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WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice)

(stephen.karotkin@weil.com)

Ray C. Schrock, P.C. (pro hac vice)

(ray.schrock@weil.com)

Jessica Liou (pro hac vice)

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice)

(matthew.goren@weil.com)

767 Fifth Avenue

New York, NY 10153-0119

Tel: 212 310 8000

Fax: 212 310 8007

Keller & Benvenutti LLP

Tobias S. Keller (#151445)

(tkeller@kellerbenvenutti.com)

Jane Kim (#298192)

(jkim@kellerbenvenutti.com)

650 California Street, Suite 1900

San Francisco, CA 94108

Tel: 415 496 6723

Fax: 650 636 9251

Attorneys for Debtors

and Debtors in Possession

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice)

(pzumbro@cravath.com)

Kevin J. Orsini (pro hac vice)

(korsini@cravath.com)

Omid H. Nasab (pro hac vice)

(onasab@cravath.com)

825 Eighth Avenue

New York, NY 10019

Tel: 212 474 1000

Fax: 212 474 3700

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION,

 - and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

ORDER RE: THE PRODUCTION OF THE 

BROWN GREER DATABASE

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). 

Signed and Filed: September 17, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

September 17, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 3922 Filed: 09/17/19 Entered: 09/17/19 17:16:36 Page 1 of

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The parties to the state court proceedings (JCCP No. 4955 California North Bay Fire 

Cases), negotiated a series of integrated orders entered by Judge Curtis Karnow, coordination 

judge JCCP 4955, parts of which addressed information concerning claimant specific damages.1 

The Debtors and the Tort Claimants Committee (the “TCC”) have agreed to adopt many of the 

claimant-specific systems, procedures and individual protections ordered in the state court in 

relation to the BrownGreer Portal. The “BrownGreer Portal” refers to the online repository that 

was used previously in the state court proceedings (JCCP No. 4955 California North Bay Fire 

Cases), and now as part of these Chapter 11 Cases, to store plaintiff-specific damages and claimsrelated information, uploaded by law firms representing individual claimants related to their firerelated claims.2

 The BrownGreer Portal contains claimant specific information that can aid the 

parties in pursuing claimant specific valuation efforts aimed at achieving a consensual resolution 

of all wildfire claims. BrownGreer does not independently value individual cases. While reports 

that can be generated from the BrownGreer Portal identifying basic information about the wildfire 

claims that are being asserted against the Debtors will not themselves provide any party to these 

Chapter 11 Cases the answer to the global value of tort claims, the exchange of those reports from 

the BrownGreer database will represent an important step in the process towards providing 

relevant information that may facilitate a consensual resolution. As reflected in the attached 

agreement, additional information will need to be entered into BrownGreer to further these efforts. 

IT IS HEREBY ORDERED THAT: 

1. Immediately upon entry of this stipulated order, and subject to the terms of this 

stipulation and order, BrownGreer shall commence efforts to create secure portals for the Debtor, 

the TCC and the Unsecured Creditors Committee (“UCC”). 

2. The first reports from the BrownGreer Portal will be produced to the Debtor, TCC 

 1 The parties to the state court orders included the debtor, the individual plaintiffs, the insurance 

carriers, and the public entities. 

2 The insurance carriers and the individual plaintiffs previously agreed to continue the state court 

systems in this bankruptcy and apply the same systems to the Camp Fire. The individual 

plaintiffs continued to work within the BrownGreer Portal in order to provide the claimants a 

better opportunity for inclusion and participation in this bankruptcy and to obtain important 

insurance data and information under CMO 5. 

Case: 19-30088 Doc# 3922 Filed: 09/17/19 Entered: 09/17/19 17:16:36 Page 2 of

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and the UCC on September 16th subject to the terms of the agreement. 

3. The Ad Hoc Equity Group represented by the Jones Day firm may have access to 

BrownGreer reports through the Debtor, and the Ad Hoc Committee of Senior Unsecured 

Noteholders represented by the Akin Gump firm may have access to BrownGreer reports through 

the UCC. 

4. Access will be subject to confidentiality agreements and protective orders with 

respect to the case specific information. 

5. The full terms of the agreement between the TCC and the Debtors are attached as 

Exhibit A to this stipulation and proposed order. 

6. The TCC and the Debtor have agreed to meet and confer to discuss formal claimant 

specific damages discovery that may be necessary in connection with estimation proceedings in 

the absence of a consensual resolution. (See Paragraph 9 to the Attached Agreement).

** END OF ORDER **

Case: 19-30088 Doc# 3922 Filed: 09/17/19 Entered: 09/17/19 17:16:36 Page 3 of

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