EXHIBIT C

Case: 19-30088 Doc# 4775-3 Filed: 11/15/19 Entered: 11/15/19 15:59:34 Page 1

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CLHLiD^NOORliD 

Christopher Tayback (SBN 145532) 

Kenneth R. Chiate (SBN 39554) 

Kristen Bird (SBN 192863) 

Jeffrey N. Boozell (SBN 199507) 

QUINN EIVIANUEL URQUHART & SULLIVAN, LLP 

865 South Figueroa Street, 10th Floor 

Los Angeles, CA 90017 

Telephone: (213) 443-3000 

chri stayback@,quinnemanuel. com 

kenchiate@quirmemanuel.com 

kristenbird@quiruiemanuel. com 

jeffboozell(a)quiimemanuel.com 

Counsel for Defendants Pacific Gas and 

Electric Company and PG&E Corporation 

Manuel Corrales, Jr. (SBN 117647) 

ATTORNEY AT LAW 

17140 Bemardo Center Drive, Ste. 358 

San Diego, CA 92128 

Telephone: (858) 521-0634 

maimycorraIes(S!yahoo.com 

NOV 2 9 2018 

By B. Loriga, Deputy Clerk 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

FOR THE COUNTY OF SACRAMENTO 

Coordination Proceeding 

Special Title (CRC 3.550) 

BUTTE FIRE CASES 

This Document Relates to: 

BARBARA ZELMER, ROBERT 

ZELMER, 

Plaintiffs, 

vs. 

PACIFIC GAS & ELECTRIC COMPANY, 

et al.. 

Defendants. 

Assigned to the Honorable Allen H. Sumner 

Department No. 42 

CASE NO. JCCP 4853 

STIPULATED JUDGMENT 

Case: 19-30088 Doc# 4775-3 Filed: 11/15/19 Entered: 11/15/19 15:59:34 Page 2

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The Parties hereby stipulate and consent to final judgment resolving the entire case as , 

follows: 

WHEREAS, Plaintiffs Barbara Jean Zelmer and Robert Thomas Zelmer ("the 

Zelmers") filed complaints against Defendant Pacific Gas & Electric Company 

("PG&E") asserting claims for inverse condemnation, negligence, trespass, public 

nuisance, private nuisance, negligence per se, premises liability, violation ofCalifomia 

Public Utilities Code § 2106, and violation ofCalifomia Health and Safety Code 

§ 13007, and alleging damage to their home in Calaveras County, California and other 

property damage as a result of the 2015 Butte Fire; 

WHEREAS, the Zelmers have requested dismissal with prejudice of their causes 

of action against PG&E for negligence, trespass, public nuisance, private nuisance, 

negligence per se, premises liability, violation of California Public Utilities Code § 2106, 

and violation of Califomia Health and Safety Code § 13007, leaving inverse 

condeirmation as their sole cause of action; 

WHEREAS, PG&E denies any liability for the damages claimed by the Zelmers; 

WHEREAS, PG&E believes this Court's June 22, 2017 and May 1, 2018 orders 

holding PG&E liable for inverse condemnation damages to be prejudicially erroneous 

and subject to reversal on appeal, but that the expense of trial, both to the court system 

and the litigants, is unwarranted given the standard for liability under inverse 

condemnation that was adopted by this Court, including the Court's rejection of legal 

arguments made in PG&E's May 5, 2017 motion and January 4, 2018 Renewed Motion; 

WHEREAS, the Parties wish to enter into a stipulated judgment that is final but 

reserves the right of PG&E to appeal from the June 22, 2017 and May 1, 2018 orders 

holding PG&E liable in inverse condemnation for damages arising out the Butte Fire; 

THEREFORE, the Parties agree that the Court should enter a final judgment 

03765-00001/10433300.1 2 

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resolving all of Plaintiffs' claims and the entire case consisting of the terms set forth 

below for the purpose of facilitating PG&E's appeal of the Court's June 22, 2017 and 

May 1,2018 orders: 

1. Plaintiffs shall take nothing on their claims against Defendant PG&E for 

negligence, trespass, public nuisance, private nuisance, negligence per se, premises 

liability, violation of Califomia Public Utilities Code § 2106, and violation of Califomia 

Health and Safety Code § 130, which have been dismissed; 

2. On Plaintiffs' First Cause of Action for Inverse Condemnation in their 

Complaint and Fourth Cause of Action for Inverse Condemnation in their Adoption 

Complaint, judgment shall be entered in favor of Plaintiffs and against Defendant PG&E 

in the amount of $850,000, inclusive of fees and costs; 

3. This stipulated final judgment resolving all of the claims in this case is 

without prejudice to the rights of PG&E to appeal this final judgment, including the 

Court's June 22, 2017 order denying PG&E's Motion for a Legal Determination of 

Inverse Condemnation Liability and its May 1, 2018 order denying PG&E's Renewed 

Motion for a Legal Determination of Inverse Condemnation Liability; 

4. Plaintiffs hereby waive, pursuant to Code ofCivil Procedm-e § 995.230, 

any requirement that Defendant post an undertaking, bond or security deposit to stay, and 

they agree not to enforce the Judgment pending appeal from this Judgment. 

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IT IS SO STIPULATED 

DATED: October! , 2018 QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

KennetiVflt.' /Chiatfe 

Jeffrey N. Boozell 

BCristen Bird 

Attomey for Defendants 

Pacific Gas and Electric Company 

and PG&E Corporation 

DATED: 2018 GILLEON LAW FIRM, APC 

Manuel Corrates—-

Attomey for the Zelmers 

IT IS SO ORDERED. 

Dated this .dayof ,2018. 

By. 

HON./^rEN H. SUMNER 

Judge of the Superior Court 

03765-00001/10433300.1 

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