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XAVIER BECERRA, SBN 118517

Attorney General of California 

MARGARITA PADILLA, SBN 99966 

Supervising Deputy Attorney General 

JAMES POTTER, SBN 166992 

Deputy Attorney General 

1515 Clay Street, 20th Floor 

P.O. Box 70550 

Oakland, CA 94612-0550 

Telephone: (510) 879-0815 

Fax: (510) 622-2270 

Margarita.Padilla@doj.ca.gov 

James.Potter@doj.ca.gov 

STEVEN H. FELDERSTEIN, SBN 059678 

PAUL J. PASCUZZI, SBN 148810 

FELDERSTEIN FITZGERALD 

WILLOUGHBY PASCUZZI & RIOS LLP 

500 Capitol Mall, Suite 2250 

Sacramento, CA 95814 

Telephone: (916) 329-7400 

Fax: (916) 329-7435 

sfelderstein@ffwplaw.com 

ppascuzzi@ffwplaw.com 

Attorneys for California Department of Forestry 

and Fire Protection, et al. 

XAVIER BECERRA, SBN 118517

Attorney General of California 

DANETTE VALDEZ, SBN 141780 

ANNADEL ALMENDRAS, SBN 

192064 

Supervising Deputy Attorneys General 

455 Golden Gate Avenue, Suite 11000 

San Francisco, CA 94102-7004 

Telephone: (415) 510-3367 

Fax: (415) 703-5480 

Danette.Valdez@doj.ca.gov 

Annadel.Almendras@doj.ca.gov 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

- and – 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors.

Bankruptcy Case

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

 Affects PG&E Corporation 

 Affects Pacific Gas and 

Electric Company 

 Affects both Debtors 

Date: August 14, 2019 

Time: 9:30 a.m. 

Ctrm: 17 

Judge: Dennis Montali 

RESPONSE OF THE CALIFORNIA STATE AGENCIES TO DEBTORS’ MOTION 

PURSUANT TO 11 U.S.C. §§ 105(a) AND 502(c) FOR THE ESTABLISHMENT OF 

WILDFIRE CLAIMS ESTIMATION PROCEDURES [DOCKET NO. 3091]

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The California Department of Forestry and Fire Protection (“CAL FIRE”), California 

Department of Toxic Substances Control (“DTSC”), California Governor’s Office of Emergency 

Services (“Cal OES”), California Department of Veterans Affairs (“CalVet”), California State 

University (“Cal State University”), and California Department of Parks and Recreation (“State 

Parks”) (collectively, the “California State Agencies”) hereby file this response to the Debtors’ 

motion to establish procedures for the estimation of Wildfire Claims1

 (the “Estimation Motion”) 

[Docket No. 3019] based on the following: 

INTRODUCTION 

1. The California State Agencies appreciate the need for urgency to resolve the 

Debtors’ bankruptcy proceedings pursuant to a chapter 11 plan by June 30, 2020, so that the 

Debtors can participate in the Wildfire Fund created by the recently enacted legislation in A.B. 

1054. However, any process for estimation of Wildfire Claims must be fair and equitable to all, 

including any agencies of the state of California, to the extent any such agencies hold Wildfire 

Claims that are “unliquidated” or “contingent” under section 502(c). 

2. With respect to Phase 3 of the proposed estimation process, and as discussed in 

more detail below, the California State Agencies filing this response believe they will not have 

unliquidated or contingent Wildfire Claims within the meaning of section 502(c) of the 

Bankruptcy Code. However, because the California State Agencies are still in the process of 

preparing their claims, there is a chance that some state agency claims might fall within the 

purview of section 502(c), and therefore, the California State Agencies file this response. In 

addition, the California State Agencies do not know whether the Debtors or Committees will 

contend that any Wildfire-related claims held by the state agencies are unliquidated or contingent 

and subject to estimation. If so, the Court will need to determine whether such claims are 

unliquidated or contingent. For these reasons, the California State Agencies (and any other state 

agency that may be determined to hold an unliquidated or contingent Wildfire Claim) reserve the 

right to participate in further court proceedings regarding the fair and proper procedures for Phase 

1

 Capitalized terms not otherwise defined shall have the same meaning as in the Estimation 

Motion. 

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3 of the estimation process. 

3. The California State Agencies also reserve the right to brief the issues raised in 

Phase 1 (inverse condemnation determination) and Phase 2 (Tubbs Fire liability). In addition, 

CAL FIRE is concerned about the potential discovery burden on it, particularly with respect to 

the determination of the Debtors’ liability for the Tubbs Fire, but also with respect to the other 

Wildfires. As set forth below, CAL FIRE requests the assistance of this Court to coordinate 

discovery directed at CAL FIRE to minimize duplication, unnecessary expense, and undue 

burden on CAL FIRE. 

4. The California State Agencies share the Court’s concerns and questions expressed 

at the hearing on July 24, 2019, regarding the lack of clarity in the Debtors’ Estimation Motion as 

to the purpose and effect of the proposed estimation process. If the Debtors intend to use the 

proposed estimation process to cap the ultimate distribution to Wildfire Claims under a chapter 11 

plan, many issues arise, including but not limited to absolute priority rule issues. The California 

State Agencies also submit that estimation should be focused on the tort victims’ Wildfire Claims, 

and not be used to limit state agency claims such as fire suppression, regulatory and police power, 

and environmental remediation claims, as more specifically described below.2

 Thus, the 

California State Agencies reserve the right to object, argue, and comment further once the 

Debtors answer the Court’s questions and/or in connection with confirmation of any chapter 11 

plan. 

RESPONSE 

A. Claims of California State Agencies Not Subject to Section 502(c) Estimation 

5. Bankruptcy Code section 502(c) permits the bankruptcy court to, among other 

things, estimate “any contingent or unliquidated claim, the fixing or liquidation of which, as the 

case may be, would unduly delay the administration of the case [.]” 11 U.S.C. § 502(c)(1). 

6. Under Ninth Circuit authority, “whether a debt is liquidated turns on whether it is 

2

 Indeed, when discussing the Wildfire Claims to be estimated, the Motion refers to the “[t]ens of 

thousands of California residents whose lives have been affected by the Wildfires,” “actual 

damages suffered by the victims,” and “compensating victims who deserve compensation.” 

Motion at pp. 1:7-8; 2:1; and 2:17-18. 

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subject to ‘ready determination and precision in computation of the amount due.’” In re Fostvedt, 

823 F.2d 305, 306 (9th Cir. 1987) (referring to the term “liquidated” as used in section 109(e)) 

(citations omitted). That same definition has been used in the context of interpreting 

“unliquidated” for section 502(c) purposes. In re Audre, Inc., 202 B.R. 490 (Bankr. S.D. Cal. 

1996). 

7. “[A] contingent debt is ‘one which the debtor will be called upon to pay only upon 

the occurrence or happening of an extrinsic event which will trigger the liability of the debtor to 

the alleged creditor.’” Fostvedt, 823 F.2d at 306 (citations omitted). “[A] debt is noncontingent 

if all events giving rise to liability occurred prior to the filing of the bankruptcy petition.” 

Nicholes v. Johnny Appleseed (In re Nicholes), 184 B.R. 82, 88 (B.A.P. 9th Cir. 1995) (citing 

Fostvedt). As the Nicholes court explained: 

A tort claim ordinarily is not contingent as to liability; the events that gave rise to 

liability to the tort claim usually have occurred and liability is not dependent on 

some future event that may never happen. It is immaterial that the tort claim is not 

adjudicated or liquidated, or that the claim is disputed, or indeed that it has any of 

the many other characteristics of claims under the Code. 

Nicholes, 184 B.R. at 88 n.7 (citation omitted). The Nicholes analysis has been applied with 

respect to interpreting “contingent” for section 502(c) purposes. Audre, Inc., 202 B.R. at 492. 

8. While the California State Agencies are still in the process of determining claims, 

most, if not all, of the California State Agencies’ respective claims are NOT contingent or 

unliquidated and thus are NOT subject to estimation. Below is a brief description of the types of 

Wildfire-related claims that the California State Agencies may have:3

a. CAL FIRE: Under California law, CAL FIRE is charged with “fire

protection, fire prevention . . . of the state’s forest, range, and brushland resources . . . associated 

emergency services, and assistance in civil disasters and other nonfire emergencies” and 

“[e]nforcing forest and fire laws” in California. Cal. Pub. Res. Code §§ 713, 714. CAL FIRE’s 

fire protection responsibilities include regularly responding to fire emergencies throughout the 

3

 As noted, the California State Agencies reserve all rights with respect to the claims to be 

asserted in their official proofs of claim, and the descriptions and statements herein shall not be 

considered an admission or other limitation on the claims that may be asserted against the Debtors 

or any other responsible parties with respect to the Wildfires.

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state. CAL FIRE also bears responsibility for investigating the origin and cause of fires that 

occur in its jurisdiction. 

California Health and Safety Code sections 13009 and 13009.1 authorize CAL 

FIRE to recover certain costs from persons who, negligently or in violation of the law, “set[] a 

fire, allow[] a fire to be set, or allow[] a fire kindled or attended by him or her to escape onto any 

public or private property.” Cal. Health & Safety Code §§ 13009, 13009.1. Recoverable costs 

include costs incurred in fighting and suppressing the fire, costs of rescue and emergency medical 

services, investigation costs, and accounting costs. Id. §§ 13009(a), 13009.1(a). The costs are 

recoverable from the responsible party “in the same manner as . . . an obligation under a contract, 

express or implied.” Id. §§ 13009(a), 13009.1(e). 

CAL FIRE’s claims for cost recovery arising out of the Wildfires are liquidated 

because they are both readily determinable and are precise computations of the amount due to 

CAL FIRE. It is CAL FIRE’s practice to complete internal processes that precisely compute the 

amount of CAL FIRE’s cost recovery claims with respect to each fire incident at issue. After a 

fire has been suppressed, a CAL FIRE employee initiates the Activity Reporting Costs (“ARC”) 

Summary for the fire, which is prepared using a CAL FIRE internal ARC software program. The 

ARC software program imports qualifying, recoverable costs associated with the incident from 

various accounting programs and processes at CAL FIRE, and once all appropriate costs have 

been imported, CAL FIRE personnel begin a review and audit of the imported costs associated 

with the fire. During this review, CAL FIRE personnel collect all finance documents related to 

the incident, confirm those documents correspond to the charges in the ARC, and adjust the costs 

claimed in the ARC to ensure compliance with CAL FIRE’s cost recovery policies. If a cost is 

not clearly supported by back-up finance documents or not clearly incurred in relation to the 

particular fire, CAL FIRE personnel make the cost “not billable,” manually writing it off of the 

ARC. In this way, CAL FIRE personnel review and analyze each and every line item charged to 

a specific fire. 

Once finished, the ARC package, consisting of the ARC Summary, supporting 

ARC Summary documents, and supporting finance documents, becomes CAL FIRE’s record of 

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recoverable costs related to a specific incident. A complete ARC package lays the foundation for 

both the reasonableness and amount of CAL FIRE’s costs, as required under CAL FIRE’s cost 

recovery statute, and California courts have held that CAL FIRE’s ARC “conclusively 

established” the amount CAL FIRE expended in recoverable fire suppression and investigation 

activities. People v. Southern Cal. Edison Co., 56 Cal. App. 3d 593, 602-607 (1976). And, the 

costs described in CAL FIRE’s ARCs are generally not subject to substantial revision because 

defendants opposing CAL FIRE’s cost recovery claims cannot make arguments of comparative 

fault or mitigation of damages to reduce CAL FIRE’s costs described in the ARC. People ex rel. 

Grijalva v. Superior Court, 159 Cal. App. 4th 1072, 1077-78 (2008). Accordingly, CAL FIRE’s 

ARC-backed cost recovery claims are liquidated for the purposes of the Debtors’ bankruptcy 

proceedings. 

b. CalVet: CalVet will assert claims for property damage as a result of the 

Butte and Camp fires. These claims are liquidated and are not contingent because they are for 

amounts already paid to veterans for their property losses or are for discrete property damage to 

property owned by CalVet. These amounts are readily determinable in precise amounts based on 

checks paid to the veterans or cost estimates of labor and materials to rebuild, repair, and clean up 

the damaged property. 

c. California State University: The Cal State University will assert claims for 

property damage, economic loss, and emergency response costs arising out of the Tubbs fire and 

Camp fire. These claims are likely liquidated and are not contingent because the amounts owed 

have been determined in precise amounts based on amounts already expended. 

d. Cal OES: Cal OES is responsible for the coordination of overall state 

agency response to disasters, including wildfires and assisting local governments with recovery. 

Cal OES acts as the “grantee” for federally funded disasters and as “grantor” for the California 

Disaster Assistance Program. Cal OES ensures state and federal support are provided through 

various state and local agencies’ emergency services. Those services included debris removal, 

/// 

/// 

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 emergency protective measures,4

 police patrols of evacuated areas, traffic control, repair of 

damaged public property, and administration and coordination of emergency services. As part of 

its mandate, Cal OES likely will assert direct and indirect reimbursement claims against the 

Debtors for emergency services provided during the various Wildfires. These claims will be 

based on amounts Cal OES expended. These amounts are expected to be liquidated and are not 

contingent. 

e. DTSC: DTSC has police and regulatory powers to enforce environmental 

laws regarding, inter alia, contamination from the release or threatened release of hazardous 

substances, including the releases of hazardous substances caused by the Debtors from the 

Wildfires. Cal. Health & Safety Code §§ 25100, 25300. DTSC is one of the California state 

agencies with authority over the cleanup of contaminated sites. DTSC incurred costs in 

responding to the releases of hazardous substances from the Wildfires, including removing 

hazardous substances from residences and other buildings damaged in a Wildfire. Similar to 

CAL FIRE, DTSC’s response costs are determinable and are therefore liquidated. DTSC 

employs a detailed process to track costs and employee time for responding to cleanup of 

hazardous substances at each site. 

f. State Parks: State Parks has a contract claim against the Debtors for failure 

to pay on a contract. The Debtors entered into a contract with State Parks for use of a state park 

as a staging area for the Camp Fire. The Debtors issued a check, but cancelled it upon the filing 

of the bankruptcy. In addition, State Parks will assert claims for economic loss, environmental 

4

 The regulations promulgated pursuant to the California Disaster Assistance Act (Gov. Code 

§ 8680, et seq.) define “emergency protective measures” to include “search and rescue, 

demolition of unsafe structures, warning of further risks and hazards, public information on health 

and safety measures, and actions necessary to remove or to reduce immediate threats to public 

property, or to private property when in the public interest, or temporary protective measures 

designed to protect public or private property from further damage.” Cal. Code Regs., tit. 19, 

§ 2930, subd. (b). “[T]emporary repairs to damaged buildings or structures,” and “reimbursement 

for the demolition of a damaged public facility,” are two of several express examples of 

emergency protective measures. Cal. Code Regs., tit. 19, § 2930, subds. (d)(2), (d)(4). The 

regulations promulgated under the Robert T. Stafford Disaster Relief and Emergency Assistance 

Act (42 U.S.C. § 5121 et seq.) define “emergency protective measures” as measures to “save 

lives, to protect public health and safety, and to protect improved property... .” Code of Federal 

Regs. tit. 44, § 206.225, subd. (a)(1). 

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work, and emergency response costs arising out of the Camp fire. Emergency response costs 

include staff time expended in assisting in evacuation of residents as well as evacuation of 

cultural resources. These claims are likely liquidated and are not contingent because the amounts 

owed have been determined in precise amounts based on amounts already expended. 

Consequently, the California State Agencies believe that their Wildfire-related claims, and 

the claims of other state agencies that are related to the Wildfires, will not be unliquidated or 

contingent, and thus should not be included as part of the estimation of Wildfire Claims as 

proposed in the Debtors’ Estimation Motion. However, it is not clear whether the Debtors’ 

Estimation Motion seeks to estimate these types of claims, which are certainly distinguishable 

from individual tort victims’ claims or subrogation claims of insurers. If the Debtors or the 

Committees dispute these characterizations, the Court will need to determine (after the bar date) 

whether particular filed claims related to the Wildfires are unliquidated or contingent. 

In the event the respective claims held by the California State Agencies are ordered 

subject to the Phase 3 estimation, the California State Agencies reserve their rights to: 

(a) participate in further Court proceedings regarding the proper and fair procedures for Phase 3; 

(b) request the appointment of an examiner or court expert under Federal Rule of Evidence 706 to 

aid the Phase 3 estimation process; and (c) object to any cap placed on unsecured Wildfire-related 

claims for distribution purposes if the cap results in not paying all valid claims in full. 

B. Anticipated Discovery Issues Related to CAL FIRE 

9. Regarding Phase 2 proposed by the Estimation Motion, the Debtors identify CAL 

FIRE as a primary source of the evidence regarding liability for the Tubbs Fire. CAL FIRE 

requests that the Debtor, the Committees, any other parties participating in Phase 2, and the Court 

as necessary, coordinate the discovery procedures to minimize the burden on CAL FIRE. It is 

already apparent that the numerous parties who have a stake in Phase 2 and Phase 3 are 

aggressively seeking information from CAL FIRE or other governmental units that work with 

CAL FIRE and are doing so in an uncoordinated, duplicative, and overly burdensome manner. 

CAL FIRE requests the Court’s assistance in ensuring a coordinated and efficient process that 

does not impose an undue burden on CAL FIRE. 

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10. An example of a need for the Court’s assistance is the recent correspondence filed 

with the Court from the Tort Claimants Committee (“TCC”) and others regarding discovery. On 

July 26, 2019, the TCC submitted a letter to this Court [Docket No. 3219] that attached a letter 

from the subrogation plaintiffs and the individual plaintiffs to the Debtors indicating that such 

plaintiffs intended to take the following depositions: (a) eight CAL FIRE employees in relation 

to the Tubbs Fire; (b) four CAL FIRE investigators in relation to the Atlas Fire; (c) the CAL 

FIRE person(s) most knowledgeable with respect to the origin area and causation of the (i) Adobe 

Fire, (ii) Norrbom Fire, (iii) Nuns Fire, (iv) Oakmont Fire, (v) Partrick Fire, and (vi) Pressley 

Fire; (d) three CAL FIRE employees in relation to the Redwood/Potter Valley Fire; (e) two CAL 

FIRE employees in relation to the Sulphur Fire; (f) CAL FIRE investigators in relation to the 

Pocket Fire; and (g) all CAL FIRE employees charged with investigating and determining the 

origin and cause of the (i) Point Fire, (ii) Highway 37 Fire, (iii) Cascade Fire, (iv) Cherokee Fire, 

(v) LaPorte Fire, (vi) Lobo Fire, (vii) McCourtney Fire, and (viii) Camp Fire. 

11. In addition to the depositions, the subrogation plaintiffs and the individual 

plaintiffs seek all native CAL FIRE Lidar, photographs, and video with respect to the (a) Tubbs 

Fire, (b) Atlas Fire, (c) Point Fire, (d) Highway 37 Fire, (e) Cascade Fire, (f) Cherokee Fire, 

(g) LaPorte Fire, (h) Lobo Fire, (i) McCourtney Fire, and (j) Camp Fire. 

12. Counsel for the SLF Fire Victim Claimants also filed a notice indicating that they 

intend to serve a subpoena on CAL FIRE on August 9, 2019, seeking the complete unredacted 

Tubbs Investigation Report, Case Number 17CALNU010045, including all unredacted 

attachments. Dkt. No. 3218. 

13. Last week, a CAL FIRE station in Butte County was served with an extremely 

broad subpoena seeking numerous categories of documents and information relating to the 2018 

Camp Fire, including documents and numerous forms of media from all first responders in the 

first two days of the Camp Fire, all communications with PG&E personnel, and a series of 

documents relating to the investigation of the cause of the Camp Fire. Dkt. No. 3341. 

14. CAL FIRE reserves all rights to object to such discovery. CAL FIRE requests the 

assistance of this Court to minimize duplicative, unnecessarily expensive, and burdensome 

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discovery aimed at CAL FIRE in this bankruptcy proceeding. As a suggestion, CAL FIRE 

believes it would be appropriate for the Court to initially limit deposition discovery of any CAL 

FIRE employees to one person per Wildfire to be identified by CAL FIRE and that any such 

depositions be limited to one day of seven hours per Wildfire. This is consistent with Federal 

Rule of Civil Procedure 30(b)(6) and (d)(1). If further depositions are necessary regarding a 

particular fire, a showing of specific need can be made by the requesting party and considered by 

the Court. With respect to written discovery, because CAL FIRE is in the position of a third party 

and these proceedings must move quickly, any written discovery should be narrowly tailored and 

focused on the key information required from CAL FIRE. Moreover, CAL FIRE must be 

allowed to redact protected personal information (e.g., social security numbers, home addresses), 

and such written discovery must provide for sufficient time for CAL FIRE to identify and 

assemble responsive documents. Further, the Court likely will need to address issues that limit 

discovery in light of the ongoing criminal investigations related to the Camp Fire. 

RESERVATION OF RIGHTS 

15. Neither this objection nor any subsequent appearance, pleading, proof of claim, 

claim or suit is intended or shall be deemed or construed as: 

a. a consent by the California State Agencies to the jurisdiction of this Court 

or any other court with respect to proceedings, if any, commenced in any case against or 

otherwise involving the California State Agencies; 

b. a waiver of any right of the California State Agencies to (i) have an 

Article III judge adjudicate in the first instance any case, proceeding, matter or controversy as to 

which a Bankruptcy Judge may not enter a final order or judgment consistent with Article III of 

the United States Constitution, (ii) have final orders in non-core matters entered only after de 

novo review by a District Court Judge, (iii) trial by jury in any proceeding so triable in the 

Chapter 11 Cases or in any case, controversy, or proceeding related to the Chapter 11 Cases, 

(iv) have the United States District Court withdraw the reference in any matter subject to 

mandatory or discretionary withdrawal, or (v) any and all rights, claims, actions, defenses, setoffs, 

recoupments or remedies to which the California State Agencies are or may be entitled under 

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agreements, in law or in equity, all of which rights, claims, actions, defenses, setoffs and 

recoupments are expressly reserved hereby; or 

c. a waiver of any objections or defenses that the State of California, the 

California State Agencies or any other agency, unit or entity of the State of California may have 

to this Court’s jurisdiction over the State of California, the California State Agencies or such 

other agency, unit or entity based upon the Eleventh Amendment to the United States 

Constitution or related principles of sovereign immunity or otherwise, all of which objections and 

defenses are hereby reserved. 

CONCLUSION 

The California State Agencies reserve their rights to: (a) have the Court determine 

whether their claims, and the Wildfire-related claims of other state agencies, are unliquidated or 

contingent, if there is a dispute over the issue; (b) brief the issues raised in Phase 1 (inverse 

condemnation determination) and Phase 2 (Tubbs Fire liability); (c) participate in further Court 

proceedings regarding the proper and fair procedures for Phase 3; (d) request consideration of the 

appointment of an examiner or court expert under Federal Rule of Evidence 706 to aid the 

Phase 3 estimation process; and (e) object to any cap placed on unsecured Wildfire-related claims 

for distribution purposes if the cap does not pay all valid claims in full. 

If the Debtors intend the proposed estimation to be used to cap the ultimate distribution to 

Wildfire Claims under a chapter 11 plan, many issues arise, including but not limited to absolute 

priority rule issues. The California State Agencies reserve the right to object, argue and comment 

further once the Debtors answer the Court’s questions and/or in connection with confirmation of 

/// 

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/// 

/// 

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any chapter 11 plan. 

In addition, CAL FIRE requests that the Court coordinate discovery aimed at CAL FIRE 

to minimize duplication, unnecessary expense and burden on CAL FIRE. 

Dated: August 7, 2019 Respectfully submitted, 

XAVIER BECERRA 

Attorney General of California 

MARGARITA PADILLA 

Supervising Deputy Attorney General 

By:/s/ Paul J. Pascuzzi_____________________________ 

STEVEN H. FELDERSTEIN 

PAUL J. PASCUZZI 

FELDERSTEIN FITZGERALD 

WILLOUGHBY PASCUZZI & RIOS LLP 

Attorneys for California Department of Forestry and 

Fire Protection, California Department of Toxic 

Substances Control, California Governor’s Office of 

Emergency Services, California Department of Veterans 

Affairs, California State University, and California 

Department of Parks and Recreation 

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PROOF OF SERVICE 

I, Lori N. Lasley, declare: 

I am a resident of the State of California and over the age of eighteen years, and not a 

party to the within action; my business address is 500 Capitol Mall, Suite 2250, Sacramento, CA 

95814. On August 7, 2019, I served the within documents: 

RESPONSE OF THE CALIFORNIA STATE AGENCIES TO DEBTORS’ 

MOTION PURSUANT TO 11 U.S.C. §§ 105(a) AND 502(c) FOR THE 

ESTABLISHMENT OF WILDFIRE CLAIMS ESTIMATION PROCEDURES 

[DOCKET NO. 3091] 

By Electronic Service only via CM/ECF. 

/s/ Lori N. Lasley

Lori N. Lasley 

Case: 19-30088 Doc# 3421 Filed: 08/07/19 Entered: 08/07/19 14:48:40 Page 13

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