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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA

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)

REPLY IN SUPPORT OF 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

Date: August 27, 2019

Time: 9:30 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Case: 19-30088 Doc# 3684 Filed: 08/23/19 Entered: 08/23/19 18:25:10 Page 1 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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The Official Committee of Tort Claimants (the “TCC”) for its Reply in support of its 

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) (the “Application”), and in response to 

the Debtors’ Objection to the retention of Trident1 (Dkt. No. 3610) (the “Objection”),2 respectfully 

states as follows:

In the Objection, the Debtors oppose the TCC’s proposed retention of Trident based on the 

scope of services Trident has agreed to perform and the terms of the indemnity in Trident’s 

Engagement Letter with the TCC. However, as explained below, Trident proposes to provide nonduplicative services crucial to enabling the TCC to effectively communicate with the tort claimants 

in these Cases. In addition, the terms of the indemnity sought by Trident are nearly identical to 

those terms previously approved by the Court for other professionals in these Cases. Therefore, the 

Debtor’s Objection lacks merit and should be overruled.

The Debtors first argue that the TCC should not be permitted to retain Trident because its 

services are unnecessary or could be performed by the TCC’s existing professionals. This argument 

fails for several reasons. As explained in the Application, the TCC has a unique role in the Cases. 

It has been tasked with representing a large and dispersed group of claimants, many of which have 

lost their loved ones and homes due to the wildfires caused by the Debtors. Most of these claimants 

are also unfamiliar with how a corporate bankruptcy works, including the claims process. 

Therefore, tort claimants will likely require greater explanation and guidance beyond the resources 

already available to them so that they may better understand what is occurring in the Cases and take 

necessary steps to preserve their rights. To effectively communicate with this uniquely-situated 

group, the TCC has engaged Trident, a full-service communications and consulting firm with 

specialized expertise in developing, executing, and managing communications strategies in the 

 1 Capitalized terms used but not defined in this Reply shall have the meanings ascribed to such terms in the Application. 2 In the Application, the TCC reserved the right to file a brief and memorandum of law in response to any objection to 

this Application. Application at 9. This Reply is filed in accordance therewith.

Case: 19-30088 Doc# 3684 Filed: 08/23/19 Entered: 08/23/19 18:25:10 Page 2 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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mass tort and bankruptcy contexts. The TCC’s existing professionals do not possess this same 

skillset nor have they been retained to provide similar communication-related services. 

As also discussed in the Application, Trident will not be hosting a separate website, nor will 

it perform other functions, such as claims processing, balloting and noticing services, that Epiq and 

Primeclerk are already providing. And to ensure that the Trident’s services do not overlap with 

those of Epiq, Primeclerk, and the TCC’s professionals, the TCC will closely monitor the activities 

of Trident and its other professionals to avoid the duplication of work. Moreover, Trident’s future 

applications for the payment of professional fees and reimbursement of expenses will also be 

subject to the scrutiny of the fee examiner appointed by this Court. To the extent an issue regarding 

duplication ever arises, it may be addressed by the fee examiner at the appropriate time. As 

compared to the quantum of fees sought by other professionals in these Cases, Trident seeks a 

relatively modest fee: a $45,000 initial monthly fee and monthly fees of $35,000 for subsequent 

months. This amount is very reasonable considering the size and scope of these Cases and the 

number of tort claimants with whom Trident will be tasked with communicating. 

Second, the Debtors contend without any support that the indemnity in Trident’s 

Engagement Letter is inappropriately broad. This position lacks merit. The Application seeks the 

Court’s authorization for the Debtors to indemnify and hold Trident harmless, but not for claims or 

expenses arising from Trident’s bad faith, willful misconduct, gross negligence, or negligence. In 

these Cases, the Court has approved the indemnification of the Debtors’ and TCC’s professionals 

on very similar terms.3

 3 See e.g., Order Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Fed. R. Bankr. P. 2014(a) and 2016 for Authority to 

Retain and Employ KPMG LLP as Information Technology, Risk, and Forensic Technology Consultants to the Debtors 

Nunc Pro Tunc to Petition Date (Dkt No. 2503); Order Approving 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 Lincoln Partners 

Advisors LLC as a Financial Adviser Effective as of March 1, 2019 (Dkt. No. 1976). 

Case: 19-30088 Doc# 3684 Filed: 08/23/19 Entered: 08/23/19 18:25:10 Page 3 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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WHEREFORE, for the reasons stated above and in the Application, the TCC respectfully 

requests that this Court enter an order, in the form attached to the Application as Exhibit A, (a) 

authorizing the retention of Trident effective as of July 18, 2019; and (b) granting such other and 

further relief as is just and proper. 

Dated: August 23, 2019 Respectfully submitted,

BAKER & HOSTETLER LLP

By: /s/ Robert A. Julian

Robert A. Julian

Counsel for Official Committee of Tort Claimants

Case: 19-30088 Doc# 3684 Filed: 08/23/19 Entered: 08/23/19 18:25:10 Page 4 of

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