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BAKER 

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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

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

□ 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)

NOTICE OF SUBPOENA ISSUED TO 

THE PARADISE POLICE DEPARTMENT

Case: 19-30088 Doc# 3340 Filed: 07/31/19 Entered: 07/31/19 17:42:19 Page 1 of

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PLEASE TAKE NOTICE that on January 29, 2019 (the “Petition Date”), PG&E 

Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the “Utility”), as debtors 

and debtors in possession (the “Debtors”) in the above-captioned chapter 11 cases (the “Chapter 

11 Cases”), each filed a voluntary petition for relief under chapter 11 of title 11 of the United 

States Code (the “Bankruptcy Code”) with the United States Bankruptcy Court for the Northern 

District of California (San Francisco Division) (the “Bankruptcy Court”). 

PLEASE TAKE FURTHER NOTICE that on July 26, 2019, counsel for the Official 

Committee of Tort Claimants issued and intends to serve a subpoena to produce documents, 

information, or objects (the “Subpoena”) on the Custodian of Records or Authorized Employee 

of the Paradise Police Department. A copy of the Subpoena is attached hereto as Exhibit 1. The 

items requested to be produced in the Subpoena are described in Exhibit A to the Subpoena.

PLEASE TAKE FURTHER NOTICE that copies of each pleading identified herein can 

be viewed and/or obtained: (i) by accessing the Court’s website at http://www.canb.uscourts.gov, 

(ii) by contacting the Office of the Clerk of the Court at 450 Golden Gate Avenue, San Francisco, 

CA 94102, or (iii) from the Debtor’s notice and claims agent, Prime Clerk LLC, at 

https://restructuring.primeclerk.com/pge or by calling (844) 339-4217 (toll free) for U.S.-based 

parties; or +1 (929) 333-8977 for International parties or by e-mail at: pgeinfo@primeclerk.com. 

Note that a password is needed to access documents on the Bankruptcy Court’s website. 

Dated: July 29, 2019

BAKER & HOSTETLER LLP

By: /s/ Robert A. Julian

Robert A. Julian

Attorneys for The Official Committee of Tort 

Claimants

Case: 19-30088 Doc# 3340 Filed: 07/31/19 Entered: 07/31/19 17:42:19 Page 2 of

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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) (12/15)

UNITED STATES BANKRUPTCY COURT

_________________________________________ District of _________________________________________ 

In re __________________________________________

Debtor

(Complete if issued in an adversary proceeding)

_________________________________________

Plaintiff

v.

__________________________________________

Defendant

Case No. _____________________

Chapter ___________

Adv. Proc. No. ________________

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT 

INSPECTION OF PREMISES IN A BANKRUPTCY CASE (OR ADVERSARY PROCEEDING) 

To: ________________________________________________________________________________________

(Name of person to whom the subpoena is directed) 

 Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following

documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the

material: 

PLACE DATE AND TIME

 Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or

other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party 

may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. 

PLACE DATE AND TIME

The following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are 

attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a 

subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not 

doing so. 

Date: _____________

CLERK OF COURT 

________________________

Signature of Clerk or Deputy Clerk

OR 

 

________________________

Attorney’s signature

The name, address, email address, and telephone number of the attorney representing (name of party) 

____________________________ , who issues or requests this subpoena, are:

Notice to the person who issues or requests this subpoena 

If this subpoena commands the production of documents, electronically stored information, or tangible things, or the 

inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on 

the person to whom it is directed. Fed. R. Civ. P. 45(a)(4). 

Northern California

PG&E Corporation and Pacific Gas and Electric Co.

19-30088 (DM) (Jointly Administered)

11

Custodian of Records or Authorized Employee of the Paradise Police Department

July 29, 2019

As described in Exhibit A, attached

TCC

c/o Dreyer Babich Buccola Wood Campora LLP

20 Bicentennial Circle

Sacramento, CA 95826

Attn: Kim Morris, Esq.

5:00 p.m. (PST) on August 19, 2019

Official Committee of Tort Claimants 

Kimberly S. Morris, Baker & Hostetler LLP, 11601 Wilshire Boulevard, Ste. 1400, Los Angeles, CA 90025, kmorris@bakerlaw.com, 628-208-6440

/s/ Kimberly S. Morris

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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.:

Case: 19-30088 Doc# 3340 Filed: 07/31/19 Entered: 07/31/19 17:42:19 Page 5 of

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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)

Case: 19-30088 Doc# 3340 Filed: 07/31/19 Entered: 07/31/19 17:42:19 Page 6 of

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EXHIBIT A

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DEFINITIONS

1. As used herein, the words “Document” and “Documents” mean each written, 

typed, printed, recorded, transcribed, taped, electronically stored, digitized, disked, filmed, or 

graphic matter of every kind, however produced or reproduced, including originals or copies of 

originals not in existence or available, all drafts or partial copies, wherever located, and including 

all Electronic Data, correspondence, letters, emails, memoranda, requests for information, reports, 

studies, tests, inspections, working papers, handwritten notes, diaries, charts, spreadsheets, 

photographs, sketches, drawings, blueprints, videos, graphs, indices, submittals, data sheets, 

databases, conversations, statements, minutes, notations (including notes or memorandum of 

conversations), telephone conversations in whatever form, suggestions, comments, instructions, 

warnings, notices, manuals, periodicals, pamphlets, brochures, catalogues, bulletins, schedules, 

invoices, and other documentation.

2. The term “Electronic Data” as used herein, shall be construed as the following 

types of electronic data and data compilations in the custody and/or control of the party 

responding to this Subpoena:

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

by the party responding to this Subpoena; 

b. All databases containing any reference and/or 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 subjects;

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 subjects; and

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g. All audio and video recordings sent, received, or stored by the party 

responding to this Subpoena that contains, references, or otherwise identifies information about 

the below listed subjects.

3. The terms “and” and “or” as used herein, shall, where the context permits, be 

construed to mean “and/or” as necessary to bring within the scope of the subpoena request. 

4. The terms “You” and “Your” refer to the party responding to this Subpoena, its 

predecessors, successors, subsidiaries, affiliated entities, officers, directors, employees, agents 

and anyone acting on its behalf or at its direction.

5. The term “PG&E” refers to PG&E Corporation and/or Pacific Gas & Electric 

Company.

6. The term “Camp Fire” means and refers to the wildfire that started on Camp Creek 

Road, on November 8, 2018, in Butte County, in Northern California, and encompassing the 

communities of Concow and Paradise, commonly known as the “Camp Fire.”

7. “First Response” means Your response to the Camp Fire between November 8, 

2018 – November 10, 2018. 

8. “First Responder” and “First Responders” means You and any other emergency 

responder providing aid and assistance during the First Response of the Camp Fire. 

9. The term “Communication(s)” means any transmission of information from one 

person or entity to another, including (without limitation) by personal meeting, conference, 

conversation, telephone, radio, electronic mail, teleconference, or any other method of 

communication or by any medium.

10. As used herein, the words “Person” or “Persons” shall refer to any natural person, 

firm, corporation, unincorporated association, partnership or other form or legal entity or 

governmental body, including its agents and representatives.

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REQUEST FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1:

All Documents and Electronic Data authored or generated by You concerning, 

referencing, or in any way related to the First Response and First Responders to the Camp Fire, 

including internal memoranda, internal communications, run sheets, photographs, audio/video 

recordings, call logs, dispatch logs, text messages, body/helmet/dash cam videos, social media 

posts, and documents related to incident management responses or activations.

REQUEST FOR PRODUCTION NO. 2:

All Communications between You and PG&E concerning, referencing, or in any way 

related to the Camp Fire.

REQUEST FOR PRODUCTION NO. 3:

All Documents or Electronic Data containing, referencing, or summarizing statements 

given by PG&E employees or personnel, oral or written concerning, relating to, or regarding the 

Camp Fire.

REQUEST FOR PRODUCTION NO. 4:

All Documents containing, referencing, or summarizing statements given by witnesses, 

including, but not limited to, eyewitnesses to the Camp Fire.

REQUEST FOR PRODUCTION NO. 5:

All Documents concerning, referencing, or in any way related to the cause of the Camp 

Fire.

REQUEST FOR PRODUCTION NO. 6:

All Documents concerning, referencing, or in any way related to any real or personal 

property damaged by the Camp Fire.

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