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BROWN RUDNICK LLP 

David J. Molton (SBN 262075) 

(DMolton@brownrudnick.com) 

Seven Times Square 

New York, New York 10036 

Telephone: (212) 209-4800 

Facsimile: (212) 209-4801 

BROWN RUDNICK LLP 

Joel S. Miliband (SBN 077438) 

(JMiliband@brownrudnick.com) 

2211 Michelson Drive, Seventh Floor 

Irvine, California 92612 

Telephone: (949) 752-7100 

Facsimile: (949) 252-1514 

Attorneys for Fire Victim Trustee 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

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) 

FIRE VICTIM TRUST’S 

SUPPLEMENTAL NOTICE 

REGARDING MCKINSEY 

SETTLEMENT 

[Relates to Docket Number 12682] 

Case: 19-30088 Doc# 13689 Filed: 04/27/23 Entered: 04/27/23 15:36:38 Page 1

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TO FIRE VICTIMS AND ALL OTHER INTERESTED PARTIES: 

PLEASE TAKE NOTICE that, as previously disclosed, the Fire Victim Trust (the “Trust”) 

has settled potential claims (the “Assigned Claims”) against McKinsey & Company, Inc. United 

States (“McKinsey”) that the Trust held as part of the Assigned Rights and Causes of Action 

transferred to the Trust pursuant to the Debtors’ and Shareholder Proponents’ Joint Chapter 11 

Plan of Reorganization dated June 19, 2020 [Dkt. No. 8048]. The Trust previously filed an 

unredacted copy of the settlement and release agreement by and among the Trustee and McKinsey 

(the “Settlement Agreement”) [Dkt. No. 13502] and posted the Settlement Agreement on the Fire 

Victim Trust Website at www.firevictimtrust.com. The Settlement Agreement provides, inter alia, 

for McKinsey to remit to the Trust the total lump sum of twenty-five million dollars 

($25,000,000.00) (the “Settlement Amount”) and for mutual releases between the parties to the 

Settlement Agreement. 

PLEASE TAKE FURTHER NOTICE that the Trust previously filed an unredacted copy of 

the engagement letter (the “McKinsey Claims Engagement Letter”) [Dkt. No. 13502] effective 

January 1, 2022, between the Trust and Andrews & Thornton, Attorneys at Law, A Law 

Corporation and Greenberg Gross LLP (together, “Litigation Counsel”) in connection with the 

Assigned Claims and posted the McKinsey Claims Engagement Letter on the Fire Victim Trust 

Website at www.firevictimtrust.com. Pursuant to the McKinsey Claims Engagement Letter, 

Litigation Counsel shall be entitled to attorneys’ fees in the form of a contingency fee equal to 20% 

of the Net Proceeds (as defined in the McKinsey Claims Engagement Letter). 

PLEASE TAKE FURTHER NOTICE that, having performed an accounting to determine 

its costs, expenses, and attorneys’ fees incurred in connection with the Assigned Claims, the Trust 

files this supplemental notice to provide the following further disclosures: the gross amount 

realized was $25,000,000.00; costs and expenses totaled $983,953.59; attorneys’ fees totaled 

$4,803,209.28; and the net benefit to the Trust was $19,212,837.13, as detailed in the following 

table: 

/ / / 

Case: 19-30088 Doc# 13689 Filed: 04/27/23 Entered: 04/27/23 15:36:38 Page 2

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2 

McKinsey Settlement Distribution 

Gross Settlement Recovery $25,000,000.00 

Minus Expenses $983,953.59 

Consultant for Electronic Database / Discovery Platform $10,175 

Electronic Database / Discovery Platform $726,106.42 

Financial Analyst $163,728.00 

Mediator $33,618.50 

Insurance Counsel $50,325.67 

TOTAL $983,953.59 

Net Proceeds $24,016,046.41 

Minus Attorneys’ Fees (20% of Net Proceeds) $4,803,209.28 

Distribution to Trust $19,212,837.13 

DATED: April 27, 2023 BROWN RUDNICK LLP 

By: /s/David J. Molton 

 David J. Molton (SBN 262075) 

(DMolton@brownrudnick.com) 

Seven Times Square 

New York, New York 10036 

Telephone: (212) 209-4800 

Facsimile: (212) 209-4801 

and 

Joel S. Miliband (SBN 077438) 

(JMiliband@brownrudnick.com) 

2211 Michelson Drive 

Seventh Floor 

Irvine, California 92612 

Telephone: (949) 752-7100 

Facsimile: (949) 252-1514 

Attorneys for Fire Victim Trustee

Case: 19-30088 Doc# 13689 Filed: 04/27/23 Entered: 04/27/23 15:36:38 Page 3

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