Eric R. Goodman 

direct dial: 216.861.7418 

egoodman@bakerlaw.com 

 

July 22, 2019 

The Honorable Dennis Montali 

U.S. Bankruptcy Court for the 

 Northern District of California 

Phillip Burton Federal Building 

 and U.S. Courthouse 

Courtroom 17, 16th Floor 

450 Golden Gate Avenue 

San Francisco, CA 94102 

Re: In re PG&E Corporation and Pacific Gas & Electric Company

Case No. 19-30088 (DM) 

Dear Judge Montali: 

We write regarding a matter of concern to the Official Committee of Tort Claimants (the “TCC”) 

in the cases of PG&E Corporation and Pacific Gas & Electric Company (the “Debtors”). 

On July 1, 2019, the Court entered an order (i) establishing October 21, 2019 as the bar date for 

filing proofs of claim, (ii) approving notices thereof and multiple claim forms, and (iii) authorizing 

the Debtors to implement their noticing plan (Dkt. No. 2806) (the “Bar Date Order”). Pursuant to 

the Bar Date Order, the Debtors have mailed notices of the bar date to claimants. 

The TCC has observed certain anomalies regarding the implementation of the Debtors’ notice plan. 

For example, the TCC has observed instances where represented Fire Claimants have received the 

Standard Bar Date Notice and the Standard Proof of Claim Form, law firms have received notices 

and claim forms for Fire Claimants represented by other law firms, and law firms have received a 

number of notices that exceeds the number of Fire Claimants they represent. The Debtors have 

confirmed that 242 Ghost Ship claimants were originally served with the Standard Bar Date Notice 

and the Standard Proof of Claim Form and then later served with the Fire Claim Bar Date Notice 

and the Fire Claimant Proof of Claim. 

The TCC has brought these and other noticing-related matters to the Debtors’ attention. The 

Debtors have agreed to provide specific information to the TCC regarding the bar date mailing in 

BakerHostetler 

Atlanta Chicago 

Houston Los Angeles 

Cincinnati 

New York 

Cleveland Columbus 

Orlando Philadelphia 

Baker & Hostetler LLP 

Key Tower 

127 Public Square, Suite 2000 

Cleveland, OH 441 14- 1214 

T 216.621.0200 

F 216.696 .0740 

www.baker1aw.com 

Costa Mesa Denver 

Seattle Washington, DC 

Case: 19-30088 Doc# 3131 Filed: 07/22/19 Entered: 07/22/19 16:07:19 Page 1 of

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July 22, 2019 

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response to the TCC’s inquiries. The Debtors have informed the TCC that upon the completion 

of the bar date mailing, the Debtors will provide the TCC with the list of notice parties that were 

served with the Fire Claim Bar Date Notice and the Fire Claimant Proof of Claim, which list will 

also identify those parties that were also served with the Standard Bar Date Notice and the Standard 

Proof of Claim Form and, where applicable, the names and address of the law firms that represent 

such parties. The Debtors have informed the TCC that they will be in a position to provide this 

list by Tuesday, July 23, 2019. 

The Debtors have further agreed to make additional information available to the TCC regarding 

the service of the bar date notices, including customer information on a confidential basis pursuant 

to the recently entered protective order (Dkt. No. 2807). Subject to the implementation of 

appropriate security measures, the Debtors have informed the TCC that they anticipate being able 

to provide access to this information by Friday, July 26, 2019.

The TCC is attempting to resolve the foregoing matters and ensure that the Debtors’ noticing plan 

is implemented in accordance with the Bar Date Order. The TCC is not filing a motion or 

requesting a status conference regarding these matters at this time but is writing to bring these 

matters to the Court’s attention should further action be necessary after the TCC has completed its 

review of the information provided by the Debtors. 

Respectfully, 

/s/ Eric Goodman 

Eric Goodman 

Counsel for the Official Committee of Tort Claimants 

cc: Stephen Karotkin (stephen.karotkin@weil.com) 

 Matthew Goren (matthew.goren@weil.com) 

 Thomas Kreller (tkreller@milbank.com) 

 Andrew Leblanc (aleblanc@milbank.com) 

 Matthew Feldman (mfeldman@wilkie.com) 

 Benjamin McCallen (bmccallen@wilkie.com) 

 Timothy Laffredi (timothy.s.laffredi@usdoj.gov) 

 Robert Julian (rjulian@bakerlaw.com) 

 Cecily Dumas (cdumas@bakerlaw.com) 

 Karen Lockhart 

Case: 19-30088 Doc# 3131 Filed: 07/22/19 Entered: 07/22/19 16:07:19 Page 2 of

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