EXHIBIT A

Case: 19-30088 Doc# 3672-1 Filed: 08/23/19 Entered: 08/23/19 11:41:24 Page 1

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Robert Julian

direct dial: 628.208.6436

rjulian@bakerlaw.com

BakerHostetler

1160 Battery Street East

Suite 100

San Francisco, CA 94111

T: 310.442.8899

F: 310.820.8859

www.bakerlaw.com

August 22, 2019

VIA EMAIL (korsini@cravath.com)

Kevin J. Orsini, Esq.

Cravath, Swaine & More LLP

Worldwide Plaza

825 Eighth Avenue

New York, NY 10019-7475

Re: In re PG&E Corporation and Pacific Gas and Electric Company, Case No. 19-30088 

(DM) (Jointly Administered)

Dear Mr. Orsini:

During the hearing before Judge Montali on the Motion for Relief from Stay, the Debtors 

stated their intention to deny liability as to all of the fires that will be the subject of the estimation 

proceedings. We assume the broad based denial is grounded in good faith, based on the Debtors’ 

analysis of the Cal Fire reports, investigation of the facts with their employees, and examination 

of the physical and documentary evidence in their possession, custody or control. Since the TCC 

and the fire victims have not had similar access to the evidence, and in order to meaningfully 

prepare for the hearing on August 27th, we request the Debtors provide the TCC and the Court in 

advance of the August 27th hearing with: (1) the factual and legal bases supporting their denial of 

liability for each fire (including any affirmative defenses); (2) the names of witnesses you contend 

will support PG&E’s denial of liability; and (3) any documents and physical evidence which 

PG&E will rely upon to support their denials. We believe such disclosures are essential in order 

to assess the discovery necessary to meet the time frame for any estimation process. A set of 

standard contention interrogatories along this line are enclosed. We will separately follow up this 

letter with a request for the production of specific documents that we believe the Debtors should 

produce immediately in connection with this process. 

Case: 19-30088 Doc# 3672-1 Filed: 08/23/19 Entered: 08/23/19 11:41:24 Page 2

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Kevin J. Orsini 

August , 2019 

Page 2 

Robert Julian 

Partner 

Enclosure 

cc: (Via Email): 

Benjamin P. McCallen 

Gregory A. Bray 

Frank M. Pitre 

Michael A. Kelly 

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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 Blvd., Suite 1400

Los Angeles, CA 90025-0509

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel to the 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)

FIRST SET OF INTERROGATORIES OF 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS TO THE DEBTORS 

PG&E CORPORATION AND PACIFIC 

GAS AND ELECTRIC COMPANY

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ATTORNEYS AT LAW

SAN FRANCISCO

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OFFICIAL COMMITTEE OF TORT CLAIMANT’S COMMITTEE’S SECOND SET OF 

INTERROGATORIES UNDER FED. R. BANKR. 2004 TO DEBTORS

Pursuant to Fed. R. Bankr. P. 9014 and 7033 (FRCP 33), and Paragraph 37 of the Second 

Amended Order Implementing Certain Notice and Case Management Procedures, dated May 13, 

2019 (Dkt No. 1996), the Official Committee of Tort Claimants (the “TCC”), by and through their 

attorneys, hereby serve the following interrogatories (the “Interrogatories”) on PG&E 

Corporation and Pacific Gas and Electric Company (collectively, the “Debtors”), to be answered 

with written responses to the law offices of Baker & Hostetler LLP, 1160 Battery Street, Suite 100, 

San Francisco, CA 94111 within 7 days day after service upon the Debtors. 

DEFINITIONS AND INSTRUCTIONS

1. “And/Or” shall be construed either disjunctively or conjunctively as necessary to 

bring within the scope of the discovery request all responses that might otherwise be construed to 

be outside of its scope.

2. The terms “You” or “Your” means Debtor Pacific Gas & Electric Company and 

Debtor PG&E Corporation, both collectively and individually as a single Debtor. 

3. The terms “Fire” or “Fires” shall have the following meaning: the “2017 and 2018 

Northern California Wildfires” defined and used by the Debtors in the Amended Declaration of 

Jason P. Wells in Support of First Day Motions and Related Relief (Dkt No. 263) filed on February 

1, 2019.

4. The term “Cal Fire Report” shall mean the following reports issued by the California 

Department of Forestry and Fire Protection (“Cal Fire”), including the statements, findings, and 

conclusions within those reports, as well as the statements, findings, and conclusions within any 

attachments to those reports:

a. Cal Fire Investigation Report, Case No. 17CAMRN0002957 (37)

b. Cal Fire Investigation Report, Case No. 17CALNU010050 (Adobe)

c. Cal Fire Investigation Report, Case No. 17CALNU010046 (Atlas)

d. Cal Fire Investigation Report, Case No. 17CAHUU008828 (Blue)

e. Cal Fire Investigation Report, Case No. 17CANEU026269 (Cascade)

f. Cal Fire Investigation Report, Case No. 17CABTU015933 (Cherokee)

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ATTORNEYS AT LAW

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g. Cal Fire Investigation Report, Case No. 17CABTU015954 (La Porte)

h. Cal Fire Investigation Report, Case No. 17CALNU010142 (Norrbom)

i. Cal Fire Investigation Report, Case No. 17CALNU010049 (Nuns)

j. Cal Fire Investigation Report, Case No. 17CALNU010051 (Partrick)

k. Cal Fire Investigation Report, Case No. 17CALNU010057 (Pocket)

l. Cal Fire Investigation Report, Case No. 17CATCU012170 (Point)

m. Cal Fire Investigation Report, Case No. 17CALNU010348 (Pythian)

n. Cal Fire Investigation Report, Case No. 17CAMEU012169 (Redwood)

o. Cal Fire Investigation Report, Case No. 17CALNU010055 (Sulphur)

p. Cal Fire Investigation Report, Case No. 17CALNU010045 (Tubbs)

q. Cal Fire Investigation Report, Case No. 17CALNU010487 (Youngs)

5. The term “CPUC Incident Investigation Report” shall mean the following reports 

issued by the California Public Utilities Commission (“CPUC”) including the statements, findings, 

conclusions within those reports, as well as the statements, findings, and conclusions within any 

attachments to those reports: 

a. CPUC Incident Investigation Report, No. E20171010-02, Apr. 29, 2019 (Adobe)

b. CPUC Incident Investigation Report, No. 171023-8596, May 2, 2019 (Atlas 1)

c. CPUC Incident Investigation Report, No. 171020-8589, May 2, 2019 (Atlas 2)

d. CPUC Incident Investigation Report, No. E20171020-06, May 6, 2019 (Cascade)

e. CPUC Incident Investigation Report, No. E20171010-01, May 2, 2019 (Cherokee)

f. CPUC Incident Investigation Report, No. E20171013-01, Apr. 29, 2019 (La Porte)

g. CPUC Incident Investigation Report, No. E20171020-05, May 10, 2019(Norrbom)

h. CPUC Incident Investigation Report, No. E20171016-01, Apr. 30, 2019 (Nuns)

i. CPUC Incident Investigation Report, No. E20171020-02, May 10, 2019 (Partrick)

j. CPUC Incident Investigation Report, No. E20171021-01, May 10, 2019 (Pocket)

k. CPUC Incident Investigation Report, No. E20171009-03, Apr. 26, 2019 (Point)

l. CPUC Incident Investigation Report, No. E20171020-03, May 1, 2019 (Pythian)

m. CPUC Incident Investigation Report, No. E20171009-02, May 3, 2019 (Redwood)

n. CPUC Incident Investigation Report, No. E20171011-02, May 10, 2019 (Sulphur)

o. CPUC Incident Investigation Report, No. E20171026-01, May 13, 2019 (Tubbs)

p. CPUC Incident Investigation Report, No. E20171020-01, May 6, 2019 (Youngs)

6. To the extent you consider any of the following requests or interrogatories 

objectionable, respond to so much of each, and each part thereof, which is not objectionable in your 

view, and separately state that part of each which is objectionable and the ground for each objection.

7. Provide a privilege log relating to Your responses to each of these Interrogatories 

and all supporting documents, from which You are withholding information. The privilege log 

must list the document or information withheld and the legal basis for withholding that information.

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SAN FRANCISCO

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INTERROGATORY NO. 1:

If You contest any of the statements, findings, or conclusions of any Cal Fire Report or any 

CPUC Incident Investigation Report pertaining to any of the Fires, identify separately for each Fire:

a. The factual basis for Your contention; and

b. The legal basis for Your contention. 

INTERROGATORY NO. 2:

To the extent You contend You are not legally liable for any of the Fires, state the following: 

a. For each Fire, state separately all affirmative defenses upon which You intend to rely to 

support Your contention;

b. For each Fire, state separately the legal basis for Your contention that You are not 

legally liable for that Fire;

c. For each Fire, state separately the factual basis for Your contention that You are not 

legally liable for that Fire; 

d. For each Fire, identify separately all witnesses that support Your contention that You 

are not legally liable for that Fire;

e. For each Fire, identify separately all physical evidence that supports Your contention 

that You are not legally liable for that Fire; and

f. For each Fire, identify separately all documents (listed by Bates Number) that support 

Your contention that You are not legally liable for that Fire. 

Dated: August 22, 2019

BAKER & HOSTETLER LLP

By: /s/ Robert Julian

Robert Julian

Counsel to the Official Committee of Tort 

Claimants 

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