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Dario de Ghetaldi – Bar No. 126782 

Amanda L. Riddle – Bar No. 215221 

Steven M. Berki – Bar No. 245426 

Sumble Manzoor – Bar No. 301704 

COREY, LUZAICH, 

DE GHETALDI & RIDDLE LLP 

700 El Camino Real 

P.O. Box 669 

Millbrae, CA 94030-0669 

Telephone: (650) 871-5666 

Facsimile: (650) 871-4144 

deg@coreylaw.com 

alr@coreylaw.com 

smb@coreylaw.com 

sm@coreylaw.com 

Michael S. Danko – Bar No. 111359 

Kristine K. Meredith – Bar No. 158243 

Shawn R. Miller – Bar No. 238447 

DANKO MEREDITH 

333 Twin Dolphin Drive, Suite 145 

Redwood Shores, CA 94065 

Telephone: (650) 453-3600 

Facsimile: (650) 394-8672 

mdanko@dankolaw.com 

kmeredith@dankolaw.com 

smiller@dankolaw.com 

Eric Gibbs – Bar No. 178658 

Dylan Hughes – Bar No. 209113 

GIBBS LAW GROUP 

505 14th Street, Suite 1110 

Oakland, CA 94612 

Telephone: (510) 350-9700 

Facsimile: (510) 350-9701 

ehg@classlawgroup.com 

dsh@classlawgroup.com 

Attorneys for Individual 

Fire Victim Creditors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

In re 

PG&E CORPORATION and 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

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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Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered)

LIMITED OBJECTION TO CROSSMOTIONS FOR ENTRY OF A 

PROTECTIVE ORDER (Docket Nos. 

2419 & 2459) 

Date: June 26, 2019 

Time: 9:30 a.m. 

 Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

 

Case: 19-30088 Doc# 2690 Filed: 06/20/19 Entered: 06/20/19 16:17:48 Page 1 of

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Individual Fire Victim Creditors (“IFVC”) represented by the law firms of Corey, Luzaich, de 

Ghetaldi & Riddle LLP and Danko Meredith (the “Corey/Danko firms”) and the Gibbs Law Group 

respectfully submit this limited objection to the following cross-motions for entry of a protective order 

(“Cross-Motions”): (1) Motion of Official Committee of Tort Claimants for Entry of a Protective 

Order, Docket No. 2419 (the “TCC Protective Order Motion”); and (2) Motion for Entry of Protective 

order Pursuant to Fed. R. Bnakr. P. 7026 and 9014(c) and 11 U.S.C. § 105(a) Governing Discovery 

Materials and other Information, Docket No. 2459 (“Debtors’ Protective Order Motion”). 

I. INTRODUCTION 

The IFVC are comprised of approximately 2,700 individuals and business entities who have 

been harmed by the 2015 Fresno Sheriff’s Gun Range Explosion and Fire, the 2015 Butte Fire, the 

2017 North Bay Fires, and the 2018 Camp Fire. The IFVC is not represented on the TCC. 

The Cross-Motions contain provisions that are contrary to the interests of the IFVC and that 

were not discussed with their attorneys prior to the Cross-Motions being filed. 

 Specifically, the protective orders advanced by the Cross-Motions would not allow counsel for 

the IFVC to receive copies of any documents marked “Confidential” by the Debtors unless the Debtors 

so agree or the Court so orders. (See TCC Protective Order Motion, Docket No. 2419-1, pp. 10-12 of 

18 at §§ 7.2-7.3; see also Debtors’ Protective Order Motion, Docket No. 2459-1, pp. 10-12 of 19 at §§ 

7.2-7.3.) 

II. ARGUMENT 

Adoption of the restrictive provisions limiting production of documents marked “Confidential” 

would be prejudicial to the IFVC and their counsel. The IFVC do not currently have a representative 

on the TCC and their counsel will not be allowed to employ their knowledge and experience to review, 

or comment on, or use to assist their clients or the TCC without approval of the Debtors or the Court. 

Requiring the IFVC’s counsel to seek approval from the Debtors or the Court prior to viewing any 

document marked “confidential” will place a substantial and unnecessary burden on the IFVC’s 

counsel given Debtors’ prior practice of being somewhat over-inclusive in designating documents as 

“confidential.” 

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The Cross-Motions do not state any reason or justification for the restrictive scope of 

production that effectively limits disclosure of document discovery to only the requesting party. No 

such justification exists. 

The Corey/Danko/Gibbs firms are veterans of litigation against PG&E going back to the 2010 

San Bruno Explosion and Fire Cases, the 2015 Butte Fire Cases, and the 2017 North Bay Fire Cases, 

and the 2018 Camp Fire Cases. The Corey/Danko firms held leadership positions in each of those 

litigations and over the years received and reviewed hundreds of thousands of PG&E documents 

including tens of thousands that were marked “confidential.” 

Finally, the restrictive provisions are unnecessary given the moving parties’ agreement on the 

form of an “Acknowledgement and Agreement to Be Bound,” an agreement to which counsel for the 

IFVC will readily agree and sign. (See TCC Protective Order Motion, Docket No. 2419-1, Ex. B, p. 

18 of 18; see also Debtors’ Protective Order Motion, Docket No. 2459-1, p. 19 of 19.) 

III. CONCLUSION 

For all of the foregoing reasons, the IFVC respectfully request that the Court only approve a 

Protective Order in a form that allows counsel for any creditor who signs the proposed 

“Acknowledgement and Agreement to Be Bound” to receive and use copies of any documents 

produced by Debtors provided any such use is pursuant to the terms of the Protective Order. 

DATED: June 20, 2019 Respectfully submitted, 

COREY, LUZAICH, DE GHETALDI & RIDDLE LLP 

By: 

Dario de Ghetaldi 

Amanda L. Riddle 

Steven Berki 

Sumble Manzoor 

Attorneys for Indivisual Fire Victim Creditors 

DANKO MEREDITH

Michael S. Danko 

Kristine K. Meredith 

Shawn R. Miller 

Attorneys for Individual Fire Victim Creditors 

GIBBS LAW GROUP

Eric Gibbs 

Dylan Hughes 

Attorneys for Individual Fire Victim Creditors 

Case: 19-30088 Doc# 2690 Filed: 06/20/19 Entered: 06/20/19 16:17:48 Page 3 of

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