EXHIBIT D

Case: 19-30088 Doc# 4235-4 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 1

of 5
1 UNITED STATES BANKRUPTCY COURT

2 NORTHERN DISTRICT OF CALIFORNIA

3 SAN FRANCISCO DIVISION

4

5 _________________________________

6 In re: )

 )

7 PG&E CORPORATION, )

8 and ) No. 19-30088 (DM)

9 PACIFIC GAS AND ELECTRIC COMPANY,) Chapter 11

10 Debtors. )

11 _________________________________)

12 

13

14 VIDEOTAPED 30(b)(6) DEPOSITION OF JASON WELLS

15 San Francisco, California

16 Friday, October 11, 2019

17 Volume I

18

19

20 Reported by:

21 CATHERINE A. RYAN, RMR, CRR

22 CSR No. 8239

23 Job No. 3565644

24

25 PAGES 1 - 212

Page 1

9HULWH[W/HJDO6ROXWLRQV



Case: 19-30088 Doc# 4235-4 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 2

of 5
1 UNITED STATES BANKRUPTCY COURT

2 NORTHERN DISTRICT OF CALIFORNIA

3 SAN FRANCISCO DIVISION

4

5 _________________________________

6 In re: )

7 )

8 PG&E CORPORATION, )

9 and ) No. 19-30088 (DM)

10 PACIFIC GAS AND ELECTRIC COMPANY,) Chapter 11

11 Debtors. )

12 _________________________________)

13

14

15 Videotaped 30(b)(6) deposition of

16 JASON WELLS, Volume I, taken on behalf of the

17 Official Committee of Tort Claimants, at Walkup,

18 Melodia, Kelly & Schoenberger, 650 California

19 Street, 26th Floor, San Francisco California,

20 beginning at 10:31 a.m. and ending at 4:49 p.m., on

21 Friday, October 11, 2019, before CATHERINE A. RYAN,

22 Certified Shorthand Reporter No. 8239.

23

24

25

Page 2

9HULWH[W/HJDO6ROXWLRQV



Case: 19-30088 Doc# 4235-4 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 3

of 5
1 conclusion. Also, I'm not sure this is in the 10:47:31

2 scope, but he can answer.

3 THE WITNESS: May I -- may I have a minute

4 to read it?

5 MR. RICHARDSON: Sure. 10:47:39

6 (Pause.)

7 THE WITNESS: I don't recall the purpose

8 of this provision.

9 BY MR. RICHARDSON:

10 Q Are you familiar at all with California 10:48:06

11 insurance regulations?

12 A Vaguely, as it's come up in the -- the --

13 in and around these topics.

14 Q At any point in the negotiations, did the

15 subrogation claim holders demand that a settlement 10:48:22

16 with the debtors include payment of fire victims'

17 deductibles?

18 A I don't recall that demand, but I,

19 personally, wasn't part of the settlement

20 negotiations directly as part of the process to 10:48:38

21 assess the -- what the company was willing to offer

22 and ultimately settle for.

23 Q At any time during the negotiations, did

24 you hear any discussion suggesting that the

25 subrogation claim holders intended to allocate part 10:48:52

Page 27

9HULWH[W/HJDO6ROXWLRQV



Case: 19-30088 Doc# 4235-4 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 4

of 5
1 of their settlement to fire victims' deductibles? 10:48:55

2 A I had not heard that, no.

3 MR. ORSINI: Are we done with this one?

4 MR. RICHARDSON: Yes.

5 Exhibit 4. 10:49:20

6 (Exhibit 002-BK-004 was marked for

7 identification.)

8 THE WITNESS: Thank you.

9 BY MR. RICHARDSON:

10 Q Now, I realize your name is not on this 10:49:51

11 email chain, so I won't ask you if you've seen the

12 email, but do you see in the first line where

13 there's a reference a draft of the side letter

14 agreement between the Baupost Creditors and PG&E?

15 A I see that reference in the attachments, 10:50:05

16 yes.

17 Q Are you familiar with a side letter

18 agreement between the Baupost Creditors and PG&E?

19 MR. ORSINI: Objection. Scope.

20 But you can answer. 10:50:16

21 THE WITNESS: I'm not aware of any side

22 letter agreement. I do see reference in the body of

23 the email to a Nondisclosure Agreement, and I am

24 aware of that.

25 //

Page 28

9HULWH[W/HJDO6ROXWLRQV



Case: 19-30088 Doc# 4235-4 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 5

of 5