ATTACHMENT B 

Case: 19-30088 Doc# 3687-2 Filed: 08/25/19 Entered: 08/25/19 17:42:04 Page 1

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+1-212-474-1596

korsini@cravath.com

August 24, 2019

PG&E Chapter 11 Proceedings, No. 19-30088 N.D. Cal. 

Dear Counsel, 

I write in response to the TCC’s August 22, 2019, letter attaching the 

TCC’s First Set of Interrogatories to the Debtors and the TCC’s Statement Regarding 

August 27, 2019 Status Conference on Estimation (the “August 23 Statement”) that you 

filed with the Court yesterday.

1

First, as you well know, the parties cannot continue to delay proceeding

with an estimation process. It is imperative that the parties determine the structure and 

schedule of that process as soon as practicable. We have set forth a detailed proposal 

about how we think the process should work, how long it should take, on which fires we 

should focus and how many witnesses might be required. To date, neither the TCC nor 

any other stakeholder has offered an alternative approach. Nor have you even suggested 

why you might believe our approach is inefficient or could be improved upon. It is easy 

to say this case is complicated. But that does not justify failing to take a position and 

engaging in a constructive dialogue to move the process forward for the benefit of all 

 

1

In its August 20, 2019 Order Regarding Further Hearings On Estimation And Other 

Case Scheduling Matters (the “Order”), the Court instructed the parties to meet and 

confer and undertake “a full discussion among counsel as to what discovery will be 

necessary, and what is the timeframe, preparatory to the scheduling of the final 

estimation proceedings”. (Order at 3-8:10, 5:6-9.) In flagrant disregard of the Court’s 

Order, and less than one day after sending its August 22 letter, the TCC filed its August 

23 Statement without any attempt to meet and confer. We nevertheless remain willing 

and able to meet and confer with respect to the issues set forth in the Court’s Order and 

the August 23 Statement at any time prior to the August 27th conference. 

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stakeholders. We remain available to meet and confer regarding these critical issues at 

your convenience.

Second, the TCC’s position that it cannot engage in discussions about how 

to structure an estimation process until it knows more about the disputed issues is 

specious. These are the TCC’s claims. The TCC is asserting the Debtors are liable under 

various state common law and statutory provisions. The claimants, including the tort 

lawyers who litigated these cases for years, obviously understand what the elements of 

those claims are. They understand what proof is required, at least in a state court trial. 

We have stated we will not challenge causation for the purpose of estimation with respect 

to any trials other than Tubbs. Everything else is disputed. 

For example, the TCC is well aware of the Debtors’ theory on inverse 

condemnation being inapplicable to investor-owned utilities. The Court has indicated 

that it will resolve that issue. (See Order Regarding Further Hearings on Estimation 

Motion and Other Case Scheduling Matters at 4:13-19.) The TCC also knows that a key 

issue in pursuing an inverse condemnation claim is proving that any PG&E power line

that may have started a fire was designed, constructed and operated for a public—rather 

than private—use. See Cantu v. Pac. Gas & Elec. Co., 189 Cal. App. 3d 160 (1987). 

(Opp. of the Official Committee of Tort Claimants to the Debtors’ Motion Pursuant to 11 

U.S.C. §§ 105(a) and 502(c) For The Establishment of Wildfire Claims Estimation 

Procedures, App. B at 3.) This will be an issue that the parties will need to address for at 

least the Adobe, Cascade, Cherokee, Honey, La Porte, Lobo, Nuns, Oakmont, Partrick 

and Point fires. 

The TCC has expressed apparent confusion with respect to the intersection 

between causation and liability as to negligence claims. But the Debtors’ position is 

clear. Even if the Debtors do not contest (for purposes of estimation) that their 

equipment caused a particular wildfire, the Debtors do not concede that any negligence 

on their part contributed to the cause. For example, the Debtors do not contest (for 

purposes of estimation) that the Redwood fire ignited when excessive winds caused a 

large branch to break and fall into a PG&E conductor. The Debtors maintain, however, 

that the subject branch was healthy and well outside of the clearance zone required by 

state law, and that their vegetation management program adequately inspected and 

maintained the vegetation at issue. It will be the TCC’s burden to prove otherwise. 

To the extent the TCC believes that it can satisfy the wildfire claimants’ 

burden of proof by demonstrating systemic deficiencies with the Debtors’ overall 

maintenance programs (e.g., vegetation management), that is incorrect. The relevant 

inquiry for purposes of the Debtors’ liability is whether any alleged deficiencies in their

programs can actually be linked to a particular wildfire ignition. As the Court of Appeal 

concluded in the Butte litigation, a plaintiff must demonstrate that the Debtors’ alleged 

negligence contributed to the wildfire. (See Pac. Gas & Elec. Co. v. Superior Court, 24 

Cal. App. 5th 1150, 1167 (2018) (“Plaintiffs also submitted expert opinion evidence that 

the audits performed by the quality assurance department and quality control program 

were scientifically unreliable. . . . There was, however, no showing that PG&E’s audit 

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methodology contributed to the Butte fire.”).) The fact that a particular branch may have 

hit a particular line and started a particular fire does not establish negligence. Nor do 

generalized complaints about the Debtors’ vegetation management program. Instead, the 

claimants will have to establish at estimation that they have a likelihood of success on a 

claim that alleged failures of PG&E’s systems and practices contributed to the failure of a 

specific limb or tree, and that such failures resulted in a violation of the standard of care.

Finally, citing to California state law doctrines of res ipsa loquitur and 

negligence per se, you state that “Debtors’ admission that their equipment caused the 

fires . . . places the burden on the Debtors to explain and prove they were not liable for 

the fires”, (August 23 Statement at 2.) This statement mischaracterizes the Debtors’ 

position and is wrong as a matter of law. The Debtors have not admitted that their 

equipment caused any of the wildfires at issue in this case. Rather, in an effort to 

facilitate the estimation process and ensure maximum efficiency, the Debtors have 

merely agreed not to contest causation (except with respect to the Tubbs fire) for 

purposes of the estimation process. As the Court has stated repeatedly and you are well 

aware,

2

estimation of claims under Bankruptcy Code Section 502(c) is unique to the 

bankruptcy process, and the Debtors’ agreement was expressly limited to that specific 

context and that specific purpose. 

Further, even if the Debtors had conceded causation for any purposes 

other than Section 502(c) estimation proceedings (which they did not), it is not the case 

that the burden of proof would shift to the Debtors. As the Court made clear in Howe v. 

Seven Forty Two Co., 189 Cal. App. 4th 1155, 1162-63 (2010), res ipsa loquitur is a 

rebuttable presumption that shifts the burden of production “when the predicate facts are 

established to give rise to the presumption”; it does not affect the burden of proof, which 

remains with the plaintiff. Likewise, in Mata v. Pac. Gas & Elec. Co., the court merely 

states that the doctrine of negligence per se may apply under certain circumstances where 

a defendant has been shown to have violated the law. 224 Cal. App. 4th 309 (2014), as 

modified on denial of reh’g (Mar. 26, 2014). But the Debtors have not admitted to 

violating any law with respect to any of the relevant wildfires (even for purposes of 

estimation). 

Third, the urgent task at hand is establishing an appropriate schedule for 

the estimation proceedings that the Court and all stakeholders (including the TCC) agree 

needs to occur to successfully resolve these Chapter 11 cases. Since, however, the TCC 

seems to believe that it needs to understand the Debtors’ factual and legal positions prior 

to the commencement of discovery or setting a schedule for the estimation process, we 

refer you to the documents set forth in Appendix A. Appendix A includes:

 

2

See, e.g., Hr’g Tr. Aug. 14, 2019 at 106:11-16 (“Court: But in a – in some of the 

large cases that you or your colleagues have been involved, there’s no counterpart. 

502(c) exists all by itself in the bankruptcy world, right? Mr. Pitre: There’s no 

counterpart -- Court: Yeah.”).

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· Almost 300 pages of detailed factual reports about each of the 2017 

and 2018 wildfires in dispute, setting forth the Debtors’ position with 

respect to each wildfire ignition as well as a detailed timeline of all 

prior inspections and patrols of the particular area at issue (e.g., 

vegetation management inspections, overhead patrols). The Debtors 

also indicate for each inspection whether the subject vegetation or 

equipment required any maintenance (e.g., pruning vegetation or 

electrical equipment repair).3

· The Debtors’ responses to more than 800 interrogatories (both form 

and special interrogatories) in the 2017 Wildfires state court 

coordinated proceeding. These interrogatory responses explicitly 

address the general facts and theories underlying the Debtors’ 

defenses, including any witnesses or documents that Debtors may use 

in support of those defenses. For example, the Debtors set forth in 

detail the facts and documents that support their defense that “any 

nuisance or trespass on land were unintentional and non-negligent”. 

(Pacific Gas and Electric Company and PG&E Corporation’s 

Responses and Objections to All Plaintiffs’ Joint Special 

Interrogatories, Set Two, Related to Atlas Fire No. 25 (“PG&E 

routinely inspects and monitors every mile of its approximate 100,000 

miles of PG&E overhead electric and transmission line each 

year . . . .”).) 

We have placed all of the documents set forth on Appendix A on an FTP 

with the following credentials:

· Globalscape URL: 

· Username: 

· Password: 

Please do not hesitate to reach out if you have any questions.

 

3 These reports reference a significant volume of data, documents and testimony. In 

preparing these reports, the Debtors gathered information from at least the following 

sources: (1) formal third-party witness discovery in the 2017 Wildfires litigation 

(including, for example, third party depositions); (2) materials identified in the Debtors’ 

files as part of their ongoing investigations or response to litigation discovery requests; 

and (3) information that the Debtors have obtained from discussions with their own 

employees. 

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Regards,

/s/ Kevin J. Orsini

Kevin J. Orsini

Robert A. Julian, Esq.

Cecily Dumas, Esq.

 Baker Hostetler

11601 Wilshire Boulevard, Suite 1400

Los Angeles, CA 90025

Copy to (via email):

Matthew A. Feldman, Esq.

Benjamin P. McCallan, Esq. 

Wilkie Farr & Gallagher LLP

787 Seventh Ave. 

Washington, DC 20006 

Andrew LeBlanc, Esq.

Samir Vora, Esq.

 Milbank LLP

1850 K Street, NW, Suite 1100

Washington, DC 20006

Stephen Karotkin, Esq. 

Jessica Liou, Esq. 

Weil, Gotshal & Manges LLP

767 Fifth Ave. 

New York, NY 10153

Paul J. Pascuzzi, Esq.

Felderstein, Fitzgerald, Willoughby & Pascuzzi LLP

500 Capitol Mall, Suite 2250

Sacramento, CA 95819 

Michael A. Kelly, Esq.

Walkup, Melodia, Kelly & Schoenberger

650 California Street, 26th Floor

San Francisco, CA 94108

Frank Pitre, Esq.

Cotchett, Pitre & McCarthy, LLP

840 Malcolm Road, Suite 200

Burlingame, CA 94010

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Steven M. Campora, Esq.

Dreyer Babich Buccola Wood Campora, LLP

20 Bicentennial Cir.

Sacramento, CA 95826

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Appendix A

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I. Fact Summaries & Supplemental Fact Summaries

Fire Docket # Date Description

-- 956-2 12/31/2018 Glossary of Terms in Fact Summaries

-- 956-3 12/31/2018 Guide to Reviewing Fact Summaries

37 956-53 12/31/2018 37 Incident Description & Factual Summary 

Adobe

956-12 12/31/2018 Adobe Incident Description & Factual Summary

956-31 12/31/2018 Supplement to Adobe Incident Description & Factual 

Summary

Atlas

956-13 12/31/2018 Atlas Incident Description & Factual Summary

956-32 12/31/2018 Supplement to Atlas Incident Description & Factual 

Summary

Blue 956-33 12/31/2018 Blue Incident Description & Factual Summary

Camp 956-1 12/31/2018 Camp Incident Description & Factual Summary

Cascade

956-14 12/31/2018 Cascade Incident Description & Factual Summary

956-34 12/31/2018 Supplement to Cascade Incident Description & Factual 

Summary

Cherokee

956-15 12/31/2018 Cherokee Incident Description & Factual Summary

956-35 12/31/2018 Supplement to Cherokee Incident Description & Factual 

Summary

Honey

956-16 12/31/2018 Honey Location Fact Report

956-36 12/31/2018 Supplement to Honey Location Fact Report

LaPorte

956-17 12/31/2018 LaPorte Incident Description & Factual Summary

956-37 12/31/2018 Supplement to LaPorte Incident Description & Factual 

Summary

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Fire Docket # Date Description

Lobo

956-18 12/31/2018 Lobo Incident Description & Factual Summary

956-38 12/31/2018 Supplement to Lobo Incident Description & Factual 

Summary

Maacama

956-19 12/31/2018 Maacama Incident Description & Factual Summary

956-39 12/31/2018 Supplement to Maacama Incident Description & Factual 

Summary

McCourtney

956-20 12/31/2018 Orion Way & McCourtney Road Incident Description & 

Factual Summary

956-40 12/31/2018 Supplement to McCourtney Incident Description & 

Factual Summary

Norrbom

956-21 12/31/2018 Norrbom Incident Description & Factual Summary

956-41 12/31/2018 Supplement to Norrbom Incident Description & Factual 

Summary

Nuns

956-22 12/31/2018 Nuns Incident Description & Factual Summary

956-42 12/31/2018 Supplement to Nuns Incident Description & Factual 

Summary

Oakmont

956-23 12/31/2018 Oakmont Incident Description & Factual Summary

956-43 12/31/2018 Supplement to Oakmont Incident Description & Factual 

Summary

Partrick

956-24 12/31/2018 Partrick Incident Description & Factual Summary

956-44 12/31/2018 Supplement to Partrick Incident Description & Factual 

Summary

Pocket

956-25 12/31/2018 Pocket Incident Description & Factual Summary

956-45 12/31/2018 Supplement to Pocket Incident Description & Factual 

Summary

Point

956-26 12/31/2018 Point Incident Description & Factual Summary

956-46 12/31/2018 Supplement to Point Incident Description & Factual 

Summary

Potter

956-27 12/31/2018 Potter Valley Busch Rd. Incident Description & Factual 

Summary

956-47 12/31/2018 Supplement to Potter Valley Busch Road Incident 

Description & Factual Summary

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II. Responses and Objections to Plaintiffs’ Interrogatories 

PG&E’s Responses and Objections to Form Interrogatories

Fire Docket # Date Description

Pressley 956-48 12/31/2018 Pressley Incident Description & Factual Summary

Redwood

956-28 12/31/2018 Redwood Location Fact Report

956-49 12/31/2018 Supplement to Redwood Location Fact Report

Sullivan 956-50 12/31/2018 Sullivan Incident Description & Factual Summary

Sulphur

956-29 12/31/2018 Sulphur Incident Description & Factual Summary

956-51 12/31/2018 Supplement to Sulphur Incident Description & Factual 

Summary

Tubbs

956-30 12/31/2018 Tubbs Incident Description & Factual Summary

956-52 12/31/2018 Supplement to Tubbs Incident Description & Factual 

Summary

Set Date Description

1 4/16/2018 Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to Plaintiffs’ Form Interrogatories, Set One

1 7/13/2018 Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Plaintiffs’ Form Interrogatories, Set One

1 9/4/2018 Pacific Gas and Electric Company and PG&E Corporation’s Responses to 

Individual Plaintiffs’ Form Interrogatories, Related to Sulphur Fire

3 4/23/2018

Pacific Gas and Electric Company and PG&E Corporation’s Objections to 

All Plaintiffs’ Form Interrogatories, Set Three, Form Interrogatory Numbers 

14.1, 15.1 and 16.1

3 6/20/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Form Interrogatories, Set Three, Form 

Interrogatory Numbers 1.1, 4.1, 4.2, 12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 12.7 

and 14.2

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PG&E’s Responses and Objections to Form Interrogatories 17.1

Set Date Description

3 7/6/2018

Pacific Gas and Electric Company and PG&E Corporation’s Supplemental 

Responses and Objections to All Plaintiffs’ Form Interrogatories, Set Three, 

Form Interrogatory Numbers 4.1, 12.2

3 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Form Interrogatories, Set Three, Form 

Interrogatory Numbers 14.1, 15.1 and 16.1

3 7/20/2018

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to All Plaintiffs’ Form Interrogatories, Set Three, 

Form Interrogatory Numbers 12.2, 12.3, 12.4, 12.5, 12.6 and 12.7 

3 9/19/2018 Pacific Gas and Electric Company and PG&E Corporation’s Amended and 

Supplemental Response to All Plaintiffs’ Form Interrogatory No. 4.1

6 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Form Interrogatories, Set Six, Related to 

Lobo Fire

7 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Form Interrogatories, Set Seven, Related to 

McCourtney Fire

8 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Form Interrogatories, Set Eight, Related to 

Redwood Fire

Set Date Description

2 4/16/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses 

and Objections to Plaintiffs’ Form Interrogatories, Set Two, Related to 

Sullivan Fire

2 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Plaintiffs’ Form Interrogatories, Set Two, 

Related to Sullivan

4 9/12/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses 

and Objections to Plaintiffs’ Form Interrogatories, Set Four, Related to 

Sullivan Fire

5 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses 

and Objections to Plaintiffs’ Form Interrogatories, Set Five, Related to 

Sullivan Fire

5 1/28/2019

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Plaintiffs’ Form Interrogatories, Set Five, 

Related to Sullivan Fire

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PG&E’s Responses and Objections to Special Interrogatories

Set Date Description

1 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set One, Related to 

Tubbs Fire

2 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Two, Related to 

Atlas Fire

3 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Three, Related 

to Cascade Fire

4 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Four, Related 

to LaPorte Fire

5 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Five, Related to 

Cherokee Fire

6 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Six, Related to 

Honey Fire

7 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Seven, Related 

to Lobo Fire

8 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Eight, Related 

to Maacama Fire

9 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Nine, Related 

to McCourtney Fire

10 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Ten, Related to 

Nuns Fire

11 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Eleven, Related 

to Pocket Fire

12 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twelve, 

Related to Point Fire

13 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Thirteen, 

Related to Redwood Valley Complex Fire

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Set Date Description

14 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Fourteen, 

Related to Sulphur Fire

15 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Fifteen, Related 

to Sullivan Fire

16 7/13/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Sixteen, 

Related to 37 Fire

17 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Seventeen, 

Related to Tubbs Fire

18 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Eighteen, 

Related to Atlas Fire

19 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Nineteen, 

Related to Cascade Fire

20 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty, 

Related to La Porte Fire

21 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-One, 

Related to Cherokee Fire

22 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Two, 

Related to Lobo Fire

23 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Three, 

Related to McCourtney Fire

24 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Four, 

Related to Nuns Fire

25 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Five, 

Related to Pocket Fire

26 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Six, 

Related to Point Fire

27 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiffs’ Joint Special Interrogatories, Set Twenty-Seven, 

Related to Sulphur Fire

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Set Date Description

28 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Twenty-Eight, 

Related to Potter Valley Fire

29 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Twenty-Nine, 

Related to Adobe Fire

30 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty, Related 

to Oakmont Fire

31 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-One, 

Related to Partrick Fire

32 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses an 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-Two, 

Related to Norrbom Fire

33 8/1/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-Three, 

Related to All Fires

34 8/10/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 34, Related to 

the Tubbs Fire

35 9/12/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 35, Related to 

the Partrick Fire

36 9/12/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 36, Related to 

the Sullivan Fire

36 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to All Plaintiff’s Joint Special Interrogatories, Set 

36, Related to the Sullivan Fire

37 10/23/2018 Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special interrogatories, Set 37

38 10/23/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Thirty-Eight, 

Related to Sulphur Fire

39 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to Subrogation Plaintiff’s Special Interrogatories, Set 39, Related 

to the Sullivan Fire

39 1/28/2019

Pacific Gas and Electric Company and PG&E Corporation’s Amended 

Responses and Objections to Subrogation Plaintiff’s Special Interrogatories, 

Set 39, Related to the Sullivan Fire

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Set Date Description

40 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set Forty, Related 

to the Lobo Fire

41 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to all Plaintiff’s Joint Special Interrogatories, Set Forty-One, 

Related to McCourtney Fire

42 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation’s Responses and 

Objections to all Plaintiffs’ Joint Special Interrogatories, Set Forty-Two, 

Related to Redwood Fire

43 12/14/2018

Pacific Gas and Electric Company and PG&E Corporation Responses and 

Objections to All Plaintiff’s Joint Special Interrogatories, Set 43, Related to 

Tubbs Fire

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