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BAKER 

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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

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

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

Counsel to the Official Committee of Tort 

Claimants

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice)

(pzumbro@cravath.com)

Kevin J. Orsini (pro hac vice)

(korsini@cravath.com)

Omid H. Nasab (pro hac vice)

(onasab@cravath.com)

825 Eighth Avenue

New York, NY 10019

Tel: 212 474 1000

Fax: 212 474 3700

Attorneys for Debtors and Debtors in 

Possession

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)

ORDER EXTENDING BAR DATE FOR 

FIRE CLAIMANTS AND APPOINTING 

CLAIMS REPRESENTATIVE

Re: Docket No. 4292

No Hearing Requested

Signed and Filed: November 11, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

November 12, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 4672 Filed: 11/11/19 Entered: 11/12/19 07:47:34 Page 1 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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The Court having considered the Stipulation Between Debtors and Official Committee of 

Tort Claimants to Extend Bar Date for Fire Claimants and Retain Claims Representative, dated 

November 8, 2019 (the “Stipulation1”), and pursuant to such Stipulation and agreement of the 

Parties, and good cause appearing, 

IT IS HEREBY ORDERED THAT:

1. The Stipulation is hereby approved.

2. The Original Bar Date will be extended solely for the benefit of Unfiled Fire 

Claimants2 to December 31, 2019 at 5:00 p.m. (Prevailing Pacific Time) (the “Extended Bar 

Date”).

3. The Court appoints Michael G. Kasolas to serve as a special claims representative 

for the benefit of Unfiled Fire Claimants (the “Claims Representative”) nunc pro tunc to 

November 1, 2019. The Claims Representative shall be given broad discretion to conduct his tasks 

for the benefit of Unfiled Fire Claimants and shall be tasked with (the “Tasks”):

(i) identifying and locating Unfiled Fire Claimants and implementing procedures to 

provide notice of the Extended Bar Date to Unfiled Fire Claimants; 

(ii) establishing and implementing procedures to inform and educate Unfiled Fire 

Claimants about their rights to file Fire Claims by the Extended Bar Date, and 

implementing reasonable methods to reach Unfiled Fire Claimants to inform them 

of the Extended Bar Date and how to file Fire Claimants Proof of Claim Forms on 

account of any Fire Claims; 

(iii) assisting Unfiled Fire Claimants with the process of filing Fire Claimants’ Proof of 

Claim Forms in these cases, including coordinating with Prime Clerk LLP (“Prime 

Clerk”) who will be independently setting up locations within the fire zone areas 

where Prime Clerk representatives shall receive Proof of Claim Forms; and

 1 Capitalized terms used but not herein defined have the meanings ascribed to such terms in the 

Stipulation.

2 For purposes of this Order, “Unfiled Fire Claimants” means any non-governmental Fire 

Claimants who have not filed Proofs of Claim by the October 21, 2019 Original Bar Date.

Case: 19-30088 Doc# 4672 Filed: 11/11/19 Entered: 11/12/19 07:47:34 Page 2 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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(iv) periodically reporting to both this Court and to Judge Donato on progress and 

results.

4. The Claims Representative will have the authority to engage staff, personnel, 

vendors (including but not limited to media/advertising, project management services, technology 

solutions, public relations, and other consultants), and counsel (collectively the “Team”) to assist 

in the implementation of the Tasks. 

5. The reasonable and documented fees and expenses of the Claims Representative and 

any of his Team shall be allowed administrative expenses of the Debtors’ estates and paid by the 

Debtors in the ordinary course of business, without further application to or order of the Court, 

upon receipt of invoice. If any dispute arises relating to any invoice, the parties shall meet and 

confer in an attempt to resolve the dispute and, if resolution is not achieved, the matter shall be 

resolved by the Court. The Claims Representative shall not be personally responsible or liable for 

the fees and expenses of his Team, and may apply to the Court for approval of advance fees or costs 

if deemed necessary in order to successfully complete the Tasks. The Claims Representative and 

his Team will not act as an agent or representative of the Debtors and, accordingly, the Debtors 

shall have no responsibility or liability for, and no obligations to indemnify or hold harmless the 

Claims Representative or his Team for any acts or omissions whatsoever. In addition, the Claims 

Representative and his Team will not owe any duty to any Unfiled Fire Claimants (whether known 

or unknown) that are unable to be located or who do not file a claim, nor shall the Claims 

Representative and his Team have any duty to represent Unfiled Fire Claimants who file Proofs of

Claim or to defend their claims once filed. In order to avoid duplication of efforts, the Claims 

Representative and his Team may capitalize and build upon the work conducted in the Wildfire 

Assistance Program and the Notice Procedures, including the Supplemental Notice Plan. The 

Claims Representative and his Team, acting within the course and scope of their agency and 

representation, are entitled to rely on all outstanding rules of law and Orders of this Court, and the U.S. 

District Court for the Northern District of California, and shall not be liable to anyone for their good 

faith compliance with any Order, rule, law, judgment or decree. In no event shall the Claims 

Representative or his Team be liable to anyone for their good faith compliance with their respective 

Case: 19-30088 Doc# 4672 Filed: 11/11/19 Entered: 11/12/19 07:47:34 Page 3 of

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duties and responsibilities as the Claims Representative or Team, nor shall the Claims Representative 

or Team be liable to anyone for any actions taken or omitted by them, in each case, except upon a 

finding of this Court that they acted or failed to act as a result of malfeasance, bad faith, intentional 

misconduct, or reckless disregard of their respective duties.

6. The Claims Representative and his Team will consult with the TCC, Debtors, and 

Prime Clerk to maximize the effectiveness of the Extended Bar Date while avoiding undue 

duplication of efforts and to minimize costs. Prime Clerk will cooperate with the Claims 

Representative, including by responding to reasonable claims-related information requests. 

7. Notwithstanding anything herein to the contrary, Fire Claimant Proof of Claim 

Forms must be submitted in accordance with the procedures and in the manner set forth in the Bar 

Date Order; except that (i) Unfiled Fire Claimants shall have until the Extended Bar Date to submit 

their claims in accordance with the procedures set forth in the Bar Date Order; (ii) Prime Clerk may 

receive Proof of Claim Forms from Unfiled Fire Claimants at the locations established within the 

fire zones pursuant to Paragraph 3(iii) above; and (iii) the Claims Representative may, at his 

discretion, utilize the claims filing system implemented between Prime Clerk and BrownGreer for 

storage and uploading of completed Proof of Claim Forms under Paragraph 3 of the Order re: the 

Production of the BrownGreer Database [Dkt. 3922].3

8. The Claims Representative shall be permitted to seek to obtain information 

necessary from any of the various parties including the TCC, the Debtors, and the Ad Hoc 

Subrogation Group. The Claims Representative will be deemed a “Receiving Party” entitled to

receive and review materials designated in discovery in these cases as Highly Confidential or 

Professional Eyes Only, pursuant to Section 7.3 of the Confidentiality and Protective Order dated 

August 8, 2019 [Dkt. 3405], as well as to receive and review any materials designated with lessprotected designations, such as “Confidential” or “Contractor Confidential,” solely for the purpose 

of contacting or providing notice to Unfiled Fire Claimants for the purposes of this Stipulation. 

 3 The Claims Representative’s access to filed claim data is limited to helping to identify Unfiled 

Fire Claimants by running comparisons with other data sources. The Claims Representative’s 

appointment is limited to Unfiled Fire Claimants and nothing in this Order shall be construed to 

expand the Claims Representative’s responsibilities to Filed Claimants or those claimants 

represented by counsel.

Case: 19-30088 Doc# 4672 Filed: 11/11/19 Entered: 11/12/19 07:47:34 Page 4 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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The Claims Representative will also be subject to all other terms of the Confidentiality and 

Protective Order pertaining to the protection and disposition of Protected Materials. Parties in these 

cases who are in possession of Protected Materials containing information about Unfiled Fire 

Claimants that may assist the Claims Representative in his duties may produce such Protected 

Materials to the Claims Representative under the terms of the Confidentiality and Protective Order.

9. The Claims Representative’s appointment will terminate at 5:00 p.m. Pacific 

Standard Time on January 20, 2020, to enable the Claim Representative to file a report with the 

Court, and the Claims Representative will be released from its duties and obligations described in 

this Stipulation other than with respect to maintaining confidentiality as set forth in Paragraphs 7 

and 8 hereof. Promptly following the termination of the Claim Representative’s appointment, the

Claims Representative shall, and shall cause all of his Team to, return all confidential materials 

received pursuant to Paragraph 8 above to the producing party. 

10. The Parties understand and agree that nothing herein nor the existence, or act of 

entering into, this Stipulation shall constitute or be construed as an admission or evidence of any 

fault, improper action, inadequacy, insufficiency, or any other legal inference or otherwise with 

respect to the Notice Procedures, the Supplemental Notice Plan, or the Debtors’ efforts generally 

to provide notice of the Bar Date and related procedures to known and unknown claimants, 

including Known and Unknown Fire Claimants, as approved by the Court pursuant to, and in 

accordance with, the Bar Date Order. 

11. Upon execution of this Stipulation, the hearing on the Bar Date Extension Motion 

shall automatically be deemed adjourned (with the Debtors’ deadline to file any response or 

objection to the Bar Date Extension Motion extended) pending approval of this Stipulation by the 

Court. 

12. Promptly following entry of this Order, the Bar Date Extension Motion shall be 

withdrawn.

13. The Bankruptcy Court retains jurisdiction to resolve any disputes or controversies

arising from the Stipulation.

**END OF ORDER**

Case: 19-30088 Doc# 4672 Filed: 11/11/19 Entered: 11/12/19 07:47:34 Page 5 of

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