1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

Keller & Benvenutti LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors 

and Debtors in Possession

CRAVATH, SWAINE & MOORE LLP 

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019 

Tel: 212 474 1000 

Fax: 212 474 3700 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STATEMENT OF THE DEBTORS IN 

ADVANCE OF THE AUGUST 27, 2019 

STATUS CONFERENCE ON 

ESTIMATION 

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: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 1 of

26
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Pacific Gas and Electric Company and PG&E Corporation (collectively, the “Debtors”) 

submit this Statement of the Debtors in Advance of the August 27, 2019 Status Conference on 

Estimation (the “Statement”). On August 23, 2019, the Official Committee of Tort Claimants 

(the “TCC”) submitted a Statement Regarding August 27, 2019 Status Conference on Estimation 

(Dkt. No. 3672) (the “TCC’s Statement”). The TCC’s Statement referenced the Debtors’ 

proposed plan for estimation, as set forth in an August 22, 2019 letter to the TCC, but did not 

attach that letter. In addition, the TCC’s Statement took the position that the TCC will not engage 

in discussions regarding a schedule for estimation prior to receiving “the Debtors’ explanation of 

their legal and factual bases for denying they are liable for the fires they admit their equipment 

caused”. (TCC’s Statement at 2.) In response to the TCC’s Statement and in advance of the 

August 27 hearing, the Debtors wish to provide the Court with the Debtors’ August 22, 2019 letter 

detailing the Debtors’ proposed estimation process and the Debtors’ August 24, 2019 letter 

responding to the position taken in the TCC’s Statement as well as the TCC’s First Set of 

Interrogatories to the Debtors. The Debtors’ August 22, 2019 letter is annexed as Attachment A 

to this Statement. The Debtors’ August 24, 2019 letter is annexed as Attachment B to this 

Statement.1

1

 Confidential FTP site information is redacted in the copy of the August 24, 2019 letter annexed 

as Attachment B to this Statement. 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 2 of

26
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Dated: August 25, 2019 

 WEIL, GOTSHAL & MANGES LLP 

 CRAVATH, SWAINE & MOORE LLP 

 KELLER & BENVENUTTI LLP 

 /s/Kevin J. Orsini 

Kevin J. Orsini 

Attorneys for Debtors and Debtors in Possession 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 3 of

26
ATTACHMENT A 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 4 of

26
+1-212-474-1596

korsini@cravath.com 

August 22, 2019 

PG&E Chapter 11 Proceedings, No. 19-30088 N.D. Cal. 

Dear Counsel, 

I write in connection with the Court’s instructions at the August 14, 2019, 

hearing that the parties meet and confer regarding the structure of estimation proceedings. 

As the Court noted during the hearing, the structure of the estimation 

hearing is entirely within the Court’s discretion. As you will see below, we have 

proposed an approach that focuses on the fires that together likely account for over 90% 

of the asserted damages and that provide the stakeholders sufficient time to present 

evidence concerning liability and damages issues while also accounting for the 

abbreviated nature of estimation proceedings under Section 502(c). 

We look forward to discussing this proposal in advance of next Tuesday’s 

status conference. 

First, the Debtors continue to believe that the threshold legal issue of 

inverse condemnation should be addressed and resolved as a discrete legal question as 

soon as practicable. While we also continue to believe that this issue can be addressed in 

advance of the bar date, we are cognizant of the TCC’s objections to this approach and 

the Court’s recent observations on that issue. Accordingly, we have revised our original 

schedule and propose that the Debtors submit their pleadings on this issue by October 14, 

2019 (one week prior to the October 21 bar date), with all oppositions be filed by 

November 11, 2019 (three weeks after the bar date), and any replies be submitted by 

November 18, 2019, with a hearing scheduled shortly thereafter.

Second, as Mr. Pitre noted at the August 14 hearing, a small number of 

fires account for the overwhelming majority of alleged damages. (See Hr’g Tr. Aug. 14, 

2019 at 226:9-14 (“Break the twenty-two fires down, they break down to five fires that 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 5 of

26
2 

make up ninety-two percent of all of the total damages.”).) As you know, in an effort to 

facilitate the estimation process, Debtors have agreed not to contest causation with 

respect to any of the 2017 or 2018 Wildfires except for the Tubbs fire. (Dkt. No. 3091 at 

4.) As a result, the issues that remain for estimation with regard to the non-Tubbs 

wildfires are: (1) the question of the Debtors’ legal liability (under inverse, negligence, 

etc.); and (2) the total estimated recoverable losses per fire. 

With the foregoing in mind, the Debtors propose that the estimation 

proceedings, following the initial phase addressing inverse condemnation, be divided 

between liability issues and damages. With respect to liability issues, the Debtors 

propose a series of successive evidentiary hearings on the following large wildfires: 

(1) Atlas; (2) Redwood; (3) Nuns; (4) Sulphur; (5) Cascade; and (6) Camp.1 Those 

evidentiary hearings would all proceed in succession, before the damages phase 

commences, at which time the losses associated with all of the fires could be addressed. 

Proceeding in that way will streamline the process. 

We believe that with respect to those six fires, it would be appropriate for 

the representatives of the wildfire claimants (through the TCC and the Ad Hoc 

Subrogation Group) to provide opening briefs, identifying in advance of the hearings the 

legal and factual issues relating to liability that they believe are in dispute. The Debtors 

will then respond, identifying any other issues and signaling their agreement or 

disagreement with the claimants’ submission. At the same time, the Debtors and the 

stakeholders can work together to stipulate to as many legal and factual issues as 

possible. In that way, the issues actually to be addressed at the evidentiary hearings on 

liability will be as narrowed and focused as possible. 

With respect to the liability-related evidentiary hearing for each of the six 

wildfires identified above, we believe that the wildfire claimants should present evidence 

first, with the witnesses subject to cross-examination by the Debtors and other 

participating parties, consistent with the order of proceedings in a regular trial. Once the 

claimants have presented their evidence, the Debtors will present their witnesses, subject 

to cross-examination by the wildfire claimants. The Debtors propose that each side be 

limited to no more than 5 witnesses (fact or expert) on liability issues per wildfire and 

that the Court employ a “chess clock” approach to time allocation for the duration of the 

liability phase of the estimation hearings. In total, the Debtors estimate that the parties 

can address the legal liability issues with respect to these six fires in no more than four 

weeks of hearings. Once those hearings are complete, the Debtors propose post-hearing 

 

1

 While Mr. Pitre focused on five fires during the August 14 hearing, we believe the size 

of these six fires along with the unique facts of Sulphur (involving an alleged pole 

failure) and Cascade (involving an alleged line slap) require addressing all six as part of 

the liability evidentiary hearings. 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 6 of

26
3 

briefing and argument on liability issues.2

 We propose closing arguments on liability 

issues for all fires, after the post-hearing briefing has been completed. 

 Separately, given the number of wildfires at issue and the limited time 

available to resolve all estimation issues, we propose that any liability issues with respect 

to the wildfires not listed above (other than Tubbs) be addressed in the post-hearing 

briefing, and that all evidence concerning those fires be submitted in written form. 

 The Debtors expect the damages phase will involve exclusively expert 

testimony. To assist the Court and ensure maximum efficiency, the Debtors propose that 

each stakeholder that wishes to be heard on the estimation of total damages file a prehearing brief addressing, for all fires, the following: (1) categories of damages sought 

(e.g., property damage, physical injury, etc.); (2) identification of the parties/claimants 

seeking each category of damages; (3) legal theories/causes of action under which 

claimants are seeking recovery for each category of damages; (4) methodologies 

employed in calculating each category of damages; (5) identification of expert(s) upon 

whom claimants rely upon for the calculation of each category of damages; and (6) any 

related legal issues that further require this Court’s determination. The submission of 

evidence on behalf of the wildfire claimants should be coordinated through a single filing 

made by the TCC.3

 The Debtors will respond to these submissions, indicating its position 

on the damages sought and identifying the methodologies employed in calculating each 

category of damages, the expert(s) upon whom the Debtors rely upon for the calculation 

of each category of damages, and any related legal issues that further require this Court’s 

determination. 

 During the damages phase of the hearing—which we propose last no more 

than two weeks and also be subject to a chess clock—the Debtors submit that the order of 

the parties presenting witnesses should be determined by the total proposed damages 

estimate across all fires, based on the pre-hearing filings, with the party proposing the 

largest number going first and the remaining parties/Debtors proceeding in descending 

order. The Debtors propose that no rebuttal evidence be presented by any of the parties 

after the Debtors’ presentation. We also suggest post-hearing briefing and argument on 

the damages issues. 

 

2

 Once a verdict with respect to the Tubbs fire has been rendered in the state court 

proceeding, the Tubbs fire will need to be incorporated into the estimation process. The 

parties should meet and confer at a subsequent date to discuss how and when that process 

should occur once we have more visibility into the schedule and structure for the state 

court Tubbs trial. 

3

 In other words, it would be inefficient for the Court and the parties for multiple 

individual wildfire claimants to file overlapping briefs on liability issues. Instead, a 

single brief on behalf of the TCC should address all the issues presented by the individual 

claimants. 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 7 of

26
4 

 Finally, we believe that the outcome of the estimation hearings will 

require the Court to estimate at least four different figures, consisting of the aggregate 

amounts required to fund a resolution of the following categories of claims: (1) personal 

injury tort claims; (2) all other individual claims; (3) the subrogation claims; and (4) the 

claims of any public entities who have not reached a settlement with the Debtors. 

This proposal is subject to any modifications in light of the 

recommendation for withdrawal of reference of the bankruptcy proceeding (in part) 

entered by Judge Montali last night (August 21, 2019). 

We are available to meet and confer by telephone with respect to these 

issues the remainder of the week. 

Regards, 

/s/ Kevin J. Orsini

Kevin J. Orsini 

Robert A. Julian, Esq. 

Cecily Dumas, Esq. 

 Baker Hostetler 

11601 Wilshire Boulevard, Suite 1400 

Los Angeles, CA 90025 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 8 of

26
5 

Copy to (via email): 

Matthew A. Feldman, Esq. 

Benjamin P. McCallan, Esq. 

Wilkie Farr & Gallagher LLP 

787 Seventh Ave. 

Washington, DC 20006 

Andrew LeBlanc, Esq. 

Gregory A. Bray, Esq. 

Samir Vora, Esq. 

 Milbank LLP 

1850 K Street, NW, Suite 1100 

Washington, DC 20006 

2029 Century Park East, 33rd Floor 

Los Angeles, CA 90067 

Bruce S. Bennett, Esq. 

Joshua M. Mester, Esq. 

James O. Johnston, Esq. 

Jones Day 

555 South Flower Street, Fiftieth Floor 

Los Angeles, CA 90071 

Michael S. Stamer, Esq. 

Ira S. Dizengoff, Esq. 

David H. Botter, Esq. 

Abid Qureshi, Esq. 

Ashley Vinson Crawford, Esq. 

Akin Gump Strauss Hauer & Feld LLP 

One Bryant Park 

New York, NY 10036 

580 California Street, Suite 1500 

San Francisco, CA 94104 

Stephen Karotkin, Esq. 

Jessica Liou, Esq. 

Weil, Gotshal & Manges LLP 

767 Fifth Ave. 

New York, NY 10153 

 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 9 of

26
6 

Paul J. Pascuzzi, Esq. 

Felderstein, Fitzgerald, Willoughby & Pascuzzi LLP 

500 Capitol Mall, Suite 2250 

Sacramento, CA 95819 

Michael A. Kelly, Esq. 

Walkup, Melodia, Kelly & Schoenberger 

650 California Street, 26th Floor 

San Francisco, CA 94108 

Frank Pitre, Esq. 

Cotchett, Pitre & McCarthy, LLP 

840 Malcolm Road, Suite 200 

Burlingame, CA 94010 

Steven M. Campora, Esq. 

Dreyer Babich Buccola Wood Campora, LLP 

20 Bicentennial Cir. 

Sacramento, CA 95826 

Alan W. Kornberg, Esq. 

Paul, Weiss, Rifkind, Wharton & Garrison LLP 

1285 Avenue of the Americas 

New York, NY 10019 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 10

of 26
ATTACHMENT B 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 11

of 26
+1-212-474-1596

korsini@cravath.com

August 24, 2019

PG&E Chapter 11 Proceedings, No. 19-30088 N.D. Cal. 

Dear Counsel, 

I write in response to the TCC’s August 22, 2019, letter attaching the 

TCC’s First Set of Interrogatories to the Debtors and the TCC’s Statement Regarding 

August 27, 2019 Status Conference on Estimation (the “August 23 Statement”) that you 

filed with the Court yesterday.

1

First, as you well know, the parties cannot continue to delay proceeding

with an estimation process. It is imperative that the parties determine the structure and 

schedule of that process as soon as practicable. We have set forth a detailed proposal 

about how we think the process should work, how long it should take, on which fires we 

should focus and how many witnesses might be required. To date, neither the TCC nor 

any other stakeholder has offered an alternative approach. Nor have you even suggested 

why you might believe our approach is inefficient or could be improved upon. It is easy 

to say this case is complicated. But that does not justify failing to take a position and 

engaging in a constructive dialogue to move the process forward for the benefit of all 

 

1

In its August 20, 2019 Order Regarding Further Hearings On Estimation And Other 

Case Scheduling Matters (the “Order”), the Court instructed the parties to meet and 

confer and undertake “a full discussion among counsel as to what discovery will be 

necessary, and what is the timeframe, preparatory to the scheduling of the final 

estimation proceedings”. (Order at 3-8:10, 5:6-9.) In flagrant disregard of the Court’s 

Order, and less than one day after sending its August 22 letter, the TCC filed its August 

23 Statement without any attempt to meet and confer. We nevertheless remain willing 

and able to meet and confer with respect to the issues set forth in the Court’s Order and 

the August 23 Statement at any time prior to the August 27th conference. 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 12

of 26
2

stakeholders. We remain available to meet and confer regarding these critical issues at 

your convenience.

Second, the TCC’s position that it cannot engage in discussions about how 

to structure an estimation process until it knows more about the disputed issues is 

specious. These are the TCC’s claims. The TCC is asserting the Debtors are liable under 

various state common law and statutory provisions. The claimants, including the tort 

lawyers who litigated these cases for years, obviously understand what the elements of 

those claims are. They understand what proof is required, at least in a state court trial. 

We have stated we will not challenge causation for the purpose of estimation with respect 

to any trials other than Tubbs. Everything else is disputed. 

For example, the TCC is well aware of the Debtors’ theory on inverse 

condemnation being inapplicable to investor-owned utilities. The Court has indicated 

that it will resolve that issue. (See Order Regarding Further Hearings on Estimation 

Motion and Other Case Scheduling Matters at 4:13-19.) The TCC also knows that a key 

issue in pursuing an inverse condemnation claim is proving that any PG&E power line

that may have started a fire was designed, constructed and operated for a public—rather 

than private—use. See Cantu v. Pac. Gas & Elec. Co., 189 Cal. App. 3d 160 (1987). 

(Opp. of the Official Committee of Tort Claimants to the Debtors’ Motion Pursuant to 11 

U.S.C. §§ 105(a) and 502(c) For The Establishment of Wildfire Claims Estimation 

Procedures, App. B at 3.) This will be an issue that the parties will need to address for at 

least the Adobe, Cascade, Cherokee, Honey, La Porte, Lobo, Nuns, Oakmont, Partrick 

and Point fires. 

The TCC has expressed apparent confusion with respect to the intersection 

between causation and liability as to negligence claims. But the Debtors’ position is 

clear. Even if the Debtors do not contest (for purposes of estimation) that their 

equipment caused a particular wildfire, the Debtors do not concede that any negligence 

on their part contributed to the cause. For example, the Debtors do not contest (for 

purposes of estimation) that the Redwood fire ignited when excessive winds caused a 

large branch to break and fall into a PG&E conductor. The Debtors maintain, however, 

that the subject branch was healthy and well outside of the clearance zone required by 

state law, and that their vegetation management program adequately inspected and 

maintained the vegetation at issue. It will be the TCC’s burden to prove otherwise. 

To the extent the TCC believes that it can satisfy the wildfire claimants’ 

burden of proof by demonstrating systemic deficiencies with the Debtors’ overall 

maintenance programs (e.g., vegetation management), that is incorrect. The relevant 

inquiry for purposes of the Debtors’ liability is whether any alleged deficiencies in their

programs can actually be linked to a particular wildfire ignition. As the Court of Appeal 

concluded in the Butte litigation, a plaintiff must demonstrate that the Debtors’ alleged 

negligence contributed to the wildfire. (See Pac. Gas & Elec. Co. v. Superior Court, 24 

Cal. App. 5th 1150, 1167 (2018) (“Plaintiffs also submitted expert opinion evidence that 

the audits performed by the quality assurance department and quality control program 

were scientifically unreliable. . . . There was, however, no showing that PG&E’s audit 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 13

of 26
3

methodology contributed to the Butte fire.”).) The fact that a particular branch may have 

hit a particular line and started a particular fire does not establish negligence. Nor do 

generalized complaints about the Debtors’ vegetation management program. Instead, the 

claimants will have to establish at estimation that they have a likelihood of success on a 

claim that alleged failures of PG&E’s systems and practices contributed to the failure of a 

specific limb or tree, and that such failures resulted in a violation of the standard of care.

Finally, citing to California state law doctrines of res ipsa loquitur and 

negligence per se, you state that “Debtors’ admission that their equipment caused the 

fires . . . places the burden on the Debtors to explain and prove they were not liable for 

the fires”, (August 23 Statement at 2.) This statement mischaracterizes the Debtors’ 

position and is wrong as a matter of law. The Debtors have not admitted that their 

equipment caused any of the wildfires at issue in this case. Rather, in an effort to 

facilitate the estimation process and ensure maximum efficiency, the Debtors have 

merely agreed not to contest causation (except with respect to the Tubbs fire) for 

purposes of the estimation process. As the Court has stated repeatedly and you are well 

aware,

2

estimation of claims under Bankruptcy Code Section 502(c) is unique to the 

bankruptcy process, and the Debtors’ agreement was expressly limited to that specific 

context and that specific purpose. 

Further, even if the Debtors had conceded causation for any purposes 

other than Section 502(c) estimation proceedings (which they did not), it is not the case 

that the burden of proof would shift to the Debtors. As the Court made clear in Howe v. 

Seven Forty Two Co., 189 Cal. App. 4th 1155, 1162-63 (2010), res ipsa loquitur is a 

rebuttable presumption that shifts the burden of production “when the predicate facts are 

established to give rise to the presumption”; it does not affect the burden of proof, which 

remains with the plaintiff. Likewise, in Mata v. Pac. Gas & Elec. Co., the court merely 

states that the doctrine of negligence per se may apply under certain circumstances where 

a defendant has been shown to have violated the law. 224 Cal. App. 4th 309 (2014), as 

modified on denial of reh’g (Mar. 26, 2014). But the Debtors have not admitted to 

violating any law with respect to any of the relevant wildfires (even for purposes of 

estimation). 

Third, the urgent task at hand is establishing an appropriate schedule for 

the estimation proceedings that the Court and all stakeholders (including the TCC) agree 

needs to occur to successfully resolve these Chapter 11 cases. Since, however, the TCC 

seems to believe that it needs to understand the Debtors’ factual and legal positions prior 

to the commencement of discovery or setting a schedule for the estimation process, we 

refer you to the documents set forth in Appendix A. Appendix A includes:

 

2

See, e.g., Hr’g Tr. Aug. 14, 2019 at 106:11-16 (“Court: But in a – in some of the 

large cases that you or your colleagues have been involved, there’s no counterpart. 

502(c) exists all by itself in the bankruptcy world, right? Mr. Pitre: There’s no 

counterpart -- Court: Yeah.”).

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 14

of 26
4

· Almost 300 pages of detailed factual reports about each of the 2017 

and 2018 wildfires in dispute, setting forth the Debtors’ position with 

respect to each wildfire ignition as well as a detailed timeline of all 

prior inspections and patrols of the particular area at issue (e.g., 

vegetation management inspections, overhead patrols). The Debtors 

also indicate for each inspection whether the subject vegetation or 

equipment required any maintenance (e.g., pruning vegetation or 

electrical equipment repair).3

· The Debtors’ responses to more than 800 interrogatories (both form 

and special interrogatories) in the 2017 Wildfires state court 

coordinated proceeding. These interrogatory responses explicitly 

address the general facts and theories underlying the Debtors’ 

defenses, including any witnesses or documents that Debtors may use 

in support of those defenses. For example, the Debtors set forth in 

detail the facts and documents that support their defense that “any 

nuisance or trespass on land were unintentional and non-negligent”. 

(Pacific Gas and Electric Company and PG&E Corporation’s 

Responses and Objections to All Plaintiffs’ Joint Special 

Interrogatories, Set Two, Related to Atlas Fire No. 25 (“PG&E 

routinely inspects and monitors every mile of its approximate 100,000 

miles of PG&E overhead electric and transmission line each 

year . . . .”).) 

We have placed all of the documents set forth on Appendix A on an FTP 

with the following credentials:

· Globalscape URL: 

· Username: 

· Password: 

Please do not hesitate to reach out if you have any questions.

 

3 These reports reference a significant volume of data, documents and testimony. In 

preparing these reports, the Debtors gathered information from at least the following 

sources: (1) formal third-party witness discovery in the 2017 Wildfires litigation 

(including, for example, third party depositions); (2) materials identified in the Debtors’ 

files as part of their ongoing investigations or response to litigation discovery requests; 

and (3) information that the Debtors have obtained from discussions with their own 

employees. 

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 15

of 26
5

Regards,

/s/ Kevin J. Orsini

Kevin J. Orsini

Robert A. Julian, Esq.

Cecily Dumas, Esq.

 Baker Hostetler

11601 Wilshire Boulevard, Suite 1400

Los Angeles, CA 90025

Copy to (via email):

Matthew A. Feldman, Esq.

Benjamin P. McCallan, Esq. 

Wilkie Farr & Gallagher LLP

787 Seventh Ave. 

Washington, DC 20006 

Andrew LeBlanc, Esq.

Samir Vora, Esq.

 Milbank LLP

1850 K Street, NW, Suite 1100

Washington, DC 20006

Stephen Karotkin, Esq. 

Jessica Liou, Esq. 

Weil, Gotshal & Manges LLP

767 Fifth Ave. 

New York, NY 10153

Paul J. Pascuzzi, Esq.

Felderstein, Fitzgerald, Willoughby & Pascuzzi LLP

500 Capitol Mall, Suite 2250

Sacramento, CA 95819 

Michael A. Kelly, Esq.

Walkup, Melodia, Kelly & Schoenberger

650 California Street, 26th Floor

San Francisco, CA 94108

Frank Pitre, Esq.

Cotchett, Pitre & McCarthy, LLP

840 Malcolm Road, Suite 200

Burlingame, CA 94010

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 16

of 26
6

Steven M. Campora, Esq.

Dreyer Babich Buccola Wood Campora, LLP

20 Bicentennial Cir.

Sacramento, CA 95826

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 17

of 26
Appendix A

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 18

of 26
I. Fact Summaries & Supplemental Fact Summaries

Fire Docket # Date Description

-- 956-2 12/31/2018 Glossary of Terms in Fact Summaries

-- 956-3 12/31/2018 Guide to Reviewing Fact Summaries

37 956-53 12/31/2018 37 Incident Description & Factual Summary 

Adobe

956-12 12/31/2018 Adobe Incident Description & Factual Summary

956-31 12/31/2018 Supplement to Adobe Incident Description & Factual 

Summary

Atlas

956-13 12/31/2018 Atlas Incident Description & Factual Summary

956-32 12/31/2018 Supplement to Atlas Incident Description & Factual 

Summary

Blue 956-33 12/31/2018 Blue Incident Description & Factual Summary

Camp 956-1 12/31/2018 Camp Incident Description & Factual Summary

Cascade

956-14 12/31/2018 Cascade Incident Description & Factual Summary

956-34 12/31/2018 Supplement to Cascade Incident Description & Factual 

Summary

Cherokee

956-15 12/31/2018 Cherokee Incident Description & Factual Summary

956-35 12/31/2018 Supplement to Cherokee Incident Description & Factual 

Summary

Honey

956-16 12/31/2018 Honey Location Fact Report

956-36 12/31/2018 Supplement to Honey Location Fact Report

LaPorte

956-17 12/31/2018 LaPorte Incident Description & Factual Summary

956-37 12/31/2018 Supplement to LaPorte Incident Description & Factual 

Summary

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 19

of 26
Fire Docket # Date Description

Lobo

956-18 12/31/2018 Lobo Incident Description & Factual Summary

956-38 12/31/2018 Supplement to Lobo Incident Description & Factual 

Summary

Maacama

956-19 12/31/2018 Maacama Incident Description & Factual Summary

956-39 12/31/2018 Supplement to Maacama Incident Description & Factual 

Summary

McCourtney

956-20 12/31/2018 Orion Way & McCourtney Road Incident Description & 

Factual Summary

956-40 12/31/2018 Supplement to McCourtney Incident Description & 

Factual Summary

Norrbom

956-21 12/31/2018 Norrbom Incident Description & Factual Summary

956-41 12/31/2018 Supplement to Norrbom Incident Description & Factual 

Summary

Nuns

956-22 12/31/2018 Nuns Incident Description & Factual Summary

956-42 12/31/2018 Supplement to Nuns Incident Description & Factual 

Summary

Oakmont

956-23 12/31/2018 Oakmont Incident Description & Factual Summary

956-43 12/31/2018 Supplement to Oakmont Incident Description & Factual 

Summary

Partrick

956-24 12/31/2018 Partrick Incident Description & Factual Summary

956-44 12/31/2018 Supplement to Partrick Incident Description & Factual 

Summary

Pocket

956-25 12/31/2018 Pocket Incident Description & Factual Summary

956-45 12/31/2018 Supplement to Pocket Incident Description & Factual 

Summary

Point

956-26 12/31/2018 Point Incident Description & Factual Summary

956-46 12/31/2018 Supplement to Point Incident Description & Factual 

Summary

Potter

956-27 12/31/2018 Potter Valley Busch Rd. Incident Description & Factual 

Summary

956-47 12/31/2018 Supplement to Potter Valley Busch Road Incident 

Description & Factual Summary

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 20

of 26
II. Responses and Objections to Plaintiffs’ Interrogatories 

PG&E’s Responses and Objections to Form Interrogatories

Fire Docket # Date Description

Pressley 956-48 12/31/2018 Pressley Incident Description & Factual Summary

Redwood

956-28 12/31/2018 Redwood Location Fact Report

956-49 12/31/2018 Supplement to Redwood Location Fact Report

Sullivan 956-50 12/31/2018 Sullivan Incident Description & Factual Summary

Sulphur

956-29 12/31/2018 Sulphur Incident Description & Factual Summary

956-51 12/31/2018 Supplement to Sulphur Incident Description & Factual 

Summary

Tubbs

956-30 12/31/2018 Tubbs Incident Description & Factual Summary

956-52 12/31/2018 Supplement to Tubbs Incident Description & Factual 

Summary

Set Date Description

1 4/16/2018 Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to Plaintiffs’ Form Interrogatories, Set One

1 7/13/2018 Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Plaintiffs’ Form Interrogatories, Set One

1 9/4/2018 Pacific Gas and Electric Company and PG&E Corporation’s Responses to 

Individual Plaintiffs’ Form Interrogatories, Related to Sulphur Fire

3 4/23/2018

Pacific Gas and Electric Company and PG&E Corporation’s Objections to 

All Plaintiffs’ Form Interrogatories, Set Three, Form Interrogatory Numbers 

14.1, 15.1 and 16.1

3 6/20/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Form Interrogatories, Set Three, Form 

Interrogatory Numbers 1.1, 4.1, 4.2, 12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 12.7 

and 14.2

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 21

of 26
PG&E’s Responses and Objections to Form Interrogatories 17.1

Set Date Description

3 7/6/2018

Pacific Gas and Electric Company and PG&E Corporation’s Supplemental 

Responses and Objections to All Plaintiffs’ Form Interrogatories, Set Three, 

Form Interrogatory Numbers 4.1, 12.2

3 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Form Interrogatories, Set Three, Form 

Interrogatory Numbers 14.1, 15.1 and 16.1

3 7/20/2018

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to All Plaintiffs’ Form Interrogatories, Set Three, 

Form Interrogatory Numbers 12.2, 12.3, 12.4, 12.5, 12.6 and 12.7 

3 9/19/2018 Pacific Gas and Electric Company and PG&E Corporation’s Amended and 

Supplemental Response to All Plaintiffs’ Form Interrogatory No. 4.1

6 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Form Interrogatories, Set Six, Related to 

Lobo Fire

7 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Form Interrogatories, Set Seven, Related to 

McCourtney Fire

8 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Form Interrogatories, Set Eight, Related to 

Redwood Fire

Set Date Description

2 4/16/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses 

and Objections to Plaintiffs’ Form Interrogatories, Set Two, Related to 

Sullivan Fire

2 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Plaintiffs’ Form Interrogatories, Set Two, 

Related to Sullivan

4 9/12/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses 

and Objections to Plaintiffs’ Form Interrogatories, Set Four, Related to 

Sullivan Fire

5 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses 

and Objections to Plaintiffs’ Form Interrogatories, Set Five, Related to 

Sullivan Fire

5 1/28/2019

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Plaintiffs’ Form Interrogatories, Set Five, 

Related to Sullivan Fire

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 22

of 26
PG&E’s Responses and Objections to Special Interrogatories

Set Date Description

1 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set One, Related to 

Tubbs Fire

2 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Two, Related to 

Atlas Fire

3 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Three, Related 

to Cascade Fire

4 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Four, Related 

to LaPorte Fire

5 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Five, Related to 

Cherokee Fire

6 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Six, Related to 

Honey Fire

7 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Seven, Related 

to Lobo Fire

8 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Eight, Related 

to Maacama Fire

9 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Nine, Related 

to McCourtney Fire

10 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Ten, Related to 

Nuns Fire

11 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Eleven, Related 

to Pocket Fire

12 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twelve, 

Related to Point Fire

13 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Thirteen, 

Related to Redwood Valley Complex Fire

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 23

of 26
Set Date Description

14 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Fourteen, 

Related to Sulphur Fire

15 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Fifteen, Related 

to Sullivan Fire

16 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Sixteen, 

Related to 37 Fire

17 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Seventeen, 

Related to Tubbs Fire

18 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Eighteen, 

Related to Atlas Fire

19 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Nineteen, 

Related to Cascade Fire

20 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty, 

Related to La Porte Fire

21 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-One, 

Related to Cherokee Fire

22 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Two, 

Related to Lobo Fire

23 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Three, 

Related to McCourtney Fire

24 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Four, 

Related to Nuns Fire

25 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Five, 

Related to Pocket Fire

26 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Six, 

Related to Point Fire

27 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Seven, 

Related to Sulphur Fire

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 24

of 26
Set Date Description

28 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Twenty-Eight, 

Related to Potter Valley Fire

29 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Twenty-Nine, 

Related to Adobe Fire

30 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty, Related 

to Oakmont Fire

31 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-One, 

Related to Partrick Fire

32 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses an 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-Two, 

Related to Norrbom Fire

33 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-Three, 

Related to All Fires

34 8/10/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 34, Related to 

the Tubbs Fire

35 9/12/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 35, Related to 

the Partrick Fire

36 9/12/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 36, Related to 

the Sullivan Fire

36 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to All Plaintiff’s Joint Special Interrogatories, Set 

36, Related to the Sullivan Fire

37 10/23/2018 Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special interrogatories, Set 37

38 10/23/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-Eight, 

Related to Sulphur Fire

39 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to Subrogation Plaintiff’s Special Interrogatories, Set 39, Related 

to the Sullivan Fire

39 1/28/2019

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Subrogation Plaintiff’s Special Interrogatories, 

Set 39, Related to the Sullivan Fire

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 25

of 26
Set Date Description

40 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Forty, Related 

to the Lobo Fire

41 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to all Plaintiff’s Joint Special Interrogatories, Set Forty-One, 

Related to McCourtney Fire

42 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to all Plaintiffs’ Joint Special Interrogatories, Set Forty-Two, 

Related to Redwood Fire

43 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 43, Related to 

Tubbs Fire

Case: 19-30088 Doc# 3687 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 26

of 26