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DIEMER & WEI, LLP

Kathryn S. Diemer (#133977)

100 West San Fernando Street, Suite 555

San Jose, CA 95113

Telephone: (408) 971-6270 

Facsimile: (408) 971-6271 

Email: kdiemer@diemerwei.com

-andWILLKIE FARR & GALLAGHER LLP

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Benjamin P. McCallen (pro hac vice)

Daniel I. Forman (pro hac vice)

787 Seventh Avenue

New York, NY 10019

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

jminias@willkie.com

bmccallen@willkie.com

dforman@willkie.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC 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)

Bankr. Case No. 19-30088 (DM)

Chapter 11 

(Jointly Administered)

ORDER GRANTING AD HOC GROUP OF 

SUBROGATION CLAIM HOLDERS’ MOTION 

PURSUANT TO 11 U.S.C. §§ 105(A) AND 107(B) 

AND FED. R. BANKR. P. 9018 FOR ENTRY OF 

AN ORDER AUTHORIZING THE FILING OF 

CERTAIN DOCUMENTS UNDER SEAL

[No Hearing Requested]

Signed and Filed: November 12, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

November 13, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 4696 Filed: 11/12/19 Entered: 11/13/19 09:30:49 Page 1 of

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The Court having considered the Ad Hoc Group of Subrogation Claim Holders’ Motion 

Pursuant to 11 U.S.C.§§ 105(a) and 107(b) and Fed. R. Bankr. P. 9018 for Entry of an Order 

Authorizing the Filing of Certain Documents Under Seal (the “Motion”), filed on November 11, 

2019 by the Ad Hoc Group of Subrogation Claim Holders (the “Ad Hoc Subrogation Group”) in 

the jointly administered chapter 11 cases of the above-captioned debtors in possession,

IT IS HEREBY ORDERED THAT:

1. The Motion is GRANTED.

2. The Ad Hoc Subrogation Group is authorized to file the Model Release 

Attachments, as defined in the Motion, under seal pursuant to sections 105(a) and 107(b) of the 

Bankruptcy Code and Bankruptcy Rule 9018. 

3. The Model Release Attachments are confidential, shall remain under seal, and 

shall not be made available to anyone without the consent of the Debtors, except that copies of the 

Model Release Attachments shall be provided to (i) the Debtors; (ii) the Court, (iii) the U.S. Trustee, 

(iv) counsel to the Official Committee of Unsecured Creditors, the Official Committee of Tort 

Claimants, and any other official committee established pursuant to section 1102 of the Bankruptcy

Code, (v) counsel to the objectors to the RSA Approval Motion, as defined in the Motion, and (vi) 

any other parties that have endorsed the Protective Order, as defined in the Motion, and have 

requested a copy of the Model Release Attachments, on a confidential and professional eyes only 

basis.

4. Notice of the Motion as provided therein shall be deemed good and sufficient 

and the requirements of the Bankruptcy Local Rules are satisfied by such notice.

5. The terms and conditions of this Order shall be immediately effective and 

enforceable upon its entry. 

6. This Court shall retain jurisdiction to hear and determine all matters arising 

from or related to the implementation, interpretation, or enforcement of this Order.

**END OF ORDER**

Case: 19-30088 Doc# 4696 Filed: 11/12/19 Entered: 11/13/19 09:30:49 Page 2 of

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