1 to open, resulting in the loss of power to a group of PG&E customers. The substation was 

2 unmanned at the time and the fire was only discovered by chance by an employee who had stopped 

3 by the substation to use the restroom. 

4 

5 80. 

5. The 1999 Pendola Fire 

A rotten pine, which the federal government detennined PG&E should have 

6 removed, fell on a power line, starting the Pendola Fire in 1999. It burned for 11 days and scorched 

7 11,725 acres, mainly in the Tahoe and Plumas National Forests. PG&E paid a $14.75 million 

8 settlement to the U.S. Forest Service in 2009. That year, the utility also reached a $22.7 million 

9 settlement with the CPUC after regulators found PG&E had not spent money earmarked for tree 

10 trimming and removal toward.those purposes. 

11 

12 81. 

6. The 2003 Mission District Substation Fire 

In December 2003, a fire broke out at PG&E's Mission District Substation in San 

13 Francisco. Despite signs of trouble appearing at control centers, the fire burned for nearly two 

14 hours before PG&E operators showed up at the Substation, found it full of smoke, and finally 

15 called the fire department. The source of the fire was not located until five hours after it began. 

16 As a result, nearly one-third of San Francisco's residents and business owners lost power, with 

17 some waiting over 24 hours for their power to be restored. 

18 

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20 

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26 

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LAW OFFICES 

COTCHEIT, PITRE & 

· McCAR'I1-IY, LLP 

82. The CPUC report of the investigation, which was released in 2004, illustrated 

PG&E's careless approach to safety and apparent inability to learn from its past mistakes. An 

excerpt from the report describes the following: 

Soon after undertaking the investigation of the 2003 fire, CPSD [CPUC's 

Consumer Protection and Safety Division] discovered that another fire had 

occurred at Mission Substation in 1996. CPSD's investigation team 

conducted a thorough analysis of both fires and found strikingly similar 

contributing factors and root causes. CPSD's team further determined that 

PG&E had not implemented the recommendations resulting from its own 

investigation of the 1996 fire. . . .CPSD finds it quite troubling that 

PG&E did not implement its own recommendations from its own 

investigation of the 1996 f1re.26 

26 http://docs.cpuc.ca.gov/publishedDocs/published/Report/40886.PDF (last accessed February 

12, 2018 . 

COMPLAINT 27 

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1 The findings related to the Mission Substation Fire should have been a wake-up call to PG&E to 

2 revamp its operating procedures to prevent future disasters. Instead, PG&E's focus remained on 

3 corporate profits, while safety was relegated to the backburner. 

4 7. The 2004 Sims Fire 

5 83. In July 2004, the Sims Fire burned over 4,000 acres of forest land in the Six Rivers 

6 and Trinity National Forests. A federal lawsuit alleged that PG&E failed to remove a decaying 

7 tree, which fell on a transmission line and ignited the blaze. 

8 

9 

8. The 2004 Freds Fire 

84. The Freds Fire started in October 2004 near Kyburz, El Dorado County, California. 

10 A lawsuit filed by the United States Government claimed that employees of PG&E's contractor 

11 lost control of a large tree they were cutting down. It fell onto a PG&E power line and caused a 

12 fire that burned over 7,500 acres. PG&E and its contractors paid $29.5 million to settle the 

13 lawsuits over the Freds Fire and the Sims Fire. 

14 

15 

9. The 2004 Power Fire 

85. In October 2004, the Power Fire burned approximately 17,000 acres on the 

16 Eldorado National Forest and on private timberlands. A federal lawsuit alleged that the Power 

17 Fire was ignited by a lit cigarette that was dropped by a PG&E tree trimming contractor. PG&E 

18 and its contractor paid the federal government $45 million to settle the lawsuit. 

19 

20 

10. The 2005 San Francisco Electrical Explosion 

86.. In August 2005, a PG&E electrical transformer exploded in the San Francisco 

21 financial district at Kearny and Post Streets, severely burning a woman who had been walking by. 

22 A lawsuit by the injured woman settled for an undisclosed sum. 

23 

24 

11. The 2008 Rancho Cordova Explosion 

87. In December 2008, a gas leak from a PG&E pipe caused an explosion in Rancho 

25 Cordova, California. This explosion left one person dead, injured several others, and caused over 

26 · $260,000 in property damage. 

27 88. A National Transportation Safety Board ("NTSB") investigation revealed that the 

28 leak was caused by incorrect repairs performed by PG&E in 2006, at which time PG&E installed 

LAW OFFICES 

COTCHETT, PITRE & 

McCARTHY, LLP 

COMPLAINT 28 

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1 a piece of pipe to patch up an earlier leak. The investigative report for the incident concluded that 

2 the walls of the new pipe were too thin, allowing gas to leak from the pipe, and that PG&E failed 

3 

4 

5 

6 

7 

8 

9 

to timely send properly trained personnel to check out the leak, even though PG&E had been told 

several months earlier that its emergency plans fell below required standards. Specifically, the 

report noted the following: 

Contributing to the accident was the 2-hour 47-minute delay in the anival 

at the job site of a Pacific Gas and Electric Company crew that was properly 

trained and equipped to identify and classify outdoor leaks and to begin 

response activities to ensure the safety of the residents and public.27 

89. In November 2010, the CPUC filed administrative charges against PG&E in 

1 o connection with the Rancho Cordova explosion, alleging that PG&E was at fault for the blast and 

11 that PG&E should have discovered the improper repair job that caused the explosion, but failed 

12 to timely do so. As a result, the CPUC required PG&E to pay a $38 million fine. 

13 

14 

12. The 2008 Whiskey Fire 

90. The June 2008 Whiskey Fire burned more than 5,000 acres of land in the 

15 Mendocino National Forest. The fire started when a gray pine tree that did not have the required 

16 clearance from a PG&E transmission line came into contact with the line. PG&E and its 

17 contractors agreed to pay $5.5 million to settle a federal lawsuit. 

18 

19 

13. The 2009 San Francisco Electrical Explosion 

91. In June 2009, a PG&E underground electrical vault exploded in San Francisco's 

20 Tenderloin neighborhood, sending 30-foot flames and smoke into the air for two hours. This 

21 explosion left thousands of people without power. 

22 

23 

14. The 2010 San Bruno Explosion 

92. On September 9, 2010, PG&E's continued disregard of public safety caused the 

24 death of eight people, injured 58 people, and destroyed an entire neighborhood in San Bruno, 

25 California when one of its gas pipelines exploded and burst into flames. Subsequent to the 

26 explosion, the NTSB issued a report that blame~ the disaster on PG&E's poor.management of its 

27 

28 

LAW OFFICES 

COTCHETI, Pmm & 

MCCARTIIY, LLP 

27 http://docs.cpuc.ca.gov/published/Final_decision/146914-03 .htm (last accessed February 12, 

2018. 

COMPLAINT 29 

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1 pipeline. In January 2011, federal investigators reported that the probable cause of the accident 

2 was: (i) PG&E's inadequate quality assurance and quality control during its Line 132 pipeline 

3 relocation project, which allowed the installation of a substandard and poorly-welded pipe section; 

4 and (ii) PG&E's inadequate pipeline integrity management program, which failed to detect and 

5 remove the defective pipe section. 

6 93. As a result, PG&E was required to pay substantial fines for its massive safety 

7 violations. In April 2015, the CPUC slapped PG&E with a $1.6 billion fine for causing the 

8 explosion and diverting maintenance funds into stockholder dividends and executive bonuses. 

9 Further, in January 2017, a federal judge convicted PG&E of six felony charges and ordered it to 

10 pay $3 million in fines for causing the explosion. 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

94. Due to PG&E's corporate culture which repeatedly ignored public safety, the 

CPUC launched an investigation into the manner by which PG&E officers, directors, and/or 

managing agents establish safety policies and practices to prevent catastrophic events. At the 

beginning of the investigation, the CPUC President called out PG&E's ongoing safety violations: 

95. 

Despite major public attention, ongoing CPUC investigations (OIis) and 

rulemakings (OIRs) into PG&E's actions and operations, including the 

investigations we voted on today, federal grand jury, and California 

Department of Justice investigation, continued safety lapses at PG&E 

continue to occur.28 

15. The 2011 Cupertino Explosion 

After the San Bruno explosion, in September 2011, PG&E caused a gas explosion 

21 that partially engulfed a condominium in Cupertino, California. The explosion was the result of 

22 cracked Aldyl-A plastic pipe. 

23 96. Prior to the explosion, the manufacture of Aldyl-A, the NTSB, and the federal 

24 Pipeline and Hazardous Materials Safety Administration had all issued warnings about this type 

25 of plastic pipe that was prone to premature brittleness, cracking, and failure dating back to at least 

26 

27 

28 

LAW OFFICES 

CarCHETI, PITRE & 

McCAR'lHY, LLP 

28 http://www.cpuc.ca.gov/uploadedFiles/CPUC _Public_ Website/Content/ About_ Us/ 

Organization/Commissioners/Michael_J._Picker/PresidentPickerCommentsonPGESafetyCultureandEnfor 

cementTheo . df last accessed Februa 12, 2018 . 

COMPLAINT 30 

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1 2002. Despite these warnings and PG&E's knowledge of this risk, PG&E did nothing to prevent 

2 the explosion. Although some utilities around the United States had been replacing Aldyl-A pipes, 

3 PG&E did not have a replacement program to phase them out and adequately protect the public. 

4 16. The 2014 Carmel Explosion 

5 97. In March 2014, a home in Cannel, California was destroyed due to a gas explosion 

6 caused by PG&E. Prior to the explosion, PG&E was attempting to replace a gas distribution line, 

7 but PG&E's legally inadequate records did not show that the steel pipe had a plastic insert .. When 

8 crews dug into the steel pipe to perform the replacement, the unknown plastic insert was pierced, 

9 allowing gas to leak through the pipe and into the res!dence. 

10 98. The CPUC once again required PG&E to pay a massive fine because of their 

11 wrongdoing. In August 2016, the CPUC imposed a $25.6 million fine on PG&E. With a $10.85 

12 million citation previously paid by PG&E in 2015 for the explosion, PG&E was require to pay a 

13 total of over $36 million in penalties for its shoddy recordkeeping and disregard of public safety. 

14 

15 

17. The 2015 San Francisco Transformer Explosion 

99. In September 2015, a PG&E underground transformer exploded in San Francisco's . 

16 Bernal Heights neighborhood. This explosion injured two people, one of them critically. 

17 18. The 2015 Butte Fire 

18 100. Tragedy struck yet again in September 2015, when PG&E's inadequate and 

19 ineffective vegetation management programs resulted in the Butte Fire in the Sierra foothills. The 

20 Butte Fire burned for 22 days across Amador and Calaveras Counties, killed two people, destroyed 

21 921 homes and/or structures, and charred over 70,000 acres. 

22 101. Similar to the other disasters caused by PG&E's wrongdoing, the Butte Fire could 

23 have been prevented by PG&E. The Butte Fire was ignited by a gray pine tree that grew and came 

24 into contact with one of PG&E's power lines. PG&E knew that gray pines posed the highest risk 

25 · of catastrophic wildfires, but failed to identify and/or remove the dangerous tree pursuant to its 

26 vegetation management practices. Instead, PG&E removed the two trees surrounding the gray 

27 pine at issue, which exposed the gray pine to sunlight and allowed it to quickly come into contact 

28 with PG&E's power line. 

LAW OFFICES 

COTCHE'IT, PITRE & 

McCARTHY,LLP 

COMPLAINT 31 

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1 102. Subsequent to the Butte Fire, in April 2017, the CPUC fined PG&E a total of $8 .3 

2 million for "failing to maintain its 12k V overhead conductors safely and properly" and failing to 

3 maintain a minimum distance between its power lines and vegetation. Cal Fire also sent PG&E a 

4 bill for $90 million to cover state firefighting costs. Despite these consequences, PG&E did not 

5 change, revise, or improve any of its vegetation management practices after the Butte Fire, paving 

6 the way for another massive wildfire. 

7 

8 

19. The 2017 North Bay Fires 

103. On or around the night of October 8, 2017, more than a dozen fires in Sonoma, 

9 Napa, Mendocino, Solano, Lake, Butte, Calaveras, Nevada, and Yuba Counties (collectively 

10 known as the "North Bay Fires") ignited and caused destruction on scale at the time which seemed 

11 unimaginable. 

12 104. In just a few weeks, the fires caused the deaths of at least 44 people, hospitalized 

13 over 185 individuals, displaced about 100,000 people who were forced to leave their homes and 

14 search for safety, burned over 245,000 acres, and damaged or destroyed an estimated 14,700 

15 homes, 3,600 vehicles, and 728 businesses. 

16 105. The North Bay Fires were caused by multiple points of failure in PG&E's electrical 

17 delivery system. Witnesses described electrical problems, transformer explosions, transformer 

18 fires, arcing transformers, down power lines, arcing power lines, and flames in trees.29 Although 

19 the numerous fires constituting the North Bay Fires had different points of origin, they all shared 

20 the same underlying causes and arose from PG&E's disregard of mandated safety practices and 

21 foreseeable hazardous risks associated with its infrastructure. 

22 106. Until the Camp Fire, the North Bay Fires were collectively the most destructive 

23 fires in California's history. 

24 Ill 

25 Ill 

26 Ill 

27 

28 29 h ://www.mercu ews.com/2017/10/10/ e- ower-lines-linked-to-wine-coun -fires 

LAW OFFICES 

COTCHETI, PITRE & 

McCARTHY, LLP 

COMPLAINT 32 

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1 

2 

3 

I. THE CORPORATE CULTURE AT PG&E THAT PUTS PROFITS 

BEFORE SAFETY 

107. Rather than spend the monopolistic profits it earns for infrastructure maintenance 

4 and safety, PG&E redirects the money to enhancing its reputation as a utility dedicated to customer 

5 safety and reliability, and paying lavish corporate bonuses-irrespective of the catastrophic losses 

6 suffered by victims of wildfires in recent years. This pattern and practice of favoring profits over 

7 having a safe and well-maintained infrastructure, left PG&E vulnerable to an increased risk of a 

8 catastrophic event such as the Camp Fire. 

9 108. For example, according to documents released by The Utility Reform Network 

10 ("TURN"), PG&E planned to replace a segment of the San Bruno pipeline in 2007 that it 

11 identified as one of the riskiest pipelines in PG&E's system. PG&E collected $5 million from its 

12 customers to complete the project by 2009, but instead deferred the project until it was too late and 

13 repurposed the money to other priorities. That same year, PG&E spent nearly $5 million on 

14 bonuses for six of its top executives. 

15 109. Moreover, PG&E implemented multiple programs that provide financial 

16 incentives to its employees, agents, anci/or contractors to not protecting public _safety. Prior to the 

17 Butte Fire, PG&E chose to provide a monetary incentive to its contractors to cut fewer trees, even 

18 though PG&E was required to have an inspection program in place that removed dangerous trees 

19 and reduced the risk of wildfires. Robert Urban, a regional officer for a PG&E contractor, stated 

20 that he had a concern that the bonus system incentivized his employees to not do their job, but 

21 PG&E chose to keep this program despite knowing this risk. Similarly, prior to the San Bruno 

22 explosion, PG&E had a program that provided financial incentives to employees to not report or 

23 fix gas leaks and keep repair costs down. This program resulted in the failure to detect a significant 

24 number of gas leaks, many of which were considered serious leaks. According to Richard 

25 Kuprewicz, an independent pipeline safety expert, PG&E's incentive system was ''training and 

26 rewarding people to do the wrong thing," emblematic of "a seriously broken process," and 

27 

28 

LAW OFFICES 

COTCHE1T, PITRE & 

McCARTHY, LLP 

COMPLAINT 33 

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1 "explains many of the systemic problems in this operation that contributed to the [San Bruno] 

2 tragedy. "30 

3 110. PG&E fed its toxic culture when it purchased policies of insurance from offshore 

4 companies in Bermuda, London, and elsewhere that expressly provide coverage for punitive 

5 damages in amounts that exceed hundreds of millions of dollars. These policies provide corporate 

6 security at the cost of public safety. This contributed to a culture ofreckless disregard for the safety 

7 of the residents of Northern and Central California and contributed to causing the Camp Fire. 

8 

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COTCHE'IT, PITRE & 

McCAR1HY,lJ..P 

i. PG&E Has Repeatedly And Continuously Diverted Safety Funds 

111. In an investigation covering 1994 to 1998, CPUC staff accused PG&E of more 

than 500,000 counts of violating state laws requiring utilities to keep trees pruned a safe distance 

from overhead electric lines. Much of the incriminating information cited by CPUC investigators 

was culled from the electric utility's own records. 

112. In another investigation by the CPUC and Overland (an independent auditing 

company) covering 1997 to 2012, it was uncovered that PG&E diverted more than $100 mi~lion 

in gas safety and operations money collected from customers and spent it for other purposes, 

including profit for stockholders and bonuses for executives. 

113. According to the audit, from 1999 to 2010, PG&E also collected $430 million more 

than its guaranteed revenue from its gas-transmission and -storage operations. 

114. In a separate report, the CPUC concluded that in the three years leading up to the 

2010 San Bruno explosion, the company spent $56 million annually on an incentive plan for 

executives and "non-employee directors," including stock awards, performance shares and 

deferred compensation. 

115. According to PG&E's 2016 Annual Report to Investors: 

The Utility incurred costs of $498 million, pre-tax, during the year ended 

December 31, 2016 associated with fmes and penalties. This includes costs of 

. $412 million, pre-tax, ~sociated with safety-related cost disallowances,imposed 

by the California Public Utilities Commission (the "CPUC") in its April 9, 2015 

30 http://www.sfgate.com/news/article/PG-E-incentive-system-blamed-for-leak-oversights2424430. h . 

COMPLAINT 34 

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1 

2 

3 

4 

5 

6 

decision in the gas transmission pipeline investigations. The Utility also recorded 

$57 million, pre-tax, for disallowances imposed by the CPUC in its final phase 

two decision of the 2015 Gas Trans~ission and Storage (GT&S) rate case for 

prohibited ex parte communications. In addition, the Utility accrued fines of 

$26 million in connection with the final decision approved by the CPUC on 

August 18, 2016 in its investigation regarding natural gas distribution recordkeeping practices and $3 million in connection with the maximum statutory fiQ.e 

imposed on January 26, 2017 in the federal criminal trial against the Utility. 

116. In 2017, Geisha Williams, PG&E's chief executive officer, was awarded $8.6 

7 million in total direct compensation, according to a PG&E filing with the Securities and Exchange 

8 Commission. This was a 106% raise from her prior year's salary. 

9 117. Nickolas Stavropoulos, chief operating officer and president of Pacific Gas and 

10 Electric, PG&E's utility subsidiary, received $6.4 million in total direct compensation in 2017, up 

11 88.9% from his prior year's salary. 

12 118. According to public documents uncovered by two investigators from the CPUC in 

13 July 2018, PG&E stocked away $246 million dollars over the last 17 years that was meant for 

14 undergrounding powerlines, which can help prevent wildfires in zones that are prone to extreme 

15 wildfire danger, but PG&E did not use the funds to do so. 

16 119. PG&E's advertising campaigns further highlight that avoiding accountability- and 

17 not public safety- is its top priority. Instead of allocating all available resources into maintenance, 

18 inspections, and fire safety, PG&E spent millions on advertising, including full page newspaper 

19 ads and feel-good television commercials, designed to distract the public from the fact that PG&E 

20 is a six-time felon. 

21 120. 

22 

23 

24 

25 

26 

27 

28 

LAW OFFICES 

CarCHETr, PITRE & 

MCCARTI-IY, I.LP 

ii. PG&E Continually And Habitually Flaunts CPUC Regulations And 

Investigations 

121. In 2007, the CPUC began working to tighten regulations on utilities and force the 

utilities to create maps that detail where power lines present the highest risk for wildfires. As of 

2017, a decade later, the maps were still incomplete. And the CPUC had not adopted strict new 

regulations. 

COMPLAINT 35 

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1 122. A review of the mapping project shows that PG&E repeatedly asked to slow 

2 down the effort, claiming for example in October 2016, that the CPUC's plans to complete the 

3 map by March of 2017 year was ''too aggressive." And in July 2017, the utility called a proposed 

4 regulation to increase the wind speed that power poles must sustain "arbitrary," and that certain 

5 proposed regulations would "add unnecessary costs to construction and maintenance projects in 

6 rural areas." On Oct. 6, 2017-two days before the deadly North Bay Fires-two administrative 

7 law judges assigned to oversee the project granted yet another delay at the request of PG&E and 

8 other utilities. 

9 123. In response to PG&E's repeated failure to correct its behavior and the 2010 San 

10 Bruno explosion, the CPUC's Safety and Enforcement Division commissioned a report, prepared 

11 by Northstar Consulting Group, to detennine whether PG&E's "organizational culture and 

12 governance prioritize safety and adequately direct resources to promote accountability and achieve 

13 safety goals and standards." The Northstar report concluded that while PG&E purportedly has 

14 been making efforts to reduce incidents and increase safety since the 2010 San Bruno explosion, 

15 ''these efforts had been somewhat reactionary" and were not driven by a "comprehensive 

16 enterprise-wide approach to addressing safety." 

17 124. The report was issued May 8, 2017 and made 61 separat~ recommendations for 

18 PG&E to be completed before July 1, 2019. While PG&E publicly supports the NorthStar 

19 recommendations, the CPUC has raised doubts that PG&E's enthusiasm is sincere. In one 

20 example, PG&E attempted to· bolster its commitment to safety in front of the CPUC by 

21 exaggerating the safety expertise of its Directors. When asked to substantiate this expertise, PG&E 

22 could not provide any support for its claim. This prompted the CPUC to question "whether PG&E 

23 truly is changing its culture, or just trying to 'check the boxes'. "31 

24 125. On April 26, 2018, PG&E agreed to pay $97.5 million because it engaged in 

25 prohibited communications with the CPUC and failed to timely report ex parte communications 

26 from 2010 to· 2014, in violation of CPUC rules. 

27 

28 

LAW OFFICES 

COTCHE1T, PITRE & 

McCARTHY, LLP 

COMPLAINT 36 

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LAW OFFICES 

COTCHETr, PITRE& 

MCCARTI-iY, LLP 

126. As part of the settlement agreement, PG&E admitted to the following: 

Owing the period from 2010 to 2014, PG&E committed multiple violations of the 

Commission's ex parte rules in Article 8 of the Rules of Practice and Procedure, 

through communications that were either prohibited or not reported to the 

Commission as required by these rules. On at least one occasion during this time 

period, PG&E also violated Rule 12.6 of the Commission's Rules of Practice 

and Procedure, which requires that parties to settlement negotiations hold 

such negotiations confidential, by disclosing to a Commission decisionmaker 

the contents of ongoing settlement negotiations. Finally, by the totality of these 

violations, PG&E also violated Commission Rule of Practice and Procedure 1.1. 

Article II,§ 2.1.B: Conduct Harmful to Customers and Other Constituents PG&E's 

employees and agents engaged in communications with decisionmakers at the 

Commission, as well as related conduct that was harmful to the regulatory process. 

127. PG&E specifically admitted to 12 violations, including: 

- a conversation between Brian Cherry, PG&E 's Vice President of Regulatory 

Affairs, and a CPUC Commissioner about whether to bump Administrative 

Law Judge Roscow from a proceeding. 

A conversation between a PG&E attorney and a CPUC Commissioner 

regarding a gas pipeline project and possible ratepayers' payment for upgrading 

the gas system. 

A meeting between the CPUC President and a PG&E officer regarding a 

"independent" forensic analysis. 

128. And this is not the first time PG&E has interfered and/or failed to comply with an 

investigation as it was also found guilty of a felony for interfering with the federal investigation 

of the 2010 San Bruno explosion. 

J. PG&E IS REQUIRED TO SAFELY DESIGN, OPERATE, AND MAINTAIN 

ITS ELECTRICAL SYSTEMS AND THE SURROUNDING VEGETATION 

129. At all times prior to November 8, 2018, PG&E had a duty to properly construct, 

inspect, repair, maintain, manage and/or operate its power lines and/or other electrical equipment 

and to keep vegetation properly trimmed and maintained so as to prevent foreseeable contact with 

such electrical equipment. In the construction, inspection, repair, maintenance, management, 

ownership, and/or operation of its power lines and other electrical equipment,. PG&E had an 

obligation to comply with a number of statutes, regulations, and standards, including the following. 

COMPLAINT 37 

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1 130. Pursuant to Public Utilities Code § 451, "Every public utility shall furnish and 

2 maintain such adequate, efficient, just, and reasonable service, instrumentalities, equipment, and 

3 facilities ... as are necessary to promote the safety, health, comfort, and convenience ofits patrons, 

4 employees, and the public." 

5 131. To meet this safety mandate, PG&E is required to comply with a number of design 

6 standards for its electrical equipment, as stated in CPUC General Order 95. In extreme fire areas, 

7 PG&E also must ensure that its power lines can withstand winds ofup to 92 miles per hour. 

8 132. Further, PG&E must follow several standards to protect the public from the 

9 consequences of vegetation and/or trees coming into contact with its power lines and other 

10 electrical equipment. Pursuant to Public Resources Code § 4292, PG&E is required to "maintain 

11 around and adjacent to any pole or tower which supports a switch, fuse, transformer, lightning 

12 arrester, line junction, or dead end or corner pole, a firebreak which consists of a clearing of not 

13 less than 10 feet in each direction from the outer circumference of such pole or tower." Also, 

14 Public Resources Code § 4293 mandates PG&E to maintain clearances of four to 10 feet for all 

15 of its power lines, depending of their voltage. In addition, "Dead trees, old decadent or rotten trees, 

16 trees weakened by decay or disease and trees or portions thereof that are leaning toward the line 

17 which may contact the line from the side or may fall on the line shall be felled, cut, or trimmed so 

18 as to remove such hazard." 

19 133. Pursuant to CPUC General Order 165, PG&E is also required to inspect its 

20 distribution facilities to maintain a safe and reliable electric system. In particular, PG&E must 

21 conduct "detailed" inspections of all of its overhead transformers in urban areas at least every five 

22 years. PG&E is also required to conduct "intrusive" inspections of its wooden poles that have not 

23 already been inspected and are over 15 years old every 10 years. 

24 134. PG&E knew or should have known that such standards and regulations were 

25 minimum standards and that PG&E has a duty to identify vegetation which posed a foreseeable 

26 hazard to power lines and/or other elecqical equipment, and manage the growth of vegetation near 

27 its power lines and equipment so as to prevent the foreseeable danger of contact between 

28 vegetation and power lines starting a fire. Further, PG&E has a duty to manage, maintain, repair, 

LAW OFFICES COMPLAINT 38 

COTCHE1•r, PITRE & 

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1 . and/or replace its aging infrastructure to protect public safety. These objectives could and should 

2 have been accomplished in a number of ways, including, by not limited to, putting electrical 

3 equipment in wildfire-prone areas underground, increasing inspections, developing and 

4 implementing protocols to shut down electrical operations in emergency situations, modernizing 

5 infrastructure, and/or obtaining an independent audit of its risk management programs to ensure 

6 effectiveness. 

7 135. Finally, in June of 2014, the CPUC directed PG&E, by way of Resolution ESRB8 4, to take remedial measures to reduce fires since the Governor had declared a drought in January. 

9 In addition, the CPUC informed PG&E that it could seek recovery of incremental costs associated 

10 with these remedial measures outside of the standard funding process, i.e. the CPUC was agreeing 

11 to provide additional funding on top of vegetation management funding already authorized in order 

· 12 to make sure remedial measures would not go unperformed due to lack of funding. "Although the 

13 Governor issued an Executive Order in April 2017 ending the Drought State of Emergency, the 

14 declaration directed state agencies 'to continue response activities that may be needed to manage 

15 the lingering drought impacts to people and wildlife.' The California Tree Mortality State of 

16 Emergency issued in October 2015 by Governor Brown regarding the bark beetle infestation and 

17 resulting tree mortality remains in effect. The CPUC has not rescinded ESRB-4, and work by the 

18 utilities to comply with it and the Tree Mortality Emergency continues. "32 

19 VI. PLAINTIFFS' LOSSES 

20 136. Plaintiff LILA WILLIAMS ("LILA") is a 93-year-old great-great-grandmother 

21 of five generations of her family who have resided on the Paradise Ridge. Prior to coming to the 

22 Ridge, she was raised on a ranch in Lake County. She worked for many years in Silicon Valley as 

23 a Lead Worker in production assembly at Hewlett-Packard. 

24 137. On November 8, LILA, who lived in Magalia, was returning from a doctor's 

25 appointment with her granddaughter when embers from the fire began landing on their vehicle. 

26 Fearful that she would not have enough gas to escape the fire, LILA stopped at two gas stations, 

27 

28 

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McCARTHY, l.LP 

32 http://cpuc.ca.gov/uploadedFiles/CPUC _Public_ Website/Content/Safety/PGE%20Vegetation 

%20 Mana ement%20S endin . df. 

COMPLAINT 39 

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1 but was unable to refuel. She was fortunately able to get a ride in her granddaughter's vehicle, but 

2 still faced clogged roads heading toward Chico. They then made the terrifying decision of turning 

3 around, heading deeper into the mountains towards Butte Meadow, which was so crowded with 

4 other evacuees ·that they kept on going uphill to Chester. She stayed there until fmally re-uniting 

5 with her family. LILA's home in Magalia, and mementos from a full life of experiences, were 

6 completely destroyed. 

7 138. LOUISE is LILA's 66-year-old daughter. LOUISE owned property in Concow at 

8 3488 Hoffinan Road, where she had built her own off-the-grid home with solar panels and storage 

9 batteries, so that she would not have to rely upon PG&E. 

10 139. The Camp Fire suddenly and quickly consumed LOUISE's property. By the time 

11 she was able to get into her car, the fire had already entered her home and was burning the fence 

12 at the end of her driveway, potentially cutting off her escape. She screamed her dog's name, but 

13 he did not answer. She had no choice but to leave her dog and cat behind. After hurrying down her 

14 driveway and onto Hoffman Road, passing burning homes along the way, LOUISE was forced to 

15 stop at Lake Concow. The single crossing was blocked by a truck and row of cars, unable to pass. 

16 The flames from the burning trees licked at the stopped vehicles. A firefighter screamed at 

17 everyone to go to the lake. LOUISE got out of her car and ran. Standing in the freezing waters of 

18 Lake Concow, they waited as crews tried to clear the road ahead of fallen trees and debris. 

19 140. LOUISE was eventually able to rejoin a convoy of cars leaving Concow. They 

20 followed behind a firetruck and through burning forest. Tree limbs consumed by flames hung over 

21 the road. After driving for miles, LOUISE was able to leave the flames behind and reach a place 

22 of relative safety. 

23 141. PLAINTIFFS' property and all of their personal items in and around their home, 

24 and other structures, were completely destroyed in the Camp Fire and are no longer ascertainable 

25 due to the intensity of the fire. As a result of the fire and evacuation, PLAINTIFFS suffered major 

26 losses and damages in an amount according to proof at trial. 

27 Ill 

28 

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COMPLAINT 40 

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II. CAUSES OF ACTION 

FIRST CAUSE OF ACTION 

NEGLIGENCE 

(Against All Defendants) 

142. PLAINTIFFS incorporate and re-allege each of the paragraphs set forth above as 

though fully set forth herein. 

143. The Camp Fire was a direct and legal result of the negligence, carelessness, 

recklessness, and/or unlawfulness of DEFENDANTS, and/or each of them. DEFENDANTS, 

and/or each of them, breached their respective duties owed individually and/or collectively to 

PLAINTIFFS by, including but not limited to: (1) failing to comply with the applicable statutory, 

regulatory, and/or professional standards of care; (2) failing to timely and properly maintain, 

manage, inspect, and/or monitor the subject power lines, electrical equipment, and/or adjacent 

vegetation; (3) failing to properly cut, trim, prune, and/or otherwise keep vegetation at a sufficient 

distance to avoid foreseeable contact with power lines; (4) failing to trim and/or prune vegetation 

so as to avoid creation of a safety hazard within close proximity of the subject power line; (5) 

failing to make the overhead lines safe under all the exigencies created by surrounding 

circumstances and conditions; (6) failing to conduct adequate, reasonably prompt, proper, 

effective, and/or frequent inspections and/or repairs of the electrical transmission lines, wires, 

and/or associated equipment; (7) failing to design, construct, monitor, and/or maintain electrical 

transmission and/or distribution power lines in a manner that avoids the potential to ignite a fire 

during long, dry seasons by allowing vegetation to grow in an unsafe manner; (8) failing to install 

the equipment necessary and/or to inspect and/or repair the equipment installed, to prevent 

electrical transmission and distribution lines from improperly sagging, operating, and/or making 

contact with other metal wires placed on its poles and igniting fires; (9) failing to keep equipment 

in a safe condition and/or manage equipment to prevent fire at all times; (10) failing to de-energize 

power lines during fire prone conditions~ (11) failing to de-energize power lines after the ignition 

of the Camp Fires; and/or (12) failing to properly train and to supervise employees and/or agents 

COMPLAINT 41 

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1 responsible for maintenance and inspection of the distribution lines and/or vegetation areas nearby 

2 these lines. 

3 144. As a direct and legal result of DEFENDANTS' actions and/or omissions, and/or 

4 each of them, PLAINTIFFS were injured in their health, strength, and/or activity in an amount 

5 according to proof at trial. 

6 145. As a further direct and legal result of the premises, PLAINTIFFS were required to 

7 and/or continue to employ physicians and other healthcare providers to examine, treat, and/or care 

8 for their injuries. PLAINTIFFS have incurred, and will continue to incur, medical and/or 

9 incidental expenses in an amount according to proof at trial. 

10 146. As a further direct and legal result of the premises, PLAINTIFFS have suffered 

11 and/or continue to suffer great mental pain and suffering, including worry, emotional distress, 

12 humiliation, embarrassment, anguish, anxiety, and/or nervousness. PLAINTIFFS are informed 

13 and believe, and upon such information and belief allege, that such injuries have resulted in 

14 debilitating injuries in an amount according to proof at trial. 

15 14 7. As a further direct and legal result of the premises, PLAINTIFFS have suffered a 

16 loss of income, loss of earning capacity, loss of profits, increased expenses due to displacement, 

17 and/or other consequential economic losses in an amount according to proof at trial. 

18 148. As a further direct and legal result of DEFENDANTS' actions and/or omissions, 

19 and/or each of them, PLAINTIFFS have suffered damage to real property, including the loss of 

20 vegetation, trees, and structures, the creation of hydrophobic soil conditions, and a loss of use, 

21 benefit, goodwill, diminution in value, and/or enjoyment of such property in an amount acc_ording 

22 to proof at trial. 

23 149. As a further direct and legal result of DEFENDANTS' actions and/or omissions, 

24 and/or each of them, PLAINTIFFS have suffered damage to and/or a loss of personal property, 

25 including but not limited to items of peculiar value to PLAINTIFFS, in an amount according to 

26 proof at trial. 

27 150. As a further direct and legal result of DEFENDANTS' actions and/or omissions, 

28 and/or each of them, PLAINTIFFS have incurred and will continue to incur expenses and other 

LAW OFFICES COMPLAINT 42 

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· 1 economic damages related to the damage to their property, including costs relating to storage, 

2 clean-up, disposal, repair, depreciation, and/or replacement of their property, and/or other related 

3 consequential damages in an amount according to proof at trial. 

4 151. PG&E has a virtual monopoly over the transmission and distribution of electrical 

5 power to the areas affected by the Camp Fire and has individual contracts with all residents and 

6 businesses in those areas to whom it distributes that electrical power. The communities affected 

7 by the Camp Fire are all dependent upon the safe transmission an<;i distribution of that electrical 

8 power for continuous residential and commercial usage, and PG&E has contractual, statutory, and 

9 public duties to provide that electrical power in a manner that promotes those individual and public 

10 interests . 

11 . 152. The potential harms to PLAINTIFFS from wildfires such as the Camp Fire was 

12 objectively foreseeable both in nature and in scope and were subjectively known to PG&E from 

13 its long and tragic history of causing such wildfires. 

14 153. As set forth above and as will be shown by proof, there is a high degree of certainty 

15 that PLAINTIFFS have suffered those injuries and damages, and that there is an extremely close 

16 connection between those injuries and damages and DEFENDANTS' conduct. A high degree of 

17 moral blame is attached to DEFENDANTS' conduct, and the policy of preventing future harm 

18 justifies both the recognition of the existence of a duty of care owed by DEFENDANTS to all 

19 PLAINTIFFS and the imposition of all damages described above. 

20 154. Based on the foregoing, DEFENDANTS, and/or each of them, acted willfully, 

21 wantonly, with oppression, fraud, malice, and/or with a knowing, conscious disregard for the rights 

22 and/or safety of others, such the PLAINTIFFS request that the trier of fact, in the exercise of 

23 sound discretion, award PLAINTIFFS additional damages pursuant to Code of Civil Procedure § 

24 3294 for the sake of example and sufficient to punish the DEFENDANTS, and/or each of them, 

25 for their despicable conduct, in an amount reasonably related to PLAINTIFFS' actual damages 

26 and DEFENDANTS' financial condition, yet sufficiently large enough to be an example to others 

27 and to deter DEFENDANTS and others from engaging in similar conduct in the future. 

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COMPLAINT 43 

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155. As a further direct and legal result of the conduct of DEFENDANTS, 

PLAINTIFFS seek exemplary damages for injuries to PLAINTIFFS' animals as allowed under 

Code of Civil Procedure§ 3340. 

SECOND CAUSE OF ACTION 

INVERSE CONDEMNATION 

(Against All Defendants) 

156. PLAINTIFFS incorporate and re-allege each of the paragraphs set forth above as 

7 though fully set forth herein. 

8 157. On or about November 8, 2018, PLAINTIFFS were owners of real property and/or 

9 personal property located within Butte County in the area of the Camp Fire. 

10 

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158. Prior to and on November 8, 2018, DEFENDANTS, and/or each of them, installed, 

owned, operated, used, controlled, and/or maintained power lines and other electrical equipment 

for the public delivery of electricity, including power lines in and around the location of the Camp 

Fire. 

159. On November 8, 2018, as a direct, necessary, and legal result of DEFENDANTS' 

installation, ownership, operation, use, control, management, and/or maintenance for a public use 

the power lines and/or other electrical equipment, the power lines and/or other electrical equipment 

came in contact with vegetation and/or broke, failed, fell down, sparked, and/or exploded, causing 

a wildfire that burned thousands of acres, including property owned or occupied by PLAINTIFFS. 

The fire damaged and/or destroyed PLAINTIFFS' real and/or personal property. 

160. The above described damage to PLAINTIFFS' property was legally and 

substantially caused by the actions of DEFENDANTS, and/or each of them, in their installation, 

ownership, operation, use, control, management, and/or maintenance of the power lines and other I 

electrical equipment for a public use. 

161. PLAINTIFFS have not received adequate compensation for the damage to and/or 

destruction of their property, thus constituting a taldng or damaging of PLAINTIFFS' property 

26 by DEFENDANTS, and/or each of them, without just compensation. 

27 

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162. As a direct and legal result of the actions and/or omissions of the DEFENDANTS, 

PLAINTIFFS suffered damages to their real and/or personal property, including loss of use, 

COMPLAINT 44 

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1 interference with access, and/or diminution in value and/or marketability in an amount according 

2 to proof at trial. 

.3 163. As a direct and legal result of the actions and/or omissions of the DEFENDANTS, 

4 PLAINTIFFS have incurred and will continue to incur costs, disbursements, and/or expenses, 

5 including reasonable attorney, appraisal, engineering, and/or other expert fees due to the conduct 

6 of the DEFENDANTS in amounts that cannot yet be ascertained, but which are recoverable 

7 pursuant to Code of Civil Procedure § 1036. 

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THIRD CAUSE OF ACTION 

PUBLIC NUISANCE 

(Against AU Defendants) 

164. PLAINTIFFS incorporate and re-allege by this reference each of the paragraphs 

set forth as though fully set forth herein. 

165. PLAINTIFFS own and/or occupy property at or near the site of the fire which is 

the subject of this action. At all relevant times herein, PLAINTIFFS had a right to occupy, enjoy, 

and/or use their property without interference by DEFENDANTS, and/or each of them. 

166. DEFENDANTS, and/or each of them, owed a duty to the public, including 

PLAINTIFFS herein, to conduct their business, in particular the maintenance and/or operation of 

power lines, power poles, and/or electrical equipment on power poles, and adjacent vegetation in 

proximity to their power lines in Butte County in a manner that did not threaten harm or injury to 

the public welfare from operation of those power lines. 

167. DEFENDANTS, and/or each of them, by acting and/or failing to act, as alleged 

hereinabove, created a condition which was harmful to the health of the public, including these 

PLAINTIFFS, and which interfered with the comfortable occupancy, use, and/or enjoyment of 

PLAINTIFFS' property. PLAINTIFFS did not consent, expressly or impliedly, to the wrongful 

conduct of DEFENDANTS, and/or each of them, in acting in the manner set forth above. 

168. The hazardous condition which was created by and/or permitted to exist by 

DEFENDANTS, and/or each of them, affected a substantial number of people within the general 

public, including PLAINTIFFS herein, and constituted a public nuisance under Civil Code §§ 

COMPLAINT 45 

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1 3479 and 3480 and Public Resources Code § 4171. Further, the ensuing uncontrolled wildfire 

2 constituted a public nuisance under Public Resources Code § 4170. 

3 169. The damaging effects of DEFENDANTS' maintenance of a fire hazard and the 

4 ensuing uncontrolled wildfire are ongoing and affect the public at large. As a result of the fire's 

5 location, temperature, and/or duration, extensive areas of hydrophobic soils developed within the 

6 fire's perimeter. This further caused significant post fire runoff hazards to occur, including hillside 

7 erosion, debris flow hazards, sediment laden flow hazards, and hillside erosion. As a result, large 

8 quantities of ash and sediment will be deposited in perennial and ephemeral watercourses. 

9 170. As a direct and legal result of the conduct of DEFENDANTS, and/or each of them, 

10 PLAINTIFFS suffered harm that is different from the type of harm suffered by the general public. 

11 Specifically, PLAINTIFFS have lost the occupancy, possession, use, and/or enjoyment of their 

12 land, real and/or personal property, including, but not limited to: a reasonable and rational fear that 

13 the area is still dangerous; a diminution in the fair market value of their property; an impairment 

14 of the salability of their property; soils that have become hydrophobic; exposure to an array of 

15 toxic substances on their land; the presence of "special waste" on their property that requires 

16 special management and disposal; and a lingering smell of smoke, and/or constant soot, ash, and/or 

17 dust in the air. 

18 171. As a further direct and legal result of the conduct of DEFENDANTS, and/or each 

19 . of them, PLAINTIFFS have suffered, and will continue to suffer, discomfort, anxiety, fear, 

20 worries, annoyance, and/or stress attendant to the interference with PLAINTIFFS' occupancy, 

21 possession, use and/or enjoyment of their property, as alleged above. 

22 172. A reasonable, ordinary person would be reasonably annoyed or disturbed by the 

23 condition created by DEFENDANTS, and/or each of them, and the resulting fire. 

24 173. The conduct of DEFENDANTS, and/or each of them, is unreasonable and the 

25 seriousness of the harm to the public, including PLAINTIFFS herein, outweighs the social utility 

26 of DEFENDANTS' conduct. 

27 174. The individual and/or collective conduct of DEFENDANTS set forth above, and/or 

28 each of them, resulting in the Camp Fire is not an isolated incident, but is ongoing and/or a 

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1 repeated course of conduct, and DEFENDANTS' prior conduct and/or failures have resulted in 

2 other fires and damage to the public. 

3 175. The unreasonable conduct of DEFENDANTS, and/or each of them, is a direct and 

4 legal cause of the harm, injury, and/or damage to the public, including PLAINTIFFS herein. 

5 176. DEFENDANTS, and/or each of them, have individually and/or collectively, failed 

6 and refused to conduct proper inspections and to properly trim, prune, and/or cut vegetation in 

7 order to ensure the sole delivery of electricity to residents through the operation of power lines in 

8 the affected area, and DEFENDANTS' individual and/or collective failure to do so exposed every 

9 member of the public, including those residing in Butte County, to a foreseeable danger of personal 

10 injury, death,. and/or a loss of or destruction real and personal property. 

11 177. The conduct of DEFENDANTS, and/or each of them, set forth above constitutes a 

12 public nuisance within the meaning of Civil Code §§ 3479 and 3480, Public Resources Code §§ 

13 4104 and 4170, and Code of Civil Procedure § 731. Under Civil Code § 3493, PLAINTIFFS have 

14 standing to maintain an action for public nuisance because the nuisance is specially injurious to 

15 PLAINTIFFS because, as more specifically described above, it is injurious and/or offensive to 

16 the senses of the PLAINTIFFS, unreasonably interferes with the comfortable enjoyment of their 

17 properties, and/or unlawfully obstructs the free use, in the customary manner, of PLAINTIFFS' 

18 properties, and have suffered harm, injury, and damages. 

19 178. For these reasons, PLAINTIFFS seek a permanent injunction ordering that 

20 DEFENDANTS, and each of them, stop continued violation of Public Resource Code § § 4292 

21 and 4293 and Public Utilities Commission General Order 95, Rule 35. PLAINTIFFS also seek 

22 an order directing DEFENDANTS to abate the existing and continuing nuisance described above. 

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FOURTH CAUSE OF ACTION 

PRIVATE NUISANCE 

(Against All Defendants) 

179. PLAINTIFFS incorporate and re-allege by this reference each of the paragraphs 

set forth as though fully set forth herein. 

COMPLAINT 47 

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1 180. DEFENDANTS, and/or each of them, by their acts and/or omissions set forth 

2 above, directly and legally caused an obstruction to the free use of PLAINTIFFS' property, an 

3 invasion the PLAINTIFFS' right to use their property, and/or an interference with the enjoyment 

4 of PLAINTIFFS' property, resulting in PLAINTIFFS suffering unreasonable harm and 

5 substantial actual damages constituting a nuisance pursuant to Civil Code §§ 34 79 and 3481. 

6 181. As a direct and legal result of the wrongful acts and/or omissions of 

7 DEFENDANTS, and/or each of them, PLAINTIFFS suffered, and continue to suffer, the injuries 

8 and damages as set forth above. 

9 182. As a further direct and legal result of the wrongful acts and/or omissions of 

10 DEFENDANTS, and/or each of them, PLAINTIFFS seek the recovery of punitive and exemplary 

11 damages against DEFENDANTS as set forth above. 

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FIFTH CAUSE OF ACTION 

PREMISES LIABILITY 

(Against All Defendants) 

183. PLAINTIFFS incorporate and re-allege by this reference, each of the paragraphs 

set forth as though fully set forth herein. 

184. DEFENDANTS, and/or each of them, were the owners ofan easement and/or real 

property in and around the area of the Camp Fire, and/or were the owners of the power lines upon 

said easement and/or right of way. 

185. DEFENDANTS, and/or each of them, acted wantonly, unlawfully, carelessly, 

recklessly, and/or negligently in failing to properly inspect, manage, maintain, and/or control the 

vegetation near its power lines along the real property and easement, allowing an unsafe condition 

presenting a foreseeable risk of fire danger to exist on said property. 

186. As a direct and legal result of the wrongful acts and/or omissions of 

DEFENDANTS, and/or each of them, PLAINTIFFS suffered, and continue to suffer, the injuries 

and damages as set forth above. 

COMPLAINT 48 

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187. As a further direct and legal result of the wrongful acts and/or omissions of 

DEFENDANTS, and/or each of them, PLAINTIFFS seek the recovery of punitive and exemplary 

damages against DEFENDANTS as set forth above. 

SIXTH CAUSE OF ACTION 

TRESPASS 

(Against All Defendants) 

188. PLAINTIFFS incorporate and re-allege by this reference each of the paragraphs 

set forth as though fully set forth herein. 

189. At all times relevant herein, PLAINTIFFS were the owners, tenants, and/or lawful 

occupants of property damaged by the Camp Fire. 

190. -DEFENDANTS, and/or each of them, in wrongfully acting and/or failing to act in 

the manner set forth above, caused the Camp Fire to ignite and/or spread out of control, causing 

harm, damage, and/or injury to PLAINTIFFS herein, resulting in a trespass upon PLAINTIFFS 

property interests. 

191. PLAINTIFFS did not grant permission for DEFENDANTS to wrongfully act in 

a manner so as to cause the Camp Fire, and thereby produce a wildland fire which spread and 

wrongfully entered upon their property, resulting in the harm, injury, and/or damage alleged above. 

192. As a direct and legal result of the wrongful conduct of DEFENDANTS, and/or 

each of them, which led to the trespass, PLAINTIFFS have suffered and will continue to suffer 

damages as set forth above, in an amount according to proof at trial. 

193. As a further direct and legal result of the wrongful conduct of DEFENDANTS, 

PLAINTIFFS, whose land was under cultivation, and/or was used for raising livestock or was 

intended to be used for raising livestock, have hired and retained counsel to recover compensation 

for loss and damage and are entitled to recover all attorney's fees, expert fees, consultant fees, and 

litigation costs and expenses, as allowed under Code of Civil Procedure§ 1021.9. 

194. As a further direct and legal result of the conduct of DEFENDANTS, 

PLAINTIFFS seek double and/or treble damages for the negligent, willful, and wrongful iajuries 

to timber, trees, or underwood on their property, as allowed under Civil Code § 3346. 

COMPLAINT 49 

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1 195. As a direct and legal result of the wrongful acts and/or omissions of 

2 DEFENDANTS, and/or each of them, PLAINTIFFS suffered, and continue to suffer, the injuries 

3 and damages as set forth above. 

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196. As a further direct and legal result of the wrongful acts and/or omissions of 

DEFENDANTS, and/or each of them, PLAINTIFFS seek the recovery of punitive and exemplary 

damages against DEFENDANTS as set forth above. 

SEVENTH CAUSE OF ACTION 

VIOLATION OF PUBLIC UTILITIES CODE§ 2106 

(Against All Defendants) 

197. PLAINTIFFS incorporate and re-allege each of the paragraphs set forth above as 

though fully set forth herein. 

198. As a Public Utility, DEFENDANTS, and/or each of them, are legally required to 

comply with the rules and orders promulgated by the Public Utilities Commission pursuant to 

Public Utilities Code § 702. 

199. Public Utilities that fail to comply with duties required by the California 

Constitution, a law of the State, a regulation, or order of the Public Utilities Commission, which 

thereby leads to loss or injury, are liable for that loss or injury pursuant to Public Utilities Code§ 

2106. 

200. As a Public Utility, DEFENDANTS, and/or each of them, are required to provide 

and maintain service, equipment and facilities in a manner adequate to maintain the safety, health, 

and convenience of their customers and the public, pursuant to Public Utilities Code § 451. 

201. DEFENDANTS, and/or each of them, are required to design, engineer, construct, 

operate, manage, and maintain electrical supply lines in a manner consistent with their use, taking 

into consideration local conditions and other circumstances, so as to provide safe and adequate 

electric service, pursuant to Public Utility Commission General Orders 95 and 165, and Rule 33.1. 

202. DEFENDANTS, and/or each of them, are required to maintain vegetation in 

compliance with Public Resources Code§§ 4293, 4294, and 4435, and Health & Safety Code§ 

13001. 

COMPLAINT 50 

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1 203. By their conduct alleged above, DEFENDANTS, and/or each of them, violated 

2 Public Utilities Code §§ 702 and 451 and/or Public Utilities Commission General Order 95, 

3 thereby imposing liability on DEFENDANTS for losses, damages, and/or injury sustained ·by 

4 fLAINTIFFS pursuant to Public Utilities Code § 2106. 

5 204. By further reason of the premises set forth above DEFENDANTS, and/or each of 

6 them, acted in a manner which violated the laws of this State and/or the orders or decisions of the 

7 Public Utilities Commission, as referenced herein. 

8 205. As a direct and legal result of the wrongful acts and/or omissions of 

9 DEFENDANTS, and/or each of them, PLAINTIFFS suffered, and continue to suffer, the injuries 

10 and damages as set forth above. 

11 206. As a further direct and legal result of the wrongful acts and/or omissions of 

12 DEFENDANTS, and/or each of them, PLAINTIFFS seek the recovery of punitive and exemplary 

13 damages against DEFENDANTS as set forth above. 

14 

15 

16 

17 

EIGHTH CAUSE OF ACTION 

VIOLATION OF HEALTH & SAFETY CODE§ 13007 

(Against All Defendants) 

207. PLAINTIFFS incorporate and re-allege each of the paragraphs set forth above as. 

18 though fully set forth herein. 

19 

208. By engaging in the acts and/or omissions alleged in this Complaint, 

20 DEFENDANTS, and/or each of them, willfully, negligently, carelessly, recklessly, and/or in 

21 violation of law, set fire to and/or allowed fire to be set to the property of another in violation of 

22 Health & Safety Code § 13007. 

. 23 

24 

25 

26 

209. As a direct and legal result ?f DEFENDANTS' violation of Health & Safety Code 

§ 13007, PLAINTIFFS suffered recoverable damages to property under Health & Safety Code§ 

13007.21. 

210. As a further direct and legal result of the DEFENDANTS, and/or each of them, 

27 violating Health & Safety Code§ 13007, PLAINTIFFS are entitled to reasonable attorney's fees. 

28 under Code of Civil Procedure§ 1021.9. 

LAW OFFICES 

CarcHETI, PITRE & 

MCCARTHY, Ll.,P 

COMPLAINT 51 

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1 211. As a direct and legal result of the wrongful acts and/or omissions of 

2 DEFENDANTS, and/or each of them, PLAINTIFFS suffered, and continue to suffer, the injuries 

3 and damages as set forth above. 

4 

5 

6 

7 

8 

9 

212. As a further direct and legal result of the wrongful acts and/or omissions of 

DEFENDANTS, and/or each of them, PLAINTIFFS seek the recovery of punitive and exemplary 

damages against DEFENDANTS as set forth above. 

NINTH CAUSE OF ACTION 

VIOLATION OF CAL. BUS. & PROF. CODE§ 17500 

(Against All Defendants) 

213. PLAINTIFFS incorporate and re-allege each of the paragraphs set forth above as 

1 O though fully set forth herein. 

11 

12 

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COTCHETI', PITRE & 

McCARTI-IY, LLP 

214. By engaging in the acts and/or omissions alleged in this Complaint, 

DEFENDANTS, and/or each of them, willfully, negligently, carelessly, recklessly, and/or in 

violation of law, made, caused to be made, and/or disseminated before the public in this state 

untrue and/or misleading publications and/or other advertising devices, public outcries and/or 

proclamations, including social media posts such as Twitter, concerning PG&E's risk management 

services, including vegetation management, maintenance, inspection, and operation of electrical 

equipment, professional or otherwise, and/or concerning any circumstance or matter of fact 

connected with the proposed performance and/or disposition thereof. And by the exercise of 

reasonable care, PG&E knew and/or should have known to be untrue and/or misleading. 

215. In the years following the September 9, 2010 San Bruno fire and explosion, PG&E 

attempted to rehabilitate its image with advertising and representations that touted its purported 

commitment to safety and proactive maintenance. This. includes the following representation 

regarding maintenance to electric transmission towers. 

Ill 

Ill 

II I 

COMPLAINT S2 

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2 

3 

4 

5 

6 

7 

8 

9 

10 

PG&E's number one priority is providing our customers with safe. reliable 

and affordable energy. As part of that commitment, we're advancing the 

state of our eledric infrastructure by extending the height of electric 

transmission tma,ers. 

What is PG&E doing? 

·we wiH be checking and adjusbng the transmission l1:nes which tr;:mspmi electncilv 

to our substat:ions th.;it feed t:he distribution lines r~5ponsib!e for serving our local 

rnmmun~ties. businesses and reside,n1ial rnstomers. The adjustments may include: 

Modfy1;ng 1?teckic transrrnss:ion towers. Repiacmg or mo,difymg 

transmission bnes 

Repfac,ing vrnoden portes 

216. This publication is untrue and/or misleading in suggesting that PG&E would be 

I I inspecting its electrical transmission towers and making necessary adjustments. As discussed 

12 herein above, PG&E failed to discover and/or coITect equipment issues with the transmission tower 

13 that malfunctioned on November 8, 2018 despite the fact that five towers along the same line were 

14 knocked over during a 2012 storm. 

15 

16 

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LAW OFFICES 

COTCI IETl', Prnrn & 

t\lcCi\lffl IY, LI ,P 

21 7. In addition to the untrue and/or misleading publications already referenced herein 

above, PG&E made and continues to make repeated untrue and/or misleading publications 

regarding their vegetation management practices, including but not limited to the television 

commercials transcribed below: 

"Years of drought, millions of dead trees, extreme winds, and leading scientists 

say there will be even more dangerous fires in the years ahead. Our weather is 

becoming more extreme, and we all need to work together to keep our 

neighborhoods safe. I'm Lisa Veliz Waweru from PG&E. At PG&E, we are 

accelerating our forest management work in high fire-threat areas, removing dead 

trees, trimming branches and creating 12-foot safety clearances around power 

lines. As pari of our Community Wildfire Safety Program, we are implementing 

additional safety measures, including a 24-hour Wildfire Safety Operation Center, 

new early warning weather stations, and stronger power lines in high fire-threat 

areas. And we want to make sure you know what steps you can take, like cutting 

back vegetation around your home, having the right emergency plar1, and signing 

up for safety alerts. For more information on how to keep you and your 

· neighborhood safe, visit pge.com/wildfiresafety'7 

"In 2017 California had the worst wildfire season on record scientists say our 

weather is becoming more extreme and we all have to be better prepared that's 

why PG&E; is adopting new and additional safety precautions to help us monitor 

COMPLAINT 53 

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COTCI-JETf, Pmm & 

MCCARTHY, LLP 

and respond to dangerous weather. hi I'm Alison Bagley a meteorologist with 

PGA's community wildfire safety program we're working now to enhance our 

weather forecasting capabilities building a network of new weather stations to· 

identify when and where extreme wildfire conditions may occur so we can 

respond faster and better we're installing cutting-edge technology to provide realtime mapping and tracking of weather patterns and we use this information in 

partnership with first responders and California's emergency response systems to 

learn more about the community wildfire safety program and how you can help 

keep your home and community safe visit PG&E. COM/wildfiresafety." 

"Wildfire season is here and we all need to be ready to address the growing 

wildfire threat. PG&E has opened a new 24 hour Operations Center the heart of 

the new community wildfire safety program this Center helps us coordinate with 

our safety partners and it's directly connected to our new weather stations network 

so we can monitor and respond to extreme weather conditions even faster we're 

out right now removing dead trees trimming vegetation back .even farther and 

strengthening existing lines we're working closely with California's mutual 

aid in emergency response systems and as a last resort we can tum off power in 

the most extreme weather conditions to help keep you safer wildfire season is 

longer than ever before winds are stronger and we must all work together to 

address the growing threat of wildfires to learn more about the community . 

wildfire safety program and how you can help keep your home and community 

safe visit PGE dot-com slash wildfire safety." 

"The greatest dangers up here in the North State are no doubt fires two things 

happen first the fire department is dispatched and secondly they call PG&E; 

dispatch center to activate PG&E; first responders to the scene the writing fire 

department is an extremely proud and busy department facing limited firefighter 

staffing with nearly 15,000 calls out of eight stations we depend very heavily on 

mutual aid with our neighboring fire agencies and PG&E is a big part of that 

effort. We rely on PG&E extensively not only for the technical expertise and the 

resources that they have but getting there quickly so that we can free up critical 

emergency response resources their expedient response and their professional 

services are essential to the successful outcome of any incident and to that end our 

relationship has been very healthy collectively and collaboratively we make a 

difference and I'm very proud of what we do every day here in Redding" 

"Every fire department every police department is part of a bigger picture that 

bigger picture is statewide mutual aid California years ago realize the need to 

work together teamwork is important to protect the community but we have to do 

it the right way we have a working knowledge and we can re.duce the impacts of a 

small disaster but we need the help of experts PG&E; is an integral part of our 

emergency response team they're the industry expert with utilities whether it's a 

gas leak or wired down just having someone there that deals with this every day is 

is pretty comforting we each bring something to the table that is unique and that is 

a specialty with all of us working together we can keep all these emergencies 

small and the fact that we can bring it together and effectively work together it's 

pretty special they bring their knowledge their tools and equipment and the 

COMPLAINT 54 

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CarCHETI, PITRE & 

MCCARTHY,LLP 

proficiency to get the job done and the whole time I've been in the fire service 

PG&E; has been there too whatever we need whenever we need it I do count on 

PG&E; to keep our firefighters safe that's why we ask for their help" 

"I'm April Kennedy and I'm an arborist with PG&E; in this years since the onset 

of the drought more than a hundred and twenty nine million trees have died in 

California PG&E; prunes and removes over a million trees every year to ensure 

that hazardous trees can't impact our lands and since the onset of the drought 

we've doubled our efforts I grew up in the forest out in this area and honestly it's 

heartbreaking to see all these trees die what guides me is ensuring that the public 

is going to be safer and that these forests can be sustained and enjoyed by the 

community in the future" 

"Firefighting is a very dangerous profession we have one to two fires a day and 

when you respond together and you put your lives on the line you do have to 

surround yourself with experts and for us the expert in gas electric is PG&E; we 

run about 2,500 to 2,800 fire calls a year and on almost every one of those calls 

PG&E is responding to that call as well and so when we show up to a fire and 

PG&E shows up with us it makes a tremendous team during a moment of crisis. I 

rely on them. The firefighters in this department rely on them. And so we have to 

practice safety every day utilizing PG&E' s talent and expertise in that area trains 

our firefighters on the gas or electric aspect of a fire and when we have an 

emergency situation we are going to be much, more skilled and prepared to 

mitigate that emergency for all concerned. The things we do every single day that 

puts ourselves in harm's way and to have a partner that is so skilled at what they 

do is indispensable and it couldn't ask for a better partner" 

"Wildfire season is here. Be prepared by signing up for alerts at 

PG&E.COM/mywildfirealerts" 

"In the years since the onset of the drought more than a hundred and twenty nine 

million trees have died in California. P&GE [sic] prunes and removes over a 

million trees every year to ensure that hazardous trees can't impact our lands and 

since the onset of the drought we've doubled our efforts. I grew up in the forest 

out in this area and honestly its heartbreaking to see all these trees die. What 

guides me is ensuring that the public is going to be safer and that these forests can 

be sustained and enjoyed by the community in the future." 

"People like to live where nature is so we've got this wildland-urban interface area 

we all of our parks and the best way to keep them healthy is to come in and 

manage them. Hi my name is Eileen Tighly [sic] I'm acting fire chief for East Bay 

Regional Park District's Fire Department. What keeps me up at night is that 

people have a short memory they'll forget the Oakland Hills fire stonn that 

happened in· 1991. We lost well over ·2000 homes. 26 people lost their lives. We 

really need to stay vigilant especially with climate change. This area California is 

a fire prone landscape. The one thing that we can control is the fuels. East Bay 

Regional Park district partners with PG&E to annually find or remove more than 

1,000 acres of hazardous vegetation. PG&E is accelerating its wildfire risk 

COMPLAINT 55 

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COTCHErl', PITRE & 

MCCARTI-IY, ll,P 

reduction program pruning around overhead electrical lines reducing the fuel 

loads underneath those electrical lines to help reduce the spread of wildfire what 

we're really doing is making the property that's adjacent to their home safer 

PG&E; East Bay Regional Parks District and our communities we're all in this 

together to keep people safe." 

218. Moreover, the continual and/or repeated use and/or dissemination of misleading 

and/or untrue advertising related to PG&E's mitigation measures, including maintenance and 

inspection of electrical equipment and facilities, as well as vegetation management, used to prevent 

the risk of wildfires caused by the operation of its equipment, foreseeably and unreasonably misled 

PLAINTIFFS and the residents of Paradise and California, generally, related to the risk of 

catastrophic wildfires caused by PG&E's equipment. And in tum, gave PLAINTIFFS and the 

residents of Paradise and California, generally, a false sense of security. 

219. PG&E made further misleading and/or untrue publications regarding its electrical 

risk management procedures, including precautions PG&E claimed to be taking to mitigate the 

risk ·of extreme weather conditions. These misleading and/or untrue claims, include but are not 

limited to, the following PG&E news release: 

"The safety of our customers and the communities we serve is 

PG&E's top priority. We know how much our customers rely on 

electric service and would only consider temporarily turning off power 

in the interest of safety, and as a last resort during extreme weather 

conditions. PG&E has a plan. We want our customers to have plans, 

too." 

220. This statement from PG&E's Vice President of Electrical Asset Management, 

Kevin Dasso, fails to mention that de-energization of transmission lines is not included in PG&E's 

"plan" or that PG&E may arbitrarily decide not to implement its de-energization plan even when 

its own stated criteria call for de-energization. Further, PG&E's avowed commitment to making 

safety its top priority is misleading and/or untrue in light of PG&E's aforementioned diversion of 

safety funds for other purposes, runaway executive compensation, and substantial investments in 

misleading and/or untrue advertising. 

221. Further, PG&E's misleading and untrue media posts during the Camp Fire, which 

indicated that while a wildfire was probable, it had not occurred yet, was over an hour after the 

COMPLAINT 56 

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1 fire had started, homes had been destroyed, and people were fleeing for their lives. This misleading 

2 and untrue media contributed to and/or caused PLAINTIFFS and/or residents of Paradise and the 

3 surrounding communities, generally, to be misled regarding the existence of a wildfire and/or the 

4 imminent and lethal nature of the fire, delaying PLAINTIFFS's evacuation efforts and leaving 

5 them with no other option than to make a desperate attempt to escape at the last minute. 

6 222. In just three years since 2015, PG&E has spent over $3 7 million dollars promoting 

7 itself as a company that places the safety of its customers and operations first. The clear 

8 implication is that its budgets and decisions on expenditures for improving its infrastructure and 

9 vegetation management practices are safety. driyen, by a culture which places the safety of the 

10 public first and foremost above profits. 

11 223. PG&E's rhetoric does not match its actions. PG&E's culture pays greater 

12 attention to its reputation and performance on Wall Street, that a dedication to ensuring that it has 

13 a robust system of risk management over its operations. As set forth hereinabove, PG&E routinely 

14 delayed safety related projects or slashed budgets for infrastructure improvement, to assure 

15 financial performance goals were satisfied. 

16 224. The aforementioned wrongful acts and/or omissions of DEFENDANTS, and/or 

17 each of them, were done in violation of California Business and Professions Code Section 17 500, 

18 and it is likely DEFENDANTS' wrongful conduct is to reoccur and/or continue into the future. 

19 225. PLAINTIFFS hereby se~k to enjoin PG&E from further exploiting their false and 

20 misleading advertising in order to .misrepresent their commitment to safety. 

21 226. PLAINTIFFS hereby seek restitution of all amount expended for such false and 

22 misleading advertising from September 9, 2010 through the present date. 

23 227. As a direct and legal result of the actions and/or omissions of the DEFENDANTS, 

24 PLAINTIFFS have incurred and will continue to iricur attorneys' fees due to the conduct of the 

25 DEFENDANTS in an amount that cannot yet be ascertained, but which is recoverable pursuant to 

26 Code of Civil Procedure§ 1021.5. 

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28 

LAW OFFICES 

COTCHETf, PITRE & 

McCARTHY, LLP 

COMPLAINT 57 

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TENTH CAUSE OF ACTION 

INJUNCTION UNDER CAL. BUS. & PROF. CODE§ 17535 

(Against All Defendants) 

228. PLAINTIFFS incorporate and re-allege each of the paragraphs set forth above as 

though fully set forth herein. 

229. Pursuant to California Business and Professions Code Section 17535, any court of 

competent jurisdiction may enjoin "any person, corporation, firm, partnership, joint stock 

company, or any other association or organization which violates or proposes to violate [Chapter 

1. Advertising [17500-17606]", which includes the prohibition against false advertising in 

California Business and Professions Code Section 17500. 

230. Pursuant to California Business and Professions Code Section 17535, "any person 

who has suffered injury in fact and has lost money or property as a result of a violation of this 

chapter," may prosecute an action for injunction. PLAINTIFFS have suffered injury in fact and 

lost money and/or property, as described hereinabove, as a result of PG&E's false advertising. 

231. In addition, pursuant to California Business and Professions Code Section 17535, 

"[ a ]ny person may pursue representative claims or relief on behalf of others," "if the claimant 

meets the standing requirements of this section and complies with Section 382 of the Code of Civil 

Procedure." Since this is a question of common or general interest of many persons, the parties 

are numerous in this action, and it is impracticable to bring them all before the court, these 

PLAINTIFFS sue for the benefit of all and ask this Court to impose an iajunction to halt PG&E's 

false advertising for the benefit of PLAINTIFFS and/or the public. 

232. As a direct and legal result of the actions and/or omissions of the DEFENDANTS, 

PLAINTIFFS have incurred and will continue to incur attorneys' fees due to the conduct of the 

DEFENDANTS in an amount that cannot yet be ascertained, but which is recoverable pursuant to 

Code of Civil Procedure§ 1021.5. 

II I 

26 Ill 

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LAWOFFICES 

CoTCHETr, Pmrn & 

McCARTI-IY, U.P 

Ill 

COMPLAINT 58 

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1 By engaging in the acts and/or omissions alleged in this Complaint, DEFENDANTS, and/<;>r each 

2 WHEREFORE, PLAINTIFFS pray for relief as set forth below. 

3 III. PRAYER FOR RELIEF 

4 WHEREFORE, PLAINTIFFS pray for judgment against Defendants PG&E 

5 CORPORATION, PACIFIC GAS & ELECTRIC COMPANY, and DOES 1 through 20, and 

6 each of them as follows: 

7 From All DEFENDANTS for Inverse Condemnation: 

8 

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1. 

2. 

3. 

4. 

5. 

6. 

Repair, depreciation, and/or replacement of damaged, destroyed, and/or lost 

personal and/or real property; 

Loss of the use, benefit, goodwill, and enjoyment of PLAINTIFFS' real and/or 

personal property; 

Loss of wages, and/or earning capacity; 

All costs of suit, including attorneys' fees where appropriate, appraisal fees, 

engineering fees, and related costs; 

Prejudgment interest according to proof; 

For such other and further relief as the Court shall deem proper, all according to 

proof. 

From All DEFENDANTS for Negligence, Public Nuisance, Private Nuisance, 

19 Premises Liability, Trespass, Private Action Under Public Utilities Code§ 2106, Violation of 

20 Health & Safety Code § 13007, and Violation of Cal. Bus. & Prof. Code § 17500: 

21 

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LAW OFFICES 

COTCHETI, PITRE & 

McCARTI-IY, LLP 

1. 

2. 

3. 

4. 

Repair, depreciation, and/or replacement of damaged, destroyed, and/or lost 

personal and/or real property; 

Loss of the use, benefit, goodwill, and enjoyment of PLAINTIFFS' real and/or 

personal property; 

Loss of wages, earning capacity, and/or business profits or proceeds and/or any 

related displacement expenses; 

Past and future medical expenses and incidental expenses according to proof; 

COMPLAINT 59 

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COTCHETI, PITRE & 

MCCARTHY, LLP 

5. 

6. 

7. 

8. 

9. 

Treble damages for wrongful injuries to timber, trees, or underwood on their 

property as allowed under Civil Code § 3346; 

Treble damages in an amount according to proof for injuries to trees as allowed 

under Code of Civil Procedure§ 733; 

Exemplary damages in an amount according to proof as allowed under Civil Code 

§ 3294; 

Exemplary damages in an amount according to proof for wrongful injuries to 

animals as allowed under Civil Code§ 3340;· 

Exemplary damages in an amount according to proof as allowed under Public 

Utilities Code § 2106; 

10. General damages for fear, worry, annoyance, disturbance, inconvenience, mental 

anguish, emotional distress, loss of quiet enjoyment of property, personal injury, 

and for such other and further relief as the Court shall deem proper, all according 

to proof; 

11. Imposition of an injunction ordering DEFENDANTS to refrain from false 

advertising related to their wildfire risk mitigation practices, including vegetation 

management and inspection, maintenance and operation of overhead electrical 

equipment and restitution of all amounts paid for advertising that falsely promotes 

the safety of their operations since September 9, 2010; 

12. Imposition of an injunction ordering that DEFENDANTS, and each of them, stop 

continued violation of: (a) General Order No. 95, Rules 31.1-31.5, 35, 38, 43, 43.2, 

44.1-44.4, and 48-48.1; (b) General Order No. 165; (c) Public Resources Code§§ 

4292, 4293, and ~435; and (d) Public Utilities Code§ 451. 

13. Issuance of an order directing DEFENDANTS to abate the existing and continuing 

nuisance they created; 

14. Attorney's fees, expert fees, consultant fees, and litigation costs and expense as 

allowed under Code of Civil Procedure§ 1021.9; 

15. Attorney's fees as allowed under Code of Civil Procedure§ 1021.5; 

COMPLAINT 60 

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C<ffCI IETI', PITRE & 

.Mc:Ci\lffl IY, LLP 

16. For all costs of suit incurred; 

17. Prejudgment interest according to proof; 

18. For punitive damages as allowed by law; and 

19. For such other and further relief as the Court shall deem proper, all according to 

proof. 

Dated: \'2/10/"-6 

COMPLAINT 

CO~ARTHY,LLP 

By· . ~ ~1 

ALISON E. CORDOVA 

Attorneys/or P/a;nt{ffs 

STEVEN M. CAMPORA (SBN 110909) 

DREYER BABICH BUCCOLA WOOD 

CAMPORA, LLP 

20 Bicentennial Circle 

Sacramento, CA 95826 

Telephone: (916) 379-3500 Fax: (916) 379-3599 

BRIAN J. P ANISH (SBN 116060) 

P ANISH SHEA & BOYLE, LLP 

11111 Santa Monica Blvd., Suite 700 

Los Angeles, CA 90025 

Tele: (310)477-1700Fax: (310)477-1699 

MICHAEL A. KELLY (SBN 71460) 

WALKUP MELODIA KELLY & 

SCHOENBERGER 

650 California Street 

San Francisco, CA 94108 

Tele: (415) 981-7210 Fax: (415) 391-6965 

RICHARD L. HARRIMAN (SBN 66124) 

LAW OFFICES OF RICHARD L. HARIUMAN 

1078 Via Verona Drive 

Chico, CA 95973 

Tele: (530) 343-1386 Fax: (530) 343-1155 

61 

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I,,\ \XI ( )J,'l•'ICl •:S 

Coro 1i:.Tr, Prrn,,: & 

l\lcC,\tffl IY, LLP 

IX. JURY DEMAND 

PLAINTIFFS demand a trial by jury as to all claims in this action. 

COMPLAINT 

coz/~ 

By: . ~/7~-

FRANK M. PITI E 

ALISON E. CORDOVA 

Attorneys for Plaint([fs 

STEVEN M. CAMPORA (SBN 110909) 

DREYER BABICH BUCCOLA WOOD 

CAMPORA, LLP 

20 Bicentennial Circle 

Sacramento, CA 95826 

Telephone: (916) 3 79-3500 Fax: (916) 3 79-3599 

BRIAN J. PANISH (SBN 116060) 

P ANISH SHEA & BOYLE, LLP 

11111 Santa Monica Blvd., Suite 700 

Los Angeles, CA 90025 

Tele: (310) 477-1700 Fax: (310) 477-1699 

MICHAEL A. KELLY (SBN 71460) 

WALKUP MELODIA KELLY & 

SCHOENBERGER 

650 California Street 

San Francisco, CA 94108 

Tele: (415) 981-7210 Fax: (415) 391-6965 

RICHARD L. HARRIMAN (SBN 66124) 

LAW OFFICES OF RICHARD L. HARRIMAN 

1078 Via Verona Drive 

Chico, CA 95973 

Tele: (530) 343-1386 Fax: (530) 343-1155 

62 

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