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WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

- and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF JEANNE C. FINEGAN 

(I) REGARDING IMPLEMENTATION OF THE

DEBTORS’ NOTICE PROCEDURES AND

SUPPLEMENTAL NOTICE PLAN AND (II) IN

SUPPORT OF THE DEBTORS’ OBJECTION TO

CLASS REPRESENTATIVE’S MOTION TO

EXTEND APPLICATION OF FEDERAL RULE

OF CIVIL PROCEDURE 23 TO CLASS PROOF

OF CLAIM

Re: Dkt. Nos.: 4370.

Date: November 19, 2019

Time: 10:00 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor 

San Francisco, CA 94102 

Judge: Hon. Dennis Montali

Debtors. 

 Affects PG&E Corporation

Affects Pacific Gas and Electric

Company

 Affects both Debtors

* All papers shall be filed in the Lead

Case, No. 19-30088 (DM).

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Pursuant to 28 U.S.C. § 1746, I, Jeanne C. Finegan, hereby declare as follows under penalty of 

perjury: 

I. INTRODUCTION 

1. I am the Vice President of Notice Media Solutions at Prime Clerk LLC (“Prime Clerk”), 

the Debtors’ court-appointed claims and noticing agent in these chapter 11 cases, and Chief Media 

Officer of HF Media LLC, an affiliate of Prime Clerk.1 Except as otherwise noted, this Declaration is 

based upon my personal knowledge of the matters set forth herein, my review of relevant documents, 

and information provided to me by PG&E Corporation and Pacific Gas and Electric Company 

(collectively, the “Debtors”) and their agents and professionals, including professionals at Weil, 

Gotshal & Manges LLP, Cravath, Swaine & Moore LLP, AlixPartners LLP, and Prime Clerk, and my 

prior experience in bankruptcy and class action noticing, and if called and sworn as a witness, I could 

and would testify competently thereto. 

2. I submit this Declaration (i) to provide the Court with a report regarding the successful 

and timely implementation of the Debtors’ robust multi-faceted plan and procedures for providing 

notice of the Bar Date and the procedures for filing proofs of claims to known and unknown claimants 

in the Debtors’ Chapter 11 Cases, including Known and Unknown Fire Claimants2 (the “Notice 

Procedures”), and (ii) in support of the Debtors’ objection, filed contemporaneously herewith, to the 

Class Representative’s Motion to Extend Application of Federal Rule of Civil Procedure 23 to Class 

Proof of Claim [Docket No. 4370]. In accordance with the Bar Date Order, the Debtors commenced 

implementation of their Notice Procedures on July 1, 2019 and continued their efforts through the 

Court-approved Bar Date of October 21, 2019 at 5:00 p.m. Pacific Time. 

                                                      

1

 In July 2019, Heffler Claims Group, including its media division HF Media LLC, was acquired by 

Prime Clerk’s parent company. 

2

 Capitalized terms used but not otherwise herein defined shall have the meaning ascribed to them in the 

Order Pursuant to 11 U.S.C. Section 502(b)(9) and 105(a), Fed. R. Bankr. P. 2002, 3003(C)(3), 5005, 

and 9007, And L.B.R. 3003-1(I) Establishing Deadline for Filing Proofs of Claim, (II) Establishing the 

Form and Manner of Notice Thereof, And (III) Approving Procedures for Providing Notice of Bar Date 

and Other Information to All Creditors and Potential Creditors [Docket No. 2806] (the “Bar Date 

Order”). 

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II. NOTICE EXPERTISE AND QUALIFICATIONS 

3. A comprehensive description of my credentials, expertise, and experience that qualify me 

to provide an expert opinion and advice regarding notice in these Chapter 11 Cases, which include more 

than 30 years of communications and advertising experience, specifically in the bankruptcy and class 

action notice context is set forth in detail the Declaration of Jeanne C. Finegan in Support of the 

Debtors' Bar Date Motion and in Response to the Tort Committee's Bar Date Motion and Related 

Filings [Docket No. 2642] (the “Original Declaration”), which is incorporated herein by reference in 

its entirety. 

III. SUMMARY OF THE RESULTS OF THE DEBTORS’ NOTICE PROCEDURES 

AND SUPPLEMENTAL NOTICE PLAN

4. As set forth in my Original Declaration, at the time I submitted my Original Declaration, 

it was my opinion that the Debtors’ Notice Procedures, including, the Supplemental Notice Plan, were 

reasonable, effective, and went well-beyond the requirements of applicable law and due process. Based 

on my experience, I believed that the Debtors’ Notice Procedures, and in particular the Supplemental 

Notice Plan, were broad, multi-faceted, and designed to have the greatest possible reach to all creditors 

and parties in interest, including those who may have relocated as a result of the Northern California 

fires. Indeed, at the time I submitted my Original Declaration, it was my further belief that the Debtors’ 

Supplemental Notice Plan, which was amended prior to entry of the Bar Date Order to incorporate 

certain additional aspects at the request of the TCC, was one of the largest and most comprehensive 

notice and media campaigns recommended in chapter 11 history. As set forth in further detail below, 

the Notice Procedures, as implemented, have been a resounding success and have exceeded the 

estimated and projected results set forth in my Original Declaration. Specifically, the Supplemental 

Notice Plan, as implemented, has exceeded the reach and frequency estimates set forth in my Original 

Declaration, as follows: 

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5. For context, the Debtors’ Supplemental Notice Plan exceeds the combined reach and 

frequency levels of even the largest, most recent class action campaigns that had similar local, regional, 

and national outreach. 

Case Name Reach Frequency 

Takata Auto Airbag Products Liability Settlement 95% 4x 

BP Deepwater Horizon3 95% 4x 

Cook et. al v. Rockwell International Corp. and the 

Dow Chemical Co.4

96% 7x 

In re Payment Card Interchange Fee and Merchant 

Discount Antitrust 

82% 2.7x 

In re Air Cargo Shipping Services Canadian 

Antitrust 

77% 2.7x 

Spotify Publishing Settlement 74% 2.6x 

Red Bull False Advertising Class Action 72% 3.9x 

New Balance “Made in the USA” Class Action 70% 4.1x 

6. The Debtors’ Notice Procedures were broad and multi-faceted, and were designed and 

implemented to maximize reach to all claimants, including Known and Unknown Fire Claimants, in a 

variety of ways, including through (i) direct mailings to known claimants, (ii) multiple local and national 

newspaper and magazine publication notices, (iii) digital advertising, including social media, social 

influencers, and other paid Internet search listings, (iv) television and radio advertising, (v) press 

releases, and (vi) extensive community and boots on the ground outreach efforts. Through these 

                                                      

3 Decl. of Cameron Azari, Rec. Doc. 7113-1, ¶¶ 5, 6. 4 Decl. of Jeanne C. Finegan dated March 30, 2017, Doc. No. 2432, at ¶¶ 30-31. 

Target Audience Estimated 

Reach/ Frequency 

Final 

Reach/ Frequency 

Adults 18+ in the 4 DMAs 95% Reach / 8x 98% Reach / 16x 

Adults 18+ in CA 81% Reach / 5x 88% Reach / 11x 

Adults 18+ outside of CA 

and moved in the last 4 

years 

78% Reach / 2.3x 80% Reach / 3x 

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comprehensive efforts, the Notice Procedures delivered more than 730,000,000 impressions, 5 i.e. 

opportunities to see the Bar Date Notice, as follows: 

Media Channel Estimated Impressions 

Direct Mailings 6,200,000 

Social Media 411,505,264 

Display Online 50,571,921 

Magazine 53,489,000 

Influencer 1,225,191 

Out of Home (Billboards) 10,520,351 

Over the Top TV (“OTT”) 1,437,291 

Streaming Radio 3,179,525 

Terrestrial Radio 23,774,300 

National Cable Television 105,427,161 

Local Cable Television 8,535,909 

Local Broadcast Television 32,037,000 

Newspaper Publication (National) 14,442,223 

Newspaper Publication (Local) 8,553,710 

Estimated Total Impressions 730,898,846 

7. An impression translates into an opportunity to see a message in a given medium. Here, 

it measures each time the Bar Date Notice is displayed and potentially viewed by claimants. For example, 

each direct mailing of the Bar Date Notice sent out to Known Claimants constitutes one impression. 

Every time, the Bar Date was displayed in a television advertisement similarly constitutes one impression 

for each person estimated to be viewing the advertisement at the time of airing. Similarly, every time 

someone had the opportunity to view the Bar Date Notice in one of the nearly 30 newspapers in which 

the Debtors’ published notice of the Bar Date constituted an impression. The Debtors’ delivered 

                                                      

5 As explained below, every time an advertisement is displayed, that instance is considered one 

impression. One person may be exposed to numerous impressions. 

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impressions, or opportunities to see the Bar Date Notice, actually exceeded the TCC’s projected 

impressions (620,000,000) in connection with its competing bar date motion.6

8. The increase in media delivery under the Supplemental Notice Plan is due in large part to 

our continuous active campaign management. The media team and Prime Clerk, in consultation with the 

Debtors, actively managed and optimized all media channels to minimize waste and to increase audience 

visibility and engagement. As the Supplemental Notice Plan progressed, the Debtors continued to refine 

the media being used to provide notice of the Bar Date and related procedures by shifting budgets away 

from under-performing channels and toward the more effective media channels and targeting that 

objectively delivered the greatest results. Optimization decisions were based on, among other things, 

data from attribution sources (e.g. Google Analytics) and other sources including social and general 

media tools (e.g. Cision7 and Socialbakers8). These tools provide detailed, real-time insight regarding 

the performance of an ongoing media campaign and allowed us to improve performance on a continuous 

and evolving basis. 

IV. THE SUPPLEMENTAL NOTICE PLAN SUMMARY 

9. The Debtors’ Notice Procedures were generally divided into two categories: (i) direct 

mailings of the Court-approved Bar Date Notices, including customized Bar Date Notices that were 

mailed to, among other parties, Known Fire Claimants and all of the Debtors’ millions of Customers; 

and (ii) the robust and unprecedented Supplemental Notice Plan designed to reach and provide 

constructive notice to unknown claimants, including Unknown Fire Claimants, that included extensive 

national and local newspaper publications and utilized other customized media tools. The summaries 

below focus on the results of the Debtors’ Supplemental Notice Plan.9

 In accordance with the Bar Date 

Order, the Debtors’ Supplemental Notice Plan included the following noticing methods: 

 Publication of the Bar Date Notice in three (3) nationally distributed magazines;  Multiple publications of the Bar Date Notice in two (2) nationally circulated 

newspapers; 

                                                      

6

 In reporting estimated impressions of 684,000,000, the TCC miscalculated its local impressions. Thus, 

the TCC’s total should have been 620,000,000. 

7 See https://www.cision.com/us/. 8 See https://www.socialbakers.com/. 9

 An in-depth discussion of the results of direct mailing campaign completed by Prime Clerk at the 

direction of the Debtors is set forth in the Declaration of Benjamin P.D. Schrag, submitted 

contemporaneously herewith. 

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 Multiple publications of the Bar Date Notice in twenty-seven (27) local newspapers; 

 Online display advertising in English and Spanish; 

 Social media advertising on Facebook, Instagram and Twitter; 

 Social Influencers;  Google keyword searches;  Out of Home advertising (e.g., static billboards and digital boards);  Online video advertising;  Radio advertisements 

o Terrestrial local radio advertisements (English and Spanish) 

o Streaming radio advertisements  Television advertising 

o Nationwide cable television advertisements in English 

o Local market cable television advertisements in English and Spanish 

o Local broadcast television advertisements in English 

o OTT television advertisements in English and Spanish  Press Releases in English and Spanish distributed nationally  Community outreach to over 230 groups in Northern California, including: 

o Boots-on-the-ground in person distribution of the flyer to:  FEMA camps  Community events  70 PG&E service centers  6 PG&E claim centers  Informational websites in English, Spanish, Chinese and Vietnamese  Informational toll-free telephone 

10. The results of each of the specific subcategories of the Supplemental Notice Plan are 

discussed in further detail below. 

A. PRINT – MAGAZINE 

11. The Supplemental Notice Plan was expanded following input from the TCC to included 

publication of a one-half page, black and white notice one (1) time in the national editions of People 

Magazine, Sport’s Illustrated and Sunset Magazine, which have a combined circulation of 6,680,000, 

with over 48,000,000 readers. 10 The magazine advertisements were written in plain English and

contained a Spanish sub-headline that directed Spanish-speaking claimants to the Debtors’ claim 

websites for more information in Spanish. The advertisements were published in accordance with the 

below schedule: 

                                                      

10 Readership for both newspaper and magazines are calculated based on a pass-along factor. This is a 

reader in addition to the subscriber that browses that title. For example, the pass along factor for a 

newspaper is 2.11, the pass along factor for People Magazine is 10.21. That means for every subscriber 

there is an average of 10.21 people who also read the title. 

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Magazine Issue On Sale Circulation 

People Magazine August 5, 2019 July 26, 2019 3,031,000 

Sport’s Illustrated August 26, 2019 August 22, 2019 2,715,000 

Sunset Magazine September/October August 23, 2019 934,000 

12. Attached as Exhibit A are proof of publication tear sheets of the published notice in these 

magazines. 

C. PRINT - NEWSPAPER 

13. The complete Standard Bar Date Notice, which included specific information for Fire 

Claimants and directions and other relevant information explaining how such parties may file a Fire 

Claimant Proof of Claim Form, was published in two (2) nationally circulated newspapers: 

A. The Wall Street Journal - The Bar Date Notice was published one (1) time in black 

and white on July 17, 2019. The Wall Street Journal’s circulation is 2,069,000. 

B. USA Today - The Bar Date Notice was published three (3) times in black and white 

on July 17, 2019, August 22, 2019 and September 26, 2019. USA Today’s circulation 

is 1,591,000. 

14. To further enhance the outreach efforts locally and with input from the TCC, the full Bar 

Date Notice was published three (3) times during the notice period in 27 local newspapers as a halfpage, black and white notice written in plain English and featured a Spanish sub-headline. The 

additional papers were included to provide more thorough coverage of Northern California. Attached 

as Exhibit B is a chart listing the newspapers and insertion dates as well as proof of publication 

affidavits from each newspaper. 

D. ONLINE NOTICE 

15. In total, the online component of the Debtors’ Supplemental Notice Plan served more 

than 50,000,000 impressions to reach Fire Claimants. The Debtors’ online notice campaign targeted 

potential Fire Claimants based on considerations such as, among other things, geography and the target 

audiences’ characteristics, such as having recently moved from or previously lived in California. Banner 

advertisements were served in English and Spanish across a whitelist11 of approximately 4,000 websites, 

                                                      

11 A whitelist is a custom list of acceptable websites where advertising content may be served. This 

allows the Debtors to control the quality of advertising inventory that is served to creditors. The creation 

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including top-tier news websites, local news websites, and Spanish language websites, among numerous 

others, and across multiple platforms, including desktops, laptops, and mobile devices. The Debtors also 

employed cutting-edge technology and data to match Known Fire Claimants’ geographic locations to 

active WIFI/IP addresses. As set forth above, each time an advertisement was served, that instance was 

considered one impression.12 Attached as Exhibit C are examples of the banner advertisements. 

16. The Debtors’ Supplemental Notice Plan also provided online notice to potential Fire 

Claimants through advanced digital tactics such as keyword/term, contextual, audience data from 

national change of address registries, and geography to residents in Lake, Sonoma, Napa, Mendocino, 

Nevada, Butte, and Humboldt counties. 

17. The online advertisements provided information for visitors to self-identify as potential 

Fire Claimants, where they could “click” on the banner and then link directly to a website containing 

information regarding the Bar Date and submission of claims with a further link to the Debtors’ chapter 

11 case website for additional information. The Debtors also retargeted users who visited the 

informational website with additional notice reminders to take action. 

E. SOCIAL MEDIA 

18. Numerous and comprehensive tactics for providing notice to Fire Claimants were 

deployed on multiple social media platforms. In total, more than 411,000,000 social media impressions 

were served under the Debtors’ Supplemental Notice Plan, which resulted in over 50,000 “likes” and 

30,000 reactions. 

                                                      

of a whitelist helps to ensure that advertisements are targeted to real websites where actual (human) 

creditors are likely to visit, rather than serving advertisements to websites and fraudsters who are 

attempting to fraudulently earn advertising revenue from the campaign, and thereby depriving actual 

creditors of their opportunity to see the Bar Date Notice. Further, the whitelist helps to ensure that 

advertisements will not appear next to offensive or objectionable content. The whitelist is actively 

maintained over the campaign with site-level reporting of brand safety during campaign and culling of 

improper or suspicious activity on websites. Further, as a measure of privacy, all advertisements feature 

AdChoices icons whenever available. 

12 Each time an advertisement is shown on a webpage, it is counted as one impression. 

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Property Estimated 

Impressions 

Engagement 

(likes, comments, shares) 

Facebook/Instagram 406,481,000 50,000 

Twitter 2,673,000 4,699 

YouTube (English) 1,577,000 382 

YouTube (Spanish) 774,000 171 

Total 411,505,000 55,252 

19. On Facebook and Instagram, more than 70 targeting resources were utilized to provide 

notice to potential Fire Claimants, including: 

 Matching creditor records to target to a custom audience of known creditors;  Targeting people who have engaged with, talked about, or shared content regarding 

the Northern California fires;  Using profile location information to target individuals who moved out of 

California;  Geographical targeting to FEMA housing locations and Paradise evacuation zone 

pages;  Targeting to followers of pages including Camp Fire Survivors, and Housing 

Connection Butte County Camp Fire  Targeting to members of awareness and support groups, including:

California Fires Support Group Cal Fire/Wives Girlfriends Connect 

California Fire Updates California Fires Relief Online Auctions 

Fire Northern Cal – Horse, Livestock Fire Associated Pages 

#WolseyFire – Redding CalFire 

Butte County Fires, Floods and Events FEMA NorCal 

Napa California Fire Crime Alert NorCal Fire Resources 

California Fires Support Group Nor Cal Fire Chaplains Association 

Camp fire aid for victims and displaced 

families 

Housing Connection Butte County 

California Regenerative Fire Recover and 

Preparedness 

CampFire Paradise 

Northern California Help/Donations 

Assistance (Camp Fire) 

Butte-Glen 211 

 Targeting to followers of school, community service and county groups, including: 

Napa Fire Department Sonoma County 

Napa Police Department Mendocino County 

Napa Valley Unified School District Nevada County 

Napa High School Butte County 

Vichy Elementary School Humboldt County 

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Alta Heights Elementary School 

20. On Twitter, the Supplemental Notice Plan targeted people who have “tweeted”, or 

posted, about the fires using keywords or hashtags13 that included the following words or phrases, among 

others: 

Butte fire ParadiseStrong CampFire 

Redwood fire Nevada wildfire Mission fire 

Lake wildfire California wildfires Pacific Gas wildfire 

Camp Fire Paradise Strong Northern California fires 

Campfire Ghost ship Pacific Gas fire 

Humboldt wildfire Northern California wildfires Napa wildfire 

Pacific Gas bankruptcy PG&E bankruptcy Butte wildfire 

Lobo wildfire GhostShip Sonoma wildfire 

Oakmont fire Lobo fire Ghostship 

PG&E fire California fires Atlas wildfire 

Pacific Gas & Electric fire Atlas fire Pacific Gas & Electric 

wildfire 

Mendocino wildfire Pacific Gas & Electric 

bankruptcy 

Mission wildfire PG&E wildfire 

21. Finally, on YouTube, the Debtors’ Supplemental Notice Plan cast a broad net to target 

people outside of California who have recently moved. Here, 30-second video advertisements were 

targeted based on the following key search terms, among others:

Story of survival Camp Fire Mission fire 

Survivor stories Fire survivor Camp Fire 

22. Attached as Exhibit D are copies of the social media advertisements. 

F. SOCIAL INFLUENCERS 

23. In order to leverage the highest indexing media to the youngest creditors, at the Debtors’ 

direction the media team and Prime Clerk engaged social media influencers to post and share information 

about the Bar Date on Instagram and Facebook. We identified and selected key influencers who had a 

significant following within the 18-24 age demographic based on factors such as their personal 

                                                      

13 Twitter users put hashtags in their tweets to categorize them in a way that makes it easy for other users 

to find and follow feeds or “tweets” about a specific topic. 

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experience with the fires, that they resided in California, and/or that they have a significant following in 

Northern California. This effort reached over 1,200,000 followers and resulted in nearly 20,000 social 

engagements (i.e. clicks, comments and shares). Attached as Exhibit E are copies of the posts. 

G. SEARCH TERMS 

24. The Supplemental Notice Plan utilized Google AdWords and keyword search terms to 

target potential Fire Claimants. When users entered on Google’s search engine, target phrases and 

keywords identified by the Debtors’ Supplemental Notice Plan, informational advertisements with links 

to the Debtors’ Case Website appeared on the search result pages. Attached as Exhibit F is a full list of 

the keyword search terms utilized in the Supplemental Notice Plan. 

H. OUT OF HOME 

25. To further enhance outreach and in consultation with the TCC, the Debtors expanded the 

Supplemental Notice Plan to utilize 17 static or digital billboards in Butte, Humboldt, Mendocino, Napa 

and Sonoma counties. The billboards appeared for nine (9) weeks and delivered more than 10,520,000 

impressions as reported by GeoPath14 using data provided by the Traffic Audit Bureau. Attached as 

Exhibit G is a map of the board locations and a copy of how they appeared. 

I. TERRESTRIAL AND STREAMING RADIO

26. Terrestrial radio aired in English and Spanish in the 6 MSAs. A total of 24 local English 

radio stations and 10 Hispanic stations were chosen to air approximately 2,680 terrestrial radio 

advertisements. Attached as Exhibit H is a complete list of stations, their formats, broadcast language 

and markets. 

                                                      

14 Geopath generates standard audience measurements for out of home media. It provides demographicspecific impressions, rating points, and reach & frequency measures for over a million pieces of out of 

home inventory. https://geopath.org. 

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Radio Spots 

Planned 

Spots 

Delivered 

Increase from 

Planned to 

Delivered 

English 360 1,888 525% 

Hispanic 180 792 440% 

Total 540 2,680 496% 

27. To further enhance notice and in consultation with the TCC, the Supplemental Notice 

Plan was expanded to include streaming audio advertisements (i.e. digital radio played via an internet 

connection), which ran on Pandora with 30-second spots. In many instances, a digital banner 

advertisement appeared while the audio spot was aired, allowing a user to click on the banner and be 

taken to the dedicated case website. Over 1.6 million streaming audio impressions ran. 

J. TELEVISION

28. Local Broadcast TV. The Supplemental Notice Plan included broadcasting of 30-second 

television commercials throughout the course of the notice period, saturating the four Designated Market 

Areas (“DMAs”) (San Francisco-Oakland-San Jose, Sacramento-Stockton-Modesto, Chico-Reading 

and Eureka). A total of 2,010 commercials aired across approximately 14 local broadcast television 

stations, generating approximately 32,037,000 impressions to potential Fire Claimants in Lake, Sonoma, 

Napa, Mendocino, Nevada, Butte, and Humboldt counties. The commercials aired across a variety of 

dayparts,15 including morning, daytime, early news, and prime/syndicated prime to reach potential Fire 

Claimants with differing television viewing habits. 

29. Local Cable TV. 2,025 commercials aired on local cable channels and generated 

approximately 8,535,909 impressions to expand awareness of the Bar Date to potential Fire Claimants 

and other parties. Attached as Exhibit I is a list of the local and cable stations in each market utilized 

by the Supplemental Notice Plan. 

                                                      

15 A “daypart” is a term traditionally used when buying television but is also used for radio; it is a block 

of time that divides the day into segments for purchase, scheduling and delivery (e.g., primetime, or for 

radio “drive time”). The dayparting method is often used to tailor content to specific audiences 

throughout the day. 

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30. Nationwide Cable TV. To reach those Fire Claimants who may have moved within the 

last four years, 59 nationwide cable television commercials aired across CNN, FOX NEWS, History 

Channel and TNT networks resulting in 105,427,161 impressions. 

31. Importantly, the Debtors’ Supplemental Notice Plan was expanded in consultation with 

the TCC to incorporate digital OTT video advertisements on devices such as Roku, Amazon, Samsung 

and PlayStation to serve video advertisements to a matched list of Known Fire Claimants and also 

targeted potential Fire Claimants who have recently moved from California. Over 1,437,000 video 

impressions were served via OTT. 

K. ADDITIONAL METHODS OF OUTREACH 

32. In addition to paid media outlets, the Supplemental Notice Plan employed earned media 

and various avenues of public relations to amplify awareness of the Bar Date. 

33. Earned Media. A total of three (3) press releases were issued during the course of 

implementing the Supplemental Notice Plan, resulting in over 273 news mentions of the Bar Date. A list 

of the media outlets mentioning the Bar Date are attached as Exhibit J. 

34. Community Outreach. As a part of the Supplemental Notice Plan, extensive community 

outreach efforts were conducted by Prime Clerk and its’ media team throughout Northern California in 

an attempt to reach as many potential Fire Claimants as possible. In connection with these efforts the 

Debtors contacted more than 230 organizations to provide information regarding the Bar Date and related 

procedures, including community organizations, religious organizations, business associations, school 

districts, charitable foundations and disaster relief groups. Specifically, among others, Prime Clerk, at 

the direction of the Debtors, contacted the following organizations and entities: 

 Over 90 community based organizations within Butte County;  5 offices of the American Red Cross in the affected areas;  6 offices of the Salvation Army in the affected areas; and 

 35 different zones that make up the Camp Fire Zone Project, a grassroots community 

organization connecting residents with resources and building community. 

35. As a part of their extensive community outreach efforts, the Debtors distributed to these 

various organizations and entities a plain English informational flyer describing the Bar Date and related 

procedures, printed in full color and designed to capture the viewer’s immediate attention with its bold 

headline and active call to action. The flyer provided a concise and easy to understand summary of the 

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information contained in the Bar Date Notice, and prominently featured information regarding the 

Debtors’ Chapter 11 Cases, the Case Website, and toll free number. In total over 49,000 flyers were 

printed and made available in English, Spanish, Mandarin, Vietnamese, Korean, and Tagalog. Attached 

as Exhibit K are the various flyers. Attached as Exhibit L is a complete list of the community groups 

and organizations contacted by the Debtors. 

36. Temporary Housing Outreach. The Debtors’ Supplemental Notice Plan employed a 

boots-on-the ground approach to community outreach, with representatives reaching out in-person to 

various FEMA temporary housing sites. Due to FEMA privacy rules, the Debtors were not able to obtain 

specific information on the number of people still living in temporary FEMA housing; however, the 

Debtors were able to identify local FEMA housing sites and sent individual representatives to each 

location to distribute Bar Date flyers in English and Spanish and to answer questions regarding the proof 

of claim submission process.16

37. Additionally, through the Butte County Recovers newsletter, we were able to identify two 

non-FEMA temporary shelter locations.17 At the direction of the Debtors, Prime Clerk representatives 

visited each location and distributed flyers in English and Spanish and answered related questions. 

38. Paradise Revival Festival. The Paradise Revival Festival, held in Butte County on 

October 12, 2019, was a gathering organized to help victims of the wildfires. At the event, the Debtors 

prominently positioned a table on “Recovery Row” where many resources were available to assist people 

affected by the wildfires. Our representatives, which included a bi-lingual speaker, were on site for the 

entirety of the festival. The Debtors took extra steps to be visible and to encourage attendees to visit the 

table, which included a bright yellow tablecloth and Prime Clerk/PG&E laminated signs. The full-color 

flyers, in English and Spanish, were available and distributed at the event. 

M. THE SUPPLEMENTAL NOTICE PLAN GOES VIRAL

39. As part of the Debtors’ active campaign management, my team worked with various third 

parties that agreed to include in their websites a link to the Debtors’ website (www.pgewildfireinfo.com), 

                                                      

16 The FEMA temporary housing sites included Rosewood in Oroville, California, and the Silver Dollar 

Fairground in Chico, California. 

17 The non-FEMA temporary housing sites identified were Lime Saddle Campground, Lake Oroville in 

Paradise, California, and the DeSabla Campground, Lake De Sabla, in Magalia, California. 

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and prominently feature the Bar Date Notice. Several other third parties participated on their own 

volition, including Attorney Helen Sedwick, who posted a video on YouTube that provides step-by-step 

instructions on how to file a Fire Proof of Claim.18 In addition, a student run university newspaper in 

Ithaca, New York, approximately 2,700 miles away, published a story that highlighted the Bar Date and 

summarized the process for filing proofs of claim. 

40. Additionally, the websites below either mentioned the Bar Date deadline or featured links 

to the www.pgewildfireinfo.com site: 

 https://www.pgefireinfo.com/  https://www.norcalfirelawyers.com/pge-fire-claims-deadline-  https://www.lieffcabraser.com/2019/10/only-2-weeks-left-for-2017-and-2018-

northern-california-wildfire-victims-to-file-claims-against-pge/  https://www.disabilityrightsca.org/post/pge-fire-claims-deadline  https://www.capersonalinjurycaselawnotes.com/  https://cawildfirelawyers.com/  https://www.potterhandy.com/northern-california-fire-lawyers/  https://www.walkuplawoffice.com/ca-wildfire-loss/  https://thompsonlawoffice.com/northern-california-wildfire-victims-lawsuitscontinues-despite-pge-bankruptcy-filing/  https://www.kqed.org/news/11767118/northern-california-wildfire-victims-cannow-file-claims-with-pge  https://www.latimes.com/opinion/story/2019-10-09/wildfire-victims-shorteneddamage-claim-period  https://neighborstogethersr.com/2019/10/08/claim-deadline-10-21-19-uninsuredand-underinsured-fire-survivors-fire-affected/ 

41. In addition, Disability Rights of California’s Facebook page, which has over 9,100 

followers and 8,400 “likes,” also posted information about the Bar Date.19 

P. ONLINE QUALITY CONTROL - ADVERTISEMENT FRAUD 

IDENTIFICATION, MITIGATION AND REPORTING 

42. As described in my Original Declaration, the Debtors’ Supplemental Notice Plan 

incorporated state of the art quality control mechanisms to ensure that the Debtors’ online advertisements 

were properly targeted to real websites where actual humans are likely to visit, rather than serving 

advertisements to websites and fraudsters that attempt to steal advertising revenue from the campaign 

(thereby depriving actual Fire Claimants of their opportunity to see the Bar Date Notice). 

                                                      

18 See https://www.youtube.com/watch?v=a5d4fCwNTVI&feature=youtu.be. 

19 See https://www.facebook.com/pg/DisabilityRightsCalifornia/posts/?ref=page_internal. 

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43. The Supplemental Notice Plan included in-advertisement, log, and site level monitoring 

and management, utilizing one of the leading cyber security advertisement fraud expert service providers 

in the country. I am pleased to report to the Court that less than one percent invalid impressions was 

detected in this campaign, which is a remarkable achievement even when compared to large brand 

campaigns. This invalid traffic has been excluded from the final reach calculations.

V. CONCLUSION 

44. In my opinion, the robust and comprehensive outreach efforts employed for the Debtors’ 

Noticing Procedures, including the Supplemental Notice Plan, are unmatched in any chapter 11 case. 

The efforts reflected a particularly appropriate, highly targeted, efficient and modern way to provide 

notice to Known and Unknown Fire Claimants. The Debtors’ Supplemental Notice Plan was broad and 

multi-faceted and more than achieved its goal of maximizing reach to the target audiences. 

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Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury, that the foregoing is true 

and correct to the best of my knowledge, information, and belief. Executed on November 11, 2019, 

in Tigard, Oregon. 

Jeanne C. Finegan

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