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Exhibit 4 

(Form of Letter) 

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 1

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Wilson Sonsini Goodrich & Rosati 

Professional Corporation 

650 Page Mill Road 

Palo Alto, California 94304-1050 

O: 650.493.9300 

F: 650.493.6811 

AUSTIN BEIJING BOSTON BOULDER BRUSSELS HONG KONG LONDON LOS ANGELES NEW YORK PALO ALTO 

SALT LAKE CITY SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE 

October 26, 2022 

Larry Peluso 

Peluso Law Group, PC 

P.O. Box 1971 

Newport Beach, CA 92659 

pelusolaw@gmail.com 

Re: Rickaby, et al. v. PG&E Corp., et al. 

Dear Counsel: 

I am writing in connection with the above-referenced litigation against PG&E 

Corporation and Pacific Gas and Electric Company (collectively “PG&E”). 

As you are aware, PG&E filed voluntary petitions for relief under chapter 11 of title 11 of 

the United States Code in the United States Bankruptcy Court for the Northern District of 

California (the “Bankruptcy Court”). By Order dated June 20, 2020 (the “Confirmation Order”), 

the Bankruptcy Court confirmed the Chapter 11 Plan of Reorganization Dated Date June 19, 

2020 (the “Plan”). The Effective Date of the Plan occurred on July 1, 2020, and as a result, the 

Plan has been substantially consummated. 

Pursuant to section 6.7 of the Plan, PG&E funded a trust for the benefit of holders of Fire 

Victim Claims (the “Fire Victim Trust”). Section 10.7 of the Plan and paragraph 53 of the 

Confirmation Order provide that the Fire Victim Trust is the sole source of recovery for your 

clients. Further, pursuant to Sections 10.6 and 10.7, and paragraphs 52 and 53, holders of Fire 

Victim Claims are “permanently and forever . . . enjoined from taking any action for the purpose 

of directly or indirectly collecting, recovering, or receiving payments, satisfaction, or recovery 

from PG&E” (the “Channeling Injunction”). 

In recognition of the terms of PG&E’s confirmed Plan and the Channeling Injunction, the 

vast majority of the cases relating to the Camp Fire already have been voluntarily dismissed. 

Specifically, there were 184 cases filed in the Superior Courts of Northern California and over 

150 cases have been voluntarily dismissed, as they should be, because further prosecution of 

these actions is prohibited by the Channeling Injunction. 

We have previously sought your clients’ voluntary dismissal of this case. On June 1, 

2021, we provided your firm with a prepared dismissal form to be executed and filed. 

Unfortunately, we have still not received a filed copy of the dismissal and, as a result, the Court 

continues to set Case Management Conferences. 

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 2

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Larry Peluso 

October 26, 2022 

Page 2 

To facilitate dismissal of this case, without the need to further burden the Court, we are 

once again providing a fully prepared dismissal form. Please execute and file it. Thank you. 

Very truly yours, 

WILSON SONSINI GOODRICH & ROSATI 

Professional Corporation 

/s/ David A. McCarthy 

David A. McCarthy 

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 3

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Wilson Sonsini Goodrich & Rosati 

Professional Corporation 

650 Page Mill Road 

Palo Alto, California 94304-1050 

O: 650.493.9300 

F: 650.493.6811 

AUSTIN BEIJING BOSTON BOULDER BRUSSELS HONG KONG LONDON LOS ANGELES NEW YORK PALO ALTO 

SALT LAKE CITY SAN DIEGO SAN FRANCISCO SEATTLE SHANGHAI WASHINGTON, DC WILMINGTON, DE 

November 30, 2022 

Christian Krankemann 

Michael Li 

Krankemann Law Offices P.C. 

420 E St Ste. 100 

Santa Rosa, CA 95404-4342 

Re: North Bay Fire Litigation 

Dear Counsel: 

I am writing in connection with the North Bay Fire litigation against PG&E Corporation 

and Pacific Gas and Electric Company (collectively “PG&E”). Your law office still has numerous 

open litigation matters. See Exhibit A. 

As you are aware, PG&E filed voluntary petitions for relief under chapter 11 of title 11 of 

the United States Code in the United States Bankruptcy Court for the Northern District of 

California (the “Bankruptcy Court”). By Order dated June 20, 2020 (the “Confirmation Order”), 

the Bankruptcy Court confirmed the Chapter 11 Plan of Reorganization Dated Date June 19, 

2020 (the “Plan”). The Effective Date of the Plan occurred on July 1, 2020, and as a result, the 

Plan has been substantially consummated. 

Pursuant to section 6.7 of the Plan, PG&E funded a trust for the benefit of holders of Fire 

Victim Claims (the “Fire Victim Trust”). Section 10.7 of the Plan and paragraph 53 of the 

Confirmation Order provide that the Fire Victim Trust is the sole source of recovery for your 

clients. Further, pursuant to Sections 10.6 and 10.7, and paragraphs 52 and 53, holders of Fire 

Victim Claims are “permanently and forever . . . enjoined from taking any action for the purpose 

of directly or indirectly collecting, recovering, or receiving payments, satisfaction, or recovery 

from PG&E” (the “Channeling Injunction”). 

In recognition of the terms of PG&E’s confirmed Plan and the Channeling Injunction, the 

vast majority of the cases relating to the North Bay Fires have already been dismissed. There 

were 889 cases filed in the Superior Courts of Northern California. On January 20, 2021, the 

Honorable Andrew Y.S. Cheng, pursuant to the Plan and Confirmation Order, entered an Order 

dismissing all 559 of the coordinated lawsuits. If your cases had been coordinated, as your firm 

was attempting to do prior to the bankruptcy, these cases would be dismissed already. In any 

event, even with respect to the 330 non-coordinated North Bay Fires actions, over 260 have 

been voluntarily dismissed, as they should be, because further prosecution of these actions is 

prohibited by the Channeling Injunction. Indeed, courts have started issuing Orders to Show 

Cause why remaining cases have not been dismissed. See, e.g., Exhibit B. 

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 4

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Christian Krankemann 

Michael Li 

November 30, 2022 

Page 2 

Your law firm has the greatest number of remaining North Bay Fire cases (by far). We 

are now two-and-a-half years past the Effective Date of the Plan and your law firm’s remaining 

cases need to be dismissed. We have previously sought your clients’ voluntary dismissal of these 

cases. Unfortunately, we have still not received dismissals and these cases continue to sit on the 

Court’s docket notwithstanding the Channeling Injunction. 

Provided herewith is a zip file containing editable pre-prepared dismissal forms to be 

executed and filed. Please confirm you will handle filing these dismissals. Thank you. 

Very truly yours, 

WILSON SONSINI GOODRICH & ROSATI 

Professional Corporation 

/s/ David A. McCarthy 

David A. McCarthy 

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 5

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Case Number Case Name

SCV-263250 Max Salkin

SCV-263261 Catherine Dale-Jablonowski; Michael Jablonowski

SCV-263267 Maurine Killough

SCV-263314 Ian Norstad

SCV-263317 Bryan Butler

SCV-263331 Brian and Buffi Frazier

SCV-263332 Chris and Sarah Keys

SCV-263333 Luis Pena

SCV-263334 Mike and Shannon Griffith

SCV-263335 David Barnes, Carrie Barnes

SCV-263336 Jennifer and Christopher Ross

SCV-263337 Gurcharan Singh and Kulwant Kaur

SCV-263338 Gary Warren

SCV-263339 Ryan and Daniella Beach

SCV-263340 Michael Hammer, Sr.

SCV-263341 Tiffany Jacobs

SCV-263342 Santa Rosa Chandi Pizza, Inc.

SCV-263343 Robin Bailey and Sawitree Matrtrai

SCV-263344 Gregory Moore

SCV-263345 Florence Fay

SCV-263346 Jennifer Tunzi and Gregory Tunzi

SCV-263347 John Martinez

SCV-263348 James Provost

SCV-263351 Todd Barnes and Penelope Barnes

SCV-263353 Rachel Adams

SCV-263355 Martin and Mary Beth Reilley

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 6

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EXHIBIT B

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 7

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SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO

400 MCALLISTER STREET, SAN FRANCISCO, CA 94102-4514

KEVIN BURNETT et al Case Management Department 610

Case Management Order

PLAINTIFF (S)

VS. NO.: CGC-18-571849

PG&E CORPORATION, A CALIFORNIA 

CORPORATION et al Order To Show Cause

DEFENDANT (S)

TO: PLAINTIFF'S COUNSEL AND/OR SELF-REPRESENTED PLAINTIFF(S)

The Nov-09-2022 CASE MANAGEMENT CONFERENCE is canceled. 

YOU ARE HEREBY ORDERED TO APPEAR in Department 610 on Dec-20-2022 at 10:30 am, pursuant 

to Local Rule 3.0 C to show cause why this action should not be dismissed or why sanctions should not 

be imposed for failure to: 

file a case management statement prior to the case management conference regarding bankruptcy 

status or to file dismissal.

CRC 3.110(i) requires that responsive papers to an order to show cause must be filed and served at 

least 5 calendar days before the hearing.

However, it would facilitate the issuance of a case management order prior to the Order to Show Cause 

hearing if the Response to Order to Show Cause is filed and served twenty (20) days before the Order to

Show Cause hearing.

PLAINTIFF(S) must serve a copy of this notice on all parties not listed on the attached proof of service 

within five (5) days of the date of this order.

You may call (415) 551-4000 after 12:00 noon the day before the hearing to determine whether your 

compliance has taken the order to show cause off calendar.

DATED: OCT-14-2022 SAMUEL K. FENG

JUDGE OF THE SUPERIOR COURT

Order To Show Cause

Form 000001

Case: 19-30088 Doc# 13685-4 Filed: 04/26/23 Entered: 04/26/23 16:35:45 Page 8

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