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DOCS_SF:101783.2 68700/001

Isaac M. Pachulski (CA Bar No. 62337) 

Debra I. Grassgreen (CA Bar No. 169978) 

PACHULSKI STANG ZIEHL & JONES LLP 

150 California Street, 15th Floor 

San Francisco, CA 94111 

Telephone: (415) 263-7000 

Facsimile: (415) 263-7010 

Email: dgrassgreen@pszjlaw.com 

 

Eric Seiler (admitted pro hac vice) 

FRIEDMAN KAPLAN SEILER AND ADELMAN LLP 

7 Times Square 

New York, NY 10036-6516 

Telephone (212) 833-1103 

Facsimile (212) 373-7903 

Email: eseiler@fklaw.com 

Attorneys for The Baupost Group, L.L.C., 

as the managing general partner and/or investment 

manager of certain entities 

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)

Case No. 19-30088 (DM) 

Chapter 11 

(Jointly Administered) 

JOINDER IN STATEMENT OF THE AD HOC 

GROUP OF SUBROGATION CLAIM 

HOLDERS REGARDING AUGUST 27, 2019 

STATUS CONFERENCE ON ESTIMATION 

Date: August 27, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

The Baupost Group, L.L.C., as the general partner and/or investment manager for certain 

entities (“Baupost”) hereby submits this Joinder (the “Joinder”) in the Statement of the Ad Hoc 

Group of Subrogation Claimants Regarding August 27, 2019 Conference on Estimation (the 

“Subrogation Group Statement”). Baupost is a substantial creditor of these estates, is a major holder 

of insurance subrogation claims and is a member of the Steering Committee of the Ad Hoc Group of 

Case: 19-30088 Doc# 3696 Filed: 08/26/19 Entered: 08/26/19 14:31:20 Page 1 of

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DOCS_SF:101783.2 68700/001

Subrogation Claim Holders (the “Ad Hoc Subrogation Group”).1 Baupost’s claims, along with the 

claims of the other members of the Ad Hoc Subrogation Group and the claims of the individual 

plaintiffs, will be the subject of the estimation proceeding. 

Baupost believes that, particularly in light of the time constraints that confront the parties in 

this extraordinarily complex estimation proceeding, and the Debtors’ possession of information 

regarding each of the wildfires that has yet to be released through discovery, the critical first step in 

this estimation proceeding must be for the Debtors to identify the bases for their objections to claims 

based on the 2017 and 2018 wildfires (both as to liability and as to damages) and to identify the 

factual and legal defenses to liability and damages on those claims that the Debtors intend to present. 

The holders of claims based on the wildfires—whether insurance subrogation claims or individual 

plaintiff claims—should not have to speculate on those bases, especially given the essential shutoff 

of their access to discovery resulting from the automatic stay. 

More generally, Baupost fully supports the Ad Hoc Subrogation Group’s proposed approach 

for the conduct of the estimation proceeding rather than the Debtors’ piecemeal proposal. In 

particular, the Debtors’ suggestion that the estimation of damages be reserved to the end of the 

process will not advance resolution of the estimation proceeding. Instead, the estimation of damages 

should proceed in parallel with a determination of liability. 

WHEREFORE, Baupost requests that the Court grant the relief consistent with the 

Subrogation Group Statement. 

Dated: August 26, 2019 PACHULSKI STANG ZIEHL & JONES LLP 

/s/ Debra I. Grassgreen 

Isaac M. Pachulski 

Debra I. Grassgreen 

- and - 

Eric Seiler 

FRIEDMAN KAPLAN SEILER 

AND ADELMAN LLP 

Attorneys for The Baupost Group, L.L.C., as the 

general partner and investment manager for certain 

entities 

 

1

 As set forth in the Third Amended Verified Statement of the Ad Hoc Group of Subrogation Claim Holders Pursuant to 

Bankruptcy Rule 2019, Baupost also holds 24,500,000 shares of PG&E Corporation Common Stock and $850,000.00 in 

other unsecured wildfire-related claims. 

Case: 19-30088 Doc# 3696 Filed: 08/26/19 Entered: 08/26/19 14:31:20 Page 2 of

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