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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000 

SAN FRANCISCO, CA 

94111 

UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 -andPACIFIC GAS & 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) 

 Case No.: 19-30088-DM 

Chapter 11 

PARTIAL JOINDER OF THE CITY 

AND COUNTY OF SAN FRANCISCO 

TO THE REPLY BRIEF OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS CONCERNING THE 

APPLICABILITY OF INVERSE 

CONDEMNATION

DATE: November 19, 2019 

TIME: 9:30 am 

PLACE: Courtroom 17 

450 Golden Gate Avenue, 16th Fl.

San Francisco, California 

JUDGE: Hon. Dennis Montali 

RELATED DOCKET NOS: 4485, 4773 

 The City and County of San Francisco (“San Francisco”) in the above-captioned chapter 11 

cases of Pacific Gas and Electric Company (the “Utility”) and PG&E Corporation (“PG&E” and, 

together with the Utility, the “Debtors”), hereby partially joins, as further described herein, in the 

EDWARD J. TREDINNICK (#84033) 

GREENE RADOVSKY MALONEY 

 SHARE & HENNIGH LLP

Four Embarcadero Center, Suite 4000 

San Francisco, California 94111-4106 

Telephone: (415) 981-1400 

Facsimile: (415) 777-4961 

E-mail: etredinnick@greeneradovsky.com 

Attorneys for Creditor, 

City and County of San Francisco 

Case: 19-30088 Doc# 4781 Filed: 11/15/19 Entered: 11/15/19 17:00:17 Page 1 of

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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000 

SAN FRANCISCO, CA 

94111 

Reply Brief of the Official Committee of Tort Claimants Concerning the Applicability of Inverse 

Condemnation (the “Tort Committee Reply”) [Dkt No. 4773] to the Joint Brief of Debtors and the 

Official Committee of Unsecured Creditors and Supplemental Statement of the PG&E Shareholders 

Concerning Applicability of Inverse Condemnation [Dkt. No. 4885] (the “Debtor’s Brief”). 

PARTIAL JOINDER 

San Francisco is interested in this issue as a creditor and potential creditor of the Debtors. As 

stated in its original objection filed herein [Dkt. No. 3412], San Francisco, along with other public 

entities, have a strong interest in ensuring that inverse condemnation continues to apply to privatelyowned utilities so that financial responsibility for the Utility’s actions does not shift to public entities 

and property owners. 

San Francisco specifically joins the Tort Committee Reply with respect to the arguments 

presented in Sections IV, A through C (Pages 9-18) that establish the applicability of inverse 

condemnation to investor owned utilities under current California case law is settled law that is 

binding on PG&E and this Court. San Francisco contends that the Court can end its inquiry there, and 

dispose of the issues presented in the Debtor’s Brief without delving into the specifics of California’s 

inverse condemnation standard. 

 San Francisco expressly reserves all rights to join in any other parties’ briefing on this issue 

CONCLUSION 

For the reasons stated herein, San Francisco joins in the arguments set forth in Sections IV, A 

through C of the Tort Committee Reply and requests that the Court determine that current California 

law regarding the application of inverse condemnation to PG&E applies in this case as set forth in this 

Partial Joinder. 

 Respectfully submitted, 

Dated: November 15, 2019 GREENE RADOVSKY MALONEY 

SHARE & HENNIGH LLP 

By: _____/s/ Edward Tredinnick_________________ 

 Edward J. Tredinnick 

 Attorneys for Creditor, 

 City and County of San Francisco 

Case: 19-30088 Doc# 4781 Filed: 11/15/19 Entered: 11/15/19 17:00:17 Page 2 of

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