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DIEMER & WEI, LLP

Kathryn S. Diemer (#133977)

100 West San Fernando Street, Suite 555

San Jose, CA 95113

Telephone: 408-971-6270 

Facsimile: 408-971-6271 

Email: kdiemer@diemerwei.com

-andWILLKIE FARR & GALLAGHER LLP

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Daniel I. Forman (pro hac vice)

787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

jminias@willkie.com

dforman@willkie.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

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

(Lead Case)

(Jointly Administered)

FOURTH AMENDED VERIFIED 

STATEMENT OF THE AD HOC GROUP 

OF SUBROGATION CLAIM HOLDERS 

PURSUANT TO BANKRUPTCY RULE 

2019

Case: 19-30088 Doc# 4228 Filed: 10/16/19 Entered: 10/16/19 12:36:48 Page 1 of

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Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy 

Rules”), the ad hoc group of subrogation claim holders (“Ad Hoc Subrogation Group”), who hold 

liquidated and unliquidated insurance subrogation claims1against PG&E Corporation and Pacific 

Gas and Electric Company (the “Debtors”), relating to certain California wildfires (the “Wildfires”) 

(and other claims as detailed below), by and through its undersigned counsel, and due to changes in 

group membership or holdings, hereby submit this fourth amended verified statement (“Fourth

Amended Verified Statement”), and in support thereof, state as follows:

1. In or around January 23, 2019, the Ad Hoc Subrogation Group engaged Willkie Farr 

& Gallagher LLP (“Willkie”) to represent it in connection with the Debtors’ restructuring. On March 

20, 2019, the Ad Hoc Subrogation Group filed the Verified Statement of the Ad Hoc Group of 

Subrogation Claim Holders Pursuant to Bankruptcy Rule 2019 [Dkt. No. 971] (“Original Verified 

Statement”). On April 17, 2019, the Ad Hoc Subrogation Group filed the First Amended Verified 

Statement of the Ad Hoc Group of Subrogation Claim Holders Pursuant to Bankruptcy Rule 2019

[Dkt. No. 1482] (“First Amended Verified Statement”), which amended and replaced the Original 

Verified Statement. On July 3, 2019, the Ad Hoc Subrogation Group filed the Second Amended 

Verified Statement of the Ad Hoc Group of Subrogation Claim Holders Pursuant to Bankruptcy Rule 

2019 [Dkt. No. 2862] (“Second Amended Verified Statement”), which amended and replaced the 

First Amended Verified Statement. On July 17, 2019, the Ad Hoc Subrogation Group filed the Third 

Amended Verified Statement of the Ad Hoc Group of Subrogation Claim Holders Pursuant to 

Bankruptcy Rule 2019 [Dkt. No. 3020] (“Third Amended Verified Statement”), which amended 

1 The term “Subrogation Claims” refers broadly to any claims arising from or related to payments made by an 

insurer to or on behalf of parties insured under policies issued by such insurer who have or had claims against the Debtors 

or a Debtor relating to the insured loss on account of which such insurer payments were made (hereinafter, “Tort 

Victims”). The use of the shorthand descriptive term “subrogation” herein is not intended to modify or limit the 

substantive rights of the holder of these claims or the bases for the claimant’s right to assert claims originating with 

insured Tort Victims. These “subrogation” claims include, but are not limited to, claims that arise from subrogation 

(whether such subrogation is contractual, equitable or statutory), assignment (whether such assignment is contractual, 

equitable or statutory), or otherwise in connection with payments made or to be made by the applicable insurer to insured 

Tort Victims, and whether arising as a matter of State or federal law, including, without limitation, Section 509 of the 

Bankruptcy Code. The holder of these claims reserves its rights to assert any and all claims arising from, as a result of, 

or in connection with payments made or to be made by the claimant (or, where the claimant is the direct or indirect 

assignee of claims of an insurer, the applicable insurer (the “Assignor Insurer”)) to or on behalf of each tort victim 

insured by the claimant or by the Assignor Insurer, and to assert all such claims both cumulatively and in the alternative.

Case: 19-30088 Doc# 4228 Filed: 10/16/19 Entered: 10/16/19 12:36:48 Page 2 of

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and replaced the Second Amended Verified Statement. This Fourth Amended Verified Statement 

amends and replaces the Third Amended Verified Statement.

2. As of the date of this Fourth Amended Verified Statement, Willkie represents only the 

Ad Hoc Subrogation Group. Willkie does not represent or purport to represent any other entities in 

connection with the Debtors’ chapter 11 cases. Each member of the Ad Hoc Subrogation Group is 

aware of, and has consented to, Willkie’s “group representation” of the Ad Hoc Subrogation Group. 

No member of the Ad Hoc Subrogation Group represents or purports to represent any other entities 

in connection with these chapter 11 cases.

3. Attached hereto as Exhibit A is a list of the names and addresses of each member of 

the Ad Hoc Subrogation Group, as well as the amount of each member’s disclosable economic 

interests (as relayed to Willkie by each member). The information contained in Exhibit A is based 

upon information provided by such members to Willkie and is subject to change. 

4. The members of the Ad Hoc Subrogation Group either hold disclosable economic 

interests, or act as investment advisors or managers to funds and/or accounts or their respective 

subsidiaries that hold disclosable economic interests relating to the Debtors. In accordance with 

Bankruptcy Rule 2019 and based upon the most recent information provided to Willkie by each 

member of the Ad Hoc Subrogation Group, attached hereto as Exhibit A is a list of the names, 

addresses and nature and amount of each disclosable economic interest of each present member of 

the Ad Hoc Subrogation Group.

5. The information set forth in Exhibit A is intended only to comply with Bankruptcy 

Rule 2019 and is not intended for any other purpose. Willkie does not make any representation 

regarding the validity, amount, allowance, or priority of such economic interests and reserves all 

rights with respect thereto.

6. Nothing contained in this Fourth Amended Verified Statement (or Exhibit A) should 

be construed as a limitation upon, or waiver of, any rights of any member of the Ad Hoc Subrogation 

Group to assert, file and/or amend their claims in accordance with applicable law and any orders 

entered in these chapter 11 cases.

Case: 19-30088 Doc# 4228 Filed: 10/16/19 Entered: 10/16/19 12:36:48 Page 3 of

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7. Willkie reserves the right to amend and/or supplement this Fourth Amended Verified 

Statement in accordance with the requirements set forth in Bankruptcy Rule 2019.

Dated: October 16, 2019

Counsel to Ad Hoc Group of Subrogation Claim Holders

WILLKIE FARR & GALLAGHER LLP

/S/ Matthew A. Feldman

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Daniel I. Forman (pro hac vice)

787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

jminias@willkie.com

dforman@willkie.com

DIEMER & WEI, LLP

Kathryn S. Diemer (#133977)

100 West San Fernando Street, Suite 555

San Jose, CA 95113

Telephone: 408-971-6270 

Facsimile: 408-971-6271 

Email: kdiemer@diemerwei.com

Case: 19-30088 Doc# 4228 Filed: 10/16/19 Entered: 10/16/19 12:36:48 Page 4 of

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