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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

EXHIBIT D 

PROPOSED ORDER 

Case: 19-30088 Doc# 2904-7 Filed: 07/09/19 Entered: 07/09/19 12:59:18 Page 1

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

 

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 Boulevard 

Suite 1400 

Los Angeles, CA 90025 

Telephone: 310.820.8800 

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 GRANTING THE MOTION OF 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS FOR RELIEF 

FROM AUTOMATIC STAY TO 

PERMIT STATE COURT JURY TRIAL 

OF 2017 TUBBS WILDFIRE CLAIMS 

Case: 19-30088 Doc# 2904-7 Filed: 07/09/19 Entered: 07/09/19 12:59:18 Page 2

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ATTORNEYS AT LAW

SAN FRANCISCO

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Upon the Motion, dated June 26, 2019, as amended (the “Motion”),1 of the Official 

Committee of Tort Claimants (the “TCC”), pursuant to section 362(d)(1) of title 11 of the United 

States Code (the “Bankruptcy Code”), sections 1334(c) and 1452(b) of title 28, Rules 4001 and 

5011(b) of the Federal Rules of Bankruptcy Procedure and Rules 4004-1 and 9015-2(d) of the 

Bankruptcy Local Rules for the United States District Court for the Northern District of California 

for entry of an order terminating the automatic stay to permit the individuals listed on Exhibit A

hereto (the “Tubbs Preference Plaintiffs”) to proceed to a jury trial on their personal injury, 

wrongful death and related property damage claims against the Debtors arising from the 2017 

Tubbs Fire in the California Superior Court, and to request the Court in the California North Bay 

Fire Cases, JCCP 4955, to order the claims of the Tubbs Preference Plaintiffs to proceed to a jury 

trial with preference pursuant to Code of Civil Procedure section 36; and the Court having found 

and determined that notice of the Motion as provided to the parties listed therein is reasonable and 

sufficient, and it appearing that no other or further notice needs to be provided; and this Court 

having reviewed the Motion, the declarations of Steven M. Campora, Robert A. Julian, and Brent 

C. Williams, and the amended declaration of Michael A. Kelly; and this Court having held a hearing 

on the Motion; this Court having determined that the legal and factual bases set forth in the Motion 

establish just cause for the relief granted therein; and it appearing that the relief requested in the 

Motion is in the best interest of the Debtors’ 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 Motion is granted as provided herein. 

2. The automatic stay of Bankruptcy Code section 362(a) is terminated to permit the 

Tubbs Preference Plaintiffs to proceed to a jury trial on their personal injury, wrongful death and 

related property damage claims against the Debtors arising from the 2017 Tubbs Fire, and to request 

the Court in the California North Bay Fire Cases, JCCP 4955, to order the claims of the Tubbs 

 

1

 Capitalized terms used but not otherwise defined herein shall have the meanings given to them in the Motion. 

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ATTORNEYS AT LAW

SAN FRANCISCO

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Preference Plaintiffs to proceed to a jury trial with preference pursuant to Code of Civil Procedure 

section 36. 

3. The automatic stay shall not be lifted with respect to enforcement or execution on 

property of the Debtors’ estates under section 541 of the Bankruptcy Code. 

4. 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# 2904-7 Filed: 07/09/19 Entered: 07/09/19 12:59:18 Page 4

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