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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.shrock@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

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

ORDER FOLLOWING DISCOVERY 

CONFERENCE HELD MAY 8, 2019 RE (I) EX 

PARTE APPLICATION OF THE TORT 

CLAIMANTS COMMITTEE PURSUANT TO 

FED. R. BANKR. P. 2004 FOR ORDERS 

AUTHORIZING PRODUCTION OF 

DOCUMENTS, AND (II) INFORMAL 

DISCOVERY LETTERS 

 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). 

Signed and Filed: May 28, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

May 28, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 2255 Filed: 05/28/19 Entered: 05/28/19 17:14:47 Page 1 of

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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”), and the Official 

Committee of Tort Claimants (the “TCC”), appeared before this Court on May 8, 2019 for a discovery 

conference (the “Discovery Conference”) to discuss (i) the Ex Parte Application of the TCC Pursuant 

to Bankruptcy Rule 2004 for Orders Authorizing Production of Documents dated April 30, 2019 (the 

“2004 Application”), and (ii) informal discovery correspondence submitted to the Court by the parties 

including (a) the TCC’s letter to the Court dated April 30, 2019 regarding the TCC’s request for the 

Debtors to produce certain “management-related” documents (the “TCC Letter”), and (b) the 

Debtors’ letter to the Court dated May 6, 2019 setting forth their positions in response to both the 

Application and the TCC Letter (the “Debtors’ Response Letter”). Appearances of counsel were as 

stated on the record. 

Having considered the 2004 Application, the correspondence submitted by the parties, and the 

arguments at the hearing, 

IT IS HEREBY ORDERED THAT: 

1. The TCC’s 2004 Application is granted to the extent set forth herein. The Debtors and 

the TCC reached agreement on Requests 1 through 24 and Request 25 (a), (b) and (f) of the 2004 

Application without intervention of the Court. With respect to Request 25(c), (d), (e), (g) and (h) 

listed in Attachment A to the 2004 Application, the Debtors have agreed and are directed to produce 

to the TCC, to the extent non-privileged documents exist and are located after a reasonable search, 

non-privileged documents in response to these Requests from 2009 to November 8, 2018. 

2. The Debtors are directed to produce to the TCC, to the extent non-privileged documents 

exist and are located after a reasonable search, the following non-privileged documents in response to 

Request 4 listed in Exhibit C to the TCC Letter: non-privileged board packages and board meeting 

agendas delivered to the Debtors’ Boards of Directors for board meetings scheduled to occur during 

the three year period preceding the bankruptcy filing, January 29, 2016 through January 29, 2019, and 

the post-bankruptcy filing period of time through the date of this Order (the “Applicable Period”), on 

the following subjects: (i) the payment of dividends to holders of equity of PG&E Corp., (ii) the 

payment of severance to the Debtors’ former CEO Geisha Williams, and (iii) the payment of severance 

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to senior officers to which Section 16 of the Securities Exchange Act would apply and to directors of 

the Board of Directors of PG&E Corp. or of the Utility ((i)-(iii) collectively, the “Relevant Subjects”). 

3. The Debtors are directed to produce to the TCC, to the extent non-privileged documents 

exist and are located after a reasonable search, the following non-privileged documents in response to 

Request 5 listed in Exhibit C to the TCC Letter: the Debtors’ Board of Directors Minute Book, 

including minutes of board of director meetings, resolutions and unanimous consents prepared or 

signed during the Applicable Period on the Relevant Subjects. 

4. The Debtors are directed to produce to the TCC, to the extent non-privileged documents 

exist and are located after a reasonable search, the following non-privileged documents in response to 

Request 10 listed in Exhibit C to the TCC Letter: the Debtors’ minutes and summaries of meetings, 

discussions and resolutions of the Debtors’ and the Board of Directors’ respective committees, 

including without limitation the audit and compensation committee meetings, during the Applicable 

Period on the Relevant Subjects. 

5. The Debtors are directed to produce to the TCC, to the extent non-privileged documents 

exist and are located after a reasonable search, the following non-privileged documents in response to 

Request 11 listed in Exhibit C to the TCC Letter: 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. 

6. The Debtors are directed to produce to the TCC, to the extent non-privileged documents 

exist and are located after a reasonable search, the following non-privileged documents in response to 

Request 12 listed in Exhibit C to the TCC Letter: 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. 

7. The Debtors are directed to produce to the TCC, to the extent non-privileged documents 

exist and are located after a reasonable search, the following non-privileged documents in response to 

Request 26 listed in Exhibit C to the TCC Letter: all ratifications of the Debtors’ officers and 

directors’ actions, granted in the Applicable Period on the Relevant Subjects. 

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8. The Debtors are directed to provide the TCC with a draft Protective Order on or before 

May 17, 2019. 

APPROVED AS TO FORM AND CONTENT: 

Dated: May 28, 2019

BAKER & HOSTETLER LLP 

/s/ Robert Julian

Robert Julian 

Attorneys for Official Committee of Tort Claimants

** END OF ORDER ** 

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