BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

 

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Case: 19-30088 Doc# 3624-1 Filed: 08/20/19 Entered: 08/20/19 17:29:10 Page 1

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

Robert A. Julian (SBN 88469)

Cecily A. Dumas (SBN 111449)

BAKER & HOSTETLER LLP

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: 628.208.6434

Facsimile: 310.820.8859

Email: rjulian@bakerlaw.com

Email: cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Boulevard

Suite 1400

Los Angeles, CA 90025

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel for Official Committee of Tort Claimants

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC 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)

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

ORDER GRANTING MOTION TO 

COMPEL PG&E PRODUCTION OF 

BUSINESS PLANS

Case: 19-30088 Doc# 3624-1 Filed: 08/20/19 Entered: 08/20/19 17:29:10 Page 2

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ATTORNEYS AT LAW

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Upon the Motion dated August 16, 2019 (the “Motion”)1 of the Official Committee of 

Tort Claimants (the “TCC”) to Compel Production of PG&E Business Plans (as defined in the 

Motion) pursuant to Rule 7037 of the Federal Rules of Bankruptcy Procedure, Rule 37 of the 

Federal Rule of Civil Procedure, and Rule 7037 of the Bankruptcy Local Rules for the United 

States District Court for the Northern District of California (the “Bankruptcy Local Rules”) for 

entry of an order compelling PG&E Corporation and Pacific Gas & Electric Corporation 

(collectively, the “PG&E”) to produce PG&E’s (a) business plans; and (b) reports, studies, 

briefings, valuations, analyses and similar documents prepared by advisors, appraisers, 

investment bankers, consultants, lawyers, accountants, auditors, investigators, and professionals 

for the Company, or any of their respective boards or committees, during the applicable period, 

regarding the value of the Company or the safety of the Company’s transmission and distribution 

lines (collectively, “Business Plans”) requested under the TCC’s March 8, 2019 “Management 

Requests” No. 1 and No. 2, and this Court having jurisdiction to consider the Motion and the 

relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334, the Order Referring Bankruptcy 

Cases and Proceedings to Bankruptcy Judges, General Order 24 (N.D. Cal.), and Bankruptcy 

Local Rule 5011-1(a); and venue being proper before this Court pursuant to 28 U.S.C. §§ 1408 

and 1409; and the Court having found and determined that notice of the Motion as provided to the 

parties listed therein was reasonable and sufficient, and it appearing that no other or further notice 

needs to be provided; and this Court having reviewed the Motion; and this Court having held a 

hearing on the Motion; and the Court having determined that the legal and factual bases set forth 

in the Motion establish just cause for the relief sought therein; and it appearing that the relief 

requested in the Motion is in the best interest of the Debtors’ estates, creditors, shareholders, and 

all parties in interest; and upon all of the proceedings had before this Court and after due 

deliberation and sufficient cause appearing therefor,

IT IS HEREBY ORDERED THAT:

1. The Motion is granted as provided herein.

 1

 Capitalized terms used but not otherwise defined herein shall have the meanings given to them in the Motion.

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ATTORNEYS AT LAW

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2. On or before ____________________, PG&E shall produce the Business Plans, 

including all documents responsive to Management Requests No. 1 and No. 2, to the TCC. 

3. Failure by the Debtors to do so shall result in the imposition of sanctions against 

PG&E, including PG&E being precluded from using any Business Plans not produced to the TCC 

by the date set forth above in any subsequent filing or hearing in or related to this Bankruptcy 

Case. 

** END OF ORDER **

Case: 19-30088 Doc# 3624-1 Filed: 08/20/19 Entered: 08/20/19 17:29:10 Page 4

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