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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)

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 for 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

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

MOTION TO FILE REDACTED 

DECLARATION OF JAMES 

DRINKHALL IN SUPPORT OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS’ MOTION PURSUANT TO 

11 U.S.C. §§ 105(a) AND 501 AND FED. R. 

BANKR. P. 3003(c) FOR ENTRY OF AN 

ORDER EXTENDING THE BAR DATE

Date: November 13, 2019

Time: 9:30 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

□ 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: 19-30088 Doc# 4316 Filed: 10/18/19 Entered: 10/18/19 16:29:01 Page 1 of

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SAN FRANCISCO

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The Official Committee of Tort Claimants (the “TCC”), by and through its undersigned 

counsel, hereby submits this motion (“Redaction Motion”) pursuant to sections 105(a) and 107(b) 

of title 11 of the United States Code (the “Bankruptcy Code”), Rule 9018 of the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 1001-2(a) of the Bankruptcy Local Rules 

for the United States District Court for the Northern District of California (the “Bankruptcy Local 

Rules”) and the New District Wide Procedures for Electronically Filing Sealed and Redacted 

Documents adopted by the United States Bankruptcy Court for the Northern District of California 

(the “Local Procedures”) for entry of an order authorizing the TCC to file a redacted Declaration 

of James Drinkhall (“Drinkhall Declaration”) in Support of the TCC’s motion to extend the bar 

date (“Bar Date Motion”).

In support of this Redaction Motion, the TCC submits the Declaration of David J. 

Richardson filed contemporaneously herewith. A proposed form of order granting the relief 

requested herein is annexed as Exhibit A. 

MEMORANDUM AND POINTS OF AUTHORITIES

I. JURISDICTION

The Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 1334. Venue 

is proper under 28 U.S.C. §§ 1408 and 1409. This Redaction Motion is a core proceeding under 28 

U.S.C. § 157(b)(2).

II. BASIS FOR RELIEF REQUESTED

Section 105(a) of the Bankruptcy Code allows a court to “issue any order . . . that is 

necessary or appropriate to carry out the provisions of the title.” 11 U.S.C. § 105(a). Section 107(c) 

further provides that a court may “protect an individual, with respect to the following types of 

information to the extent the court finds that disclosure of such information would create undue 

risk of identity theft or other unlawful injury to the individual or the individual’s property: (A) Any 

means of identification . . . .” The Bankruptcy Rules similarly authorize the Court to “require 

redaction of additional information” for cause. Bankruptcy Rule 9037.

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ATTORNEYS AT LAW

SAN FRANCISCO

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Finally, Local Procedures require that a request to redact portions of a document be 

narrowly tailored to sealable materials. New District Wide Procedures for Electronically Filing 

Sealed and Redacted Documents.

The TCC seeks to redact the names of the individual fire victims whose stories are related 

in the Drinkhall Declaration. These names are being redacted to avoid disturbing individual fire 

victims’ privacy. These fire victims provided detailed private information pertaining to certain 

impairments that have constrained their respective ability to comply with the claims bar date in 

these Cases, and have shared such private information for the benefit of all fire victims. Their 

individual identity is not relevant or necessary for the general public to understand the points made 

in the Bar Date Motion. Contemporaneously herewith, the TCC is sending a confidential 

unredacted Drinkhall Declaration to the Debtors. 

III. NOTICE

Notice of this motion is being provided in accordance with the Second Amended Order 

Implementing Certain Notice and Case Management Procedures, entered on May 14, 2019 [Docket 

No. 1996]. 

WHEREFORE, the TCC respectfully requests that the Court grant the Redaction Motion 

and allow the TCC to file the redacted Drinkhall Declaration.

Dated: October 18, 2019

BAKER & HOSTETLER LLP

By: /s/ David J. Richardson

David J. Richardson

Counsel for The Official Committee of Tort 

Claimant

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