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0l 7558.0085\5676427.8 FIRST REPORT

Mark S. Bostick (Bar No. l1I24I)

Lisa Lenherr (Bar No. 258091)

WENDEL ROSEN LLP

I 1 1 1 Broadway, 24th Floor

Oakland, California 94607 -4036

Telephone: (510) 834-6600

Fax: (510) 834-1928

Email: mbostick@wendel.com

Email: llenhen@wendel.com

Attorneys for Michael G. Kasolas, Claims

Representative

In re:

PG&E CORPORATION

-andPACIFIi GAS AND ELECTRIC

coMPANY,

Debtors.

n Affects PG&E Corporation

n Affects Pacific Gas and Electric Company

r Affects both Debtors

LTNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

Case No. 19-30088-DM

Chapter 11 (Lead Case)

(Jointly Administered)

FIRST REPORT OF COURT

APPOINTED CLAIMS

REPRESENTATIVE

*All papers shall be filed in the Lead Case,

No. I9-30088 (DM)

MICHAEL G. KASOLAS, the Court appointed claims representative (the "Claims

Representative"), hereby submits his First Report, as follows:

I. BACKGROUND

On November 11, 2019, the Honorable Dennis Montali, United States Bankruptcy Court,

Northern District of California, entered the Order Extending Bar Date for Fire Claimants and

Appointment of Claims Representative (the "Bar Date Extension Order"). (Docket No. 4672.) The

Bar Date Extension Order provides that the Claims Representative shall be given broad discretion

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to conduct the following tasks (the "Tasks") for the benefit of Unfiled Fire Claimantsl:

(i) identifying and locating Unfiled Fire Claimants and implementing procedures to

provide notice of the Extended Bar Date to Unfiled Fire Claimants;

(ii) obtaining and interpreting data to identify and locate Unfiled Fire Claimants and, in

particular, to identify and locate displaced Unfiled Fire Claimants.

(iii) establishing and implementing procedures to inform and educate Unfiled Fire

Claimants about their rights to file Fire Claims by the Extended Bar Date, and implementing

reasonable methods to reach Unfiled Fire Claimants to inform them of the Extended Bar Date and

how to file Fire Claimants Proof of Claim Forms on account of any Fire Claims;

(iv) assisting Unfiled Fire Claimants with the process of filing Fire Claimants' Proof of

Claim Forms in these cases, including coordinating with Prime Clerk LLP ("Prime Clerk") who

will be independently setting up locations within the fire zone areas where Prime Clerk

representatives shall receive Proof of Claim Forms; and

(v) periodically reporting to both this Court and to Judge Donato on progress and results.

N. CLAIMS REPRESENTATIVE'S ROLE, BACKGROUND AND

QUALIFICATIONS

Michael G. Kasolas, as the Claims Representative, is being asked to identifr, locate and

assist traumatized and/or displaced fire victims who are eligible to file claims by December 31,

2019. He is thus required to perform a substantial body of work under intense time constraints to

identify and reach fire victims who were not previously reached by prior noticing programs, or

who were unable to protect their interests in these cases. Rather than blanket the community with

generalized repetition of past noticing programs, the program that is described in this Report is

designed to identify and target those fire victims who were not reached by, or were not responsive

to, prior noticing programs, or who were unable to respond because of reasons such as ongoing

trauma. The Claims Representative was selected based upon his ability to successfully achieve the

objectives of his appointment within the limited time afforded. Mr. Kasolas will oversee and direct

I Capitalized terms not defined herein shall have the meaning ascribed to them in the Bar Date

Extension Order

2

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017558 0085\5676427 8 FIRST REPORT

his Team in an effort to effectively and efficiently accomplish the Tasks.

Mr. Kasolas is currently a Chapter 7 Trustee for cases in the Oakland Division of the

Northern District of California, formerly a Chapter 7 Trustee in the Sacramento Division of the

Eastern District of Califomia, has acted as a Chapter I 1 Trustee and Examiner for the Sacramento

Division of the Eastem District of California, and the Oakland, San Jose, and Santa Rosa

Divisions Northern District of California, and has previously acted, and currently acts, as

Receiver, Referee, and Partition Referee for cases in the Superior Court of California, Counties of

San Francisco, Alameda, and Contra Costa.

III. CLAIMS REPRESENTATIVE'S TEAM

Bar Date Extension Order provides the Claims Representative with the authority to engage

staff, personnel, vendors (including but not limited to media/advertising, project management

services, technology solutions, public relations, and other consultants), and counsel (collectively

the ooTeam") to assist in the implementation of the Tasks. To assist him in completion of the Tasks,

the Claims Representative has engaged the following as the Team members:

1) Media-Kinsella Media, an Exela Technologies Brand

Role: Kinsella Media will design and implement the media outreach that will focus

attention on those who have not filed, or been unable to file, claims in these cases.

Oualifications: Kinsella Media, a leading notice expert firm, has designed and

implemented more than 1,000 notification programs and placed over $400 million in legal notice

advertising during the course of 28 years in business. They are particularly well-suited to the task

of reaching fire victims who have not been reached by prior notices, or who have been unable to

come forward to protect their interests in these cases. Katherine Kinsella founded Kinsella Media

in 1991 and worked to establish the methodology that became the industry standard for legal

notification programs. Shannon Wheatman, Ph.D., is the current president of Kinsella Media and

has 19 years of experience in legal notice. Katherine Kinsella and Dr. Wheatman have been

recognized as legal notice experts in state and federal courts across the U.S. in both class action

and bankruptcy cases. Dr. Wheatman's plain language expertise was advanced by her education,

including her doctoral dissertation on plain language drafting of legal notice. Under their

J

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0I 7558.0085\5676427.8 FIRST REPORT

leadership, the firm developed and implemented some of the most complex notice programs in the

legal industry (see Exhibit A for some relevant case experience).

Team Cpntribution: Kinsella Media is drafting all materials in plain language and

designing all creative materials (flyers, poster, newspaper ads, TV and radio ads, digital banner

ads, social media ads, graphics for Facebook group page). Kinsella Media has recommended a

media program that will run in the weeks leading up to the extended deadline and will plan and

buy all approved media. Kinsella Media will continuously monitor the delivery of the campaign

and make adjustments as necessary to optimize effectiveness by targeting traumatized and/or

displaced fire victims. Upon completion of the campaign, Kinsella Media will provide an

implementation report confirming everything ran as planned.

2) Public Relations & Outreach-Holmes Associates

Role: Holmes Associates will design and implement a communications strategy that is

focused on the particular fire victims who have not been reached by, or responded to, prior

noticing programs.

Oualifications: Holmes Associates was established by Shelly Holmes, a 30-year marketing

communications and public relations professional, who spent years as a senior partner in

international and regional agencies, overseeing complex clients and multimillion-dollar budgets.

Her goal was to create an agency that used a more efficient, flexible and results-driven approach

than many other agencies were offering. The Holmes Associates team members come from large

agencies, corporations, newsrooms, startups and more. Because of these varied backgrounds and

experiences, members are adept at branding and messaging, general and targeted market outreach,

grassroots and community outreach, key influencer relations, media relations, social media and

crisis communications. Team members currently working on this outreach program have

significant experience in public outreach and education campaigns that included working with

rural communities in distress or with unique needs and circumstances, including but not limited to

those surviving/addressing natural disasters.

Team Contribution: Holmes Associates is working with the Team to develop a

communications strategy that takes into account a short timeframe but large geographic reach,

4

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with the goal of using prioritized tactics that reach the most traumatized and displaced people

possible by December 3 I , 2019.It is taking into account the feedback from media, organizations

and local residents that the fire-survivor community and the region at-large is dealing with "fire

fatigue" and somewhat overwhelmed with all the information and deadlines they have received

over the last year or so. Holmes Associates will implement this strategy through the use of

Community Partnerships, Community Grassroots Outreach, Social Media and Media Relations.

Additionally, Holmes Associates is coordinating efforts with other PR and communications firms

and efforts that represent PG&E, TCC and local business concems.

3) Technology & Data-BMC Group

Role: BMC Group will design and perform the data analysis that will be critical to ensure

that the Claims Representative does not duplicate the efforts of prior noticing programs, but

instead focuses on those fire victims who can be identified as having not filed a claim in these

cases.

Qualifications: BMC Group is a leading provider of technology-enabled information

management and collaboration services. The BMC Group team is made up of leading industry

professionals, many with significant experience in both the legal and administrative aspects of

large, complex Chapter l1 and Class Action cases. For over 20 years, BMC Group has acted as

information agent, offrcial claims and noticing agent, solicitation and balloting agent and

distribution agent in thousands of cases nationwide.

Team Contribution: BMC Group's role is as 'information agent' on the Team. It will

design, host and administer a SmartRoom secure virtual dataroom that will be used to compile and

analyze data to assist the Claims Representative and his Team to pinpoint the traumatized and

displaced Unfiled Fire Claimants and ensure that the media efforts are directed to the correct

markets. Further, based on data analysis results, BMC Group will execute direct outbound print,

mail, text, and telephone notice outreach to potential Unfiled Fire Claimants. In addition, BMC

Group will design and host the website and related social media links, email inbox, and call center.

In coordination with these efforts, BMC Group will work with the Team to develop website

content and call center scripts, including FAQs.

5

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4) Legal-Wendel Rosen LLP

Role: Legal support for the Claims Representative.

Qualifications: Founded in 1909, Wendel Rosen LLP is one of the oldest and largest law

firms in the East Bay region of the San Francisco Bay Area. The firm has a nationally recognrzed

and highly regarded bankruptcy and creditor debtor rights, insolvency and reorganization law

practice. Mark Bostick, lead counsel in this matter, has more than 35 years of experience focused

on insolvency law, representing trustees, debtors, creditors and other interested parties in all forms

of insolvency proceedings and out-of-court workouts.

Team Contribution: Wendel Rosen LLP will work with the Team and third parties, including the

TCC, the Debtors, and Prime Clerk, to ensure that all media, communications and outreach

activities provide legally accurate information in compliance with the Bar Date Extension Order.

The firm will also assist the Team in preparing any necessary reports, requests for funds or

payment, and other submissions to the courts.

IV. PRELIMINARY STRATEGY AND CURRENT STATUS

The Team has formulated the following preliminary2 strategy to accomplish the Tasks:

1. Media:

The paid media program seeks to provide notice of the Extended Bar Date to Unfiled Fire

Claimants focusing specifically on the fire counties and contiguous counties in Northern

California, and generating content that encourages those who have not yet filed proofs of claim to

do so for damages and losses not previously emphasized in previous noticing.efforts. Per

discussions with members of the TCC, it is Kinsella Media's understanding that among those least

likely to file claims are individuals who are renters, occupants, the elderly, under-employed, and

those who suffered non-property damages and loss. Although people have moved out of the area

and out of state, it is Kinsella Media's belief that many remain pursuant to news reports citing

2 The Claims Representative and his Team are still gathering data and coordinating their efforts

with third-party groups and individuals familiar with the issues related to locating fire-related

claimants and outreach efforts. The Team is agile and can (and will) pivot when necessary to

ensure that funds are effectively utilized to maximize impact and effectiveness.

6

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0t7558 0085\567642? 8 FIRST REPORT

20,000 fire victims still living in Chico, California.

Building off the original notice efforts, the claims outreach media program will be targeted

to the specific counties and contiguous areas affected by the Northern California Fires. The media

program will provide awareness that will dovetail with and support local on-ground efforts to

identify Fire Claimants.

The media program is a layered approach using social media, radio, local and community

newspapers, general market and cable TV, Social media will be used in the affected counties as

we believe Fire Victims are in many cases still in touch with each other.

While the reach of the media program is important, the content is unique to reflect the

specific and targeted goals of the Claims Representatives' assigned Tasks. The extension of the

bar date, the role that residents can play in reaching out to former neighbors, and the message that

the Court is taking this extra step in an effort to reach all fire victims, are indicative of the content

that will attempt to reach targeted claimants rather than blanket the community with repetition of

prior media content. The exact media scheduling will be determined based on timing of funding

and on costs and targeting information.

For the cuffent status of media efforts, see the media activity report attached as Exhibit B.

2, Public Relations & Outreach:

The limited time frame and budgeting for this program does not permit the Claims

Representative's Team to create new communications networks to reach potential fire victims.

Instead, Holmes Associates is working to establish Community Partnerships which will allow the

Team to utilize communications networks from agencies, organizations and businesses who

already have existing channels of outreach and lists of clients or customers who have opted-in to

receive communications. Holmes Associates has created relationships with: Butte County

Department of Employment and Social Services (flyer distribution to all partners, plus flyer

distribution at their weekly survivor dinners); NorCal United Way (Facebook posting of

messaging and flyer, and text-out to 30,000 survivors who have opted-in for communications);

HopeNow (social media posts on its platforms; multiple outreach lists provided); the Long Term

Recovery Group (attended Nov. 22 agency meeting for program announcement and flyer

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0t75s8 0085\5676427.8 FIRST REPORT

distribution); the Red Cross (flyer distribution to Red Cress partners and regional offrces); and

TCC members (flyer distribution at Gridley FEMA camp, social media postings, blast emails to

partner agencies); to name a few of the current partners. An initial outreach has also been made to

the Califomia Association of REALTORS, Northern California, and LeadingAge (senior

nonprofit). Partnership development will continue through December 31,2019,

Grassroots flyer outreach has started through the Butte County Dept. of Employment and

Social Services (weekly survivor dinners and County partners); churches (Sunday bulletins,

messages from the pulpit, weekly meals for survivors), Charitable Based Organizations (flyers for

distribution through counters, clients, customers; inclusion in newsletters), survivor groups (flyer

distribution and social media platforms), FEMA facilities, and local businesses, as well as

attending community events including college football and basketball games to distribute flyers.

Four thousand (4,000) flyers have been distributed by November 25,2019. Grassroots outreach

and flyer distribution will continue through December 3I,2019.

Social media is being used to "talk" to people through existing survivor and wildfire Group

pages. Cunently the following survivor and wildfire groups have allowed the Holmes Associates

team to join and post: Chico Needs (29k); Camp Fire Survivors (1.8k); California Wildfires

(3.6k); Rebuilding Hope: Camp Fire Recovery Resources (2.3k). We are awaiting entry into other

related Groups, and the team is creating @NorCalFireClaims Facebook and Instagram pages

which will be used to post information.

In coordination with Kinsella Media, media outreach is being conducted to local, regional

and national print, broadcast and online media. Holmes Associates is also coordinating efforts

with other PR and communications firms and efforts that represent PG&E, TCC and local business

concems. A media release was written and distributed on November 15,2019, through a blast

email list and through a wire service. Cunently the pickup report from our wire service shows 559

release views and hits. The Holmes Associates team has started and will continue follow-up calls

to educate media of the efforts being undertaken to help more traumatized and displaced people

file a PG&E claim before December 3I,2019.

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3. Technolow &, Data:

Since November 1,2019, BMC Group has expended approximately 300 hours engaged in

the following:

. Analysis of proof of claim data, insurance data, and other address and claims

information, to create a database of people who are most likely to be fire victims who have not

filed proofs of claim in these cases, in order to avoid repetition of past noticing programs;

. Design, host and administer the SmartRoom secure virtual dataroom for internal

team use and for hosting data subject to the Protective Order;

. Design and host the website www.OfficialFireClaims.com launched on November

15;

. Host and administer email box info@officialfireclaims.com;

. Design and host the Call Center (888.909.0100) launched on November 15;

. Participate in drafting and act as administrator of Frequently Asked Questions on

the "OfficialFire Claims" website;

. Record and post a Call Center script including FAQs, administer updates;

. Receive, analyze and report on various data;

. Ongoing maintenance and administration of the website and the Call Center;

. Participate in Team communications;

. Participate in communications with existing fire victim support groups; and

. Conduct research in support of Team initiatives.

Anticipated additional activity will include dataanalysis, mechanics of outreach, a.9., text, email

and direct mail; and social media account monitoring and maintenance targeted to identifying and

locating traumatized andior displaced Unfiled Fire Claimants. An abbreviated Spanish language

message will be recorded and added to the Call Center line. BMC Group's staffing strategy

focuses on the ability to scale, while assigning the right resources to complement the client and its

advisors.

V. PROJECTED BUDGET

To accomplish the Tasks and above-described strategy, the Claims Representative's

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overall anticipated budget for himself and his Team for the period between November I,2019,

and January 20,2020, is $11575,380.00, broken down as follows:

For informational purposes, as of Novemb er 20r20lg,the estimated6 fees and costs

incurred by the Claims Representative and his Team is as follows:

Claims Representative $111,000

Media $ 27,000 (media costs)

$ 77,280 (Kinsella Media fees)

Public Relations & Outreach $ 39,790

Technology &Data $ 37,500

Legal $ 25,000

TOTAL: $317,570

Pursuant to the Bar Date Extension Order, and except to the extent that advance funds are

approved by further Court order, invoices for the above services will be submitted by the Claims

Representative and his Team directly to the Debtors for payment and are due upon receipt without

3 The Claims Representative's hourly rate is $600 and $125 for his administrative staff. For

purposes of this budget, he estimates incurring 600 hours and 48 hours for his administrative staff

between November 1,2019, and January 20,2020.

a Kinsella Media's hourly rates range from $125 to $600. Both Ms. Kinsella and Dr. Wheatman

are court-recognized notice experts and their hourly rates are $600 and $500 respectively;

professional staff s hourly rates are between $125 and $350.

s Wendel Rosen LLP's fees are based on its standard hourly billing rates which range from $345

to $620 for attomeys and from $165 to $300 for paralegals, law clerks, and case clerks. Hourly

rates are subject to reasonable change, usually at the beginning of each year. Time is billed in

increments of one-tenth of an hour.

6 For purposes of this First Report, fees and costs through November 20,2019, have been

estimated and are subject to change.

Claims Representative $ 366,000.003

Media $ 300,000.00 (media costs)

$ 125,000.004 (Kinsella Media fees)

Public Relations & Outreach $ 300,380.00

Technology &DaIa $ 359,000.00

Legal $ 125,000.00s

TOTAL: $ 1.575.380.00

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017558.0085\5676427.8 FIRST REPORT 11

further Court order. Also pursuant to the Bar Date Extension Order, the Claims Representative is

not incurring any personal responsibility or liability for these substantial costs, all of which are to

be paid by the Debtors. Due to the truncated timeframe and substantial fees and costs that must be

paid up front, funds must be advpnced as set forth in section VI.

VI. REQUEST FOR ADVANCED FUNDS

The Bar Date Extension Order provides that the Claims Representative may apply to the

Court for approval of advance fees or costs if deemed necessary in order to successfully complete

the Tasks. The Claims Representative has determined that advance funds in the amount of

$395,000.00 are required (the'oAdvance").7

The Media portion of the Advance ($300"000.00 to Kinsella Media) will be used to

purchase and pay for advertising and services such as: booking and paying for all media; paying

producers to create television, radio, and online video spots; voice talent; Spanish translation

costs; and graphic designer fees to create digital banner ads. Receipt of the Advance is required as

soon as possible to ensure that media and other third-party services can be timely purchased and

paid for.

The Public Relations & gutreach portion of the Advance ($70"000 to Holmes Associates)

will be used for part of the first-month fees (already incurred) for: strategy; social and traditional

media relations; and community outreach efforts and third-party out-of-pocket costs for non-Team

member services (such as text-out services; printing of flyers and supplies for flyer distribution;

and other outreach expenses).

Subject to Bankruptcy Court approval, the Debtors have agreed to advance the requested

funds as provided in the Stipulation to Advance Funds to Claims Representative, which is being

fi led contemporaneously herewith.

VII. PRELIMINARYEXPECTATIONS

As of November 19, 2}lg,there were just over 72,000 fire-related claims filed. The TCC

7 The Advance is for: $300,000.00 media; $70,000 outreach, and $25,000 advance for out-ofpocket expense (postage, paper and envelopes to +20,000; also technology and translation fees).

Case: 19-30088 Doc# 4963 Filed: 12/03/19 Entered: 12/03/19 17:11:07 Page 11

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estimates that there could be 70,000 to 100,000 fire-related claims, (Docket No. 4293, p, 9, filed

Oct 18, 20l9)-suggesting that there are as many as 28,000+ unaccounted for fire-related claims.

Since his appointment, the Claims Representative and his Team have met with various parties that

have conducted, or are continuing to conduct, outreach activities related to fire victims. Anecdotal

evidence suggests that there may be as few as 8,000 unaccounted-for claims. However, it is

impossible to know with any accuracy the actual number of unaccounted-for fire-related claims.

The Claims Representative has obtained data from the insurance subrogation group and is seeking

to obtain rebilling data from PG&E to assist in the identification and location of the Unfiled Fire

Claimants with the assistance with the TCC. Therefore, the Claims Representative and his Jeam

have developed the strategy described above to effectively and efficiently reach as many potential

Unfiled Fire Victims as possible, targeting those who are traumatized or displaced to ensure that

they are aware of the new claims bar deadline and have the necessary support and assistance to get

their claims filed by the extended claim bar date.

VIII. CONCLUSION

Until and unless the Court orders otherwise, the Claims Representative will proceed to

effectuate the foregoing strategy within the anticipated budget.

DATED: December 3,2019 Respectfully submitted,

WENDEL ROSEN LLP

By /s/ Lisa Lenherr

Mark S. Bostick

Lisa Lenherr

Attorneys for Michael G. Kasolas, Claims

Representative

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EXHIBIT A

Case: 19-30088 Doc# 4963 Filed: 12/03/19 Entered: 12/03/19 17:11:07 Page 13

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,

KINSELLA

MET,IA

Relevant Case Experience

In r€ l{olocaust Victim,4ssefs Litigation, Nos. CV-96-4t149, CV-96-5161, and CV-97-46L

(E.D.N.Y.),

Ca$e: 1.2.5 billion settlement - Reparations 

,

Claimant Population: f ews, Roma, homosexuals, and physically and mentally disabled

people persecuted by the Nazis,

Notice Programr Kinsella Media had responsibility for providing notice to the Romani

I-lolocaust victims. Using in-country organizers and human rights organizations, the

firm designed and implemented a grassroots campaign to reach the isolated and

educationally disadvantaged Roma in 15 countries in Europe and the former Soviet

Union. In addition, Kinsella Media planned and managed paid media directed to fewish

people in the Unibed States as well as press outreach in 37 countries orchestrating five

press conferences in Berlin, Budapest, Moscclw, Paris, Tel Aviv, ancl New York over a 24-

hour period.

Cobell v, Salazar, No. 1:96-CV-'12U5 (D.D.C.).

Case: $3,4 billion settlement - Mismanagement of Funds

Claimant Population: Bellieved to be the largest civil rights settlement with the federal

government, thg class included over 500,000 Native Americans with Individual Indian

Money accounts managed by the U.S, Department of the Interior for decades.

Notice Program: The notice program included direct notice supported by TV and radio ads

in targeted areas around the country, ads in more than 75 Native American publications

and tribal newsletters, dr"rd Internet advertising on Native American websites. Kinsella

Media also oversaw a lrroad earned meclia campaign that distributed a press release to

Native American and national and local mainstream publications with telephone follow-

-up to encourage media coverage of the set[lement, '

Highlights: To complement paid and earned media efforts, Kinsella Media constructed a

layered community outreach program with over L,800 tribal governments, non-profit

organizatictns, and conrmercial enterprises participating in the notice prograrn by

hanging poslers, showing a video about the settlemenL translated into eight Native

American languages and Spanish, and/or distributing flyers about the settlement.

EXHIBIT A.

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Case: 19-30088 Doc# 4963 Filed: 12/03/19 Entered: 12/03/19 17:11:07 Page 14

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Ke ep s e agle v. Vils ack, N o. 1 : 9 9 - CV -3 LLg (I). D. C.),

Case: $760 million settlement - Discrimination

Claimant Population: Native American farmers, ranchers, and their heirs who were

denied the same opportunities to obtain farm loans as white farmers.

Notice Program: Kinsella Media placed advertisements in tribal, regional, and national

Native American tnedia; regional and national agricultural trade publicatiohs; and a

ma$s newspaper supplement targeted primarily at rural areas nationwide. lnternet

banner ads on local and national Native Arnerican-focused websites .supported the print

and broadcast aspects of the media program. Kinsella also implemented an earned

media program that generated additional free media coverage,

Highlights: English and Navajo radio eids were placed in key markets with significant

concentrations of Native American farmers and ranchers along with Native American

networks.

In re Black Farmers Discrimination Litigation, MDL No. 0g-mc-s11 (D.D,c.),

Case: $1.25 billion settlement - Discrimination

Claimant Population: African American farmers

discrimination by the USDA.

who experiencecl farm loan

Notice Program; A robust direct notice program, using an easily understanclable postcard

rhat directed people to a toll-fi'ee number or website fbr more informaLion, was

supported by paid and earned media efforts. The print media program was structu.red

around advertisenlents placed in African American ancl community newspapers,

farrning and ranching trade publications, a national newspaper supplement. Radjo was

a critical part of the rrotice program with spots airing on radio stations in two large

African-American networks as well as targeted local radio and agricultural radio in

areas with the highest numbers of class members.

Highlights: Hxtensive third-party outreach includecl mailings to over 6,180 AfricanAmerican farmer gfoup.s, predominantly African-American churches, civil rights groups,

general agriculture organizations, historically black colleges and universities and other

relevanl entities.

,

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Case: 19-30088 Doc# 4963 Filed: 12/03/19 Entered: 12/03/19 17:11:07 Page 15

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In re: Think Finance, LLC, No. 17-33964 (Bankr. N,D. Tex.)

Case: Chapter 11 Bankruptcy with $40 million consumer settlement

Claimant Population: Over 1 million consumer payday loan borrowers

Expert Services: Kinsella Media provided an expert review of the Bar Date Notice

Program, especially how well it reached consumers. Dr. Wheaiman testified at the 7023

Motion llearing as an experl wifness for several groups of con5umer borrow.er

plaintiffs. The Court qualified Dr. Wheatman as an expert on bankruptcy notice.

Subsequently, the debtors reached a settlement with the consumer borrowers and

Kinsella Media assisted with the developmenl of the settlement notice program,

Highlights: In the order granling lhe 7023 MoLions, U.S. Bankruptcy fudge Harlin DeWayne

llale, noted: "The results indicate that while the Notice Procedures may have been

constitutionally sufficient, they were not successful in facilitating creditor participation

in these Bankruptcy Cases. A fundamental goal of bankruptcy is to promote creditor

participation."

Good v, West Virginia American Water Co., No, L4-CV-Lil7a [S,D.W. Va.)

Case: $151 million settlement

Claimant Population: Businesses, homeowners, renters, ancl employees in nine counties

in West Virginia who were impacted by the EII< River contamination spill. Clairns could

be made fbr economic losses and medical costs.

Notice Program: Direct notice (in color postcards with tear-r:ff claim form) were sent to

identifiable class members. Mailing lists were created through property lists, utility

company customer database, and use of a third-party to identify renters. Broad notice

through the use of paid media, incltrding color ads in local newspapers, TV, radio, and

local Internet.

Highlights; Resulted in a 600/o claims rate.

Dolmagev. Province of Ontario, No. CV-09-376927 (Ont. S.C.|.J.

Case: $35 million settlement

Claimant Population: Former residents of three treatment facilities in Canada for the

mentally challengecl and ctisabletl (Huronia Residential Centre, Rideau Regional Centre,

and Southwestern Regional Centre), and heirs of deceased residents.

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,

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Notice Program: Direct notice (in large readable fbnt, written at a 5Ch grade level) to

identifiable former residents. Broad notice through the use of p.aid media, including

national consumer magazines, local newspapers, TV, radio, a national newspaper, and

national and local Internet, Media outreach using a multirnedia news release,

Hightightsr Extensive outreach to agencies that assist/house former residents, long term

care facilities, communi[y centers, recirement homes, adult protective services workers,

a disability law center, and a group representing people with intellectual disabilities.

In re W.R, Grace & Co, No, 0L-01139 (Bankr. D. Del.).

Claimant Population: Asbestos property damage claimants, general creditors, and

Zonolite Attic Insulaticln claimants exposed to W.R. Grace's asbest<ls-containing

products,

Notice Program: Three separate bar: date notice programs were tmplementecl in the U.S.

and Canada using various combinations of consumer magazines, trade publications,

newspaper supplements, newspapers, InterneL, and TV.

Highlights: A website and print and TV advertisements were produced in English, French

Canadian, ahd lnuktitut, an aboriginal language, fbr the Zonolite Artic Insulation notice

program in Canada.

In re Dow Corning, No.95-2051.2 (Bankr, H.D. Mich,).

Claimant Population: Individuals with silicone implants manufactured by Dow Corning

subject to a bar date to file personal injury claims.

Notice Program: The notice program used extensive direct notice; r:obuqt publication and

1l'V advertising; third-party notice to medical, health, and legal organizations; and a

national press conference that initiated a broad public relations outreach.

Highlights:'l'he paid media alone reached 95o/o of tJ.S. adults.

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Case: 19-30088 Doc# 4963 Filed: 12/03/19 Entered: 12/03/19 17:11:07 Page 17

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EXHIBIT B

Case: 19-30088 Doc# 4963 Filed: 12/03/19 Entered: 12/03/19 17:11:07 Page 18

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PG&E Bankruptcy: Media Activity Report

Updated: November 21, 2019 

mXJ6

I=IFI

II

Research articles on fires and fire related websites and social media groups, review-court documprevious notice program declarations.

Compile information on all fires and affected counties. Share with team.

Research organizations in affected area that could assist with on-ground outreach. Prodde res

lists to PR firm.

Analpis of media consumption habits and geograpfry of potential claimants.Compile media rates and timing for implementing media prognrn in December.

Submit media recommendationS, budgeg and potential schedule.

Review both desktop and mobile claims submission pages for Prime€erlc Recommend changenavigation to Fire Claimant Proof of Oaim.Drdft initial laneauge and review feedbackfor new Landing Page and FAQs forwebsite.English Flyers dnfted and approved.

Spanish Flyers drafted and approred.

Poster drafted and approved.English Publication Notice drafted and approrred.

Shared draft VRadio scipts and TV storyboard with team forfeedback l7{21.l.

Publication Notice is being laid out in various ad sizes for newspapers.

Trarulation has been completed. Awaiting final layout to circulate for approval.

Draftin8 ads that will be circulated by Norember 22.

Assist PR firm with ad/ertising research for areas where they will focus outreach.

GompleteCompleteCompleteCompleteCompleteCompleteCompleteComplete

6mpleteCompleteComplete

6mplete

ln Progressln Progressln Progressln Progress

ln Progress

Publication Notice - Spanish

Social/Digital Ads

PR Firm Assistance

Gmeral Research

Fire Profiles

Organizatidn

R esea rch

Media Research

Media Rates

Media

Proposal/Budget

Website Review

La nding 'Page/FAQs

Flyer - English - color & b/w

Flyer - Spanish - color &.b/w

Poster

Publication Notice - English

flRadio

Scrip{Storyboard

Publication Layouts

1

2345

67

8

9

10

11

LZ13t415

16

a7

Component Statu s Description

Case: 19-30088 Doc# 4963 Filed: 12/03/19 Entered: 12/03/19 17:11:07 Page 

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