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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:

DEBTOR 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)

RESPONSE OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

TO MOTION OF DEBTORS

PURSUANT TO 11 U.S.C. §§ 105(a) AND 

363 FOR AN ORDER AUTHORIZING 

DEBTORS TO PARTICIPATE IN AB1054 WILDFIRE FUND (THE 

“WILDFIRE FUND MOTION”) (DKT. 

NO. 3444)

Date: August 28, 2019

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

Place: United States Bankruptcy Court 

Courtroom: 17, 16th Floor 

San Francisco, CA 94102

Objection Deadline: August 22, 2019

Case: 19-30088 Doc# 3664 Filed: 08/22/19 Entered: 08/22/19 15:37:53 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 (“TCC”) does not oppose the election by PG&E 

Corporation (“Holdco”) and Pacific Gas and Electric Company (“Utility,” and together with 

Holdco, the “Debtors”) to participate in the Wildfire Fund to be established pursuant to AB 1054, 

or the Court’s approval, by September 10, 2019, of that participation.

While the TCC does not object to the specific relief requested by the Debtors, the TCC does 

not believe that this Court’s discretion in administering these bankruptcy cases can or should be 

directed or impacted by provisions of AB 1054 that purport to preclude the Debtors from 

participating in the Wildfire Fund unless the Debtors confirm a reorganization plan that meets 

certain requirements within a certain time frame (i.e., by June 30, 2020). Specifically, the TCC 

respectfully submits that this Court must adopt procedures for the estimation or liquidation of 

Northern California Wildfire claims that provide due process for claimants without regard to the 

provisions of AB 1054 that attempt to impose a June 30, 2020 deadline on resolution of these 

bankruptcy cases to access the Wildfire Fund. 

The TCC’s failure to object to the relief requested by the Debtors does not waive, and the 

TCC expressly reserves, the TCC’s right to challenge any aspect of the administration of these 

bankruptcy cases including on the grounds that the Court’s administration of these bankruptcy cases 

denies procedural and substantive due process to the Northern California Wildfire claimants or on 

the grounds that state law is preempted by federal bankruptcy laws.

Dated: August 22, 2019 Respectfully submitted,

BAKER & HOSTETLER LLP

By: /s/ Cecily A. Dumas

Cecily A. Dumas

Counsel for Official Committee of Tort Claimants

Case: 19-30088 Doc# 3664 Filed: 08/22/19 Entered: 08/22/19 15:37:53 Page 2 of

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