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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

WILLKIE FARR & GALLAGHER LLP

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Benjamin P. McCallen (pro hac vice)

787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

 jminias@willkie.com

 bmccallen@willkie.com 

Counsel for Ad Hoc Group of Subrogation

Claim Holders

UNITED STATES BANKRUPTCYCOURT

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)

Case No. 19-30088

Chapter 11

(Lead Case)

(Jointly Administered)

ORDER RE: THE PRODUCTION OF 

CURRENT ADDRESS INFORMATION 

FOR INSUREDS

Signed and Filed: November 19, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

November 19, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 4815 Filed: 11/19/19 Entered: 11/19/19 14:53:59 Page 1 of

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The Court, having considered the Stipulation Re: the Production of Current Address 

Information for Insureds (the “Stipulation”),1entered into by the Official Committee of Tort 

Claimants (the “TCC”), any fiduciary, if any, appointed to represent wildfire victims who have 

not yet filed proofs of claim (the “Claims Representative”) and the Ad Hoc Group of 

Subrogation Claim Holders (the “Ad Hoc Subrogation Group”), filed on November 18, 2019 

in connection with the above-captioned chapter 11 cases pending before the United States Court 

for the Northern District of California (the “Chapter 11 Cases”), pursuant to such stipulation 

and agreement of the Parties, and good cause appearing,

IT IS HEREBY ORDERED THAT:

1. The Stipulation is granted.

2. The Information will be shared only with counsel for the TCC, the TCC’s 

professionals retained in these bankruptcy cases, or the Claims Representative, and the Claims 

Representative’s support staff, vendors or professionals for the Requested Purposes. Any 

documents or spreadsheets produced that contain the Information for Requested Purposes shall 

be designated “PROFESSIONAL EYES ONLY” for TCC Counsel, professionals, and the 

Claims Representative. 

3. The TCC and the Claims Representative agree that the Ad Hoc Subrogation 

Group will receive drafts of any notifications they plan to send to insureds using the Information, 

and that the Ad Hoc Subrogation Group will have an opportunity to review and comment on 

those drafts. 

4. The Information will not be shared with counsel for the individual plaintiffs, the 

interests of which are represented by the TCC.

5. The Information will be used solely for the Requested Purposes and will not be 

used for any other purpose, including but not limited to attorney advertisement, solicitations, or 

promoting claims against insurers. 

6. Given, among other things, (i) the short time period remaining until the Bar Date, 

(ii) the burden that would be imposed on the TCC or the Claims Representative to attempt to 

 

1 Capitalized terms used and not defined herein shall have the meanings ascribed to them in the Stipulation.

Case: 19-30088 Doc# 4815 Filed: 11/19/19 Entered: 11/19/19 14:53:59 Page 2 of

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obtain the Information from other sources, (iii) the limited number of sources available other 

than the members of the Ad Hoc Subrogation Group to obtain this information, and (iv) the 

potential harm to fire victims who do not file proofs of claim by the Bar Date, the Court 

accordingly finds that a compelling need exists to order the production of this Information from 

the members of the Ad Hoc Subrogation Group that outweighs any privacy interest the insureds 

may have in that Information. 

7. The members of the Ad Hoc Subrogation Group will undertake reasonable efforts 

to provide such Information and shall not be held responsible in any way if any of the 

Information is incorrect or incomplete. The Ad Hoc Subrogation Group reserves all rights to 

object to any additional requests for insured information on any and all grounds.

8. In agreeing to provide the Information pursuant to the Stipulation and pursuant 

to this Order, the members of the Ad Hoc Subrogation Group act reasonably, in good faith and 

are advancing and protecting the interests of their insureds.

9. Nothing in the Stipulation or this Order approving the Stipulation shall diminish 

or alter the obligations of the members of the Ad Hoc Subrogation Group set forth in the Order 

(I) Establishing Deadline for Filing Proofs of Claim, (II) Establishing the Form and Manner of 

Notice Thereof, and (III) Approving Procedures for Providing Notice of Bar Date and Other 

Information to All Creditors and Potential Creditors (Dkt. No. 2806) entered on July 1, 2019, 

which obligations remain in full force and effect.

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

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

APPROVED AS TO FORM AND CONTENT:

Dated: November 18, 2019

WILLKIE FARR & GALLAGHER LLP

/s/ Benjamin P. McCallen

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Benjamin P. McCallen (pro hac vice)

Joseph G. Davis

Antonio Yanez, Jr. (pro hac vice)

Case: 19-30088 Doc# 4815 Filed: 11/19/19 Entered: 11/19/19 14:53:59 Page 3 of

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787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

 jminias@willkie.com

 bmccallen@willkie.com

 jdavis@willkie.com

 ayanez@willkie.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

BAKER & HOSTETLER LLP

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: (628) 208-6434

Facsimile: (310) 820-8859

 Email: kmorris@bakerlaw.com

Counsel to the Official Committee of Tort Claimants

 MICHAEL G. KASOLAS

/s/ Michael G. Kasolas

Michael G. Kasolas

Claims Representative

** END OF ORDER **

/s/ Kimberly S. Morris

Kimberly S. Morris

Case: 19-30088 Doc# 4815 Filed: 11/19/19 Entered: 11/19/19 14:53:59 Page 4 of

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