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UNITED STATES DEPARTMENT OF JUSTICE 

CIVIL DIVISION 

JOSEPH H. HUNT 

Assistant Attorney General 

RUTH A. HARVEY 

Director 

KIRK MANHARDT 

Deputy Director 

MATTHEW J. TROY (GABN 717258) 

Senior Trial Counsel 

DANIELLE A. PHAM (CABN 269915) 

Trial Attorney 

P.O. Box 875 

Ben Franklin Station 

Washington, DC 20044-0875 

Telephone: (202) 514-7451 

E-mail: danielle.pham@usdoj.gov 

DAVID L. ANDERSON (CABN 149604) 

United States Attorney 

ROBIN M. WALL (CABN 235690) 

Assistant United States Attorney 

Attorneys for the United States of America 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

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) 

STIPULATION AND AGREEMENT FOR 

ORDER ADDING THE UNITED STATES OF 

AMERICA AS PARTIES TO 

CONFIDENTIALITY AND PROTECTIVE 

ORDER [DOCKET NO. 3405] AS MODIFIED 

HEREIN 

 

[No hearing requested] 

Case: 19-30088 Doc# 4673 Filed: 11/12/19 Entered: 11/12/19 08:26:50 Page 1 of

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This stipulation and agreement for order (“Stipulation and Agreement for Order”) is entered 

into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and debtors in possession 

(collectively, the “Debtors”), on the one hand, and the United States of America, on behalf of the United 

States Department of Agriculture, United States Forest Service; the United States Department of the 

Interior, Bureau of Land Management, Bureau of Indian Affairs, Fish and Wildlife Service, and the 

National Park Service; the Small Business Administration, and the Department of Homeland Security, 

Federal Emergency Management Agency (together, the “U.S. Agencies”), on the other hand. The Debtors 

and the U.S. Agencies are referred to in this Stipulation and Agreement for Order collectively as the 

“Parties,” and each as a “Party.” The Parties hereby stipulate and agree as follows: 

RECITALS 

A. The U.S. Agencies desire to be parties to the Confidentiality and Protective Order entered 

by the United States Bankruptcy Court for the Northern District of California on August 7, 2019 in In re 

PG&E Corp., et al., Case No. 3:19-bk-30088 at Docket No. 3405 (the “Order”), with certain 

modifications, to which the Debtors have agreed. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, THAT 

THE ORDER BE MODIFIED AS FOLLOWS: 

 

1. Treatment of Protected Material by the United States. Nothing in the Order supersedes the U.S. 

Agencies’ law enforcement, national security, or regulatory obligations regarding the disclosure 

of information required by applicable federal law. 

2. Freedom of Information Act Requests. The provisions of paragraph 8 of the Order shall apply to 

requests made to the U.S. Agencies pursuant to the Freedom of Information Act, 5 U.S.C. § 552, 

et seq. 

3. Congressional Requests. The Order shall not prevent or limit the U.S. Agencies’ ability to provide 

Protected Material to the United States Congress pursuant to a Congressional request. The United 

States will use reasonable efforts to notify the Designating Party of such request if, and only if, the 

requesting Congressional party does not object to such notification. 

Case: 19-30088 Doc# 4673 Filed: 11/12/19 Entered: 11/12/19 08:26:50 Page 2 of

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Dated: November 12, 2019 

 

KELLER & BENVENUTTI LLP 

 

THE UNITED STATES OF AMERICA 

/s/ Jane Kim /s/ Danielle A. Pham 

Jane Kim 

Attorneys for Debtors 

and Debtors in Possession

 JOSEPH H. HUNT 

Assistant Attorney General 

DAVID L. ANDERSON (CABN 

149604) 

United States Attorney 

ROBIN M. WALL (CABN 235690) 

Assistant United States Attorney 

RUTH A. HARVEY 

Director 

KIRK MANHARDT 

Deputy Director 

MATTHEW J. TROY 

Senior Trial Counsel 

DANIELLE A. PHAM 

Trial Attorney 

Attorneys for the United States 

Case: 19-30088 Doc# 4673 Filed: 11/12/19 Entered: 11/12/19 08:26:50 Page 3 of

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