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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice)

(stephen.karotkin@weil.com)

Ray C. Schrock, P.C. (pro hac vice)

(ray.schrock@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

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)

DEBTORS’ OBJECTION TO THE APPLICATION 

OF THE OFFICIAL COMMITTEE OF TORT 

CLAIMANTS PURSUANT TO 11 U.S.C. § 1103 

AND FED. R. BANKR. P. 2014 AND 5002 TO 

RETAIN AND EMPLOY TRIDENT DMG LLC AS 

COMMUNICATIONS CONSULTANT EFFECTIVE 

AS OF JULY 18, 2019

Related Docket No.: 3224

Date: August 27, 2019

Time: 9:30 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Judge: Hon. Dennis Montali

 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# 3610 Filed: 08/20/19 Entered: 08/20/19 11:43:27 Page 1 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

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”) in the 

above-captioned chapter 11 cases (the “Chapter 11 Cases”), hereby submit this objection

(the “Objection”) to the application of the Official Committee of Tort Claimants (the “TCC”) to retain 

and employ Trident DMG LLC (“Trident”), as communications consultant effective as July 18, 2019 

[Docket No. 3224] (the “Retention Application”).

1

 

1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms 

in the Retention Application.

Case: 19-30088 Doc# 3610 Filed: 08/20/19 Entered: 08/20/19 11:43:27 Page 2 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

I. THE RETENTION APPLICATION SHOULD BE DENIED

Pursuant to the Retention Application, the TCC seeks to retain Trident as its 

“communications consultant”. This retention would be in addition to the retention of Epiq Systems and 

the website services Epiq Systems is providing on behalf of the TCC. 

As set forth in Trident’s engagement letter, the services to be performed by Trident are 

as follows:

The services shall constitute advising the Client and its counsel on communications 

strategies and efforts to support its litigation positions in the Matter and to otherwise 

serve the needs of the Client and related tort claimants. This shall include helping educate 

stakeholders about the Client’s legal positions, helping educate the public about the 

October deadline for tort claimants to identify themselves, helping tort victims learn 

about and benefit from funds already available to assist them in the wakes of their injuries 

and losses, and performing related communications services. 

Trident Engagement Letter at p. 1. (emphasis supplied).

In addition, the Trident Engagement Letter provides for a broad indemnification of 

Trident by the Debtors for Trident’s activities over which the Debtors have no control. 

Since we will act at your discretion, you agree to seek a court order requiring the Debtors 

to indemnify and hold us and our agents and assigns harmless with respect to any claims 

or actions for litigation-related discovery arising from the Matter or any claims against 

you. You also agree to seek a court order requiring the Debtors to indemnify and hold 

us and our agents and assigns harmless with respect to any claims or actions for libel, 

slander, defamation, or invasion of rights of privacy arising out of our work on the Matter 

where we have acted in good faith an in accordance with your instructions; it being 

understood and agreed that this indemnity shall not extend to any claims or actions for 

libel, slander, defamation, or invasion of rights of privacy where we have acted contrary 

to or absent your instructions or otherwise have acted with gross negligence. 

Trident Engagement Letter at p. 2.

The Debtors do not understand the need for the retention of Trident or the services it 

proposes to perform. The TCC’s existing professionals certainly have the capability of communicating 

with their constituency on all aspects of these cases and clearly have demonstrated the ability to do so, 

including, if necessary, their position on the various matters brought before the Court. 

Moreover, as to the claims filing process, the Court already has approved an 

unprecedented and robust information and noticing protocol with substantial input from the TCC. Why 

Trident is needed to supplement this or to provide any additional communications services certainly is 

not justified in the Retention Application. Further, even if justified, the broad indemnity that is sought 

Case: 19-30088 Doc# 3610 Filed: 08/20/19 Entered: 08/20/19 11:43:27 Page 3 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

to be provided by the Debtors is not warranted, particularly where the Debtors would have absolutely 

no input into any of the activities of Trident. 

The Retention Application fails to present any facts to support the need for the retention 

of Trident and the imposition of the costs associated with the retention on the Debtors’ estates. 

II. CONCLUSION

The TCC has failed to establish any need or basis that would support the retention of a 

communications consultant. Accordingly, the Retention Application should be denied.

WHEREFORE the Debtors request that the Court deny the Retention Application and 

grant the Debtors such other and further relief as the Court may deem just and appropriate. 

Dated: August 20, 2019

WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP

By: /s/ Stephen Karotkin

Stephen Karotkin

Attorneys for Debtors 

and Debtors in Possession

Case: 19-30088 Doc# 3610 Filed: 08/20/19 Entered: 08/20/19 11:43:27 Page 4 of

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