined in Section 1.79 of the Plan to mean “any Fire Claim that is not a 

Public Entities Wildfire Claim, Subrogation Wildfire Claim, or a Subrogation Butte Fire Claim.” A 

“Fire Claim” is defined in Section 1.78 of the Plan as “any Claim against the Debtors in any way 

arising out of the Fires, including, but not limited to, any Claim resulting from the Fires for (a) general 

and/or specific damages, including any Claim for personal injury, wrongful death, emotional distress 

and similar claims, pavement fatigue, damage to culverts, ecosystem service losses, municipal budget 

adjustments/reallocation, lost revenue and tax impacts, local share of reimbursed fire clean-up costs, 

future estimated infrastructure costs, water service losses, lost landfill capacity, costs related to unmet 

housing (e.g., housing market impact due to the Fires and adjustments for increased homeless 

population), and/or hazard mitigation costs (including, watershed restoration and hazardous tree 

removal expenses); (b) damages for repair, depreciation and/or replacement of damaged, destroyed, 

and/or lost personal and/or real property; (c) damages for loss of the use, benefit, goodwill, and 

enjoyment of real and/or personal property; (d) damages for loss of wages, earning capacity and/or 

business profits and/or any related displacement expenses; (e) economic losses; (f) damages for 

wrongful injuries to timber, trees, or underwood under California Civil Code § 3346; (g) damages for 

injuries to trees under California Code of Civil Procedure § 733; (h) punitive and exemplary damages 

under California Civil Code §§ 733 and 3294, California Public Utilities Code § 2106, or otherwise, (i) 

restitution; (j) fines or penalties; (k) any and all costs of suit, including all attorneys’ fees and 

expenses, expert fees, and related costs, including all attorneys and other fees under any theory of 

inverse condemnation; (l) for prejudgment and/or postpetition interest; (m) other litigation costs 

stemming from the Fires; and (n) declaratory and/or injunctive relief. For avoidance of doubt and 

without prejudice to the Debtors’ right to object to any such Claim, “Fire Claim” shall not include any 

(x) Claim for substantial contribution under section 503(b) of the Bankruptcy Code, (y) Subordinated 

Debt Claim, HoldCo Common Interest or HoldCo Rescission or Damage Claim, or (z) Ghost Ship Fire 

Claim. The Fire Claims shall not include claims arising from any fire other than the Fires (including, 

without limitation, the Kincade Fire or any postpetition fire) or any Administrative Expense Claims.” 

“Fires” means the fires that occurred in Northern California, listed on Exhibit A to the Plan, which 

includes the 2018 Camp Fire and the 2017 North Bay Fires. 

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