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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)

STIPULATION RE: THE PRODUCTION 

OF CURRENT ADDRESS 

INFORMATION FOR INSUREDS

[No Hearing Requested]

Case: 19-30088 Doc# 4794 Filed: 11/18/19 Entered: 11/18/19 13:32:39 Page 1 of

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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” 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 Michael Kasolas as Claims 

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

filed proofs of claim in these bankruptcy cases;

WHEREAS the TCC has requested that the members of the Ad Hoc Subrogation Group 

provide current address information 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 contact addresses for insureds to the Claims Representative and TCC (the 

“Information”), while requiring that certain limitations be placed on the use of that Information; 

and 

WHEREAS those efforts are limited to providing address information for insureds 

reasonably obtainable from electronic databases available with insurers, to the extent such 

Case: 19-30088 Doc# 4794 Filed: 11/18/19 Entered: 11/18/19 13:32:39 Page 2 of

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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’ Information, filed concurrently 

with this Stipulation. Specifically, the Parties agree that the TCC may use the Information for 

the Requested Purposes. 

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. The production of the 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 Information 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 

Case: 19-30088 Doc# 4794 Filed: 11/18/19 Entered: 11/18/19 13:32:39 Page 3 of

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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, 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 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.

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

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

So stipulated:

Dated: November 18, 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

/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# 4794 Filed: 11/18/19 Entered: 11/18/19 13:32:39 Page 4 of

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Email: kdiemer@diemerwei.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

Dated: November 18, 2019 BAKER & HOSTETLER LLP

/s/ Kimberly S. Morris

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)

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

drichardson@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel to the Official Committee of Tort Claimants

Dated: November 18, 2019 MICHAEL G. KASOLAS

/s/ Michael G. Kasolas

Michael G. Kasolas

Claims Representative

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# 4794 Filed: 11/18/19 Entered: 11/18/19 13:32:39 Page 5 of

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