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WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Debtors in Possession

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019

Tel: 212 474 1000 

Fax: 212 474 3700 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

- and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered) 

NOTICE OF RULE 30(B)(6) DEPOSITION 

OF TRIDENT DMG LLC 

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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Please take notice that, pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure, made 

applicable to this proceeding pursuant to Rules 7030 and 9014 of the Federal Rules of Bankruptcy 

Procedure, PG&E Corporation and Pacific Gas and Electric Company, as debtors and debtors in 

possession (collectively, the “Debtors”), by and through their attorneys, will take the deposition upon 

oral examination of the representative(s) of Trident DMG LLC (“Trident”), in connection with the 

Motion of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. §§ 105(a) and 50 and Fed. 

R. Bankr. P. 3003(c) for Entry of an Order Extending the Bar Date, dated October 18, 2019 (Dkt. No.

4292), and specifically regarding the subject matters identified in Exhibit A. 

 The deposition will take place at the offices of Weil, Gotshal & Manges LLP, 2001 M St NW 

#600, Washington DC 20036, on October 31, 2019 at 9:30 a.m., or at such other time and place as 

may be agreed to among counsel for the parties, and shall continue from day to day thereafter until 

completed. The deposition will be recorded by stenographic means and videotape and will be taken 

before a Notary Public or other officer authorized by law to administer oaths. The deposition will be 

taken for the purposes of discovery on the above motion, for use at hearings on the above motion in 

the above captioned case, and for any other purpose permitted under the Federal Rules of Bankruptcy 

Procedure, the Federal Rules of Civil Procedure, and the rules of this Court. 

Pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure, Trident shall designate one 

or more officers, directors, representatives, agents, or other persons most knowledgeable regarding all 

information known or reasonably available to Trident relating to the subject matters identified in 

Exhibit A. Such designation shall include the identity, description, or title of such individual(s), and 

if Trident designates more than one individual, it shall set out the subject matters on which each 

individual will testify. 

Dated: October 23, 2019 CRAVATH, SWAINE & MOORE LLP 

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

By: /s/ Peter J. Benvenutti _ 

Peter J. Benvenutti 

Attorneys for Debtors 

and Debtors in Possession

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EXHIBIT A 

DEFINITIONS 

1. Capitalized terms used but not otherwise defined herein shall have the respective

meanings ascribed to such terms in the Motion. 

2. “AHC” means the Ad Hoc Committee of Senior Unsecured Noteholders of Pacific Gas

and Electric Company and each of its members (individually or collectively) as identified in the Rule 

2019 statement on July 18, 2019 (Dkt. No. 3083), and any officers, directors, employees, 

representatives, agents, attorneys, accountants, advisors, consultants, independent contractors, or other 

Persons or entities acting or purporting to act on behalf of, or otherwise representing or engaged by, 

the AHC or its members (individually or collectively). 

3. “Application” means the Application of the Official Committee of Tort Claimants

Pursuant to 11 U.S.C. § 1103 and Fed. R. Bankr. P. 2014 and 5002 to Retain and Employ Trident 

DMG LLC as Communications Consultant Effective as of July 18, 2019 (Dkt. No. 3224). 

4. “Bankruptcy Court” means the United States Bankruptcy Court for the Northern

District of California (San Francisco). 

5. “Bar Date” has the meaning given in the Bar Date Order.

6. “Bar Date Order” means the Order Pursuant to 11 U.S.C. §§ 502(b)(9) and 105(a),

Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 (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, dated July 1, 2019 (Dkt. No. 2806). 

7. “Chapter 11 Cases” means the cases initiated by the Debtors on January 29, 2019,

under chapter 11 of the Bankruptcy Code (Bankruptcy Case Nos. 19-30088 (lead case) and 19-30089), 

as well as all other associated actions, cases, and proceedings in the Bankruptcy Court, including, 

without limitation, Bankruptcy Case Nos. 19-03003, 19-03005, 19-03006, 19-03006, 19-03008, 19-

03015, 19-03037, and 19-03039. 

8. “Communications” means all inquiries, discussions, conversations, negotiations,

agreements, understandings, meetings, telephone conversations, letters, notes, telegrams, 

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correspondence, memoranda, emails, facsimile transmissions, or other form of verbal, written, 

mechanical, or electronic disclosure, in Your actual or constructive control or custody or in the control 

or custody of any current or former affiliates, representatives or advisors. 

9. “Documents” means any writings, recordings, electronic files and mails, or

photographs, whether original or duplicate, as defined in Federal Rule of Evidence 1001 and Federal 

Rule of Civil Procedure 34(a), inclusively, including (but not limited to) all documents and 

information in Your possession, custody, or control, and includes: all and any written, recorded, or 

graphic material, however produced or reproduced, minutes, summaries, memoranda, transcripts, 

tapes, or other voice recordings, and all other documents and tangible things, including booklets, 

brochures, pamphlets, circulars, notices, periodicals, papers, records, contracts, agreements, 

photographs, minutes, memoranda, messages, appraisals, analyses, reports, files, interoffice 

memoranda, or interoffice communications of any description, calculations, invoices, accounting 

entries, diary entries, calendars, inventory sheets, ledgers, correspondence, emails, phone recordings, 

instant messages, text messages, telegrams, advertisements, press releases, notes, letters, diaries, 

working papers, schedules, projections, graphs, charts, films, tapes, print-outs, and all other data, 

whether recorded by electronic or other means, and all drafts thereof. If a Document was prepared in 

several copies, or if additional copies were thereafter made, and if any such copies are not identical in 

all respects or are no longer identical by reason of subsequent notation or modification of any kind 

whatsoever, including notes on the front or back, in the margins, or on any of the pages thereof, then 

each such non-identical copy is a separate Document and must be produced. When examples of 

categories or types of Documents are given in a particular Request by use of phrases such as 

“including,” this shall always be interpreted as being for illustrative purposes only (i.e., to be 

understood as “including without limitation”) and in no way limits or narrows the scope of any 

Request. “Documents” always includes Communications, whether so-stated in a particular Request 

or not. 

10. “Engagement Letter” means the Engagement Letter entered into by and between

Trident and the TCC, dated July 26, 2019, as attached to the Declaration of Adam W. Goldberg in 

support of Application of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. § 1103 and 

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Fed. R. Bankr. P. 2014 and 5002 to Retain and Employ Trident DMG LLC as Communications 

Consultant Effective as of July 18, 2019 (Dkt. No. 3225). 

11. “Fire Claim Bar Date Notice” has the meaning given in the Bar Date Order.

12. “Fire Claimant” has the meaning given in the Bar Date Order.

13. “Fire Claimant Proof of Claim Form” has the meaning given in the Bar Date Order.

14. “Government Agency” means any Persons or entities acting or purporting to act on

behalf of, or otherwise representing or engaged by, any executive, judicial, or legislative body, or other 

government agency or instrumentality, including but not limited to, the California Public Utility 

Commission, the Federal Energy Regulatory Commission, the Nuclear Regulatory Commission, the 

Securities and Exchange Commission, the Internal Revenue Service, the Office of the Governor Gavin 

Newsom, the Office of the California Attorney General, or the Office of the United States Attorney 

for the Northern District of California. 

15. “Hearing” means the hearing on the Motion, which is currently set for November 13,

2019, at 9:30 a.m. (Pacific Time), in Courtroom 17, 450 Golden Gate Ave, 16th Floor, San Francisco, 

CA 94102. 

16. “Northern California Fires” has the meaning given in the Bar Date Order.

17. “Notice Procedures” means the Procedures for Mailing of the Bar Date Notices and

the Supplemental Notice Plan set forth in the Bar Date Order. 

18. “Person” means any corporation, partnership, limited partnership, limited liability

company, or other business organization, or any natural person. 

19. “TCC” means the Official Committee of Tort Claimants in these Chapter 11 Cases, as

appointed in the Amended Appointment of the Official Committee of Tort Claimants, dated February 

21, 2019 (Dkt. No. 530), each member of the Official Committee of Tort Claimants (individually or 

collectively) and all representatives, agents, attorneys, accountants, advisors, independent contractors, 

or other Persons or entities acting or purporting to act on behalf of the TCC or any of its members. 

20. “Trident” or “You” means Trident DMG LLC.

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SUBJECT MATTER AREAS

1. Any services performed by You to assist the TCC with “helping educate . . . the public

about the October deadline for tort claimants to identify themselves. Engagement Letter at 1. 

2. Any services performed by You to assist the TCC with “effectively communicat[ing]

with [the Fire Claimants], to understanding what is occurring in the [Chapter 11 Cases] . . . and what 

they need to do to fully realize their rights in the [Chapter 11 Cases].” Application ¶ 6. 

3. Any services performed by You to educate or assist any Fire Claimants with respect to

“how a corporate bankruptcy works, the claims process or other aspects of the [Chapter 11 Cases] that 

may concern their interests,” and to provide the Fire Claimants with “more explanation and guidance 

regarding basic bankruptcy terms and principles, and bankruptcy proceedings.” Application ¶ 8. 

4. Any efforts undertaken by You to locate, find, identify, or contact any Fire Claimants,

including but not limited to the specific manner(s) in which You undertook such efforts. 

5. The Bar Date or Fire Claim Bar Date Notice, including but not limited to:

a. Any efforts undertaken by You to ensure or confirm that any Fire Claimants are

aware of the Bar Date or have received the Fire Claim Bar Date Notice, including relating to any such 

efforts undertaken prior to October 12, 2019; 

b. Any efforts undertaken by You to educate any Fire Claimants with respect to

the Bar Date; 

c. The number of Fire Claimants who are aware of the Bar Date or have received

the Fire Claim Bar Date Notice, including any related calculations, studies, projections, estimates or 

analyses; 

d. The number of Fire Claimants who are not aware of the Bar Date, have not

received the Fire Claim Bar Date Notice, or have received but subsequently lost the Fire Claim Bar 

Date Notice, including any related calculations, studies, projections, estimates or analyses. 

6. The Fire Claimant Proof of Claim Form, including but not limited to:

a. Any efforts undertaken by You to educate or assist any Fire Claimants with

respect to the Fire Claimant Proof of Claim Form, including but not limited to efforts to educate or 

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assist Fire Claimants with understanding, completing and timely filing the Fire Claimant Proof of 

Claim Form; 

b. The number of Fire Claimants who have not completed or have not timely filed

the Fire Claimant Proof of Claim Form, including any related calculations, studies, projections, 

estimates or analyses. 

7. The Notice Procedures, including but not limited to the efficacy of the Notice

Procedures. 

8. Communications between You, on the one hand, and the TCC, the AHC, any

Government Agency, any Fire Claimants, or any attorneys for any Fire Claimants, on the other hand, 

relating to: 

a. Any efforts undertaken to locate, find, identify, or contact any Fire Claimants;

b. The Bar Date;

c. The Fire Claim Bar Date Notice;

d. The Fire Claimant Proof of Claim Form, or;

e. The Notice Procedures.

9. Any visits by You to any temporary housing facilities at which any Fire Claimants are

currently residing or have previously resided, including but not limited to temporary housing facilities 

operated by FEMA or any other Government Agency, and including relating to any such visits made 

prior to or after October 12, 2019. 

10. Any Fire Claimants who are unable to understand, complete or timely file the Fire

Claimant Proof of Claim Form due to any emotional distress, including but not limited to posttraumatic stress disorder, they may be experiencing as a result of the Northern California Fires. 

11. Any Fire Claimants who have been unable to understand, complete or file the Fire

Claimant Proof of Claim Form due to any power outages or other loss of power. 

12. Documents or Communications produced in response to Debtors’ Requests for

Production of Documents to Trident DMG LLC in connection with the Motion, dated October 23, 

2019. 

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