1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

017558.0085\5686177.1

DIEMER & WEI, LLP

Kathryn S. Diemer (#133977)

100 West San Fernando Street, Suite 555

San Jose, CA 95113

Telephone: 408-971-6270

Facsimile: 408-971-6271

Email: kdiemer@diemerwei.com

WILLKIE FARR & GALLAGHER LLP

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Benjamin P. McCallen (pro hac vice)

787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

 jminias@willkie.com

 bmccallen@willkie.com 

Counsel for Ad Hoc Group of Subrogation

Claim Holders

UNITED STATES BANKRUPTCYCOURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

- and -

PACIFIC 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)

Case No. 19-30088

Chapter 11

(Lead Case)

(Jointly Administered)

ORDER RE: THE PRODUCTION OF 

CURRENT CONTACT INFORMATION 

FOR INSUREDS

Signed and Filed: December 11, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

December 11, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 5075 Filed: 12/11/19 Entered: 12/11/19 16:12:33 Page 1 of

5
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

017558.0085\5686177.1 1

The Court, having considered the Stipulation Re: the Production of Current Contact 

Information for Insureds (the “Stipulation”),1entered into by the Official Committee of Tort 

Claimants (the “TCC”), Michael Kasolas as the claims representative appointed to assist

wildfire victims who have not yet filed proofs of claim (the “Claims Representative”) and 

the Ad Hoc Group of Subrogation Claim Holders (the “Ad Hoc Subrogation Group”), filed 

on December 9, 2019 in connection with the above-captioned chapter 11 cases pending 

before the United States Court for the Northern District of California (the “Chapter 11 

Cases”), pursuant to such stipulation and agreement of the Parties, and good cause appearing,

IT IS HEREBY ORDERED THAT:

1. The Stipulation is granted.

2. The Additional Information will be shared only with counsel for the TCC, the 

TCC’s professionals retained in these bankruptcy cases, or the Claims Representative, and the 

Claims Representative’s support staff, vendors or professionals for the Requested Purposes. 

Any documents or spreadsheets produced that contain the Additional Information for 

Requested Purposes shall be designated “PROFESSIONAL EYES ONLY” for TCC Counsel, 

professionals, and the Claims Representative. 

3. The TCC and the Claims Representative agree that the Ad Hoc Subrogation 

Group will receive drafts of any notifications they plan to send to insureds using the Additional 

Information or any scripts of phone calls, and that the Ad Hoc Subrogation Group will have an 

opportunity to review and comment on those drafts. 

4. The TCC and the Claims Representative agree that no more than two emails 

will be sent to each insured using the Additional Information and no more than two phone calls

or text messages will be made to each insured using the Additional Information regardless of 

whether a response is received from the insured. The TCC and the Claims Representative shall 

make a good faith effort to reduce potential harassment, limit automated calls, and make calls 

by live phone operators where it is feasible to do so, including by unmasking the phone 

number used to make the phone calls or text messages.

 

1 Capitalized terms used and not defined herein shall have the meaning ascribed to them in the Stipulation.

Case: 19-30088 Doc# 5075 Filed: 12/11/19 Entered: 12/11/19 16:12:33 Page 2 of

5
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

017558.0085\5686177.1 2

5. The TCC and the Claims Representative shall make a good faith effort to limit 

any communications sent to insureds using the Additional Information to only those insureds 

who have not yet filed a proof of claim.

6. The Additional Information will not be shared with counsel for the individual 

plaintiffs, the interests of which are represented by the TCC.

7. The Additional Information will be used solely for the Requested Purposes and 

will not be used for any other purpose, including but not limited to attorney advertisement, 

telemarketing, solicitations, or promoting claims against insurers. 

8. Given, among other things, (i) the short time period remaining until the Bar 

Date, (ii) the burden that would be imposed on the TCC or the Claims Representative to 

attempt to obtain the Additional Information from other sources, (iii) the limited number of

sources available other than the members of the Ad Hoc Subrogation Group to obtain this 

information, and (iv) the potential harm to fire victims who do not file proofs of claim by the 

Bar Date, the Court accordingly finds that a compelling need exists to order the production of

this Additional Information from the members of the Ad Hoc Subrogation Group that 

outweighs any privacy interest the insureds may have in that Additional Information. 

9. The members of the Ad Hoc Subrogation Group will undertake reasonable 

efforts to provide such Additional Information and shall not be held responsible in any way if 

any of the Additional Information is incorrect or incomplete. The Ad Hoc Subrogation Group

reserves all rights to object to any additional requests for insured information on any and all 

grounds.

10. In agreeing to provide the Additional Information pursuant to the Stipulation 

and pursuant to this Order, the members of the Ad Hoc Subrogation Group act reasonably, in 

good faith and are advancing and protecting the interests of their insureds.

11. Nothing in the Stipulation or this Order approving the Stipulation shall diminish 

or alter the obligations of the members of the Ad Hoc Subrogation Group set forth in the Order 

(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 (Dkt. No. 2806) entered on July 1, 2019, 

Case: 19-30088 Doc# 5075 Filed: 12/11/19 Entered: 12/11/19 16:12:33 Page 3 of

5
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

017558.0085\5686177.1 3

which obligations remain in full force and effect.

12. This Court shall retain jurisdiction to hear and determine all matters arising 

from or related to the implementation, interpretation or enforcement of this Order.

APPROVED AS TO FORM AND CONTENT:

Dated: December 9, 2019

WILLKIE FARR & GALLAGHER LLP

787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

 jminias@willkie.com

 bmccallen@willkie.com

 jdavis@willkie.com

 ayanez@willkie.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

 /s/ Benjamin P. McCallen

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Benjamin P. McCallen (pro hac vice)

Joseph G. Davis

Antonio Yanez, Jr. (pro hac vice)

Case: 19-30088 Doc# 5075 Filed: 12/11/19 Entered: 12/11/19 16:12:33 Page 4 of

5
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

017558.0085\5686177.1 4

Counsel to the Official Committee of Tort Claimants

 WENDEL ROSEN LLP

 /s/ Lisa Lenherr

Mark S. Bostick

Lisa Lenherr

Counsel to Michael G. Kasolas

Claims Representative

** END OF ORDER **

BAKER & HOSTETLER LLP

 /s/ David J. Richardson

Kimberly S. Morris (SBN 249933)

Cecily A. Dumas (SBN 111449)

Robert A. Julian (SBN 88469)

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: 628.208.6434

Facsimile: 310.820.8859

Email: kmorris@bakerlaw.com

Email: cdumas@bakerlaw.com

Email: rjulian@bakerlaw.com

Eric E. Sagerman (SBN 155496)

David J. Richardson (SBN 168592)

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: drichardson@bakerlaw.com

Email: lattard@bakerlaw.com

Case: 19-30088 Doc# 5075 Filed: 12/11/19 Entered: 12/11/19 16:12:33 Page 5 of

5