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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA

Exhibit A

Proposed Order

Case: 19-30088 Doc# 4018-1 Filed: 09/26/19 Entered: 09/26/19 16:06:38 Page 1

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA

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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: 310.442.8800

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)

ORDER APPROVING APPLICATION 

OF THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS FOR ENTRY OF 

AN ORDER (I) CONFIRMING THE 

SCOPE OF EMPLOYMENT OF BAKER 

& HOSTETLER LLP, OR 

ALTERNATIVELY (II) AMENDING 

THE ORDER APPROVING 

APPLICATION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. § 1103 AND 

FED. R. BANKR. P. 2014 AND 5002, 

FOR AN ORDER AUTHORIZING 

RETENTION AND EMPLOYMENT OF 

BAKER & HOSTETLER LLP, 

EFFECTIVE AS OF FEBRUARY 15, 

2019 (DKT. NO. 1331) (THE 

“RETENTION ORDER”) 

Case: 19-30088 Doc# 4018-1 Filed: 09/26/19 Entered: 09/26/19 16:06:38 Page 2

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ATTORNEYS AT LAW

SAN FRANCISCO, CA

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Upon the Application, filed September 26, 2019, (the “Application”),1 of the Official 

Committee of Tort Claimants (the “TCC”) of PG&E Corporation and Pacific Gas and Electric 

Company (collectively, the “Debtors”) for an order either (i) confirming that the scope of Baker 

& Hostetler LLP’s employment (“Baker”) pursuant to the Retention Order includes representation 

of the TCC in connection with the California North Bay Fire Cases, JCCP 4955 (the “State Court 

Litigation”), or (ii) amending the Retention Order to expressly provide that Baker is authorized 

to represent the TCC in the State Court Litigation, and this Court having jurisdiction to consider 

the Application and the relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334, Order 

Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24 (N.D. Cal.), 

and Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District Court for the 

Northern District of California (the “Bankruptcy Local Rules”); and consideration of the 

Application and the requested relief being a core proceeding pursuant to 28 U.S.C. § 157(b); and 

venue being proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court 

having found and determined that notice of the Application as provided to the parties listed therein 

is reasonable and sufficient; and it appearing that no other or further notice need be provided; and 

this Court having reviewed the Application; and it appearing that the relief requested in the 

Application is in the best interests of the Debtors, their estates, creditors, shareholders, and all 

parties in interest; and upon all of the proceedings had before this Court and after due deliberation 

and sufficient cause appearing therefor,

IT IS HEREBY ORDERED THAT:

1. The Application is approved to the extent set forth herein.

2. The TCC is authorized, pursuant to section 1103 of the Bankruptcy Code and 

Bankruptcy Rules 2014(a) and 5002, to employ and retain Baker as counsel to represent the TCC 

in connection with the State Court Litigation, effective as of August 21, 2019.

3. Other than as provided in paragraph 2 above, the Retention Order shall continue to 

govern the terms of Baker’s employment. 

 1 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such terms in the 

Application. 

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ATTORNEYS AT LAW

SAN FRANCISCO, CA

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4. To the extent that there may be any inconsistency between the terms of the 

Application and this Order, the terms of this Order shall govern.

5. The relief granted herein shall be binding upon any chapter 11 trustee appointed in 

the Cases, or upon any chapter 7 trustee appointed in the event of a subsequent conversion of the 

Cases to cases under chapter 7.

6. The TCC is authorized to take all steps necessary or appropriate to carry out this 

Order.

7. This Court shall retain jurisdiction to hear and determine all matters arising from 

or related to the implementation, interpretation, or enforcement of this Order. 

** END OF ORDER **

Case: 19-30088 Doc# 4018-1 Filed: 09/26/19 Entered: 09/26/19 16:06:38 Page 4

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