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017558.0085\5686159.1

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)

STIPULATION RE: THE PRODUCTION 

OF CURRENT CONTACT

INFORMATION FOR INSUREDS

[No Hearing Requested]

Case: 19-30088 Doc# 5037 Filed: 12/09/19 Entered: 12/09/19 14:30:31 Page 1 of

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017558.0085\5686159.1 1

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

The Official Committee of Tort Claimants (the “TCC”), Michael Kasolas as the 

claims representative appointed to assist 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” and, together with the TCC, the “Parties”), hereby reach 

the following stipulation as to the production by the Ad Hoc Subrogation Group of certain 

information related to their insureds.

STIPULATION

WHEREAS on November 12, 2019, the United States Bankruptcy Court for the 

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

Appointing Claims Representative [Dkt. 4672], by which the Bankruptcy Court extended the 

claims bar date for Fire Claimants to December 31, 2019, and appointed the Claims 

Representative, tasked among other things with locating potential Fire Claimants who have not 

filed proofs of claim in these bankruptcy cases;

WHEREAS on November 18, 2019, the TCC and the Ad Hoc Subrogation Group 

entered into a Stipulation Re: the Production of Current Address Information For Insureds 

[Dkt. 4794]. This stipulation was so-ordered by the Court on November 19, 2019 [Dkt. 4815].

WHEREAS the TCC and the Claims Representative have requested that, in addition to 

providing address information, the members of the Ad Hoc Subrogation Group also provide 

phone numbers and email addresses for their insureds to the Claims Representative and TCC in 

order to assist the Claims Representative in his efforts to locate potential claimants who have 

not yet filed proofs of claim in these bankruptcy cases (the “Requested Purposes”); 

WHEREAS it would impose a significant burden on the TCC in terms of both time and 

expense to attempt to obtain this information from other sources; 

WHEREAS members of the Ad Hoc Subrogation Group have agreed to make 

reasonable efforts to provide phone numbers and email addresses for insureds (the “Additional 

Case: 19-30088 Doc# 5037 Filed: 12/09/19 Entered: 12/09/19 14:30:31 Page 2 of

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017558.0085\5686159.1 2

Information”) to the Claims Representative and TCC, while requiring that certain limitations 

be placed on the use of that Additional Information; and 

WHEREAS those efforts are limited to providing phone number and email address 

information for insureds reasonably obtainable from electronic databases available with 

insurers, to the extent such information exists; 

THEREFORE the TCC, the Claims Representative, and the Ad Hoc Subrogation 

Group agree as follows:

1. The Ad Hoc Subrogation Group, the Claims Representative and the TCC agree 

to the Order regarding the Production and Use of the Insureds’ Additional Information, filed 

concurrently with this Stipulation. Specifically, the Parties agree that the TCC and the Claims 

Representative may use the Additional Information for the Requested Purposes. 

2. The Additional 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 Additional 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 Additional

Information or any scripts of phone calls, and that the Ad Hoc Subrogation Group will have an 

opportunity to review and comment on those drafts. 

4. The TCC and the Claims Representative agree that no more than two emails 

will be sent to each insured using the Additional Information and no more than two phone calls

or text messages will be made to each insured using the Additional Information regardless of 

whether a response is received from the insured. The TCC and the Claims Representative shall 

make a good faith effort to reduce potential harassment, limit automated calls, and make calls 

by live phone operators where it is feasible to do so, including by unmasking the phone 

Case: 19-30088 Doc# 5037 Filed: 12/09/19 Entered: 12/09/19 14:30:31 Page 3 of

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017558.0085\5686159.1 3

number used to make the phone calls or text messages.

5. The TCC and the Claims Representative shall make a good faith effort to limit 

any communications sent to insureds using the Additional Information to only those insureds 

who have not yet filed a proof of claim. 

6. The Additional Information will not be shared with counsel for the individual 

plaintiffs, the interests of which are represented by the TCC.

7. The Additional 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, 

telemarketing, solicitations, or promoting claims against insurers. 

8. The production of the Additional Information by the Ad Hoc Subrogation 

Group is conditioned on the Bankruptcy Court entering a finding in its Order approving this 

Stipulation determining that there is a compelling need for the production of the Additional 

Information that outweighs any privacy interest the insureds may have in that Additional 

Information. 

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

efforts to provide such Additional Information and shall not be held responsible in any way if 

any of the Additional 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. 

10. In agreeing to provide the Additional Information, the members of the Ad Hoc 

Subrogation Group act reasonably, in good faith and are advancing and protecting the interests 

of their insureds.

11. Nothing in this Stipulation or the Order approving this 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.

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

Case: 19-30088 Doc# 5037 Filed: 12/09/19 Entered: 12/09/19 14:30:31 Page 4 of

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017558.0085\5686159.1 4

from or related to the implementation, interpretation or enforcement of this Stipulation.

So stipulated:

Dated: December 9, 2019 WILLKIE FARR & GALLAGHER LLP

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

Email: kdiemer@diemerwei.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

Dated: December 9, 2019 BAKER & HOSTETLER LLP

/s/ David J. Richardson 

Kimberly S. Morris (SBN 249933)

Cecily A. Dumas (SBN 111449)

Robert A. Julian (SBN 88469)

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: 628.208.6434

Facsimile: 310.820.8859

Email: kmorris@bakerlaw.com

Email: cdumas@bakerlaw.com

Email: rjulian@bakerlaw.com

Eric E. Sagerman (SBN 155496)

/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)

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 

Case: 19-30088 Doc# 5037 Filed: 12/09/19 Entered: 12/09/19 14:30:31 Page 5 of

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017558.0085\5686159.1 5

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

Dated: December 9, 2019 WENDEL ROSEN LLP

/s/ Lisa Lenherr

Mark S. Bostick

Lisa Lenherr

Counsel to Michael G. Kasolas,

Claims Representative

Case: 19-30088 Doc# 5037 Filed: 12/09/19 Entered: 12/09/19 14:30:31 Page 6 of

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