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EXHIBIT B 

AMENDED ORDER FOR TCC BAR DATE MOTION 

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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 Boulevard 

Suite 1400 

Los Angeles, CA 90025 

Telephone: 310.820.8800 

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) 

ORDER (I) ESTABLISHING A BAR 

DATE FOR FILING FIRE CLAIMS, 

(II) APPROVING THE FORM AND 

PROCEDURES FOR NOTICE OF THE 

BAR DATE FOR FIRE CLAIMS, AND 

(III) APPROVING SUPPLEMENTAL 

PROCEDURES FOR NOTICE OF THE 

BAR DATE TO FIRE CLAIMANTS 

Upon the Motion, dated May 31, 2019 (the “Motion”),1 of the Official Committee of Tort 

 

1

 Capitalized terms used but not otherwise defined herein shall have the meanings given to them in the Motion. The 

term “Fire Claim” shall have the meaning given to it in the Memorandum of Points and Authorities in Support of 

Motion of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. §§ 105(a) and 501 and Fed. R. Bankr. P. 

3001(a) for Entry of an Order Approving Proposed Model Proof of Claim Form and Fire Claims and Related 

Procedures (Dkt. No. 1825). The word “claim” shall refer to “claim” as defined in 11 U.S.C. § 101(5). 

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Claimants (the “TCC”), pursuant to sections 105(a), 501 of title 11 of the United States Code, 

Rules 3001(a), 3003(c), 5005 and 9007 of the Federal Rules of Bankruptcy Procedure and 

Rule 3003-1 of the Bankruptcy Local Rules for the United States District Court for the Northern 

District of California (the “Bankruptcy Local Rules”), for entry of an order (i) approving a 

separate bar date for Fire Claims, (ii) approving the form for notice of the bar date for Fire Claims 

and related procedures, and (iii) approving supplemental procedures for providing notice of 

important deadlines to Fire Claimants in the above-captioned chapter 11 cases; and this Court 

having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. 

§§ 157 and 1334, the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, 

General Order 24 (N.D. Cal.), and Bankruptcy Local Rule 5011-1(a); 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 Motion as provided to the parties listed therein is reasonable and 

sufficient, and it appearing that no other or further notice needs to be provided; and this Court 

having reviewed the Motion, the Weisbrot Declaration and the Dion Declaration; and this Court 

having held a hearing on the Motion; the Court having reviewed the proposed Fire Claim Bar Date 

Notice attached to the Motion as Exhibit A and determined that the legal and factual bases set forth 

in the Motion establish just cause for the relief granted therein; and it appearing that the relief 

requested in the Motion is in the best interest of the Debtors’ 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 Motion is granted as provided herein. 

2. The TCC’s Notice Program (including the Supplemental Notice Program) is hereby 

approved and Angeion Group, LLC (“Angeion”) is authorized as noticing agent to provide notice 

of the Fire Claim Bar Date as set forth in the Motion and this Order. 

3. The following procedures for filing Fire Proofs of Claim are approved: 

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(a) Except as otherwise noted herein, the Fire Claim Bar Date for filing all Fire 

Proofs of Claim in the Chapter 11 Cases shall be January 31, 2020 at 9:00 

p.m. (Pacific Time). 

(b) Fire Proof of Claim Forms must: 

(1) be written in the English language; 

(2) conform substantially to the Fire Proof of Claim Form or Official 

Form No. 410; and 

(3) be signed by the Fire Claimant or, if the Fire Claimant is not an 

individual, by an authorized agent of the Fire Claimant. 

(c) All timely-filed Fire Proof of Claim Forms will be deemed filed against both 

Debtors (without prejudice to the Debtors’ right to assert that any such claim 

should be allowed only as to one of the Debtors). 

(d) All Fire Proofs of Claim must be filed either (i) electronically through Prime 

Clerk’s website using the interface available on the Case Website under the 

link entitled “Submit a Claim” (the “Electronic Filing System”) or (ii) by 

delivering the original Fire Proof of Claim Form by hand, or mailing the 

original Fire Proof of Claim Form so that is received on or before the Bar 

Date as follows: 

If by first class mail: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

Grand Central Station, PO Box 4850 

New York, NY 10163-4850 

If by overnight courier: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

850 Third Avenue, Suite 412 

Brooklyn, NY 11232 

If by hand delivery: 

PG&E Corporation Claims Processing Center 

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c/o Prime Clerk LLC 

850 Third Avenue, Suite 412 

Brooklyn, NY 11232 

-orAt one of the Debtors’ Claim Service Centers located at the following PG&E 

locations: 

(i) 350 Salem Street, Chico, CA 95928; 

(ii) 231 “D” Street, Marysville, CA 95901; 

(iii) 1567 Huntoon Street, Oroville, CA 95965; 

(iv) 3600 Meadow View Road, Redding, CA 96002; 

(v) 111 Stony Circle, Santa Rosa, CA 95401; or 

(vi) 1850 Soscol Ave. Ste 105, Napa, CA 94559. 

(e) A Fire Proof of Claim Form shall be deemed timely filed only if it is actually 

received by Prime Clerk (i) at the addresses listed above in subparagraph (d) 

or (ii) electronically through the Electronic Filing System on or before the 

Fire Claim Bar Date. 

(f) Fire Proofs of Claim sent by facsimile, telecopy, or electronic mail 

transmission (other than Fire Proofs of Claim filed electronically through the 

Electronic Filing System) will not be accepted. 

(g) In the event that the Debtors amend or supplement their Schedules 

subsequent to the date of entry of this Order, the Debtors shall give notice of 

any amendment or supplement to the holders of claims or interests affected 

thereby and reasonably sufficient information for such claimants to 

determine the identity of the claimant and the nature of the amendment or 

supplement, and such holders shall have until the later of (i) the Fire Claim 

Bar Date or (ii) thirty (30) days from the date of such notice to file a Fire 

Proof of Claim or be barred from doing so and shall be given notice of such 

deadline. This Paragraph 3(g) shall not apply to any creditor who filed a 

proof of claim prior to the amendment or supplement to the Debtors’ 

Schedules. 

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(h) The following persons or entities are not required to file a Fire Proof of 

Claim solely with respect to the claims described below: 

(i) any person or entity that is not a Fire Claimant; 

(ii) any Fire Claimant who has already filed a Fire Proof of Claim against 

any of the Debtors with respect to the claim being asserted, utilizing 

a claim form that substantially conforms to the Fire Proof of Claim 

Form or Official Form No. 410; provided, however, that any Fire

Claimant who holds or asserts a claim other than a Fire Claim must 

file a general proof of claim prior to the general claims bar date set 

in the Chapter 11 Cases; 

(iii) any Fire Claimant whose claim has been paid in full; 

(iv) any Fire Claimant who holds a claim that heretofore has been 

allowed by Order of the Court entered on or before any applicable 

bar date set for Fire Claims in the Chapter 11 Cases; and 

(v) any Fire Claimant whose claim is listed on the Schedules; provided 

that (A) the claim is not listed on the Schedules as “disputed,” 

“contingent,” or “unliquidated,” (B) the Fire Claimant does not

dispute the amount, nature, and priority of the claim as set forth in 

the Schedules, and (C) the Fire Claimant does not dispute that the 

claim is an obligation of the specific Debtor against which the claim 

is listed in the Schedules. 

4. Pursuant to Bankruptcy Rule 3003(c)(2), all holders of Fire Claims, including Fire 

Claimants, that fail to comply with this Order by timely filing a Proof of Claim in the appropriate 

form shall not be treated as a creditor with respect to such claim for the purposes of voting and 

distribution with respect to any chapter 11 plan or plans of reorganization that may be filed in these 

Chapter 11 Cases. Notwithstanding the foregoing, late filings shall be permitted where the failure 

to act was the result of “excusable neglect” under the standard set forth in Pioneer Investment 

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Services Co. v. Brunswick Associates Ltd. Partnership, 507 U.S. 380 (1993) or as otherwise 

permitted by the Court. 

5. Notwithstanding anything to the contrary herein, Fire Claimants that made a good 

faith effort to assert a Fire Claim in the appropriate form shall be permitted to revise, amend and/or 

supplement their proof of claim until such claim is allowed or disallowed by Court order. 

6. Notwithstanding anything herein to the contrary, for purposes of this Order, (i) Fire 

Claims shall not include any claims of any State of California governmental unit, (ii) no such State 

of California governmental until shall be included as a Fire Claimant, and (iii) the claims of any 

such State of California governmental unit may be submitted in accordance with the requirements 

of Bankruptcy Rule 3001(c) or otherwise applicable law regarding proofs of claim. 

7. Within five (5) days of entry of this Order, the Debtors, Prime Clerk, and the TCC 

shall post the Fire Claim Bar Date Notice on their respective websites. 

8. At least one hundred twenty (120) days prior to the Fire Claim Bar Date, Angeion 

shall cause to be mailed to their last known address as identified using the methods more fully laid 

out in the Motion and the Weisbrot Declaration (i) a Fire Proof of Claim Form, and (ii) the Fire 

Claim Bar Date Notice on all known and reasonably identifiable Fire Claimants. 

9. Within fourteen (14) days after entry of this Order, the Debtors and Prime Clerk 

shall turn over to Angeion a file containing the name and address of all known or identifiable Fire 

Claimants derived from the information sources listed in the Weisbrot Declaration, which include 

but are not limited to: pre-petition litigation records; PG&E customer data; Geographic 

Information Systems (“GIS”) data; Emergency Fund data; and first-party intelligence such as 

public records. The Debtors and Prime Clerk shall furnish updated contact information on an 

ongoing basis and in no event later than three (3) days after receipt of such information. 

10. The Supplemental Notice Plan is hereby approved and Angeion is authorized to 

implement the components of the Supplemental Notice Program as set forth in the Motion. 

11. Nothing contained in this Order or in the Motion is intended to be or shall be 

construed as (a) an admission as to the validity of any claim against the Debtors, (b) a waiver of 

the Debtors’ or any appropriate party in interest’s rights to dispute any claim, or (c) an approval or 

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assumption of any agreement, contract, program, policy, or lease under section 365 of the 

Bankruptcy Code. 

12. Notwithstanding entry of this Order, nothing herein shall create, nor is intended to 

create, any rights in favor of or enhance the status of any claim held by any party, or a waiver of 

the right to object to any designation that a matter is an executory contract. 

13. The Debtors, Prime Clerk, the TCC, and Angeion are authorized and directed to take 

all steps necessary or appropriate to carry out this Order. 

14. Entry of this Order is without prejudice to the right of the Debtors to seek a further 

order of this Court fixing the date by which holders of claims not subject to the Fire Claim Bar Date 

established herein must file such claims against the Debtors or be forever barred from so doing. 

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

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

** END OF ORDER ** 

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 Capitalized terms used but not otherwise defined herein shall have the meanings given to them in the Motion. The 

term “Fire Claim” shall have the meaning given to it in the Memorandum of Points and Authorities in Support of 

Motion of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. §§ 105(a) and 501 and Fed. R. Bankr. 

P. 3001(a) for Entry of an Order Approving Proposed Model Proof of Claim Form and Fire Claims and Related 

Procedures (Dkt. No. 1825). The word “claim” shall refer to “claim” as defined in 11 U.S.C. § 101(5).

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 Boulevard

Suite 1400

Los Angeles, CA 90025

Telephone: 310.820.8800

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)

ORDER (I) ESTABLISHING A BAR

DATE FOR FILING FIRE CLAIMS, (II)

APPROVING THE FORM AND

PROCEDURES FOR NOTICE OF THE

BAR DATE FOR FIRE CLAIMS, AND

(III) APPROVING SUPPLEMENTAL

PROCEDURES FOR NOTICE OF THE

BAR DATE TO FIRE CLAIMANTS

Upon the Motion, dated May 31, 2019 (the “Motion”),1

 of the Official Committee of Tort

Claimants (the “TCC”), pursuant to sections 105(a), 501 of title 11 of the United States Code,

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Rules 3001(a), 3003(c), 5005 and 9007 of the Federal Rules of Bankruptcy Procedure and Rule

3003-1 of the Bankruptcy Local Rules for the United States District Court for the Northern

District of California (the “Bankruptcy Local Rules”), for entry of an order (i) approving a

separate bar date for Fire Claims, (ii) approving the form for notice of the bar date for Fire Claims

and related procedures, and (iii) approving supplemental procedures for providing notice of

important deadlines to Fire Claimants in the above-captioned chapter 11 cases; and this Court

having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C.

§§ 157 and 1334, the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges,

General Order 24 (N.D. Cal.), and Bankruptcy Local Rule 5011-1(a); 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 Motion as provided to the parties listed therein is reasonable and

sufficient, and it appearing that no other or further notice needs to be provided; and this Court

having reviewed the Motion, the Weisbrot Declaration and the Dion Declaration; and this Court

having held a hearing on the Motion; the Court having reviewed the proposed Fire Claim Bar

Date Notice attached to the Motion as Exhibit A and determined that the legal and factual bases

set forth in the Motion establish just cause for the relief granted therein; and it appearing that the

relief requested in the Motion is in the best interest of the Debtors’ 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 Motion is granted as provided herein.

2. The TCC’s Notice Program (including the Supplemental Notice Program) is

hereby approved and Angeion Group, LLC (“Angeion”) is authorized as noticing agent to

provide notice of the Fire Claim Bar Date as set forth in the Motion and this Order.

3. The following procedures for filing Fire Proofs of Claim are approved:

(a) Except as otherwise noted herein, the Fire Claim Bar Date for filing all

Fire Proofs of Claim in the Chapter 11 Cases shall be January 31, 2020 at

9:00 p.m. (Pacific Time).

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(b) Fire Proof of Claim Forms must:

(1) be written in the English language;

(2) conform substantially to the Fire Proof of Claim Form or Official

Form No. 410; and

(3) be signed by the Fire Claimant or, if the Fire Claimant is not an

individual, by an authorized agent of the Fire Claimant.

(c) All timely-filed Fire Proof of Claim Forms will be deemed filed against

both Debtors (without prejudice to the Debtors’ right to assert that any

such claim should be allowed only as to one of the Debtors).

(d) All Fire Proofs of Claim must be filed either (i) electronically through

Prime Clerk’s website using the interface available on the Case Website

under the link entitled “Submit a Claim” (the “Electronic Filing System”)

or (ii) by delivering the original Fire Proof of Claim Form by hand, or

mailing the original Fire Proof of Claim Form so that is received on or

before the Bar Date as follows:

If by first class mail:

PG&E Corporation Claims Processing Center

c/o Prime Clerk LLC

Grand Central Station, PO Box 4850

New York, NY 10163-4850

If by overnight courier:

PG&E Corporation Claims Processing Center

c/o Prime Clerk LLC

850 Third Avenue, Suite 412

Brooklyn, NY 11232

If by hand delivery:

PG&E Corporation Claims Processing Center

c/o Prime Clerk LLC

850 Third Avenue, Suite 412

Brooklyn, NY 11232

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-orAt one of the Debtors’ Claim Service Centers located at the following

PG&E locations:

(i) 350 Salem Street, Chico, CA 95928;

(ii) 231 “D” Street, Marysville, CA 95901;

(iii) 1567 Huntoon Street, Oroville, CA 95965;

(iv) 3600 Meadow View Road, Redding, CA 96002;

(v) 111 Stony Circle, Santa Rosa, CA 95401; or

(vi) 1850 Soscol Ave. Ste 105, Napa, CA 94559.

(e) A Fire Proof of Claim Form shall be deemed timely filed only if it is

actually received by Prime Clerk (i) at the addresses listed above in

subparagraph (d) or (ii) electronically through the Electronic Filing System

on or before the Fire Claim Bar Date.

(f) Fire Proofs of Claim sent by facsimile, telecopy, or electronic mail

transmission (other than Fire Proofs of Claim filed electronically through

the Electronic Filing System) will not be accepted.

(g) In the event that the Debtors amend or supplement their Schedules

subsequent to the date of entry of this Order, the Debtors shall give notice

of any amendment or supplement to the holders of claims or interests

affected thereby and reasonably sufficient information for such claimants

to determine the identity of the claimant and the nature of the amendment

or supplement, and such holders shall have until the later of (i) the Fire

Claim Bar Date or (ii) thirty (30) days from the date of such notice to file a

Fire Proof of Claim or be barred from doing so and shall be given notice of

such deadline. This Paragraph 3(g) shall not apply to any creditor who

filed a proof of claim prior to the amendment or supplement to the

Debtors’ Schedules.

(h) The following persons or entities are not required to file a Fire Proof of

Claim solely with respect to the claims described below:

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(i) any person or entity that is not a Fire Claimant;

(ii) any Fire Claimant who has already filed a Fire Proof of Claim

against any of the Debtors with respect to the claim being asserted,

utilizing a claim form that substantially conforms to the Fire Proof

of Claim Form or Official Form No. 410; provided, however, that

any Fire Claimant who holds or asserts a claim other than a Fire

Claim must file a general proof of claim prior to the general claims

bar date set in the Chapter 11 Cases;

(iii) any Fire Claimant whose claim has been paid in full;

(iv) any Fire Claimant who holds a claim that heretofore has been

allowed by Order of the Court entered on or before any applicable

bar date set for Fire Claims in the Chapter 11 Cases; and

(v) any Fire Claimant whose claim is listed on the Schedules; provided

that (A) the claim is not listed on the Schedules as “disputed,”

“contingent,” or “unliquidated,” (B) the Fire Claimant does not

dispute the amount, nature, and priority of the claim as set forth in

the Schedules, and (C) the Fire Claimant does not dispute that the

claim is an obligation of the specific Debtor against which the

claim is listed in the Schedules.

4. Any documentation submitted in connection with Fire Proof of Claim Forms shall

remain confidential in these Chapter 11 Cases and shall not be made available to the general

public. Copies of such information shall be provided to counsel for the Committees, the U.S.

Trustee and any additional parties the Court directs but only after each such party agrees to keep

the information provided in the Fire Proof of Claim Forms confidential.

4. 5. Pursuant to Bankruptcy Rule 3003(c)(2), all holders of Fire Claims, including

Fire Claimants, that fail to comply with this Order by timely filing a Proof of Claim in the

appropriate form shall (i) be forever barred, estopped and enjoined from asserting such claims

against the Debtors, their property, or their estates (or submitting a Proof of Claim with respect

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thereto) and (ii) not be treated as a creditor with respect to such claim for the purposes of voting

and distribution with respect to any chapter 11 plan or plans of reorganization that may be filed in

these Chapter 11 Cases. Notwithstanding the foregoing, late filings shall be permitted where the

failure to act was the result of “excusable neglect” under the standard set forth in Pioneer

Investment Services Co. v. Brunswick Associates Ltd. Partnership, 507 U.S. 380 (1993) or as

otherwise permitted by the Court.

5. Notwithstanding anything to the contrary herein, Fire Claimants that made a good

faith effort to assert a Fire Claim in the appropriate form shall be permitted to revise, amend

and/or supplement their proof of claim until such claim is allowed or disallowed by Court order.

6. No party, including the Debtors, may object in whole or in part to any Fire Claim

prior to the Fire Claim Bar Date.Notwithstanding anything herein to the contrary, for purposes of

this Order, (i) Fire Claims shall not include any claims of any State of California governmental

unit, (ii) no such State of California governmental until shall be included as a Fire Claimant, and

(iii) the claims of any such State of California governmental unit may be submitted in accordance

with the requirements of Bankruptcy Rule 3001(c) or otherwise applicable law regarding proofs

of claim.

7. Within five (5) days of entry of this Order, the Debtors, Prime Clerk, and the TCC

shall post the Fire Claim Bar Date Notice on their respective websites.

8. At least one hundred twenty (120) days prior to the Fire Claim Bar Date, Angeion

shall cause to be mailed to their last known address as identified using the methods more fully

laid out in the Motion and the Weisbrot Declaration (i) a Fire Proof of Claim Form, and (ii) the

Fire Claim Bar Date Notice on all known and reasonably identifiable Fire Claimants.

9. Within fourteen (14) days after entry of this Order, the Debtors and Prime Clerk

shall turn over to Angeion a file containing the name and address of all known or identifiable Fire

Claimants derived from the information sources listed in the Weisbrot Declaration, which include

but are not limited to: pre-petition litigation records; PG&E customer data; Geographic

Information Systems (“GIS”) data; Emergency Fund data; and first-party intelligence such as

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BAKER & HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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public records. The Debtors and Prime Clerk shall furnish updated contact information on an

ongoing basis and in no event later than three (3) days after receipt of such information.

10. The Supplemental Notice Plan is hereby approved and Angeion is authorized to

implement the components of the Supplemental Notice Program as set forth in the Motion.

11. Nothing contained in this Order or in the Motion is intended to be or shall be

construed as (a) an admission as to the validity of any claim against the Debtors, (b) a waiver of

the Debtors’ or any appropriate party in interest’s rights to dispute any claim, or (c) an approval

or assumption of any agreement, contract, program, policy, or lease under section 365 of the

Bankruptcy Code.

12. Notwithstanding entry of this Order, nothing herein shall create, nor is intended to

create, any rights in favor of or enhance the status of any claim held by any party, or a waiver of

the right to object to any designation that a matter is an executory contract.

13. The Debtors, Prime Clerk, the TCC, and Angeion are authorized and directed to

take all steps necessary or appropriate to carry out this Order.

14. Entry of this Order is without prejudice to the right of the Debtors to seek a further

order of this Court fixing the date by which holders of claims not subject to the Fire Claim Bar

Date established herein must file such claims against the Debtors or be forever barred from so

doing.

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

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

** END OF ORDER **

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