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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

Sander L. Esserman (Admitted Pro Hac Vice)

Cliff I. Taylor (Admitted Pro Hac Vice)

STUTZMAN, BROMBERG, ESSERMAN & PLIFKA, P.C. 

2323 Bryan Street, Suite 2200 

Dallas, TX 75201-2689 

Telephone: 214-969-4900 

Email: esserman@sbep-law.com

Scott Summy 

John Fiske (CSBN 249256) 

BARON & BUDD, P.C. 

3102 Oak Lawn Avenue #1100 

Dallas, TX 75219 

Telephone: 214-521-3605 

Email: ssummy@baronbudd.com 

Christopher H. Hart (CSBN 184117) 

Kimberly S. Fineman (CSBN 184433) 

NUTI HART LLP 

411 30TH Street, Suite 408 

Oakland, CA 94609-3311 

Telephone: 510-506-7152 

Email: kfineman@nutihart.com 

Attorneys for Public Entities Impacted by the Wildfires 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

In re 

PG&E CORPORATION, 

and 

PACIFIC 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. 

 Case No. 19-30088-DM 

Chapter 11 

Lead Case, Jointly Administered 

OBJECTION OF PUBLIC ENTITIES 

IMPACTED BY THE WILDFIRES TO 

MOTION OF DEBTORS PURSUANT 

TO 11 U.S.C. §§ 502(b)(9) AND 105(a), 

FED. R. BANKR. P. 2002, 3003(c)(3), 

5005, AND 9007, AND L.B.R. 3003-1 FOR 

ORDER (I) ESTABLISHING DEADLINE 

FOR FILING PROOFS OF CLAIM, (II) 

ESTABLISHING THE FORM AND 

MANNER OF NOTICE THEREOF, AND 

(III) APPROVING PROCEDURES FOR 

PROVIDING NOTICE OF BAR DATE 

AND OTHER INFORMATION TO ALL 

CREDITORS AND POTENTIAL 

CREDITORS AND STATEMENT 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 

Case: 19-30088 Doc# 2239 Filed: 05/28/19 Entered: 05/28/19 14:23:52 Page 1 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

2 

MODEL PROOF OF CLAIM FORM 

FOR FIRE CLAIMS AND RELATED 

PROCEDURES 

Date: June 11, 2019 

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

Place: 450 Golden Gate Avenue, Ctrm 17 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

The Public Entities Impacted by the Wildfires (the “Public Entities”)1 hereby submit this 

objection to the Motion of Debtors Pursuant to 11 U.S.C. §§ 502(b)(9) and 105(a), Fed. R. 

Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 for Order (I) Establishing 

Deadline for Filing Proofs of Claim, (II) Establishing the Form and Manner of Notice Thereof, 

and (III) Approving Procedures for Providing Notice of Bar Date and Other Information to All 

Creditors and Potential Creditors [Docket No. 1784] (the “Debtors’ Bar Date Motion”) and 

statement in support of the 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 (the “Tort 

Committee POC Motion”). In support hereof, the Public Entities, by and through their 

undersigned counsel, respectfully represent as follows: 

PRELIMINARY STATEMENT 

The Debtors2

 and the Official Committee of Tort Claimants (the “Tort Committee”) have 

each proposed a proof of claim form to be used for wildfire claims, including the wildfire claims 

 1

 The Public Entities consist of the following California public entities: (a) Calaveras County Water 

District, (b) Napa County, (c) City of Napa, (d) Mendocino County, (e) Lake County, (f) City of 

Clearlake, (g) Nevada County, (h) Yuba County, (i) City of Santa Rosa, (j) Sonoma County, (k) Sonoma 

County Agricultural Preservation and Open Space District, (l) Sonoma County Community Development 

Commission, (m) Sonoma County Water Agency, (n) Sonoma County Sanitation District, (o) Town of 

Paradise, and (p) Butte County.

2

 The Debtors are comprised of PG&E Corporation and Pacific Gas and Electric Company, 

debtors and debtors in possession in these bankruptcy cases. 

Case: 19-30088 Doc# 2239 Filed: 05/28/19 Entered: 05/28/19 14:23:52 Page 2 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

3 

of the Public Entities (the “Wildfire Claims”). The proof of claim form submitted with the Tort 

Committee POC Motion (the “Tort Committee POC”) provides a reasonable and fair mechanism 

by which to put the Debtors on notice of the wildfire claims asserted in these bankruptcy cases, 

while also taking into account the dire circumstances of the individual claimants and the nature 

of the Wildfire Claims. In contrast, the Debtors have proposed an onerous proof of claim form 

(the “Debtors’ POC”) that seems designed more to trip up claimants with labyrinthine 

requirements than to give Debtors fair notice of a claim. The Debtors’ POC would require 

claimants with Wildfire Claims (“Wildfire Claimants”) to marshal all of their evidence for the 

claim form, by demanding unnecessarily detailed information, multiple submissions and 

voluminous documentation in a clear effort to dissuade Wildfire Claimants from filing their 

Wildfire Claims and to provide the Debtors with “gotcha” mechanisms by which to reject 

Wildfire Claims at the outset because of some failure to comply with one or another of the 

detailed demands that the Debtors’ POC would impose. The Public Entities, therefore, support 

the Tort Committee POC Motion in so far as it seeks approval of the Tort Committee POC and 

object to the Debtors’ POC Motion in so far as it seeks approval of the Debtors’ POC for the 

reasons provided herein. 

 The Public Entities’ primary objection to the Debtors’ POC is the proposed requirement 

that Wildfire Claimants submit all available documentation supporting their claims at the time 

they submit their proof of claim or be subject to being “forever barred, estopped, and enjoined 

from asserting such claims against the Debtors.” (Debtors’ Bar Date Motion Exhibit A, Dkt. 

No. 1784-1 at ¶ 5). This requirement is unduly burdensome to the claimants, requiring claimants 

to submit all their supporting evidence for what is functionally the complaint stage of the claims 

determination process and would result in an unmanageable and unnecessary amount of 

documentation being submitted to the Debtors. The purpose of a proof of claim is to put the 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

4 

Debtors on notice of a creditor’s claim, the basis of the claim, and when available, the amount 

of the claim. It is not for the purpose of requiring a claimant to marshal all of its evidence, which 

in the case of the Public Entities, will require production of a substantial amount of 

documentation. The Public Entities are already overburdened with the administrative and 

logistical exigencies arising out of the damage to their communities due to the Debtors’ tortious 

conduct. They should not be further burdened with accumulating, processing, redacting and 

producing every conceivable document that might support their claim as part of the proof of 

claim submission process. Further, the Debtors have failed to explain why they need the 

documentation to be submitted with the proof of claims. As the Debtors concede in the Debtors’ 

Bar Date Motion, “. . . the Debtors certainly have no intention of having the Court address all of 

the Wildfire Claims on a claim by claim basis.” (Debtors’ Bar Date Motion, Dkt. No. 1784 at p. 

27). 

 The Public Entities further object to the Debtors’ POC to the extent that it requires 

Wildfire Claimants to identify if their claims are insured, the name of their insurer(s), the 

aggregate amount of insurance coverage, and the amount of insurance proceeds already received 

by the Wildfire Claimants. These matters are not relevant to the issue of the Debtors’ liability 

to claimants and should not be required on a proof of claim form. The Debtors’ purported 

purpose for requiring Wildfire Claimants’ insurance information is to “value claims accurately 

and avoid any double-counting of losses recovered across the different categories of claimants 

(i.e., Wildfire Claimants and Wildfire Subrogation Claimants)” (Debtors’ Bar Date Motion, Dkt. 

No. 1784 at p. 28). However, the Debtors provide no explanation as to how information about 

a Wildfire Claimant’s insurance coverage will provide insight into the value of the Wildfire 

Claimant’s claim. To burden individual Wildfire Claimants with the requirement of producing 

documentation and information regarding insurance coverage as part of the proof of claim 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

5 

submission process is unduly burdensome and unnecessary for purposes of resolving the 

Wildfire Claims. Any information the Debtors may need to resolve the claims of the Wildfire 

Subrogation Claimants should be sought from the Wildfire Subrogation Claimants, not the 

Wildfire Claimants. 

 Furthermore, the Public Entities object to the Debtors’ POC to the extent that it proposes 

to require the Public Entities and other Wildfire Claimants to submit separate proofs of claim as 

to each Debtor and as to each fire that resulted in the claims of the claimants. (See Debtors’ Bar 

Date Motion Exhibit C-2, Dkt. No. 1784-6 at Part 3, Section 7). Requiring the filing of multiple 

proofs of claim is unnecessary and would be unduly burdensome on Wildfire Claimants. The 

Debtors have not provided an adequate explanation as to why such a requirement would be 

warranted. It would be just as effective for a Wildfire Claimant to submit one proof of claim 

form that identifies the Debtor against whom its Wildfire Claims are asserted (or whether the 

claims are asserted against both Debtors) and to identify on the proof of claim form each fire 

from which the claimant’s Wildfire Claims arise. 

 Finally, the Public Entities object to the Debtors’ POC to the extent that it fails to 

adequately identify the discrete fires that have given rise to claims against the Debtors. (See

Debtors’ Bar Date Motion Exhibit C-2, Dkt. No. 1784-6 at Part 3, Section 7). The Debtors 

identify the fires colloquially, using names such as “37,” “Pocket,” and “Cherokee.” Any proof 

of claim approved by this Court should adequately identify each fire by location and the date(s) 

upon which the fire occurred. 

BACKGROUND 

 On January 29, 2019, the Debtors commenced voluntary cases under chapter 11 of the 

Bankruptcy Code. 

Case: 19-30088 Doc# 2239 Filed: 05/28/19 Entered: 05/28/19 14:23:52 Page 5 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

6 

 The Debtors’ Bar Date Motion was filed on May 1, 2019. In the motion, the Debtors 

request that this Court enter an order establishing the last day to file proofs of claim and 

approving proposed proofs of claim forms for use in these bankruptcy cases. The Debtors have 

proposed a discrete proof of claim form for Wildfire Claims. On May 3, 2019, the Tort 

Committee filed a motion and memorandum of law seeking approval of its own proposed model 

proof of claim form for Wildfire Claims. (See Dkt. Nos. 1824 and 1825). 

STATEMENT IN SUPPORT OF THE TORT COMMITTEE POC 

 The Public Entities hereby support the Tort Committee’s proposed Tort Committee POC 

and, for the reasons stated in the Tort Committee POC Motion, request that the Court enter an 

order approving the Tort Committee POC and ordering the Debtors to utilize such proof of claim 

form for purposes of Wildfire Claims. 

OBJECTION TO DEBTORS’ POC 

The Public Entities do not object to the establishment of a bar date or the Court approving 

a discrete proof of claim form for Wildfire Claims. However, the Debtors’ POC and the relief 

requested in the Debtors’ Bar Date Motion with respect thereto is improper, unfair to Wildfire 

Claimants, overly burdensome and unnecessary for the reasons discussed below. 

A. The Debtors’ POC would improperly require a Wildfire Claimant to marshal all of 

the evidence supporting its claim when submitting a proof of claim or be subject to 

having its claim forever barred. 

It is wholly improper for the Debtors to request an order of this Court that would require 

Wildfire Claimants to marshal their evidence as part of the proof of claim submission process, 

which is functionally the complaint stage of the claims determination process. Most Wildfire 

Claimants are still reeling from the massive devastation and havoc created by the Debtors’ 

tortious conduct. They are understandably pre-occupied with attending to the business of putting 

their lives, businesses and communities back together. Specifically, the Public Entities are 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

7 

already burdened with the administrative and logistical exigencies of repairing the infrastructure 

of their communities, including roads, bridges, sidewalks, culverts, drains, storm and waste water 

systems, traffic lights, stop signs, public landscaping and art, drinking water systems in their 

communities and protecting the public from dead or dying trees, soil erosion, debris flows, 

flooding, and mudslides that resulted from the wildfires. The efforts of the Public Entities should 

be focused on initiating and maintaining processes that protect their communities from 

conditions that continue to threaten public welfare and safety, not to accumulating, processing, 

redacting and responding to onerous and needless document demands that the Debtors want to 

impose on the Public Entities to simply state and preserve a claim against the Debtors. The 

Debtors would have this Court require full production of all supporting documentation, including 

but not limited to the following: 

 For property damage claims: 

- Proof of ownership of destroyed property (such as titles and deeds); 

- Property appraisals, 

- Insurance documents, 

- Lease/rental agreements, 

 For business economic loss claims: 

- Proof of operation at time of fire 

- Federal tax returns for two-year period preceding fire, 

- Monthly and annual profit and loss statements 

- W-9 forms, 

 For personal injury claims: 

- Hospital records, 

- Physician office visit records 

Case: 19-30088 Doc# 2239 Filed: 05/28/19 Entered: 05/28/19 14:23:52 Page 7 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

8 

- Insurance benefit summaries 

The Debtors’ document requests are atypical, unduly burdensome, and inappropriate for 

the proof of claim submission process. The purpose of a proof of claim is not to “prove up” 

one’s claim, but merely to put interested parties on notice that the claim exists. 

What is more, the Debtors have proposed an order that would permanently bar a Wildfire 

Claimants’ claim if full production of the requested documentation is not submitted along with 

the proof of claim. Specifically, the Debtor’s proposed order on the Bar Date Motion provides 

that a Wildfire Claimant must “set forth with specificity the legal and factual basis for the alleged 

claim, including all of the information requested in the Wildfire Claimant Proof of Claim 

Form” (Debtors’ Bar Date Motion Exhibit A, Dkt. No. 1784-1 at ¶3(c)) (emphasis added). The 

Debtors’ proposed order further provides that any Wildfire Claimants who “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 thereto) and (ii) not be treated as a creditor 

with respect to such claim for the purposes of voting and distribution . . . .” (Debtors’ Bar Date 

Motion Exhibit A, Dkt. No. 1784-1 at ¶ 5). The Debtors would have this Court disallow 

otherwise valid Wildfire Claims if a Wildfire Claimant were not able to provide full supporting 

documentation along with the Wildfire Claimant’s proof of claim form. Such a proposal is unfair 

to Debtors’ wildfire victims. 

Furthermore, the Debtors have failed to provide any reason for requiring Wildfire 

Claimants to marshal their evidence as part of the proof of claim process. As the Debtors 

concede in their Bar Date Motion, “. . . the Debtors certainly have no intention of having the 

Court address all of the Wildfire Claims on a claim by claim basis . . . .” (Debtors’ Bar Date 

Motion, Dkt. No. 1784 at p. 27). The Debtors, therefore, concede that the documentation to be 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

9 

supplied is not to be used in the claim allowance process. Even if it were, the time for requesting 

the information would come after a claim objection is filed, not with the initial proof of claim. 

The Debtors’ requirement of voluminous documentation instead appears to be for the sole 

purpose of making the claim submission process as onerous as possible on the very Wildfire 

Claimants devastated by the Debtors’ tortious conduct and to provide a mechanism for the 

Debtors to reject Wildfire Claims outright and avoid liability based on a technicality (i.e., a 

Wildfire Claimants’ failure to produce all the requested documentation with their proof of claim). 

The Court should not allow the Debtors to spring such traps on Wildfire Claimants. 

B. The Debtors’ POC would improperly require a Wildfire Claimant to respond to 

numerous information requests regarding the Wildfire Claimant’s insurance 

coverage, which are irrelevant to the Debtors’ liability for the claims asserted. 

The Debtors have inappropriately included in the Debtors’ POC numerous information 

requests regarding a Wildfire Claimant’s insurance coverage, without providing any explanation 

as to how such information is in any way relevant to a Wildfire Claimant’s claim or the Debtors’ 

liability therefor. More specifically, the Debtors’ POC would require a Wildfire Claimant to 

provide: 

 The name of the claimant’s insurer(s); 

 The property (e.g., structure, personal property, other) covered by the insurance; 

 The total amount of insurance coverage with respect to the claimant’s claims; and 

 The amount of insurance proceeds already received by the claimant with respect to the 

claimant’s claims. 

 Whether a Wildfire Claimant’s Wildfire Claim is insured is immaterial to the existence 

of the claim or the Debtors’ liability for the claimant’s damages. The Debtors’ only stated reason 

for including this information on the Debtors’ POC is that “[i]dentifying whether a claim has 

been covered by insurance is required to value claims accurately and avoid any double-counting 

of losses recovered across the different categories of claimants (i.e., Wildfire Claimants and 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

10 

Wildfire Subrogation Claimants).” (Debtors’ Bar Date Motion, Dkt. No. 1784 at p. 28). 

However, demanding evidence regarding the existence and amount of insurance coverage 

available to a Wildfire Claimant is not appropriate at the proof of claim stage of a claim, and 

such evidence ultimately has nothing to do with the valuation of the Wildfire Claimant’s claim. 

The Debtors certainly have not identified any reasonable nexus between the two. Otherwise, 

they would have presumably included a more reasonable explanation as to the necessity of this 

information in their Bar Date Motion, rather than providing this Court with a sweeping and 

unsubstantiated assertion that such information is “required.” Furthermore, the Debtors have 

failed to explain how the information the Debtors seek to solicit regarding a Wildfire Claimant’s 

insurance coverage would avoid double-counting of the Wildfire Claims and the Wildfire 

Subrogation Claims. Even if the Debtors could provide such an explanation (which, to date, they 

have not), the information would be more appropriately solicited from the Insurance Subrogation 

Claimants, not the Wildfire Claimants, and the information should certainly not be solicited by 

way of a proof of claim form. 

C. The Debtors’ Bar Date Motion seeks an order that would improperly require 

Wildfire Claimants to submit multiple proofs of claim for each Debtor and each 

wildfire. 

The Debtors provide no support for the proposed requirement that a Wildfire Claimant 

file a separate proof of claim for each Debtor and also a separate proof of claim for each fire 

giving rise to the claimant’s Wildfire Claims. A requirement that Wildfire Claimants file 

multiple proofs of claim does nothing but add complexity, redundancy and unneeded additional 

costs to the claims filing process. Whether a Wildfire Claimant is asserting a claim against one 

or both of the Debtors and the designation of each wildfire giving rise to the claimant’s Wildfire 

Claim can easily be provided by Wildfire Claimants through the submission of a single proof of 

claim form. Again, the Debtors have provided no explanation or rationale as to why a Wildfire 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

11 

Claimant should be required to submit multiple proofs of claim for its Wildfire Claims. 

Requiring the filing of multiple proofs of claim is unnecessary and would be unduly burdensome 

on Wildfire Claimants. The only practical result of requiring multiple proofs of claim would be 

to provide yet another foot-fault by which the Debtors may avoid addressing the claims of 

Wildfire Claimants altogether. 

D. The Debtors’ POC inadequately describes the wildfires giving rise to the claims 

against them. 

The Debtors’ POC also requires each Wildfire Claimant to identify the fire relevant to 

the claimant’s claim. (See Debtors’ Bar Date Motion Exhibit C-2, Dkt. No. 1784-6 at Part 3, 

Section 7, p. 3). However, the Debtors provide little guidance as to the date(s) of each of the 

fires identified in the Debtors’ POC, the location of the fires, and other relevant information that 

would enable a Wildfire Claimant to accurately identify the fire or fires from which its claims 

arise. More specifically, the Debtors ask Wildfire Claimants to check a box next to one of the 

following names in order to designate the fire applicable to the Wildfire Claimant’s claim: 

37 

Adobe 

Atlas 

Blue 

Butte 

Camp 

Cascade 

Cherokee 

Honey 

La Porte 

Lobo 

Maacama 

McCourtney 

Norrbom 

Nuns 

Partrick 

Pocket 

Point 

Pressley 

Pythian (a.k. Oakmont) 

Redwood 

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

12 

Sulphur 

Tubbs 

 The use of colloquial names for the fires fails to provide Wildfire Claimants with 

adequate information regarding which fire the Debtors mean to designate, which could cause 

confusion on the part of Wildfire Claimants and potentially mis-identified fires. At the very 

least, any proof of claim approved by this Court should adequately identify each fire by location 

and the date(s) upon which the fire occurred. 

E. The Public Entities reserve their right to further object. 

The Public Entities reserve their right to adopt any other objection filed in these 

bankruptcy cases pertaining to the relief requested by the Debtors in the Debtors’ Bar Date 

Motion. 

CONCLUSION 

WHEREFORE, the Public Entities respectfully request that (a) their objection be 

granted, (b) the proposed Debtors’ POC not be approved by this Court, (c) the Tort Committee’s 

POC be approved by this Court, and (d) the Public Entities be granted such other and further 

relief as the Court deems just and proper. 

Dated: May 28, 2019 STUTZMAN, BROMBERG, ESSERMAN & 

PLIFKA, P.C. 

 By: /s/ Sander L. Esserman 

 Sander L. Esserman 

Attorneys for Public Entities Impacted by the Wildfires 

Dated: May 28, 2019 BARON & BUDD, P.C. 

 By: /s/ Scott Summy

 Scott Summy

Attorneys for Public Entities Impacted by the Wildfires 

Case: 19-30088 Doc# 2239 Filed: 05/28/19 Entered: 05/28/19 14:23:52 Page 12

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

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Dated: May 28, 2019 NUTI HART LLP 

 By: /s/ Kimberly S. Fineman 

 Kimberly S. Fineman 

Attorneys for Public Entities Impacted by the Wildfires 

 

Case: 19-30088 Doc# 2239 Filed: 05/28/19 Entered: 05/28/19 14:23:52 Page 13

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