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DIEMER & WEI, LLP

Kathryn S. Diemer (#133977)

100 West San Fernando Street, Suite 555

San Jose, CA 95113

Telephone: 408-971-6270 

Facsimile: 408-971-6271 

Email: kdiemer@diemerwei.com 

WILLKIE FARR & GALLAGHER LLP

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Daniel I. Forman (pro hac vice)

787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

jminias@willkie.com

dforman@willkie.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

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)

Chapter 11 

Bankr. Case No. 19-30088 (DM)

(Jointly Administered)

ORDER PURSUANT TO 11 U.S.C. §§ 

105(a), 107(b) AND 501 AND FED. R. 

BANKR. P. 3001(a) AND 9018 FOR 

ENTRY OF AN ORDER APPROVING 

PROPOSED MODEL OMNIBUS 

INSURANCE SUBROGATION PROOF 

OF CLAIM FORM FOR 

SUBROGATION CLAIMS AND 

RELATED PROCEDURES

Case: 19-30088 Doc# 2044-3 Filed: 05/16/19 Entered: 05/16/19 12:49:07 Page 1

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Upon the Motion, dated May [_], 2019 (the “Motion”) of the Ad Hoc Group of 

Subrogation Claim Holders (the “Ad Hoc Subrogation Group”) pursuant to sections 105(a), 

107(b) and 501 of title 11 of the United States Code (the “Bankruptcy Code”) and Rules 

3001(a) and 9018 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), for 

entry of an order approving the proposed model Omnibus Insurance Subrogation Proof of Claim 

Form for Subrogation Claims and related procedures 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 Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District 

Court for the Northern District of California; 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 is reasonable and sufficient, and it appearing that no other or further notice needs to be 

provided; and this Court having reviewed the Motion and accompanying memorandum of law; 

and this Court having held a hearing on the Motion; and the Court having reviewed the 

proposed Omnibus Insurance Subrogation Proof of Claim Form attached to the Motion as 

Exhibit A (the “Subrogation Group’s Form”) and determined that it conforms substantially to 

the appropriate Official Form; and this Court having determined that the legal and factual bases 

set forth in the Motion and accompanying memorandum of law 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. Capitalized terms used but not defined herein shall have the meanings 

ascribed in the Motion.

3. The Subrogation Group’s Form is hereby approved. Each Subrogation 

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Claim filed using the Subrogation Group’s Form shall be deemed filed against each of the 

Debtors.

4. To facilitate the use of the Subrogation Group’s Form, the Court hereby 

approves the following procedure: Prime Clerk will modify the website maintained for the 

Debtors’ chapter 11 cases located at https://restructuring.primeclerk.com/pge/ so that (i) the 

Subrogation Group’s Form is publicly accessible, (ii) the webpage associated with the link 

entitled “Submit a Claim” is modified so that potential Subrogation Claimants that choose to 

file a proof of claim form for Subrogation Claims are directed to, and can, complete the 

Subrogation Group’s Form, and (iii) the supporting information submitted in connection with 

the Subrogation Group’s Form is maintained in a confidential manner.

5. The supporting information submitted in connection with the Subrogation 

Group’s Form shall be sealed, remain confidential in these chapter 11 cases, and not become 

part of the public record. Copies of such information may be provided to: (a) the Court, the 

Debtors, and the Office of the United States Trustee; and (b) counsel for any official committees 

in these cases on a professional eyes’ only basis.

6. 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) establishing a bar date for filing proofs of claim in the chapter 11 cases. 

7. The use of the term “subrogation” herein is not intended to modify or limit 

the substantive rights of the holder of claims or the basis for any claimant’s right to assert 

claims originating with insured tort victims. 

8. The Ad Hoc Subrogation Group, the Debtors, and Prime Clerk are each 

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

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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.

** END OF ORDER **

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