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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA 

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Exhibit A 

Proposed Order 

 

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA 

- 9 - 

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: 310.442.8875 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for 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) 

[PROPOSED] ORDER 

SUPPLEMENTING COMPENSATION 

PROCEDURES ORDER FOR 

RETENTION OF EXPERTS (DOC. NO. 

701) 

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ATTORNEYS AT LAW

SAN FRANCISCO, CA 

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Upon the Application, dated June 19, 2019, (the “Application”),2 of the Official 

Committee of Tort Claimants (the “TCC”) of PG&E Corporation and Pacific Gas and Electric 

Company (collectively, the “Debtors”) for an order supplementing the Order Pursuant to 11 

U.S.C. §§ 331 and 105(a) and Fed. R. Bankr. P. 2016 for Authority to Establish Procedures for 

Interim Compensation and Reimbursement of Expenses of Professionals (the “Compensation 

Procedures Order”) [Doc. No. 701] to provide for the TCC’s employment of experts (the 

“Experts”) and approving the compensation procedures in connection therewith; and this Court 

having jurisdiction to consider the Application and the relief requested therein pursuant to 28 

U.S.C. §§ 157 and 1334, Order Referring Bankruptcy Cases and Proceedings to Bankruptcy 

Judges, General Order 24 (N.D. Cal.), and Rule 5011-1(a) of the Bankruptcy Local Rules for the 

United States District Court for the Northern District of California (the “Bankruptcy Local 

Rules”); and consideration of the Application and the requested relief being a core proceeding 

pursuant to 28 U.S.C. § 157(b); and venue being proper before this Court pursuant to 28 U.S.C. 

§§ 1408 and 1409; and the Court having found and determined that notice of the Application as 

provided to the parties listed therein is reasonable and sufficient; and it appearing that no other or 

further notice need be provided; and this Court having reviewed the Application; and it appearing 

that the relief requested in the Application is in the best interests of the Debtors, their estates, 

creditors, shareholders, and all parties in interest; and upon all of the proceedings had before this 

Court and after due deliberation and sufficient cause appearing therefor, 

IT IS HEREBY ORDERED THAT: 

1. The Application is approved solely to the extent set forth herein. 

2. The Compensation Procedures Order is hereby amended to include the following: 

Expert Compensation Procedures: 

a) The TCC, UCC and Debtors are authorized to retain expert witnesses and consultants 

for the purposes of claims calculation, litigation and related matters, without need for 

further order of the Court, and the Debtors shall pay such fees and expenses pursuant 

to the Compensation Procedures Order and herein. 

 

2

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

Application. 

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ATTORNEYS AT LAW

SAN FRANCISCO, CA 

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b) Counsel for each of the TCC, UCC and Debtors will include the aggregate amount of 

each Expert’s monthly fees and expenses as a line item in each of their monthly fee 

statements. There shall be a separate line item for each Expert. The names of the 

Experts will be redacted to protect confidential information. 

c) Upon request, counsel for the TCC, UCC or Debtors, as applicable, will submit 

unredacted invoices to the U.S. Trustee and Fee Examiner. To the extent a dispute 

relating to any Expert invoice is presented to the Court, such invoice will be submitted 

under seal to the Court. All invoices so submitted will remain under seal and 

confidential and not made available to anyone without the consent of the TCC, UCC 

or Debtors, as applicable, or further order of the Court. 

d) The provisions of the Compensation Procedures Order governing payment of fee 

statements and fee applications will govern payment to the TCC, UCC, Debtors or their 

respective counsel for the Experts. 

3. Notwithstanding anything to the contrary herein, to the extent the Office of the 

United States Trustee and Fee Examiner object to any invoices of the Experts, the U.S. Trustee 

and Fee Examiner shall redact any discussion of the invoices (and shall not disclose the name of 

any Expert) in their objections and any invoices attached to the objections shall be submitted under 

seal. 

4. Notwithstanding anything to the contrary in the Application, or any engagement 

agreements, the Experts shall not seek reimbursement of any fees or costs arising from the defense 

of any of the Experts’ invoices submitted in these Cases. 

5. To the extent that there may be any inconsistency between the terms of the 

Application, any agreements retaining Experts, and this Order, the terms of this Order shall govern. 

6. Notwithstanding anything to the contrary in the Application or any agreement 

retaining any Expert, the Experts’ allowed compensation shall have the same priority as the 

allowed professional fees and expenses of professionals retained in the Cases. 

7. The relief granted herein shall be binding upon any chapter 11 trustee appointed in 

the Cases, or upon any chapter 7 trustee appointed in the event of a subsequent conversion of the 

Cases to cases under chapter 7. 

8. The TCC is authorized to take all steps necessary or appropriate to carry out this 

Order. 

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ATTORNEYS AT LAW

SAN FRANCISCO, CA 

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9. This Court shall retain jurisdiction to hear and determine all matters arising from 

or related to the implementation, interpretation, or enforcement of this Order. For the avoidance 

of doubt, notwithstanding any provision in any engagement agreement to the contrary, during the 

pendency of these Cases, this Court shall have exclusive jurisdiction over the approval of fees due 

and owing to the Experts. 

** END OF ORDER ** 

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