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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)

David J. Richardson (SBN 168592)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Blvd., Suite 1400

Los Angeles, CA 90025-0509

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: drichardson@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)

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. §§ 105(a) AND 

501 AND FED. R. BANKR. P. 3003(c) 

FOR ENTRY OF AN ORDER 

EXTENDING THE BAR DATE

Date: November 13, 2019

Time: 9:30 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Objection Deadline: November 6, 2019

Case: 19-30088 Doc# 4292 Filed: 10/18/19 Entered: 10/18/19 15:02:47 Page 1 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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The Official Committee of Tort Claimants (the “TCC”), hereby submits this Motion 

(the “Motion”), pursuant to sections 105(a) and 501 of title 11 of the United States Code 

(the “Bankruptcy Code”) and Rule 3003(c) of the Federal Rules of Bankruptcy Procedure 

(the “Bankruptcy Rules”), for entry of an order granting the following relief:

1. An Order extending the bar date of October 21, 2019 to January 31, 2020, on the 

ground that a substantial number of fire victims have been unable to file proofs of 

claim in this case, because they erroneously believe they may not file claims, have 

not received notice of the case, and/or are physically, mentally and/or emotionally 

impaired as a result of the trauma, injuries and living conditions caused by the 

Debtors’ fires.

2. In the alternative, an Order extending the bar date of October 21, 2019 to December 

5, 2019; appointing an independent Court-Appointed Expert pursuant to Fed. R. 

Evid. 706 to investigate the extent to which fire victims have not received notice of 

the current bar date, erroneously believe they may not file claims in this case, and/or 

are physically, mentally or emotionally impaired from filing claims by the current 

or extended bar date; and extending the bar date past December 5, 2019, up through 

a maximum extension of January 31, 2020, to the extent the Court determines 

following receipt of the Court-Appointed Expert’s report that there is cause for such 

a further extension.

3. An Order appointing a Court-Appointed Fiduciary to educate the fire victims and to 

assist the fire victims to file claims, to the extent the Fiduciary determines the 

victims are under physical, mental or emotional circumstances that impair their 

ability to file claims without assistance.

In support of the Motion, the TCC submits the Declarations of Richard Barton (the “Barton 

Declaration”), Mikko Bojarsky (the “Bojarsky Declaration”), Lynda Bradway (the “Bradway 

Declaration”), Nathanial Brown (the “Brown Declaration”), Samantha Chocktoot (the 

“Chocktoot Declaration”), Elizabeth Davis (the “Davis Declaration”), Marjorie Everidge (the 

“Everidge Declaration”), Brooke Gardner (the “B Gardner Declaration”), Mary Gardner 

Case: 19-30088 Doc# 4292 Filed: 10/18/19 Entered: 10/18/19 15:02:47 Page 2 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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(the “M Gardner Declaration”), Patricia Garrison (the “Garrison Declaration”), Ryan Mooney 

(the “Mooney Declaration”), Dr. Scheherazade Shamsavari (the “Shamsavari Declaration”) 

Steven Thomas (the “Thomas Declaration”), Roger K. Pitman, M.D. (the “Pitman Declaration”), 

James Drinkhall (the “Drinkhall Declaration”) and Robert A. Julian (the “Julian Decl.”) filed 

contemporaneously herewith. A proposed form of order granting the relief requested herein is 

attached hereto as Exhibit A (the “Proposed Order”). 

Dated: October 18, 2019

BAKER & HOSTETLER LLP

By: /s/ Robert Julian

Robert Julian

Counsel for The Official Committee of Tort 

Claimants

Case: 19-30088 Doc# 4292 Filed: 10/18/19 Entered: 10/18/19 15:02:47 Page 3 of

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