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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

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice)

(pzumbro@cravath.com)

Kevin J. Orsini (pro hac vice)

(korsini@cravath.com)

Omid H. Nasab (pro hac vice)

(onasab@cravath.com)

David A. Herman (pro hac vice)

(dherman@cravath.com)

825 Eighth Avenue

New York, NY 10019

Tel: 212 474 1000

Fax: 212 474 3700

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’ RESPONSE TO THE

COURT’S ORDER RE TELEPHONIC 

DISCOVERY CONFERENCE [DKT. NO. 

3235] 

Date: August 7, 2019

Time: 9:30 a.m. PST

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

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). 

Case: 19-30088 Doc# 3371 Filed: 08/05/19 Entered: 08/05/19 11:54:12 Page 1 of

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Pursuant to the Court’s July 29, 2019 Order regarding a Telephonic Discovery 

Conference (Dkt. No. 3235), 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”) submit this 

statement concerning open discovery issues with respect to the Official Committee of Tort 

Claimants (the “TCC”) and the Ad Hoc Group of Subrogation Claim Holders (the 

“Subrogation Group”) in advance of the conference scheduled for August 7, 2019. 

I. The Debtors’ Requests to the TCC and Subrogation Group

As the Court is aware, on July 18, 2019, the Debtors filed their Motion for the

Establishment of Wildfire Claims Estimation Procedures (Dkt. 3091) (the “Estimation 

Procedures Motion”). In connection with the Estimation Procedures Motion and anticipated 

estimation proceedings, the Debtors have sought discovery from both the TCC and the 

Subrogation Group concerning the alleged values of the claims that they have asserted and will 

assert against the Debtors. To date, although the TCC alleges that total damages for wildfire 

claims exceed $50 billion and the Subrogation Group claims damages approaching or exceeding 

$20 billion, neither has provided any documentation or other information to the Debtors—or 

any other stakeholders—to substantiate those claims. 

The Debtors have the following currently outstanding requests to the TCC 

concerning their wildfire damages claims: 

 Any and all documents and/or information in the possession, custody or 

control of the TCC, its financial advisors, and the trial lawyers (including 

but not limited to Frank Pitre and Michael Kelly) that support the TCC’s

assertion, calculation and/or justification of alleged damages, including 

the $54 billion amount asserted in the TCC’s recent filings.

 Any and all documents and/or information in the possession, custody or 

control of those same individuals or entities concerning the damages 

asserted by any wildfire claimant.

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 Any and all documents and/or information in the possession, custody or 

control of those same individuals or entities concerning Butte fire 

settlements.

 All documents and/or information concerning the claims of the members 

of the TCC who assert wildfire claims.

The TCC has not yet provided the Debtors with its position on these discovery 

issues, which the Debtors raised by letter dated August 1, 2019. In that letter, the Debtors also 

stated their willingness to discuss using a damages questionnaire that each claimant would be 

required to timely complete to provide basic information essential to the calculation of 

economic and non-economic damages, including supporting documentation. 

Additionally, the Debtors have the following outstanding requests to the 

Subrogation Group:

 All Documents, Communications and ESI concerning or relating to the 

underlying insured losses that relate to the Subrogation Wildfires Claims 

Amount, including, but not limited to, the underlying claims files.

 All Documents, Communications and ESI concerning or relating to the 

calculations, studies, projections, estimates and/or analyses concerning 

and/or relating to the Subrogation Wildfires Claims Amount.

Finally, on July 23, 2019, the Debtors served a subpoena on the Custodian of 

Records of BrownGreer PLC to request the production of “[a]ll documents and ESI contained 

in and/or accessible through the BrownGreer Portal.”1 At BrownGreer’s request, the Debtors 

have agreed to extend the response date on that subpoena until August 9, 2019. Based on 

discussions with counsel for the wildfire claimants, including the leadership group from the 

 

1 The “BrownGreer Portal” refers to the online repository that was used previously in the state court 

proceedings (JCCP No. 4955 California North Bay Fire Cases), and now as part of these Chapter 11 Cases, to store 

plaintiff-specific damages and claims-related information, uploaded by law firms representing individual claimants 

related to their wildfire-related claims.

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state court proceedings, the Debtors believe they have an agreement in principle with the 

wildfire claimants to adopt many of the claimant-specific systems, procedures and individual 

protections ordered in the state court in relation to the BrownGreer Portal. The Debtors and 

the wildfire claimants are working on the details of an agreement that, if finalized, will provide 

the Debtors and certain other stakeholders with access to the BrownGreer Portal and provide a 

process to continue discussions about a potential consensual resolution of the individual 

wildfire claims. 

II. Responses to TCC Submission (Dkt. No. 3351) and Subrogation Group Submission 

(Dkt. No. 3352)

The Debtors’ responses to each of the TCC’s requests, as detailed in its 

submission (Dkt. 3351), are below. 

No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

Outstanding Claims Estimation Documents 

1

Settlement demands and settlement 

agreements from the 2015 Butte Fire and 

the 2010 San Bruno Explosion

(Accepted foundation of estimating 

claims in mass tort bankruptcies 

(“Claims Estimation”). In re EaglePicher Indus., Inc., 189 B.R. 681, 684 

(Bankr. S.D. Ohio 1995), as amended 

(Dec. 14, 1995).) 6/27/2019

The TCC and the Debtors have 

met and conferred about 

settlement documents, which are 

subject to various state and 

Federal privileges and immunities 

from production. The Debtors are 

prepared to produce documents 

concerning the 2015 Butte Fire if 

these privilege issues, including 

the state law mediation privilege, 

can be addressed. 

2

All documents setting forth any 

allocation of settlement amounts to 

various categories of damages from the 

2015 Butte Fire settlements.

(Claims Estimation) 6/27/2019 See Response to Request 1. 

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

3

All documents used by the Debtors to 

estimate their potential losses on the 

2010 San Bruno Explosion, the 2015 

Butte Fire, the Ghost Ship fire, and the 

2017 and 2018 Northern California 

Wildfires, including in their January 

2019 8-K, February 2019 8-K and May 

2019 10-Q.

(Debtors’ admission of potential tort 

claims exposure (“Debtors’ Claims 

Estimation”)) 6/27/2019

The Debtors have produced, or 

confirmed they will produce, all 

non-privileged documents 

concerning any estimates of their 

potential losses related to the 

2015 Butte Fire, the Ghost Ship 

fire, and the 2017 and 2018 

Northern California Wildfires, 

including in their January 2019 8-

K, February 2019 8-K and May 

2019 10-Q.

The Debtors do not believe 

discovery into the 2010 San 

Bruno Explosion, for which there 

are no claims in these cases, is 

necessary or appropriate. 

4

All documents used by Jason Wells to 

support the statement in his January 

2019 Declaration that PGE’s potential 

liability for the 2017 and 2018 wildfires 

could exceed $30B.

(Debtors’ Claims Estimation) 6/27/2019

The Debtors have produced all 

responsive, non-privileged

documents located after a 

reasonable search. 

5

All documents setting forth the fines and 

penalties the Debtors incurred in 

connection with the 2015 Butte Fire and 

the 2017 and 2018 Northern California 

Wildfires.

(Debtors’ Claims Estimation) 6/27/2019

The Debtors will produce any 

outstanding documents by August 

9, 2019.

6

All documents explaining the figures set 

forth in Debtors’ January 2019 8-K, 

February 2019 8-K and May 2019 10-Q 

filings disclosing PG&E settled 2015 

Butte Fire claims to date for $900M.

(Debtors’ Claims Estimation) 6/27/2019 See Response to Request 1. 

7

All documents explaining the figures set 

forth in Debtors’ January 2019 8-K, 

February 2019 8-K and May 2019 10-Q 

filings disclosing that the 2015 Butte 

Fire claims involved 549 residences, 

2,000 households and 3,900 plaintiffs.

(Debtors’ Claims Estimation) 6/27/2019 See Response to Request 1. 

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

8

All documents produced to the SEC or 

documents detailing any meetings or 

proceedings with the SEC in connection 

with the SEC’s investigation into “public 

disclosures and accounting for losses 

associated with the 2017 and 2018 

Northern California wildfires and the 

2015 Butte fire” disclosed in PGE’s first 

quarter 2019 report.

(Debtors’ Claims Estimation) 6/27/2019

The Debtors have produced, and 

will produce, documents 

responsive to other properly 

served Requests that are also 

responsive to this Request. 

However, the Debtors do not 

believe they have an obligation to 

produce documents merely 

because they were produced to 

the SEC. The Debtors have 

requested the TCC explain why 

this Request is appropriate. The 

TCC is yet to respond.

Outstanding Documents Covered by the May 28, 2019 Order [Dkt. No. 2255]

9

All formal reports prepared by or at the 

request of any special litigation 

committee or committee of the Board of 

the Debtors, or any investigation or audit 

team including without limitation all 

formal audit committee reports on the 

Relevant Subjects and the wildfires that 

occurred during the 2017 and 2018 

wildfire seasons. [Dkt. No. 2255 ¶ 5.] 3/8/2019

The Debtors have not located any

responsive, non-privileged 

documents after a reasonable 

search.

10

All formal investigation reports prepared 

by the Debtors’ counsel, auditors or 

investigators on the Relevant Subjects 

and the wildfires that occurred during the 

2017 and 2018 wildfire seasons. [Dkt. 

No. 2255 ¶ 6] 3/8/2019

The Debtors have not located any

responsive, non-privileged 

documents after a reasonable 

search.

11

All ratifications of the Company’s 

officers’ and directors’ actions granted 

during the applicable period. [Dkt. No. 

2255 ¶ 7] 3/8/2019

The Debtors have not located any

responsive, non-privileged 

documents after a reasonable 

search.

12

Agreements between PG&E and third 

party contractors who worked on the 

Caribou-Palermo Line. [Dkt. Nos. 2255 

¶ 1 and 3205] 4/29/2019

The Debtors have produced all 

responsive documents located 

after a reasonable search. 

13

Agreements between PG&E and third 

party contractors who inspected the CHook on Tower 27/222. [Dkt. Nos. 2255 

¶ 1 and 3205] 4/29/2019

The Debtors have not identified

any Third Party Contractors who 

performed electrical inspections 

on Tower 27/222 between 

January 1, 2009 and November 8, 

2018, the agreed upon time period 

for this request. There are, 

therefore, no documents to 

produce. 

Case: 19-30088 Doc# 3371 Filed: 08/05/19 Entered: 08/05/19 11:54:12 Page 6 of

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

14

Documents describing the scope of the 

third party contractors’ services related 

to the Caribou-Palermo Line. [Dkt. Nos. 

2255 ¶ 1and 3205] 4/29/2019

In response to this request, the 

Debtors produced contracts 

between Third Party Contractors 

and PG&E describing the scope 

of the Third Party Contractors’

services related to the CaribouPalermo Line. The Debtors have 

not located any other responsive 

documents after a reasonable 

search.

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Documents describing the work 

performed by third party contractors on 

the Caribou-Palermo Line. [Dkt. Nos. 

2255 ¶ 1 and 3205] 4/29/2019

In response to this request, the 

Debtors produced contracts 

between Third Party Contractors 

and PG&E describing the work 

performed by the Third Party 

Contractors related to the 

Caribou-Palermo Line. The 

Debtors have not located any 

other responsive documents after 

a reasonable search.

16

Documents containing the findings or 

work product of all third party 

contractors performing work on the 

Caribou-Palermo Line, including Risk 

Assessments. [Dkt. Nos. 2255 ¶ 1 and 

3205] 4/29/2019

In response to this request, the 

Debtors produced vegetation 

management records from Third 

Party Contractors who performed 

vegetation management from 

2012 to November 8, 2018. The 

Debtors’ position is that 

producing vegetation 

management records from prior to 

2012 is unduly burdensome and 

such documents are not relevant 

to the TCC’s claims. The 

Debtors have not located any 

other responsive documents after 

a reasonable search. 

17

All insurance policies that provide 

coverage for claims arising from the 

work of third party contractors who 

performed work on the Caribou-Palermo 

Line. [Dkt. Nos. 2255 ¶ 1 and 3205] 4/29/2019

There are no such insurance 

policies in the Debtors’ 

possession located after a 

reasonable search. 

18

Inspection reports relating to work 

performed on Tower 27/222 by third 

party contractors. [Dkt. Nos. 2255 ¶ 1 

and 3205] 4/29/2019

The Debtors have produced all 

responsive documents located 

after a reasonable search, to the 

extent any such documents exist. 

19

Each writing which documents any 

inspection performed of Tower 27/222 

on the Caribou-Palermo Line. [Dkt. Nos. 

2255 ¶ 1 and 3205] 4/29/2019

The Debtors have produced all 

responsive documents located 

after a reasonable search, to the 

extent any such documents exist. 

Case: 19-30088 Doc# 3371 Filed: 08/05/19 Entered: 08/05/19 11:54:12 Page 7 of

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

20

Each writing which sets forth the result 

of any inspection performed on Tower 

22/227 at any time from January 1, 2009 

to and including April 24, 2019 by any 

third-party contractor performing work 

on the Caribou-Palermo Line. [Dkt. Nos. 

2255 ¶ 1 and 3205] 4/29/2019

The Debtors have produced all 

responsive documents located 

after a reasonable search, to the 

extent any such documents exist. 

21

Insurance policies or other proof of 

coverage provided by any third-party 

contractor that performed any Vegetation 

Management or Electrical Services for 

each of the Northern California 

Wildfires. [Dkt. Nos. 2255 ¶ 1 and 3205] 4/29/2019

The Debtors have produced all 

responsive documents located 

after a reasonable search.

22

All audit committee directives to 

directors and officers directing them to 

take action or correct matters relating to 

dividends, wildfire claims, wildfire 

safety. [Dkt. No. 2504] 3/8/2019

The TCC incorrectly cites to 

Docket No. 2504; this request

corresponds to Request 18 of 

Exhibit C to the TCC’s April 30, 

2019 letter to the Court.

The Debtors have not located any

responsive, non-privileged 

documents after a reasonable 

search.

23

All notifications to insurers for claims 

threatened or asserted against Directors 

& Officers and the Debtors for the 2014-

2019 policy periods, including notices 

and tenders of claims. [Dkt. No. 2504] 3/8/2019

The TCC incorrectly cites to 

Docket No. 2504; this request 

corresponds to Request 16 of 

Exhibit C to the TCC’s April 30, 

2019 letter to the Court. The 

TCC also misstates the scope of 

the request. Request 16 of 

Exhibit C seeks “all notifications 

to insurers of claims threatened or 

asserted against the Company or 

its directors and officers during 

the applicable period [Jan 29, 

2016 – May 28, 2019] . . . that 

relate to dividends, wildfire 

claims, wildfire safety, and 

insider transactions.”

The Debtors have produced all 

documents located after a 

reasonable search.

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

24

All reports that address misuse of funds 

or Company property by Company 

directors and officers. [Dkt. No. 2504] 3/8/2019

The TCC incorrectly cites to 

Docket No. 2504; this request

corresponds to Request 13 of 

Exhibit C to the TCC’s April 30, 

2019 letter to the Court.

The Debtors have not located any

responsive, non-privileged 

documents after a reasonable 

search.

25

Any non-public report that summarizes 

trades of the Company’s stock during the 

applicable period by the Company’s 

directors or officers. [Dkt. No. 2504] 3/8/2019

The TCC incorrectly cites to 

Docket No. 2504; this request 

corresponds to Request 23 of 

Exhibit C to the TCC’s April 30, 

2019 letter to the Court.

The Debtors have not located any

responsive, non-privileged 

documents after a reasonable 

search.

Outstanding Documents Covered by the June 12, 2019 Order [Dkt. No. 2504]

26

All Punitive Damage Liability Policies 

for 2015 [Dkt. No. 2504] 6/7/2019

The Debtors will produce any 

outstanding documents by August 

9, 2019. 

27

All Errors & Omissions Policies for 

2015-2019 [Dkt. No. 2504] 6/7/2019

To the extent these documents are 

responsive to the TCC’s request 

for “copies of insurance policies . 

. . that have provided or may 

provide coverage for any claim 

against the Debtors arising from 

or concerning the Northern 

California Wildfires” or “the 

Ghost Ship Fire”, the Debtors 

provided the TCC with such 

policies on June 27, 2019.

28

All Property Insurance Policies for 2015-

2019 [Dkt. No. 2504] 6/7/2019

The Debtors do not believe these 

documents are responsive to the 

TCC’s request for “copies of 

insurance policies . . . that have 

provided or may provide 

coverage for any claim against 

the Debtors arising from or 

concerning the Northern 

California Wildfires” or “the 

Ghost Ship Fire”.

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

29

All Environmental Insurance Policies for 

2015-2019 [Dkt. No. 2504] 6/7/2019

To the extent these documents are 

responsive to the TCC’s request 

for “copies of insurance policies . 

. . that have provided or may 

provide coverage for any claim 

against the Debtors arising from 

or concerning the Northern 

California Wildfires” or “the 

Ghost Ship Fire”, the Debtors 

provided the TCC with such 

policies on June 27, 2019.

30

All Products Liability Policies for 2015-

2019 [Dkt. No. 2504] 6/7/2019

To the extent these documents are 

responsive to the TCC’s request 

for “copies of insurance policies . 

. . that have provided or may 

provide coverage for any claim 

against the Debtors arising from 

or concerning the Northern 

California Wildfires” or “the 

Ghost Ship Fire”, the Debtors 

provided the TCC with such 

policies on June 27, 2019.

31

All Fiduciary Liability Policies for 2015-

2019 [Dkt. No. 2504] 6/7/2019

The Debtors do not believe these 

documents are responsive to the 

TCC’s request for “copies of 

insurance policies . . . that have 

provided or may provide 

coverage for any claim against 

the Debtors arising from or 

concerning the Northern 

California Wildfires” or “the 

Ghost Ship Fire”.

322

PG&E 2015-16 General Liability Policy: 

Ace Bermuda Ins. Ltd., Policy No. PCG1035/5 (full policy not produced) [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

33

PG&E 2015-16 General Liability Policy: 

AIG Excess Limited, Policy No. 

26157606 (full policy not produced) 

[Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

34

PG&E 2015-16 General Liability Policy: 

AIG Excess Limited (formerly Starr 

Excess), Policy No. 200682 (full policy 

not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

 

2 With respect to requests 32-68, the TCC did not inform the Debtors of any specific deficiencies in the 

Debtors’ production until prior to its August 1, 2019, filing with the Court. The Debtors require further clarification 

from the TCC as to why they believe the insurance policies produced in response to these requests are incomplete

and are prepared to meet and confer with the TCC on this issue. 

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

35

PG&E 2015-16 General Liability Policy: 

Apollo Consortium, Policy No. 

15NL5257490 (full policy not produced) 

[Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

36

PG&E 2015-16 General Liability Policy: 

Argo Re, Policy No. ARGO-CAS-OR000398 (full policy not produced) [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

37

PG&E 2015-16 General Liability Policy: 

Argo Re Limited, Policy No. ARGOCAS-OR-000594 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

38

PG&E 2015-16 General Liability Policy: 

Argo Re Limited, Policy No. ARGOCAS-OR-000106 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

39

PG&E 2015-16 General Liability Policy: 

Argo Re Limited, Policy No. ARGOCAS-OR-000690 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

40

PG&E 2015-16 General Liability Policy: 

AW AC, Policy No. C015037 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

41

PG&E 2015-16 General Liability Policy: 

Canopius Bermuda, Policy No. PGE005/004 (full policy not produced) [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

42

PG&E 2015-16 General Liability Policy: 

Iron Starr, Policy No. 1S0000624 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

43

PG&E 2015-16 General Liability Policy: 

Iron Starr, Policy No. 0000050-00 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

44

PG&E 2015-16 General Liability Policy: 

Iron Starr, Policy No. IS0001954 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

45

PG&E 2015-16 General Liability Policy: 

Markel Bermuda Ltd. (MaxBermuda), 

Policy No. 29692-3176-UMB-2009 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

46

PG&E 2015-16 General Liability Policy: 

OCIL, Policy No. U920021-0804 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

Case: 19-30088 Doc# 3371 Filed: 08/05/19 Entered: 08/05/19 11:54:12 Page 11

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

47

PG&E 2016-2017 General Liability 

Policy: Canopius, Policy No. PGE005/00 [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

48

PG&E 2016-17 General Liability Policy: 

Argo Re, Policy No. ARGO-CAS-OR000398 (full policy not produced) [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

49

PG&E 2016-17 General Liability Policy: 

Argo Re, Policy No. ARGO-CAS-OR000594 (full policy not produced) [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

50

PG&E 2016-17 General Liability Policy: 

Liberty, Policy No. DL473806 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

51

PG&E 2016-17 General Liability Policy: 

Apollo Consortium, Policy No. 

DL638514 (full policy not produced) 

[Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

52

PG&E 2016-17 General Liability Policy: 

Munich Re, Policy No. EI291315 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

53

PG&E 2016-17 General Liability Policy: 

AXIS US, Policy No. 

EAU742127/01/2015 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

54

PG&E 2016-17 General Liability Policy: 

Argo Re, Policy No. ARGO-CAS-OR000106 (full policy not produced) [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

55

PG&E 2016-17 General Liability Policy: 

Argo Re, Policy No. ARGO-CAS-OR000690 (full policy not produced) [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

56

PG&E 2016-17 General Liability Policy: 

Iron Starr Excess Agency Ltd., Policy 

No. IS0002821 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

57

PG&E 2016-17 Punitive Liability 

Policy: Mana Carta Insurance, Ltd, 

Policy No. MCPD203305 [Dkt. No. 

2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

58

PG&E 2016-17 Punitive Liability 

Policy: Mana Carta Insurance, Ltd, 

Policy No. MCPD203306 [Dkt. No. 

2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

Case: 19-30088 Doc# 3371 Filed: 08/05/19 Entered: 08/05/19 11:54:12 Page 12

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

59

PG&E 2016-17 Punitive Liability 

Policy: Mana Carta Insurance, Ltd, 

Policy No. MCPD203309 [Dkt. No. 

2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

60

PG&E 2017-2018 General Liability 

Policy: American International 

Reinsurance, Policy No. 200682 [Dkt. 

No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

61

PG&E 2017-2018 General Liability 

Policy: Allied World Assurance 

Company Ltd, Policy No. C015037 (full 

policy not produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

62

PG&E 2017-2018 General Liability 

Policy: Argo Re, Policy No. ARGOCAS-OR-000398 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

63

PG&E 2017-2018 General Liability 

Policy: Apollo (Lloyds), Policy No. 

B0509BOWCN1500003 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

64

PG&E 2017-2018 General Liability 

Policy: Iron Starr Excess Agency Ltd., 

Policy No. IS0002821 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

65

PG&E 2017-2018 General Liability 

Policy: OCIL, Policy No. U920021-0804 

(full policy not produced) [Dkt. No. 

2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

66

PG&E 2018-2019 General Liability 

Policy: Apollo (Lloyds), Policy No. PL 

1800075 [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

67

PG&E 2018-2019 General Liability 

Policy: Inter Hannover (Lloyds), Policy 

No. BOWCN1500033 (full policy not 

produced) [Dkt. No. 2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

68

PG&E 2018-2019 General Liability 

Policy: Allianz Global Corporate & 

Specialty SE, Policy No. PL1800076 

(full policy not produced) [Dkt. No. 

2504] 6/7/2019

The Debtors produced this policy 

on June 27, 2019. The Debtors 

need further information about 

what is missing. 

Other Outstanding Documents

69

All PG&E Director & Officer Liability 

Policies for 2014-15.

(The TCC desires assignment of 

Debtors’ litigation assets to tort 

resolution trust under plan, i.e., the pot. 

Documents necessary to value litigation 

asset (“Assigned Asset”).) 3/5/2019

The Debtors do not believe that 

policies from 2014 are relevant to 

these Chapter 11 Cases.

Case: 19-30088 Doc# 3371 Filed: 08/05/19 Entered: 08/05/19 11:54:12 Page 13

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No.

Outstanding Documents per TCC 

Submission

Date 

Requested Debtors’ Response

70

All PG&E Director & Officer Liability 

Policies for 2016-17

(Assigned Asset) 3/5/2019

The Debtors will produce any 

outstanding documents by August 

9, 2019. 

The Debtors’ responses to each of the Subrogation Group’s requests included in 

their filing (Dkt. No. 3352) are below. 

Outstanding Documents Per 

Subrogation Group Response

Date 

Requested Debtors’ Response

1

Non-destructive examination of PG&E 

equipment and other evidence collected in 

connection with the 2017 and 2018 

wildfires, including near any potential 

area(s) of origin. 7/1/2019

The Debtors have explained to 

the Subrogation Group that they 

agree with this request and that 

similar testing should be 

conducted of evidence in the 

possession of the subrogation 

group and/or any third parties. 

2

Non-destructive examination of evidence 

in CAL FIRE’s possession and depositions 

of appropriate CAL FIRE investigators 

and representatives. 7/1/2019

The Debtors have explained to 

the Subrogation Group that they 

agree with this request. 

3

Documents relating to PG&E’s policies 

and practices regarding de-energizing 

power in certain weather conditions and 

vegetation management. 7/1/2019

The Debtors have explained to 

the Subrogation Group that they 

are willing to agree to 

reasonable discovery in the 

context of estimation 

proceedings on these topics. 

4

Depositions of PG&E representatives who 

were not deposed on relevant issues prepetition. 7/1/2019

The Debtors have explained to 

the Subrogation Group that they 

are willing to agree to 

reasonable discovery in the 

context of estimation 

proceedings on relevant issues. 

5

Documents sent by PG&E to the CPUC 

regarding the Caribou-Palermo 115kV

transmission line (Camp Fire). 7/1/2019

The Debtors have explained to 

the Subrogation Group that they 

are willing to agree to 

reasonable discovery in the 

context of estimation 

proceedings on relevant issues. 

6

Documents regarding the Caribou-Palermo 

115kV transmission line 10 miles on either 

side of transmission tower 27/222 (Camp 

Fire). 7/1/2019

The Debtors have explained to 

the Subrogation Group that they 

are willing to agree to 

reasonable discovery in the 

context of estimation 

proceedings on relevant issues. 

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28

Outstanding Documents Per 

Subrogation Group Response

Date 

Requested Debtors’ Response

7

Documents concerning the tap line on 

Zink Hill, including vegetation 

management in or around the same (Tubbs 

Fire). 7/1/2019

The Debtors have explained to 

the Subrogation Group that they 

are willing to agree to 

reasonable discovery in the 

context of estimation 

proceedings on relevant issues. 

8

Documents or information that support 

estimates or projections of wildfire claim 

amounts as set forth in public and court 

filings by the Debtors. 7/1/2019

The Debtors have produced all 

non-privileged documents on 

this topic in response to the 

TCC’s requests. 

Dated: August 5, 2019

 WEIL, GOTSHAL & MANGES LLP

 CRAVATH, SWAINE & MOORE LLP

 KELLER & BENVENUTTI LLP

 /s/Kevin J. Orsini

 Kevin J. Orsini 

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 3371 Filed: 08/05/19 Entered: 08/05/19 11:54:12 Page 15

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