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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

Robert A. Julian (SBN 88469)

Cecily A. Dumas (SBN 111449)

BAKER & HOSTETLER LLP

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: 628.208.6434

Facsimile: 310.820.8859

Email: rjulian@bakerlaw.com

Email: cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Blvd., Suite 1400

Los Angeles, CA 90025-0509

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel to the Official Committee of Tort Claimants

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

□ 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)

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

EXHIBIT A TO DECLARATION OF 

FRANK M. PITRE IN SUPPORT OF 

THE MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR AN ORDER DETERMINING 

PROCEDURES FOR PRESERVING 

JURY TRIAL RIGHTS (Dkt. Nos. 3479, 

3480)

Case: 19-30088 Doc# 3487 Filed: 08/09/19 Entered: 08/09/19 10:07:53 Page 1 of

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From: Frank Pitre <FPitre@cpmlegal.com> 

Date: August 3, 2019 at 6:37:36 PM PDT 

To: Kevin Orsini <K0rsini@cravath.com> 

Cc: Steven Skikos <sskikos@skikos.com>, "Michael A. Kelly" <MKelly@walkuplawoffice.com>, Steve Campora 

<scampora@dbbwc.com> 

Subject: Re: PG&E 

Thanks 

Sent from my iPhone 

On Aug 3, 2019, at 6:15 PM, Kevin Orsini <K0rsini@cravath.com> wrote: 

Frank, 

We agree that the Brown Greer dispute is and should be separate from any jury trial 

issue dispute. 

There is a motion before the court presently to set estimation procedures, as well as 

your motion to lift the stay. If you would like to file some other motion that you believe 

raises the jury trial issue, you are of course free to do so and we will respond in due 

course. 

I don't know why the edits did not come through, but attached is a pdf version that 

shows the clarifications. 

Kevin 

This e-mail is confidential and may be privileged. Use or disclosure of it by anyone other 

than a designated addressee is unauthorized. If you are not an intended recipient, 

please delete this e-mail from the computer on which you received it. 

Sent from my iPad 

On Aug 3, 2019, at 4:40 PM, Frank Pitre <FPitre@cpmlegal.com> wrote: 

Kevin: 

The issue of Jury Trial Waiver is important for all claimants to 

understand going into the process. If we cannot reach agreement, I 

suggest we take up the issue with the Court and set a short briefing 

schedule to get the issue resolved. I this manner we separate the 

dispute from access to Brown Greer. 

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Case: 19-30088 Doc# 3487 Filed: 08/09/19 Entered: 08/09/19 10:07:53 Page 2 of

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As to the Brown Greer edits, my version does not show those edits in 

red line or highlights, so I can easily make sure I understand any changes. 

If you could send in some format to highlight the changes, it would be 

appreciated. 

I will need to process this with the rest of my group, and get back 

Monday am. 

Best Frank 

Sent from my iPhone 

On Aug 3, 2019, at 1:15 PM, Kevin Orsini <KOrsini@cravath.com> wrote: 

Frank, 

The Debtors are not prepared to enter into any 

stipulation concerning jury trial rights that claimants 

may or may not have in connection with the Chapter 11 

proceedings. That issue will need to be addressed 

based on the existing law governing these proceedings. 

I have made a few clarifying edits in the attached 

version of the agreement based on discussions to 

date. These changes do not change the substance, but 

are designed to avoid ambiguity for both sides. We are 

prepared to move forward with the agreement with 

those changes. 

Kevin 

This e-mail is confidential and may be privileged. Use or 

disclosure of it by anyone other than a designated 

addressee is unauthorized. If you are not an intended 

recipient, please delete this e-mail from the computer 

on which you received it. 

Sent from my iPad 

On Aug 2, 2019, at 1:16 PM, Frank Pitre 

<FPitre@cpmlegal.com> wrote: 

Kevin: 

We are prepared to finalize and 

accept the terms reflected in the 

attachment to this email, with the 

additional provision that: 

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Case: 19-30088 Doc# 3487 Filed: 08/09/19 Entered: 08/09/19 10:07:53 Page 3 of

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"Claimants submission of 

information into the Brown Greer 

system for use in connection with these 

bankruptcy proceedings, including the 

filing of claims in bankruptcy, shall not 

constitute a waiver of their right to jury 

trial for any claim which seeks recovery 

for damages arising from wrongful 

death or personal injury". 

If the additional term is 

acceptable, we have a complete 

agreement. 

Please confirm as soon as you 

can so we will know how to deal with 

the presently issued subpoenas for 

Brown Greer data. Call me with any 

questions (650) 697-6000 or (650 245-

8020. 

Thanks Kevin 

Frank M. Pitre 

Partner 

COTCHETT PITRE & 

McCARTHY LLP 

A LITIGATION LAW FIRM - SAN FRANCISCO, 

LOS ANGELES, NEW YORK 

840 Malcolm Road, Suite 

200 I Burlingame, CA 94010 

Tel: (650) 697-6000 I Fax: (650) 

697-0577 I Email: 

fpitre@cpmlegal.com 

CONFIDENTIALITY NOTICE: This email is 

covered by the Electronic Communications 

Privacy Act, 18 U.S.C. Sections 2510-

2521. This email and any documents 

accompanying this email contain legally 

privileged and confidential information 

belonging to the sender. The information 

is intended only for the use of the individual 

or entity named above. if you are not the 

intended recipient, you are hereby notified 

that any disclosure, copying, distribution, or 

the taking of any action in reliance on the 

contents of this email communication is 

strictly prohibited. If you have received this 

email in error, please notify us immediately 

by telephone or email and permanently 

delete the email, any attachments, and ail 

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