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UNITED STATES DEPARTMENT OF JUSTICE 

CIVIL DIVISION 

JOSEPH H. HUNT 

Assistant Attorney General 

RUTH A. HARVEY 

Director 

KIRK MANHARDT 

Deputy Director 

MATTHEW J. TROY (GABN 717258) 

Senior Trial Counsel 

DANIELLE A. PHAM (CABN 269915) 

Trial Attorney 

P.O. Box 875 

Ben Franklin Station 

Washington, DC 20044-0875 

Telephone: (202) 514-7451 

E-mail: danielle.pham@usdoj.gov 

DAVID L. ANDERSON (CABN 149604) 

United States Attorney 

ROBIN M. WALL (CABN 235690) 

Assistant United States Attorney 

Attorneys for the United States of America 

UNITED STATES BANKRUPTCY COURT 

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).

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Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case)

 (Jointly Administered) 

ORDER ADDING THE UNITED STATES OF 

AMERICA AS PARTIES TO 

CONFIDENTIALITY AND PROTECTIVE 

ORDER [DOCKET NO. 3405] AS MODIFIED 

HEREIN 

 

[No hearing requested] 

Signed and Filed: November 12, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

November 13, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 4698 Filed: 11/12/19 Entered: 11/13/19 09:40:39 Page 1 of

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The Court having considered the Stipulation and Agreement for Order Adding the United States 

of America as Parties to Confidentiality and Protective Order as Modified (“Stipulation and Agreement 

for Order”) entered into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), on the one hand, and the United States of America, 

on behalf of the United States Department of Agriculture, United States Forest Service; the United States 

Department of the Interior, Bureau of Land Management, Bureau of Indian Affairs, Fish and Wildlife 

Service, and the National Park Service; the Small Business Administration, and the Department of 

Homeland Security, Federal Emergency Management Agency (together, the “U.S. Agencies”), on the 

other hand, filed on November __, 2019; and good cause appearing, 

IT IS HEREBY ORDERED: 

1. The U.S. Agencies shall be parties to the Confidentiality and Protective Order entered by 

the United States Bankruptcy Court for the Northern District of California on August 7, 2019 in In re 

PG&E Corp., et al., Case No. 3:19-bk-30088 at Docket No. 3405 (the “Order”), as modified herein. 

2. The Order is modified as follows. 

A. Treatment of Protected Material by the United States. Nothing in the Order supersedes the U.S. 

Agencies’ law enforcement, national security, or regulatory obligations regarding the disclosure 

of information required by applicable federal law. 

B. Freedom of Information Act Requests. The provisions of paragraph 8 of the Order shall apply to 

requests made to the U.S. Agencies pursuant to the Freedom of Information Act, 5 U.S.C. § 552, 

et seq. 

C. Congressional Requests. The Order shall not prevent or limit the U.S. Agencies’ ability to provide 

Protected Material to the United States Congress pursuant to a Congressional request. The United 

States will use reasonable efforts to notify the Designating Party of such request if, and only if, the 

requesting Congressional party does not object to such notification. 

Case: 19-30088 Doc# 4698 Filed: 11/12/19 Entered: 11/13/19 09:40:39 Page 2 of

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APPROVED AS TO FORM AND 

CONTENT: 

Dated: November 12, 2019 

KELLER & BENVENUTTI LLP 

/s/ Jane Kim 

Jane Kim 

Attorneys for Debtors 

and Debtors in Possession

***END OF ORDER*** 

Case: 19-30088 Doc# 4698 Filed: 11/12/19 Entered: 11/13/19 09:40:39 Page 3 of

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