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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO

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: 310.820.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel to the 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) 

OBJECTION BY THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS TO 

APPLICATION PURSUANT TO 11 U.S.C. § 

327(e) AND FED. R. BANKR. P. 2014(a) AND 

2016 FOR ORDER AUTHORIZING THE 

DEBTORS TO RETAIN COBLENTZ 

PATCH DUFFY & BASS LLP AS SPECIAL 

COUNSEL NUNC PRO TUNC TO THE 

PETITION DATE (DKT. NO. 2595) 

Date: July 9, 2019 

Time: 9:30 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: July 2, 2019

Case: 19-30088 Doc# 2834 Filed: 07/02/19 Entered: 07/02/19 15:52:14 Page 1 of

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO

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The Official Committee of Tort Claimants (the “TCC”), one of the largest stakeholders in 

the bankruptcy cases of PG&E Corporation and Pacific Gas and Electric Company, (collectively, 

the “Debtors”), by and through their proposed undersigned counsel, hereby files this objection and 

reservation of rights (the “Objection”) to the Application Pursuant to 11 U.S.C. § 327(e) and Fed. 

R. Bankr. P. 2014(a) and 2016 for Order Authorizing the Debtors to Retain Coblentz Patch Duffy 

& Bass LLP as Special Counsel Nunc Pro Tunc to the Petition Date (the “Motion”) (Doc. No. 

2595). In support of this Objection, the TCC respectfully states as follows: 

OBJECTION 

1. The TCC objects to the Motion based on Coblentz Patch Duffy & Bass LLP’s 

(“Coblentz”) past and current representation of the City of Oakland in Gregory v. Chor Nar Siu 

Ng, Case No. RG 16843631 (“Ghost Ship Fire Case”), which is a conflict of interest. Coblentz is 

the lead counsel for the City of Oakland in the Ghost Ship Fire Case. Pacific Gas and Electric 

Company (“PG&E”) is a co-defendant in the Ghost Ship Fire Case and is represented by different 

counsel. With regard to PG&E, the matter is stayed, but PG&E is a co-tortfeasor under Proposition 

51. Coblentz has also obtained non-public information regarding two members of the TCC in the 

Ghost Ship Fire Case, Susan Slocum and Samuel Maxwell1. 

2. The TCC objects because the Motion states that Coblentz currently has a 

relationship with one of the professional consultants to the TCC, Lincoln Partners Advisors LLC 

(“Lincoln”), which relationship the Motion lists as an “Affiliate or Subsidiary of Former and 

Current Client.” Motion, p. 22, Exhibit B. Lincoln is one of the financial advisors of the TCC and 

is actively engaged in advising the TCC on financial matters involving the Debtors. 

3. While the Motion indicates that the Debtors anticipate that much of the work 

Coblentz will perform involves regulatory matters, the Motion is vague enough to encompass work 

on the Ghost Ship Fire. Indeed, the Motion states in part that “Coblentz will also perform other 

legal services as requested by the Debtors during the pendency of their Chapter 11 Cases, to the 

 

1

 Coblentz represents a member of the TCC, Wagner Family Wines-Caymus Vineyards (“Caymus Vineyards”). To 

represent the Debtors and a member of the TCC at the same time may be a conflict of interest. Baker & Hostetler LLP 

does not represent Caymus Vineyards in its individual capacity, and neither asserts nor waives any privilege on Caymus 

Vineyards’ behalf. 

Case: 19-30088 Doc# 2834 Filed: 07/02/19 Entered: 07/02/19 15:52:14 Page 2 of

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BAKER 

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ATTORNEYS AT LAW SAN FRANCISCO

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extent Coblentz agrees to perform such work.” Motion at pps. 7-8. The TCC submits that the 

Debtors should clarify the scope of Coblentz’s engagement so that interested parties have a greater 

understanding of the work Coblentz will perform as special counsel. 

4. The Motion is also silent about the potential use of information obtained through the 

Ghost Ship Fire Case. Accordingly, if the Court is inclined to grant the Motion, the TCC 

respectfully requests that the Court condition any order on precluding Coblentz (1) from 

representing the Debtors on matters relating to the Ghost Ship Fire, claims estimation or the claims 

process, and (2) sharing with the Debtors any information Coblentz learned or learns as counsel to 

City of Oakland that was not in the Debtors’ possession, custody or control as of the Petition Date. 

5. The TCC reserves its right to join in any other opposition or response to the Motion 

and to amend or supplement this Objection. 

WHEREFORE, the TCC requests that the Court sustain the TCC’s limited Objection and 

require the Debtors and Coblentz to satisfy the conditions described above, and grant such other 

relief as is just. 

Dated: July 2, 2019 

BAKER & HOSTETLER LLP 

By: /s/ Lauren Attard 

Lauren Attard 

Counsel to the Official Committee of Tort 

Claimants 

 

Case: 19-30088 Doc# 2834 Filed: 07/02/19 Entered: 07/02/19 15:52:14 Page 3 of

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