EXHIBIT O

Case: 19-30088 Doc# 2460-15 Filed: 06/07/19 Entered: 06/07/19 20:02:19 Page 1

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Minga, Jay

From: Vora, Samir <SVora@milbank.com>

Sent: Tuesday, June 4, 2019 12:35 PM

To: Minga, Jay

Cc: Slack, Richard; Tran, An; Liou, Jessica; Peter Benvenutti; Singh, David; Leblanc, Andrew; 

Stone, Alan

Subject: RE: PG&E - Draft Protective Order

Jay, all of these edits are fine except we would like to revert to our version of the “Timing of Challenge to Confidentiality 

Designations” provision (no issue with the re‐ordering of that section). 

Happy to discuss. 

Samir L. Vora | Milbank | Special Counsel

1850 K Street, NW, Suite 1100 | Washington D.C. 20006 

T: +1 202.835.7544 

svora@milbank.com | milbank.com 

*Not yet admitted to practice in D.C. Admitted to practice in California. 

From: Minga, Jay [mailto:Jay.Minga@weil.com]  

Sent: Monday, June 3, 2019 9:24 PM 

To: Vora, Samir <SVora@milbank.com> 

Cc: Slack, Richard <richard.slack@weil.com>; Tran, An <An.Tran@weil.com>; Liou, Jessica <jessica.liou@weil.com>; 

Peter Benvenutti <pbenvenutti@kellerbenvenutti.com>; Singh, David <David.Singh@weil.com> 

Subject: PG&E ‐ Draft Protective Order 

Samir, 

Thank you very much again for your comments on the draft protective order.  We’ve accepted virtually all your 

suggested changes, with a few limited exceptions that we explain below.  Also, for your convenience we have attached a 

revised clean version along with a redline against the last received from you.  Please note that this new version also 

incorporates edits and comments from the TCC, which accounts for virtually all of the changes not suggested by the 

UCC. 

We did not modify the “Highly Confidential” and “Professional Eyes Only” designations because Debtors have already 

anticipated using both designations on documents. 

                                                        

Regarding Professional Eyes Only Material, we have accepted your suggestion that adverse witnesses be allowed to 

review Professional Eyes Only Material, subject to the witnesses signing an “Acknowledgement and Agreement to Be 

Bound (Exhibit A).”   

We largely accepted your proposed paragraph 7.6 regarding use of protected material in open court.  We propose, 

however, that the party seeking to offer or use protected material would be best situated to seek relief from court, since 

that party knows of its own need to seek relief in advance of the 72 hours’ notice to the other party.  This allocation 

would also permit keeping the notice period to 72 hours before the intended use without potentially prejudicing the 

Producing Party.   We further propose that it would be appropriate and consistent with precedent that absent relief the 

party seeking to use protected material would not be permitted to make use of it in open court.   

Case: 19-30088 Doc# 2460-15 Filed: 06/07/19 Entered: 06/07/19 20:02:19 Page 2

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Lastly, we have accepted the extension of time to return Protected Material and agree with portions of your proposed 

language as to the final disposition of Protected Material, including retention of certain work product, etc., and have 

proposed additional language and options consistent with Judge Montali’s past protective orders. 

We hope that these changes work.  We are available for a call if you would like to discuss any of the foregoing. 

Thanks, 

Jay 

Jay Minga 

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153 

Jay.Minga@weil.com

+1 212 310 8378 Direct 

+1 646 467 2079 Mobile 

+1 212 310 8007 Fax 

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Case: 19-30088 Doc# 2460-15 Filed: 06/07/19 Entered: 06/07/19 20:02:19 Page 3

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