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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) 

Matthew Goren (pro hac vice) 

(matthew.goren@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 

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) 

DECLARATION OF JEANNE C. FINEGAN 

(I) REGARDING IMPLEMENTATION OF THE 

DEBTORS’ NOTICE PROCEDURES AND 

SUPPLEMENTAL NOTICE PLAN AND (II) IN 

SUPPORT OF THE DEBTORS’ OBJECTION TO 

CLASS REPRESENTATIVE’S MOTION TO 

EXTEND APPLICATION OF FEDERAL RULE 

OF CIVIL PROCEDURE 23 TO PROOF OF 

CLAIM

Re: Dkt. Nos.: 5042 

Date: January 29, 2020 

Time: 10:00 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali

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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Pursuant to 28 U.S.C. § 1746, I, Jeanne C. Finegan, hereby declare as follows under penalty of 

perjury: 

I. INTRODUCTION 

1. I am the Vice President of Notice Media Solutions at Prime Clerk LLC (“Prime Clerk”), 

the Debtors’ court-appointed claims and noticing agent in these chapter 11 cases, and Chief Media 

Officer of HF Media LLC, an affiliate of Prime Clerk.1 Except as otherwise noted, this Declaration is 

based upon my personal knowledge of the matters set forth herein, my review of relevant documents, 

and information provided to me by PG&E Corporation and Pacific Gas and Electric Company 

(collectively, the “Debtors”) and their agents and professionals, including professionals at Weil, 

Gotshal & Manges LLP, Cravath, Swaine & Moore LLP, AlixPartners LLP, and Prime Clerk, and my 

prior experience in bankruptcy and class action noticing, and if called and sworn as a witness, I could 

and would testify competently thereto. 

2. I submit this Declaration (i) to provide the Court with a report regarding the successful 

and timely implementation of the Debtors’ robust multi-faceted plan and procedures for providing 

notice of the Bar Date and the procedures for filing proofs of claims to known and unknown claimants 

in the Debtors’ Chapter 11 Cases, including Known and Unknown Fire Claimants2 (the “Notice 

Procedures”), and (ii) in support of the Debtors’ objection, filed contemporaneously herewith, to the 

Securities Lead Plaintiff’s Motion to apply Bankruptcy Rule 7023 to Class Proof of Claim [Docket 

No. 5042]. In accordance with the Bar Date Order, the Debtors commenced implementation of their 

Notice Procedures on July 1, 2019 and continued their efforts through the Court-approved Bar Date of 

October 21, 2019 at 5:00 p.m. Pacific Time. 

                                                      

1

 In July 2019, Heffler Claims Group, including its media division HF Media LLC, was acquired by 

Prime Clerk’s parent company. 

2

 Capitalized terms used but not otherwise herein defined shall have the meaning ascribed to them in the 

Order Pursuant to 11 U.S.C. Section 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 [Docket No. 2806] (the “Bar Date 

Order”). 

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II. NOTICE EXPERTISE AND QUALIFICATIONS 

3. A comprehensive description of my credentials, expertise, and experience that qualify me 

to provide an expert opinion and advice regarding notice in these Chapter 11 Cases, which include more 

than 30 years of communications and advertising experience, specifically in the bankruptcy and class 

action notice context is set forth in detail the Declaration of Jeanne C. Finegan in Support of the 

Debtors' Bar Date Motion and in Response to the Tort Committee's Bar Date Motion and Related 

Filings [Docket No. 2642] (the “Original Finegan Declaration”), which is incorporated herein by 

reference in its entirety. 

III. SUMMARY OF THE RESULTS OF THE DEBTORS’ NOTICE PROCEDURES 

AND SUPPLEMENTAL NOTICE PLAN

4. As set forth in the Original Finegan Declaration, and the November 11, 2019 Declaration 

of Jeanne C. Finegan (i) Regarding Implementation of the Debtors’ Notice Procedures and 

Supplemental Notice Plan and (ii) in Support of Debtors’ Objection to Class Representative’s Motion 

to Extend Application of Federal Rule of Civil Procedure 23 to Class Proof of Claim (the 

“Supplemental Finegan Declaration”), which is incorporated herein by reference in its entirety, at the 

time I submitted my Original Declaration, it was my opinion that the Debtors’ Notice Procedures, 

including, the Supplemental Notice Plan, were reasonable, effective, and went well-beyond the 

requirements of applicable law and due process. Based on my experience, I believed that the Debtors’ 

Notice Procedures, and in particular the Supplemental Notice Plan, were broad, multi-faceted, and 

designed to have the greatest possible reach to all creditors and parties in interest, including those who 

may have relocated as a result of the Northern California fires. Indeed, at the time I submitted my 

Original Declaration, it was my further belief that the Debtors’ Supplemental Notice Plan, which was 

amended prior to entry of the Bar Date Order to incorporate certain additional aspects at the request of 

the TCC, was one of the largest and most comprehensive notice and media campaigns recommended in 

chapter 11 history. As set forth in further detail below, the Notice Procedures, as implemented, have 

been a resounding success and have exceeded the estimated and projected results set forth in my 

Original Declaration. Specifically, the Supplemental Notice Plan, as implemented, has exceeded the 

reach and frequency estimates set forth in my Original Declaration, as follows: 

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5. For context, the Debtors’ Supplemental Notice Plan exceeds the combined reach and 

frequency levels of even the largest, most recent class action campaigns that had similar local, regional, 

and national outreach. 

Case Name Reach Frequency 

Takata Auto Airbag Products Liability Settlement 95% 4x 

BP Deepwater Horizon3 95% 4x 

Cook et. al v. Rockwell International Corp. and the 

Dow Chemical Co.4

96% 7x 

In re Payment Card Interchange Fee and Merchant 

Discount Antitrust 

82% 2.7x 

In re Air Cargo Shipping Services Canadian 

Antitrust 

77% 2.7x 

Spotify Publishing Settlement 74% 2.6x 

Red Bull False Advertising Class Action 72% 3.9x 

New Balance “Made in the USA” Class Action 70% 4.1x 

6. The Debtors’ Notice Procedures were broad and multi-faceted, and were designed and 

implemented to maximize reach to all claimants in a variety of ways, including through (i) direct 

mailings to known claimants, (ii) multiple local and national newspaper and magazine publication 

notices, (iii) digital advertising, including social media, social influencers, and other paid Internet search 

listings, (iv) television and radio advertising, (v) press releases, and (vi) extensive community and boots 

                                                      

3 Decl. of Cameron Azari, Rec. Doc. 7113-1, ¶¶ 5, 6. 4 Decl. of Jeanne C. Finegan dated March 30, 2017, Doc. No. 2432, at ¶¶ 30-31. 

Target Audience Estimated 

Reach/ Frequency 

Final 

Reach/ Frequency 

Adults 18+ in the 4 DMAs 95% Reach / 8x 98% Reach / 16x 

Adults 18+ in CA 81% Reach / 5x 88% Reach / 11x 

Adults 18+ outside of CA 

and moved in the last 4 

years 

78% Reach / 2.3x 80% Reach / 3x 

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on the ground outreach efforts. Through these comprehensive efforts, the Notice Procedures delivered 

more than 730,000,000 impressions,5 i.e. opportunities to see the Bar Date Notice, as follows: 

Media Channel Estimated Impressions 

Direct Mailings 6,200,000 

Social Media 411,505,264 

Display Online 50,571,921 

Magazine 53,489,000 

Influencer 1,225,191 

Out of Home (Billboards) 10,520,351 

Over the Top TV (“OTT”) 1,437,291 

Streaming Radio 3,179,525 

Terrestrial Radio 23,774,300 

National Cable Television 105,427,161 

Local Cable Television 8,535,909 

Local Broadcast Television 32,037,000 

Newspaper Publication (National) 14,442,223 

Newspaper Publication (Local) 8,553,710 

Estimated Total Impressions 730,898,846 

7. An impression translates into an opportunity to see a message in a given medium. Here, 

it measures each time the Bar Date Notice is displayed and potentially viewed by claimants. For example, 

each direct mailing of the Bar Date Notice sent out to Known Claimants constitutes one impression. 

Every time, the Bar Date was displayed in a television advertisement similarly constitutes one impression 

for each person estimated to be viewing the advertisement at the time of airing. Similarly, every time 

someone had the opportunity to view the Bar Date Notice in one of the nearly 30 newspapers in which 

the Debtors’ published notice of the Bar Date constituted an impression. The Debtors’ delivered 

                                                      

5 As explained below, every time an advertisement is displayed, that instance is considered one 

impression. One person may be exposed to numerous impressions. 

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impressions, or opportunities to see the Bar Date Notice, actually exceeded the TCC’s projected 

impressions (620,000,000) in connection with its competing bar date motion.6

8. The increase in media delivery under the Supplemental Notice Plan is due in large part to 

our continuous active campaign management. The media team and Prime Clerk, in consultation with the 

Debtors, actively managed and optimized all media channels to minimize waste and to increase audience 

visibility and engagement. As the Supplemental Notice Plan progressed, the Debtors continued to refine 

the media being used to provide notice of the Bar Date and related procedures by shifting budgets away 

from under-performing channels and toward the more effective media channels and targeting that 

objectively delivered the greatest results. Optimization decisions were based on, among other things, 

data from attribution sources (e.g. Google Analytics) and other sources including social and general 

media tools (e.g. Cision7 and Socialbakers8). These tools provide detailed, real-time insight regarding 

the performance of an ongoing media campaign and allowed us to improve performance on a continuous 

and evolving basis. 

IV. THE SUPPLEMENTAL NOTICE PLAN SUMMARY 

9. The Debtors’ Notice Procedures were generally divided into two categories: (i) direct 

mailings of the Court-approved Bar Date Notices, including customized Bar Date Notices that were 

mailed to, among other parties, Known Fire Claimants and all of the Debtors’ millions of Customers; 

and (ii) the robust and unprecedented Supplemental Notice Plan designed to reach and provide 

constructive notice to unknown claimants, including Unknown Fire Claimants, that included extensive 

national and local newspaper publications and utilized other customized media tools. The summaries 

below focus on the results of the Debtors’ Supplemental Notice Plan.9

 In accordance with the Bar Date 

Order, the Debtors’ Supplemental Notice Plan included the following noticing methods: 

 Publication of the Bar Date Notice in three (3) nationally distributed magazines; 

                                                      

6

 In reporting estimated impressions of 684,000,000, the TCC miscalculated its local impressions. Thus, 

the TCC’s total should have been 620,000,000. 

7 See https://www.cision.com/us/. 8 See https://www.socialbakers.com/. 9

 An in-depth discussion of the results of direct mailing campaign completed by Prime Clerk at the 

direction of the Debtors is set forth in the Declaration of Benjamin P.D. Schrag (i) Regarding 

Implementation of the Debtors’ Notice Procedures and Supplemental Notice Plan and (ii) in Support of 

Debtors’ Objection to Class Representative’s Motion to Extend Application of Federal Rule of Civil 

Procedure 23 to Class Proof of Claim [Docket No. 4687]. 

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 Multiple publications of the Bar Date Notice in two (2) nationally circulated 

newspapers; 

 Multiple publications of the Bar Date Notice in twenty-seven (27) local newspapers; 

 Online display advertising in English and Spanish;  Social media advertising on Facebook, Instagram and Twitter;  Social Influencers;  Google keyword searches;  Out of Home advertising (e.g., static billboards and digital boards);  Online video advertising;  Radio advertisements 

o Terrestrial local radio advertisements (English and Spanish) 

o Streaming radio advertisements  Television advertising 

o Nationwide cable television advertisements in English 

o Local market cable television advertisements in English and Spanish 

o Local broadcast television advertisements in English 

o OTT television advertisements in English and Spanish  Press Releases in English and Spanish distributed nationally  Community outreach to over 230 groups in Northern California, including: 

o Boots-on-the-ground in person distribution of the flyer to:  FEMA camps  Community events  70 PG&E service centers  6 PG&E claim centers  Informational websites in English, Spanish, Chinese and Vietnamese  Informational toll-free telephone 

10. The results of each of the specific subcategories of the Supplemental Notice Plan are 

discussed in further detail below. 

A. PRINT – MAGAZINE 

11. The Supplemental Notice Plan included publication of a one-half page, black and white 

notice one (1) time in the national editions of People Magazine, Sport’s Illustrated and Sunset Magazine, 

which have a combined circulation of 6,680,000, with over 48,000,000 readers. 10 The magazine 

advertisements were written in plain English and contained a Spanish sub-headline that directed Spanishspeaking claimants to the Debtors’ claim websites for more information in Spanish. The advertisements 

were published in accordance with the below schedule: 

                                                      

10 Readership for both newspaper and magazines are calculated based on a pass-along factor. This is a 

reader in addition to the subscriber that browses that title. For example, the pass along factor for a 

newspaper is 2.11, the pass along factor for People Magazine is 10.21. That means for every subscriber 

there is an average of 10.21 people who also read the title. 

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Magazine Issue On Sale Circulation 

People Magazine August 5, 2019 July 26, 2019 3,031,000 

Sport’s Illustrated August 26, 2019 August 22, 2019 2,715,000 

Sunset Magazine September/October August 23, 2019 934,000 

12. Attached as Exhibit A to the Supplemental Finegan Declaration are proof of publication 

tear sheets of the published notice in these magazines. 

B. PRINT - NEWSPAPER 

13. The complete Standard Bar Date Notice was published in two (2) nationally circulated 

newspapers: 

A. The Wall Street Journal - The Bar Date Notice was published one (1) time in black 

and white on July 17, 2019. The Wall Street Journal’s circulation is 2,069,000. 

B. USA Today - The Bar Date Notice was published three (3) times in black and white 

on July 17, 2019, August 22, 2019 and September 26, 2019. USA Today’s circulation 

is 1,591,000. 

14. To further enhance the outreach efforts, the full Bar Date Notice was published three (3) 

times during the notice period in 27 local newspapers as a half-page, black and white notice written in 

plain English and featured a Spanish sub-headline. The additional papers were included to provide 

more thorough coverage of Northern California. Attached as Exhibit B to the Supplemental Finegan 

Declaration is a chart listing the newspapers and insertion dates as well as proof of publication affidavits 

from each newspaper. 

C. ONLINE NOTICE 

15. In total, the online component of the Debtors’ Supplemental Notice Plan served more 

than 50,000,000 impressions to reach potential claimaints. The Debtors’ online notice campaign targeted 

potential claimants based on considerations such as, among other things, geography and the target 

audiences’ characteristics, such as having recently moved from or previously lived in California. Banner 

advertisements were served in English and Spanish across a whitelist11 of approximately 4,000 websites, 

                                                      

11 A whitelist is a custom list of acceptable websites where advertising content may be served. This 

allows the Debtors to control the quality of advertising inventory that is served to creditors. The creation 

of a whitelist helps to ensure that advertisements are targeted to real websites where actual (human) 

creditors are likely to visit, rather than serving advertisements to websites and fraudsters who are 

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including top-tier news websites, local news websites, and Spanish language websites, among numerous 

others, and across multiple platforms, including desktops, laptops, and mobile devices. 

16. The Supplemental Finegan Declaration provides a complete description of the Debtors’ 

online notice campaign. 

D. SOCIAL MEDIA

17. The Debotrs deployed numerous and comprehensive tactics for providing notice on 

multiple social media platforms. In total, more than 411,000,000 social media impressions were served 

under the Debtors’ Supplemental Notice Plan, which resulted in over 50,000 “likes” and 30,000 reactions. 

Property Estimated 

Impressions 

Engagement 

(likes, comments, shares) 

Facebook/Instagram 406,481,000 50,000 

Twitter 2,673,000 4,699 

YouTube (English) 1,577,000 382 

YouTube (Spanish) 774,000 171 

Total 411,505,000 55,252 

18. The Supplemental Finegan Declaration provides a complete description of the Debtors’ 

social media campaign. 

E. SOCIAL INFLUENCERS

19. In order to leverage the highest indexing media to the youngest creditors, at the Debtors’ 

direction the media team and Prime Clerk engaged social media influencers to post and share information 

about the Bar Date on Instagram and Facebook. This effort reached over 1,200,000 followers and 

resulted in nearly 20,000 social engagements (i.e. clicks, comments and shares). The Supplemental 

Finegan Declaration provides a complete description of the Debtors’ engagement with social influencers. 

                                                      

attempting to fraudulently earn advertising revenue from the campaign, and thereby depriving actual 

creditors of their opportunity to see the Bar Date Notice. Further, the whitelist helps to ensure that 

advertisements will not appear next to offensive or objectionable content. The whitelist is actively 

maintained over the campaign with site-level reporting of brand safety during campaign and culling of 

improper or suspicious activity on websites. Further, as a measure of privacy, all advertisements feature 

AdChoices icons whenever available. 

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F. SEARCH TERMS 

20. The Supplemental Notice Plan utilized Google AdWords and keyword search terms to 

target potential Fire Claimants. When users entered on Google’s search engine, target phrases and 

keywords identified by the Debtors’ Supplemental Notice Plan, informational advertisements with links 

to the Debtors’ Case Website appeared on the search result pages. Attached as Exhibit F to the 

Supplemental Finegan Declaration is a full list of the keyword search terms utilized in the Supplemental 

Notice Plan. 

G. OUT OF HOME 

21. The Debtors expanded the Supplemental Notice Plan to utilize 17 static or digital 

billboards in Butte, Humboldt, Mendocino, Napa and Sonoma counties. The billboards appeared for nine 

(9) weeks and delivered more than 10,520,000 impressions as reported by GeoPath12 using data provided 

by the Traffic Audit Bureau. Attached as Exhibit G to the Supplemental Finegan Declaration is a map 

of the board locations and a copy of how they appeared. 

H. TERRESTRIAL AND STREAMING RADIO

22. Terrestrial radio aired in English and Spanish in the 6 MSAs. A total of 24 local English 

radio stations and 10 Hispanic stations were chosen to air approximately 2,680 terrestrial radio 

advertisements. Attached as Exhibit H to the Supplemental Finegan Declaration is a complete list of 

stations, their formats, broadcast language and markets. 

Radio Spots 

Planned 

Spots 

Delivered 

Increase from 

Planned to 

Delivered 

English 360 1,888 525% 

Hispanic 180 792 440% 

Total 540 2,680 496% 

23. To further enhance notice and in consultation with the TCC, the Supplemental Notice 

Plan was expanded to include streaming audio advertisements (i.e. digital radio played via an internet 

                                                      

12 Geopath generates standard audience measurements for out of home media. It provides demographicspecific impressions, rating points, and reach & frequency measures for over a million pieces of out of 

home inventory. https://geopath.org. 

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connection), which ran on Pandora with 30-second spots. In many instances, a digital banner 

advertisement appeared while the audio spot was aired, allowing a user to click on the banner and be 

taken to the dedicated case website. Over 1.6 million streaming audio impressions ran. 

I. TELEVISION 

24. The Supplemental Finegan Declaration contains a complete description of the Debtors 

efforts to notice potential claimaints via 30-second commercials on local broadcast, local cable, and 

nationwide cable television. 

25. Local Broadcast TV. A total of 2,010 commercials aired across approximately 14 local 

broadcast television stations, generating approximately 32,037,000 impressions to potential claimants in 

Lake, Sonoma, Napa, Mendocino, Nevada, Butte, and Humboldt counties. The commercials aired across 

a variety of dayparts,13 including morning, daytime, early news, and prime/syndicated prime to reach 

potential claimants with differing television viewing habits. 

26. Local Cable TV. 2,025 commercials aired on local cable channels and generated 

approximately 8,535,909 impressions to expand awareness of the Bar Date to potential claimants and 

other parties. Attached as Exhibit I to the Supplemental Finegan Declaration is a list of the local and 

cable stations in each market utilized by the Supplemental Notice Plan. 

27. Nationwide Cable TV. To reach those claimants who may have moved within the last 

four years, 59 nationwide cable television commercials aired across CNN, FOX NEWS, History Channel 

and TNT networks resulting in 105,427,161 impressions. 

J. ADDITIONAL METHODS OF OUTREACH 

28. In addition to paid media outlets, the Supplemental Notice Plan employed earned media 

and various avenues of public relations to amplify awareness of the Bar Date. 

29. The Supplemental Finegan Declaration provides a complete description of the Debtors’ 

additional outreach through earned media, community outreach, temporary housing outreach, and efforts 

at the Paradise Revival Festival. 

                                                      

13 A “daypart” is a term traditionally used when buying television but is also used for radio; it is a block 

of time that divides the day into segments for purchase, scheduling and delivery (e.g., primetime, or for 

radio “drive time”). The dayparting method is often used to tailor content to specific audiences 

throughout the day. 

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K. ONLINE QUALITY CONTROL - ADVERTISEMENT FRAUD 

IDENTIFICATION, MITIGATION AND REPORTING 

30. As described in my Original Declaration, the Debtors’ Supplemental Notice Plan 

incorporated state of the art quality control mechanisms to ensure that the Debtors’ online advertisements 

were properly targeted to real websites where actual humans are likely to visit, rather than serving 

advertisements to websites and fraudsters that attempt to steal advertising revenue from the campaign 

(thereby depriving actual Fire Claimants of their opportunity to see the Bar Date Notice). 

31. The Supplemental Notice Plan included in-advertisement, log, and site level monitoring 

and management, utilizing one of the leading cyber security advertisement fraud expert service providers 

in the country. I am pleased to report to the Court that less than one percent invalid impressions was 

detected in this campaign, which is a remarkable achievement even when compared to large brand 

campaigns. This invalid traffic has been excluded from the final reach calculations.

V. CONCLUSION 

32. In my opinion, the robust and comprehensive outreach efforts employed for the Debtors’ 

Noticing Procedures, including the Supplemental Notice Plan, are unmatched in any chapter 11 case. 

The efforts reflected a particularly appropriate, highly targeted, efficient and modern way to provide 

notice to potential claimants. The Debtors’ Supplemental Notice Plan was broad and multi-faceted and 

more than achieved its goal of maximizing reach to the target audiences. 

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Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury, that the foregoing is true 

and correct to the best of my knowledge, information, and belief. Executed on January 14, 2020, in 

Tigard, Oregon. 

Jeanne C. Finegan

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