Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Exhibit B

Objection Summary Chart

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Page 1

of 9
OBJECTION RESPONSE 

Burden of Proof 1. The Debtors are seeking to 

improperly shift the initial burden of proof to claimants by requiring them to answer numerous / confusing questions in the proposed Wildfire Proof of Claim Forms and submit onerous supporting documentation. Interested Paradise Parties Objection [Dkt. No. 2240] at 13:6-12; 15; 1-10. Individual Fire Victims Objection [Dkt. No. 2242] at 8:19-9:9. SLF Fire Victim Objection [Dkt. No. 2248] at 3:11-17. TCC Objection [Dkt. No. 2306] at 18:20-19:5. 

The Debtors believe their procedures, as original proposed in the Bar Dimproperly shift the initial burden of proof to claimants and believe the proposed in their Wildfire Proof of Claim Forms is reasonable, straightfway burdensome. Notwithstanding this, as set forth in the Reply, the Dto adopt the TCC’s summary Wildfire Claimant Proof of Claim Form. SRevised Bar Date Order. In addition, the Debtors have reached an agreeHoc Subrogation Group on the Wildfire Subrogation Proof of Claim Fothe Revised Bar Date Order. Furthermore, in addition to adding clarifyiRevised Bar Date Order making clear that Claimants need only submit “the information” requested in the applicable Proof of Claim Forms, the Dthe language below to the Revised Bar Date Order and related notices. 

Debtors believe these Objections have been resolved. “Notwithstanding anything herein to the contrary, any claimant that tim

Claim and makes a good faith effort to complete the appropriate form as shall be permitted to revise, amend, and/or supplement their applicable Pto the extent permitted by applicable law until such time as their claim idisallowed by order of the Court.” See Revised Bar Date Order, at ¶4. 

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9
2. The Debtors’ proposed Notice 

Procedures impose unnecessary burdens by requiring Wildfire Claimants to re-file claims previously filed utilizing the Standard Form 410 with the applicable Wildfire Proof of Claim Forms. Interested Paradise Parties Objection [Dkt. No. 2240] at 15:6-12; 15; 1-10. U.S. Trustee Objection [Dkt. No. 2316] at 8: 10-21. TCC Objection [Dkt. No. 2306] at 18:20-19:5. 

As the Debtors have agreed to adopt the TCC’s summary Wildfire Claim

Form (see No. 1 above), the Debtors have removed the requirement from 

Procedures that Wildfire Claimants that have previously filed claims utiForm 410 re-file their claims utilizing the applicable Wildfire Proof of Cbelow). Accordingly, the Debtors believe these Objections have been re

“Any holder of a Wildfire Claim that has either (i) filed a lawsuit agains

to the Petition Date or (ii) filed a Proof of Claim in the Chapter 11 Caseof this Order, must submit the applicable Wildfire Proof of Claim FormWildfire Claim must file the applicable Wildfire must file a Proof of Clasuch claimant may be included in, or represented by, a purported class aclass Proof of Claim, or similar representative action filed against the Dto such claimant’s Wildfire Claim.” “The following persons or entities are not required to file a Proof of ClaBar Date, solely with respect to the claims described below: 

(6) any person or entity (other than the holder of a Wildfire Claim) 

filed a Proof of Claim with Prime Clerk against the Debtors wiclaim being asserted, utilizing a claim form that substantially c

Standard Proof of Claim Form or Official Form No. 410;” 

See Revised Bar Date Order, at ¶¶ 3(e), 3(o)(6). 

3. The Debtors are impermissibly 

seeking, pursuant to the Bar Date Order, to automatically discharge claims that fail to fully comply with the proposed Notice Procedures. 

As set forth above, the Debtors have agreed to adopt the TCC’s summarProof of Claim Form (see No. 1 above). Moreover, in addition to the ain No.1 above, the Debtors have removed the language below from the Order. Accordingly, the Debtors believe these Objections have been res

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9
California State Agencies 

Objection [Dkt. No. 2307] at 4:11-25. U.S. Trustee Objection [Dkt. No. 2316] at 18: 25-26. 

Pursuant to Bankruptcy Rule 3003(c)(2), but subject to Paragraph 4 of tof claims, including Wildfire Claimants, Wildfire Subrogation Claimantthat fail to comply with this Order by timely filing a Proof of Claim in tshall (i) be forever barred, estopped, and enjoined from asserting such cDebtors, their property, or their estates (or submitting a Proof of Claim wand (ii) accordance with this Order shall not be treated as a creditor with claim (as defined in section 101(5) of the Bankruptcy Code) for the purpdistribution with respect to any chapter 11 plan or plans of reorganizatioin these Chapter 11 Cases. See Revised Bar Date Order, at ¶7. 

Future Injuries 4. The Debtors should adequately 

explain how future harm claims will be handled; The Debtors must clarify that a prepetition claim is defined as a claim based on date of injury only. Sonoma Clean Power Objection [Dkt. No. 2321] at 26:4-8. California State Agencies Objection [Dkt. No. 2307] at 3:4-7. 

The Debtors have added the language below to the Revised Bar Date Or

only claims that relate to the prepetition period are subject to the Bar DaOrder. Accordingly, the Debtors believe these Objections have been resextent they remain outstanding, they should be overruled. “The following persons or entities are not required to file a Proof of Cla

Bar Date, solely with respect to the claims described below: 

(12) any person or entity who holds a claim for personal injury or p

solely to the extent that such claim arises from an event that oc29, 2019.” 

See Revised Bar Date Order, at ¶3(o)(12). 

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9
Confidentiality and Sealing Objections 

5. The Debtors’ proposal to treat 

all information submitted in connection with the Wildfire Proof of Claim Forms as confidential is not appropriate. 

U.S. Trustee [Dkt. No. 2316] at 8:10-21. 

This Objection remains outstanding and is addressed in the Debtors’ Re

11-12. In light of the sensitive nature of the claims and the damages assbelieve this procedure is appropriate and similar procedures have previoin other chapter 11 cases. See USA Gymnastics, Case No. 18-09108 (Ba25, 2019) [Dkt. No. 301]; In re Archdiocese of Milwaukee, Case No. 11

E.D. Wisc. July 14, 2011) [Dkt. No. 331]; In re Roman Catholic Bishop 

Montana, Case No. 17-60271 (Bankr. D. MT June 6, 2016) [Dkt. No. 12

for the reasons set forth in the Reply, this Objection should be overruledSee Reply, at 11-12. 

6. Wildfire Claimants must not be 

required to provide irrelevant personal information such as their driver’s license numbers. U.S. Trustee Objection [Dkt. 2316] at 5:12-27. 

As the Debtors have agreed to adopt the TCC’s summary Wildfire ClaimForm (see No. 1 above), the Debtors believe this Objection has been res

See Revised Bar Date Order, at Ex. A-2. 

7. Claims submitted by the 

United States and any State California Agency should be exempt from the Debtors’ proposed confidential treatment of Wildfire Claims. In addition, any 

The Debtors have added the language below to the Revised Bar Date Or

issues. Accordingly, the Debtors believe these Objections have been re

Notwithstanding anything herein to the contrary, for purposes of this OrClaims shall not include any claims of any Governmental Unit of the St(each, a “California State Agency”) related to or in any way arising fro

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9
California State Agency 

submitting a claim relating to the Northern California Wildfires should not be required to file a Wildfire Claimant Proof of Claim Form. California State Agencies Objection [Dkt. No. 2307] at 3: 4-17; 7:18-21. 

California Wildfires, (ii) no California State Agency shall be included aClaimant, and (iii) the claims of any California State Agency may be suStandard Proof of Claim Form in accordance with the procedures set forotherwise applicable law.Except with respect to any Wildfire Proof of Claim Forms submitted by and any California State Agency, the supporting documentation submittwith Wildfire Proof of Claim Forms (including any individual claim infsubsequently submitted by any Wildfire Subrogation Claimant to Prime confidential in these Chapter 11 Cases and shall not be made available tpublic. Copies of such information shall be provided on a confidential aeyes only basis to counsel for the Debtors, the Committees, the U.S. Truadditional parties the Court directs but only after each such party agrees information provided in the Wildfire Proof of Claim Forms confidentialSee Revised Bar Date Order, at ¶¶ 5, 6. 

Class Proofs of Claims 8. The Debtors are seeking to 

improperly litigate the propriety of class proofs of claims in the Bar Date Motion Interested Paradise Parties Objection [Dkt. No. 2240] at 17:1-6. 

The Debtors are not seeking to litigate the propriety or allowance of clathe Bar Date Order. The Bar Date Motion does not request any action bCourt with respect to class proofs of claim. The proposed Bar Date NotWildfire Claimants that they should file Proofs of Claim. Accordingly, Objection remains outstanding it should be overruled. See Revised Bar Date Order, at ¶3(e). 

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9
Proposed Bar Date 

9. The Debtors’ proposed 95-Day 

Bar Date is insufficient and should be extended. SLF Objection [Dkt. No. 2248] at 6:9-11. TCC Objection [Dkt. No. 2306] at 29:9-10. 

These Objections remain outstanding and are addressed in the Debtors’ 9-11. The Debtors’ proposed notice period of approximately ninety-fivonly consistent with but largely exceeds the notice periods provided cla

asbestos mass tort cases. See In re TK Holdings, Inc., Case No. 17-1137Del. 2017) (approving 79-day bar date notice period for individuals asse

injury, wrongful death, or property damage that resulted from defective re Blitz U.S.S., Inc., Case No. 11-13603 (PJW) (Bankr. D. Del. 2011) [D(approving 61-day bar date notice period for personal injury claims that defective gasoline cans); In re Exide Techs., Case No. 02-11125 (KJC) 2002) [Dkt. No. 1989] (approving 52-day bar date notice period for persproperty damage, and other claims relating to exposure to lead and othere Suntech Am., Inc., Case No. 15-10054 (CSS) (Bankr. D. Del. 2009) [(establishing 35-day bar date notice period for creditors, including produ

antitrust, breach of contract, and other commercial litigation claimants). the reasons set forth in the Reply, these Objections should be overruled. See Reply, at 9-11. 

Noticing Procedures 10. The list of Known Wildfire 

Claimants receiving direct notice is under-inclusive and the Debtors have not satisfied their burden of providing actual notice to all known Wildfire Claimants. 

The Debtors believe their Notice Procedures are reasonably calculated tnotice of the Bar Date to known and unknown claimants and more than 

requirements of due process of law. See Reply, at 12-20. Accordingly, forth in the Reply, this Objection should be overruled. See Reply, at 12-20, Finnegan Decl., at ¶26. 

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9
TCC Objection [Dkt. No. 

2306] at 24:2-11. 

11. The Debtors’ proposed 

Supplemental Notice Plan fails to satisfy due process with respect to their efforts to identify Unknown Wildfire Claimants. TCC Objection [Dkt. No. 2306] at 14:12-13. 

The Debtors believe their Supplemental Notice Plan is more than reasonprovide adequate notice of the Bar Date to known and unknown claiman

satisfies the requirements of due process of law. Notwithstanding this, iany concerns the TCC or any other parties may have with respect to the Notice Plan, the Debtors have included certain additional measures in thSupplemental Notice Plan, including, Over the Top TV, streaming radioadvertising. See Reply, at 19-20. Accordingly, for the reasons set forth Objection should be overruled. See Reply, at 19-20, Finnegan Decl., at ¶¶ 60-96.

Executory Contract and Rejection Damage Claims 12. The Debtors (i) must clarify 

what claims relate to the rejection of an executory contract, (ii) make clear that parties reserve the right to object to the designation of any contract or agreement as an executory contract in their Schedules, and (iii) should set an earlier deadline for resolving disputes as to the applicability of section 365 to “force of law contracts.” 

At the request of certain Objectors, the Debtors have added the languagRevised Bar Date Order to address these issues. The Debtors are not awrequirement to set an earlier deadline for the rejection of any executory as set forth in section 365 of the Bankruptcy Code. Accordingly, the DeObjections have been resolved but, to the extent they remain outstandin

overruled. “The following persons or entities are not required to file a Proof of Cla

Bar Date, solely with respect to the claims described below: 

(j) Any person or entity (including, without limitation, individuals

corporations, joint ventures, trusts, and Governmental Units) ththat arises from or relates to the rejection of an executory contr

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9
California State Agencies 

Objection [Dkt. No. 2307] at 3:23-25. Sonoma Clean Power Objection [Dkt. No. 2321] at 27:3-12. 

lease must file a Standard Proof of Claim Form based on such rof (i) the Bar Date, and (ii) the date that is thirty (30) days follothe Court order approving such rejection, (which order may be a chapter 11 plan in the Debtors’ Chapter 11 Cases) or be forevdoing so. 

(k) Notwithstanding the foregoing, a party to an executory contrac

that asserts a claim on account of unpaid amounts accrued and Petition Date pursuant to such executory contract or unexpired 

rejection damages claimclaim for damages that arises from or r

rejection of the executory contract or unexpired lease) must file Claim Form for such amounts on or before the Bar Date unless identified in paragraph (o) below applies.” 

 “Nothing contained in this Order shall constitute a waiver of the right ointerest to dispute the Debtors’ designation of any contract, program, poother document or agreement as an executory contract or unexpired leassection 365 of the Bankruptcy Code.” See Revised Bar Date Order, at ¶¶ 3(j)-(k), 16. 

Case: 19-30088 Doc# 2646-2 Filed: 06/19/19 Entered: 06/19/19 15:11:15 Pag

of 9