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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

Robert A. Julian (SBN 88469)

Cecily A. Dumas (SBN 111449)

BAKER & HOSTETLER LLP

600 Montgomery Street, Suite 3100

San Francisco, CA 94111-2806 

Telephone: 415-659-2900

Facsimile: 415-659-2601

Email: rjulian@bakerlaw.com

Email: cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

David J. Richardson (SBN 168592)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Blvd., Suite 1400

Los Angeles, CA 90025-0509

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: drichardson@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel to the Official Committee of Tort Claimants

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)

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11 (Lead Case)

(Jointly Administered)

JOINDER OF OFFICIAL COMMITTEE OF 

TORT CLAIMANTS TO GHOST SHIP 

PLAINTIFFS’ MOTION FOR RELIEF 

FROM STAY [Dkt. No. 4875]

Date: December 17, 2019

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Case: 19-30088 Doc# 4945 Filed: 12/02/19 Entered: 12/02/19 17:14:02 Page 1 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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The Official Committee of Tort Claimants (“TCC”) in the chapter 11 cases of PG&E 

Corporation and Pacific Gas and Electric Company, as debtors and debtors in possession 

(collectively, “PG&E” or the “Debtors”) respectfully files this joinder (“Joinder”) to the motion 

(“Motion”) of the Ghost Ship plaintiffs (“Ghost Ship Plaintiffs”) for relief from the automatic 

stay [Dkt. No. 4875]. 

The December 2, 2016 Ghost Ship Fire killed 36 individuals and injured dozens more. A 

total of 70 survivors and family members who lost their loved ones filed 53 lawsuits against a group 

of defendants and PG&E alleging the defendants were responsible for their damages. Declaration 

of Mary Alexander [Dkt. No. 4877], filed in support of the Motion, at ¶¶ 4-9. PG&E’s insurance 

for 2016 fully insures the Ghost Ship claims and hence does not compete with the 2015, 2017 and 

2018 wildfire claims that caused PG&E to file this chapter 11 case. Id. at ¶¶ 23, 30.

In both of the proposed plans of reorganizations, the Ghost Ship Plaintiffs’ claims would 

ride through the bankruptcy subject to the Debtors’ insurance. See Debtors’ Joint Chapter 11 Plan 

of Reorganization Dated Nov. 4, 2019 at Section 4.21 [Dkt. No. 4563]; Joint Chapter 11 Plan of 

Reorganization of Official Committee of Tort Claimants and Ad Hoc Committee of Unsecured 

Noteholders at Section 10.09(f) [Dkt. No. 4257]. It is in the best interests of the Ghost Ship 

Plaintiffs for their resolution of their claims by that insurance to be advanced, rather than delayed 

to after plan confirmation.

The Ghost Ship Plaintiffs have stated that they believe that their claims are within the limits 

of the Debtors’ insurance. Alexander Declaration at ¶ 23. According to Ms. Alexander, “Granting 

relief from stay will allow the Ghost Ship Litigation to proceed against the Debtors, in order to 

establish liability of the Debtors, obtain judgment(s) against the Debtors, and collect any 

judgment(s) obtained against the Debtors to the extent of available insurance.” Id. at ¶ 31. Hence, 

relief from stay is in the best interests of the estate and wildfire victims who seek to maximize their 

recoveries from the non-Ghost Ship insurance assets.

The Ghost Ship Plaintiffs have filed their Motion to enable them to recover from the 

Debtors’ insurance policies without delay. Insurance coverage for both Valero Refining Company 

Case: 19-30088 Doc# 4945 Filed: 12/02/19 Entered: 12/02/19 17:14:02 Page 2 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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California (“Valero”) and the Ghost Ship Plaintiffs exists under 2016 policies that do not cover the 

2015, 2017 and 2018 wildfire claims. The Court has granted relief from stay for Valero to proceed 

against the same 2016 insurance [Dkt. No. 3819] and therefore the Ghost Ship Plaintiffs’ claims 

against the 2016 insurance should have equal access and relief from stay. The Ghost Ship Plaintiffs 

are suffering and there is no valid reason for delaying the liquidation of their claims against the 

insurance. 

CONCLUSION

Wherefore, for all of the reasons argued herein and in the Motion, the TCC respectfully 

requests that this Court grant the Motion.

Dated: December 2, 2019 Respectfully submitted,

BAKER & HOSTETLER LLP

By: /s/Robert A. Julian 

Robert A. Julian

Counsel to the Official Committee of Tort Claimants 

Case: 19-30088 Doc# 4945 Filed: 12/02/19 Entered: 12/02/19 17:14:02 Page 3 of

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