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XAVIER BECERRA, SBN 118517

Attorney General of California 

MARGARITA PADILLA, SBN 99966 

Supervising Deputy Attorney General 

JAMES POTTER, SBN 166992 

Deputy Attorney General 

1515 Clay Street, 20th Floor 

P.O. Box 70550 

Oakland, CA 94612-0550 

Telephone: (510) 879-0815 

Fax: (510) 622-2270 

Margarita.Padilla@doj.ca.gov 

James.Potter@doj.ca.gov 

STEVEN H. FELDERSTEIN, SBN 059678 

PAUL J. PASCUZZI, SBN 148810 

FELDERSTEIN FITZGERALD 

WILLOUGHBY PASCUZZI & RIOS LLP 

500 Capitol Mall, Suite 2250 

Sacramento, CA 95814 

Telephone: (916) 329-7400 

Fax: (916) 329-7435 

sfelderstein@ffwplaw.com 

ppascuzzi@ffwplaw.com 

Attorneys for California Department of Toxic 

Substances Control, et al. 

XAVIER BECERRA, SBN 118517 

Attorney General of California 

DANETTE VALDEZ, SBN 141780 

ANNADEL ALMENDRAS, SBN 

192064 

Supervising Deputy Attorneys General 

Cara M. Porter, SBN 266045 

Deputy Attorney General 

455 Golden Gate Avenue, Suite 11000 

San Francisco, CA 94102-7004 

Telephone: (415) 510-3367 

Fax: (415) 703-5480 

Danette.Valdez@doj.ca.gov 

Annadel.Almendras@doj.ca.gov 

Cara.Porter@doj.ca.gov 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

- and – 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors.

Bankruptcy Case

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

 Affects PG&E Corporation 

 Affects Pacific Gas and 

Electric Company 

 Affects both Debtors 

STIPULATION AND AGREEMENT FOR 

ORDER ADDING CERTAIN CALIFORNIA 

STATE AGENCIES AS PARTIES TO 

CONFIDENTIALITY AND PROTECTIVE 

ORDER [DKT. NO. 3405], AS MODIFIED 

HEREIN 

[No hearing requested] 

Case: 19-30088 Doc# 4961 Filed: 12/03/19 Entered: 12/03/19 16:42:19 Page 1 of

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This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

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 California Department of 

Forestry and Fire Protection, California Department of Toxic Substances Control, California 

Governor’s Office of Emergency Services, California Department of Veterans Affairs, California 

State University, California Department of Parks and Recreation, California Department of 

Developmental Services and the California Department of Transportation (collectively, the 

“California State Agencies”)1

, on the other hand. The Debtors and the California State Agencies 

are referred to in this Stipulation and Agreement for Order collectively as the “Parties,” and each 

as a “Party.” The Parties hereby stipulate and agree as follows: 

RECITALS 

A. The California State Agencies desire to 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”), with certain modifications, to which the Debtors have agreed. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH 

ARE INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, 

THAT THE ORDER BE MODIFIED AS FOLLOWS: 

1. Treatment of Confidential Information for Law Enforcement Purposes. 

Notwithstanding anything to the contrary in the Order, the California State Agencies may use 

Protected Material for duly authorized law enforcement or regulatory purposes and disclose such 

information to law enforcement personnel and agencies as set forth in California Government Code 

§ 11181(g), and personnel of other California government agencies for such purpose (in either case, 

hereinafter referred to as “Law Enforcement Personnel”), provided that all such Law Enforcement 

Personnel agree to maintain the confidentiality of all Protected Material consistent with the terms 

of this Order. To the extent the California State Agencies or Law Enforcement Personnel deem it 

1

 For avoidance of doubt, the California State Agencies joining the Order are only those listed 

herein above. 

Case: 19-30088 Doc# 4961 Filed: 12/03/19 Entered: 12/03/19 16:42:19 Page 2 of

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necessary in their regulatory or law enforcement discretion to disclose Protected Material in any 

public filing before a court or regulatory body, the California State Agencies or Law Enforcement 

Personnel may do the following: (a) file a motion or request with the applicable court or regulatory 

body to submit the Protected Material under seal for a minimum of 20 business days based on the 

terms of this Protective Order; (b) provide the Designating Party written notice no fewer than the 

greater of (i) 14 calendar days or (ii) 10 business days prior to the day such motion or request is 

filed so as to allow the Designating Party an opportunity to request that the filing remain under seal; 

and (c) agree to maintain the filing under seal for 20 business days, unless an applicable court or 

regulatory body orders otherwise. Provided, however, nothing in the Order or any modification 

herein: (i) prevents the California State Agencies or Law Enforcement Personnel from obtaining 

any document or writing produced in discovery in the Chapter 11 Cases through any other lawful 

procedure(s) and to use the information obtained through such lawful procedure(s) in accordance 

with applicable law or (ii) limits the California State Agencies or Law Enforcement Personnel from 

challenging, at any time, the propriety of a confidential designation under the terms of the Order. 

2. Treatment of Confidential Information Under California Public Records Act. 

Protected Material may include documents relating to litigation and confidential financial, 

proprietary and trade secret information of the Debtors entitled to protection from public disclosure 

under 11 U.S.C. § 107. As such, a Designating Party may contend that the Protected Material is 

exempt from disclosure under the California Public Records Act (Cal. Gov’t Code § 6250 et seq.), 

and protected from disclosure under 11 U.S.C. § 107, which is incorporated as an exemption from 

disclosure under the California Public Records Act, California Government Code § 6254(k). 

a. If Protected Material is sought by a non-party to the Order by discovery request, 

subpoena, deposition question, interrogatories, Public Records Act request (California Government 

Code section 6250 et seq.), or otherwise sought through a requirement by law or regulation 

(collectively a “Requirement”) such information shall not be disclosed except as required by 

applicable law or court order. A Party to the Order, as may be modified by the Court, receiving a 

Public Records Act request shall be the party that determines whether the disclosure of Protected 

Material in its possession is required by law or court order. 

Case: 19-30088 Doc# 4961 Filed: 12/03/19 Entered: 12/03/19 16:42:19 Page 3 of

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b. The Party receiving a request or demand for Protected Material through a 

Requirement shall immediately provide written notice to the Designating Party of the existence, 

terms, and circumstances of the request or demand, and will not disclose the Protected Material at 

issue for at least 10 calendar days from the date of providing the Designating Party written notice 

of such demand or request, to give each other Party an opportunity to seek an order to prevent such 

disclosure. If such an order is sought, the Party that received the request or demand shall refrain 

from disclosing the requested or demanded Protected Material until such time as a final 

determination is made on that order. 

c. In the event that no order is timely sought by the Designating Party as provided for 

by paragraph (b) and a Party subject to a request or demand through a Requirement is compelled, 

in the opinion of its legal counsel, to disclose Protected Material in order to avoid violating the law, 

being found in contempt, or other substantial penalty, that party shall furnish only that portion of 

the Privileged Material which is legally required and will not be liable to any other party for the 

disclosure of Protected Material. 

d. The costs and expenses for seeking a protective order shall be borne only by the 

party(ies) seeking the protective order. 

Dated: December 3, 2019 

KELLER & BENVENUTTI LLP 

/s/ Jane Kim 

Jane Kim 

Attorneys for Debtors and 

Debtors in Possession 

XAVIER BECERRA 

Attorney General of California 

MARGARITA PADILLA 

Supervising Deputy Attorney General 

/s/ Paul J. Pascuzzi 

STEVEN H. FELDERSTEIN 

PAUL J. PASCUZZI 

FELDERSTEIN FITZGERALD 

WILLOUGHBY PASCUZZI & RIOS LLP 

Attorneys for California Department of 

Forestry and Fire Protection, California 

Department of Toxic Substances Control, 

California Governor’s Office of Emergency 

Services, California Department of Veterans 

Affairs, California State University, California 

Department of Parks and Recreation, 

California Department of Developmental 

Services, and California Department of 

Transportation

Case: 19-30088 Doc# 4961 Filed: 12/03/19 Entered: 12/03/19 16:42:19 Page 4 of

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PROOF OF SERVICE 

I, Karen L. Widder, declare: 

I am a resident of the State of California and over the age of eighteen years, and not a party 

to the within action; my business address is 500 Capitol Mall, Suite 2250, Sacramento, CA 95814. 

On December 3, 2019, I served the within documents: 

STIPULATION AND AGREEMENT FOR ORDER ADDING CALIFORNIA

STATE AGENCIES AS PARTIES TO CONFIDENTIALITY AND PROTECTIVE

ORDER [DKT. NO. 3405], AS MODIFIED HEREIN 

By Electronic Service only via CM/ECF. 

/s/ Karen L. Widder 

Karen L. Widder 

Case: 19-30088 Doc# 4961 Filed: 12/03/19 Entered: 12/03/19 16:42:19 Page 5 of

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