EXHIBIT 1

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B2570 (Form 2570 – Subpoena to Produce Documents, Information, or Objects or To Permit Inspection in a Bankruptcy Case or Adversary Proceeding) (Page 2)

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)

I received this subpoena for (name of individual and title, if any): ______________________________________________ 

on (date) __________ .

I served the subpoena by delivering a copy to the named person as follows: ____________________________________

___________________________________________________________________________________________________

__________________________________ on (date) ___________________ ; or 

I returned the subpoena unexecuted because: ____________________________________________________________

___________________________________________________________________________________________________

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the 

witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of $ _______________________ .

My fees are $ _________ for travel and $_________ for services, for a total of $_________ .

I declare under penalty of perjury that this information is true and correct.

Date: _______________

________________________________________________

Server’s signature

________________________________________________

Printed name and title

________________________________________________

Server’s address

Additional information concerning attempted service, etc.:

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B2570 (Form 2570 – Subpoena to Produce Documents, Information, or Objects or To Permit Inspection in a Bankruptcy Case or Adversary Proceeding) (Page 3)

Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13)

(made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)

(c) Place of compliance.

 (1) For a Trial, Hearing, or Deposition. A subpoena may command a 

person to attend a trial, hearing, or deposition only as follows:

 (A) within 100 miles of where the person resides, is employed, or 

regularly transacts business in person; or 

 (B) within the state where the person resides, is employed, or regularly 

transacts business in person, if the person 

 (i) is a party or a party’s officer; or

 (ii) is commanded to attend a trial and would not incur substantial 

expense.

 (2) For Other Discovery. A subpoena may command:

 (A) production of documents, or electronically stored information, or 

things at a place within 100 miles of where the person resides, is employed, 

or regularly transacts business in person; and

 (B) inspection of premises, at the premises to be inspected.

(d) Protecting a Person Subject to a Subpoena; Enforcement.

(1) Avoiding Undue Burden or Expense; Sanctions. A party or 

attorney responsible for issuing and serving a subpoena must take 

reasonable steps to avoid imposing undue burden or expense on a person 

subject to the subpoena. The court for the district where compliance is 

required must enforce this duty and impose an appropriate sanction —

which may include lost earnings and reasonable attorney's fees — on a 

party or attorney who fails to comply.

 (2) Command to Produce Materials or Permit Inspection.

 (A) Appearance Not Required. A person commanded to produce 

documents, electronically stored information, or tangible things, or to 

permit the inspection of premises, need not appear in person at the place of 

production or inspection unless also commanded to appear for a deposition, 

hearing, or trial.

 (B) Objections. A person commanded to produce documents or tangible 

things or to permit inspection may serve on the party or attorney designated 

in the subpoena a written objection to inspecting, copying, testing or 

sampling any or all of the materials or to inspecting the premises — or to 

producing electronically stored information in the form or forms requested. 

The objection must be served before the earlier of the time specified for 

compliance or 14 days after the subpoena is served. If an objection is made, 

the following rules apply:

 (i) At any time, on notice to the commanded person, the serving party 

may move the court for the district where compliance is required for an 

order compelling production or inspection.

 (ii) These acts may be required only as directed in the order, and the 

order must protect a person who is neither a party nor a party's officer from 

significant expense resulting from compliance.

 (3) Quashing or Modifying a Subpoena.

 (A) When Required. On timely motion, the court for the district where 

compliance is required must quash or modify a subpoena that:

 (i) fails to allow a reasonable time to comply; 

 (ii) requires a person to comply beyond the geographical limits 

specified in Rule 45(c);

 (iii) requires disclosure of privileged or other protected matter, if no 

exception or waiver applies; or

 (iv) subjects a person to undue burden.

 (B) When Permitted. To protect a person subject to or affected by a 

subpoena, the court for the district where compliance is required may, on 

motion, quash or modify the subpoena if it requires:

 (i) disclosing a trade secret or other confidential research, 

development, or commercial information; or

 (ii) disclosing an unretained expert's opinion or information that does 

not describe specific occurrences in dispute and results from the expert's 

study that was not requested by a party.

 (C) Specifying Conditions as an Alternative. In the circumstances 

described in Rule 45(d)(3)(B), the court may, instead of quashing or 

modifying a subpoena, order appearance or production under specified 

conditions if the serving party:

 (i) shows a substantial need for the testimony or material that cannot 

be otherwise met without undue hardship; and

 (ii) ensures that the subpoenaed person will be reasonably 

compensated.

(e) Duties in Responding to a Subpoena.

 (1) Producing Documents or Electronically Stored Information. These 

procedures apply to producing documents or electronically stored 

information:

 (A) Documents. A person responding to a subpoena to produce 

documents must produce them as they are kept in the ordinary course of 

business or must organize and label them to correspond to the categories in 

the demand.

 (B) Form for Producing Electronically Stored Information Not 

Specified. If a subpoena does not specify a form for producing 

electronically stored information, the person responding must produce it in 

a form or forms in which it is ordinarily maintained or in a reasonably 

usable form or forms.

 (C) Electronically Stored Information Produced in Only One Form. The 

person responding need not produce the same electronically stored 

information in more than one form.

 (D) Inaccessible Electronically Stored Information. The person 

responding need not provide discovery of electronically stored information 

from sources that the person identifies as not reasonably accessible because 

of undue burden or cost. On motion to compel discovery or for a protective 

order, the person responding must show that the information is not 

reasonably accessible because of undue burden or cost. If that showing is 

made, the court may nonetheless order discovery from such sources if the 

requesting party shows good cause, considering the limitations of Rule 

26(b)(2)(C). The court may specify conditions for the discovery.

 (2) Claiming Privilege or Protection.

 (A) Information Withheld. A person withholding subpoenaed 

information under a claim that it is privileged or subject to protection as 

trial-preparation material must:

 (i) expressly make the claim; and

 (ii) describe the nature of the withheld documents, communications, 

or tangible things in a manner that, without revealing information itself 

privileged or protected, will enable the parties to assess the claim.

 (B) Information Produced. If information produced in response to a 

subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that 

received the information of the claim and the basis for it. After being 

notified, a party must promptly return, sequester, or destroy the specified 

information and any copies it has; must not use or disclose the information 

until the claim is resolved; must take reasonable steps to retrieve the 

information if the party disclosed it before being notified; and may 

promptly present the information under seal to the court for the district 

where compliance is required for a determination of the claim. The person 

who produced the information must preserve the information until the claim 

is resolved.

...

(g) Contempt. The court for the district where compliance is required – and 

also, after a motion is transferred, the issuing court – may hold in contempt 

a person who, having been served, fails without adequate excuse to obey 

the subpoena or an order related to it.

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)

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EXHIBIT A 

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DEFINITIONS 

1. “BrownGreer PLC” and/or “BrownGreer” refers to the claims administration firm

that has been appointed pursuant to Case Management Order 5 in the California North Bay Fire 

Cases to “collect and organize case-specific information of common interest to plaintiffs’ counsel in 

a central repository to facilitate and track compliance with previously established Case Management 

Orders in that case”. Declaration of Philip R. Strunk in Support of Objection of the Official 

Committee of Tort Claimants to Motion of the Debtors for Order (I) Establishing Deadline for Filing 

Proofs of Claim, (II) Establishing the Form and Manner of Notice Thereof, and (III) Approving 

Procedures for Providing Notice of Bar Date and Other Information to All Creditors and Potential 

Creditors (DKT. No. 1784) (Dkt. 2306-6, at ¶ 4). 

2. “BrownGreer Portal” refers to an 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 claims-related information, uploaded by 

law firms representing individual claimants related to their wildfire-related claims. 

3. “Chapter 11 Cases” means the cases initiated by the Debtors on January 29, 2019,

under chapter 11 of the Bankruptcy Code (Bankruptcy Case Nos. 19-30088 (lead case) and 19-

30089), as well as all other associated actions, cases, and proceedings in the Bankruptcy Court, 

including, without limitation, Bankruptcy Case Nos. 19-03003, 19-03005, 19-03006, 19-03006, 19-

03008, 19-03015, 19-03037, and 19-03039. 

4. “Communications” means all inquiries, discussions, conversations, negotiations,

agreements, understandings, meetings, telephone conversations, letters, notes, telegrams, 

correspondence, memoranda, emails, facsimile transmissions, or other form of verbal, written, 

mechanical, or electronic disclosure, in the control or custody of BrownGreer. 

5. “Debtors” means Debtor Pacific Gas & Electric Company and Debtor PG&E

Corporation, both collectively and individually as a single Debtor. 

6. “Documents” means any writings, recordings, electronic files and mails, or

photographs, whether original or duplicate, as defined in Federal Rule of Evidence 1001 and Federal 

Rule of Civil Procedure 34(a), inclusively, including (but not limited to) all documents and 

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information in BrownGreer’s possession, custody, or control, and includes: all and any written, 

recorded, or graphic material, however produced or reproduced, minutes, summaries, memoranda, 

transcripts, tapes, or other voice recordings, and all other documents and tangible things, including 

booklets, brochures, pamphlets, circulars, notices, periodicals, papers, records, contracts, 

agreements, photographs, minutes, memoranda, messages, appraisals, analyses, reports, files, 

interoffice memoranda, or interoffice communications of any description, calculations, invoices, 

accounting entries, diary entries, calendars, inventory sheets, ledgers, correspondence, emails, phone 

recordings, instant messages, text messages, telegrams, advertisements, press releases, notes, letters, 

diaries, working papers, schedules, projections, graphs, charts, films, tapes, print-outs, and all other 

data, whether recorded by electronic or other means, and all drafts thereof. If a Document was 

prepared in several copies, or if additional copies were thereafter made, and if any such copies are 

not identical in all respects or are no longer identical by reason of subsequent notation or 

modification of any kind whatsoever, including notes on the front or back, in the margins, or on any 

of the pages thereof, then each such non-identical copy is a separate Document and must be 

produced. When examples of categories or types of Documents are given in a particular Request by 

use of phrases such as “including,” this shall always be interpreted as being for illustrative purposes 

only (i.e., to be understood as “including without limitation”) and in no way limits or narrows the 

scope of any request. “Documents” always include Communications, whether so-stated in a 

particular Request or not. 

7. “Electronically Stored Information” or “ESI” means the following types of 

electronic data and data compilations in the custody and/or control of BrownGreer: 

a. All electronic mail and information about electronic mail sent or received by 

BrownGreer; 

b. All databases containing and/or referencing information; 

c. All activity logs on any computer system which may have been used to 

process or store electronic data containing information; 

d. All word processing files and file fragments, including metadata, containing 

information about the below listed topic; 

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e. All electronic data files and file fragments created by application programs 

that process information requested herein; 

f. All electronic data files and file fragments from electronic calendars and 

scheduling programs that contain information about the below listed topic; and 

g All audio and video recordings sent, received or stored by BrownGreer that 

contain, reference or otherwise identify information about the below listed topic. 

 

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INSTRUCTIONS 

 1. All Documents and ESI described below shall be made available in the same manner 

in which they are made available to the individual law firms who currently have access to the 

BrownGreer Portal, including via authorized usernames and secure login passwords which shall be 

provided to Debtors to access the BrownGreer Portal. 

2. The following rules of construction apply to all Requests: 

a. The terms “any,” “all,” “each,” and “every” should be understood in either their 

most or least inclusive sense as necessary to bring within the scope of a Request all information that 

might otherwise be construed to be outside of its scope. 

b. The terms “and” and “or” shall be construed either disjunctively or 

conjunctively as necessary to bring within the scope of a Request all information that might otherwise 

be construed to be outside of its scope. 

c. The terms “concern,” “concerning,” “relate,” and “relating to” shall be 

construed as broadly as possible and shall mean and include, without limitation, constituting, 

comprising, setting forth, summarizing, reflecting, stating, supporting, weakening, describing, 

recording, noting, embodying, mentioning, studying, analyzing, discussing, or evaluating, directly or 

indirectly. 

3. Produce all Documents described below which are in Your possession, custody, or 

control, including those Documents in the possession, custody, or control of Your present or former 

attorneys or counsel, advisors, investigators, accountants, employees or other agents, as well as any 

other Person(s) acting on Your behalf, wherever located and in whatever form they may exist. 

4. Produce all Documents in their entirety, without deletion or excision, and along with 

any attachments, regardless of whether You consider the entirety of any such Documents or 

attachments to be responsive to any Request. 

5. All Documents produced shall be Bates stamped to facilitate identification and future 

reference. 

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6. In objecting to any Request, identify the specific grounds for the objection and the part 

of the Request objected to, and shall state with specificity which Documents will be withheld and 

which Documents will be produced notwithstanding such objection. 

7. If any Document responsive to these Requests is withheld or redacted by You under a 

claim of privilege, provide a privilege log describing the basis for the claim of privilege and all 

information necessary for the Debtors and the Court to assess the claim of privilege. The privilege 

log shall include the following: 

a. Specific grounds for the claim of privilege; 

b. The date of the privileged communication; 

c. The Persons involved in the privileged communication; 

d. A description of the subject matter of the privileged communication in 

sufficient detail to assess the claim of privilege; and 

e. The Request(s) to which the privileged information is responsive. 

8. If in answering these Requests You claim any ambiguity in interpreting either a request 

or a Definition or Instruction applicable thereto, such claim shall not be utilized by You as a basis for 

refusing to respond, but You shall set forth as part of Your response to such Request the language 

deemed to be ambiguous and the interpretation chosen to be used in responding to the Request. 

9. If You are unable to answer or respond fully to any Request, answer or respond to the 

extent possible and specify the reason(s) for Your inability to answer or respond in full. If You have 

no Documents responsive to a particular Request, so state. 

10. If any responsive Document has been destroyed, set forth the contents of the Document, 

the reason for and date of its destruction, the name of the person who authorized its destruction, and 

the Request(s) to which it was responsive. If any responsive Document is otherwise not available or 

accessible in the full detail requested, provide sufficient explanation of the reasons therefor, as well as 

all Documents available or accessible. 

11. These Requests are continuing in nature, such that a supplemental response is required 

if and when You discover, obtain, or recollect other or further information responsive to any Request. 

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In addition, You must amend the answer to any Request if and when You discover or ascertain that 

the answer was incorrect when made or that the answer is no longer correct. 

 

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DOCUMENT REQUESTS 

1. All Documents and ESI contained in and/or accessible through the BrownGreer

Portal. 

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