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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 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) 

STATUS REPORT REGARDING 

REVISIONS TO (A) THE FIRE PROOF 

OF CLAIM FORM (DKT. NOS. 1824 & 

2605) AND (B) THE AMENDED ORDER 

ON MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ENTRY OF AN 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 (DKT. NOS. 2297 & 2605) 

Date: June 26, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 2747 Filed: 06/25/19 Entered: 06/25/19 11:02:07 Page 1 of

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

2 

The Official Committee of Tort Claimants (the “TCC”) hereby submits the following Status 

Report regarding its efforts to resolve objections to: 

• 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 for Fire Claims and 

Related Procedures (Dkt. No. 1824) (the “Claim Form Motion”); and 

• Motion of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. 

§§ 105(a), 501 and Fed. R. Bankr. P. 3001(a), 3003(c), 5005 and 9007 for 

Entry of an 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 (Dkt. No. 2297) (the “TCC Bar Date Motion”). 

The TCC has revised its proposed Fire Proof of Claim Form to address certain objections 

raised by the SLF Claimants (see Dkt. Nos. 2248 & 2658) and comments received from the United 

States Trustee, and to include updated address information where proofs of claim can be delivered. 

The proposed revisions include the following: 

• Question 11, and the related Instruction therefor, gives Fire Claimants the 

option of providing a claim amount. 

• Question 2 asks Fire Claimants to identify whether their claim has been 

acquired from someone else. 

• Question 6 asks Fire Claimants to identify whether they know if anyone else 

has filed a proof of claim for them. 

• The Instructions include updated address information where Fire Proof of 

Claim Forms can be delivered. 

The revised Fire Proof of Claim Form also includes Question 3, and the related Instruction 

therefor, which gives Fire Claimants the option of filing a claim on behalf of a family. It is the 

TCC’s understanding that the SLF Claimants still intend to oppose the adoption of the TCC’s Fire 

Proof of Claim Form notwithstanding these modifications. 

The TCC has also revised the proposed amended form of order for the TCC Bar Date 

Motion to address the objection filed by State Farm Mutual Automobile Insurance Company 

(“State Farm”) (see Dkt. No. 2603) and further comments provided by certain California State 

Agencies. The proposed revisions include: 

• The definition of the term “Fire Claim” is now set forth in Paragraph 2 of 

the Order rather than being incorporated by reference in a footnote. 

Case: 19-30088 Doc# 2747 Filed: 06/25/19 Entered: 06/25/19 11:02:07 Page 2 of

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BAKER 

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ATTORNEYS AT LAW

SAN FRANCISCO

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• The carve-out in Paragraph 7 for claims of any State of California 

governmental unit contains language clarifying that it includes claims of 

any city, county, special district or joint authority, or other local 

governmental unit. 

• Paragraph 16 was added to clarify that the Order does not predetermine the 

propriety of any subpoena to be issued on behalf of the TCC and does not 

affect any rights of the subpoena’s target to oppose, move to quash, or object 

to it on any available grounds under the Federal Rules of Evidence, Federal 

Rules of Civil or Bankruptcy Procedure, or other applicable law. 

It is the TCC’s understanding that these revisions address the objection filed by State Farm 

and the comments received from the California State Agencies. The TCC has not been able to 

reach an agreement with the Debtors or the UCC regarding the bar date and related notice 

procedures. 

Attached hereto as Exhibit A and Exhibit B, respectively, are a revised Fire Proof of Claim 

Form and a proposed amended order on the TCC Bar Date Motion. Exhibit A and Exhibit B also 

include redlines reflecting the applicable revisions made since June 19, 2019. 

Dated: June 25, 2019 

BAKER & HOSTETLER LLP 

By: /s/ Eric Goodman 

 Eric Goodman 

Case: 19-30088 Doc# 2747 Filed: 06/25/19 Entered: 06/25/19 11:02:07 Page 3 of

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