EXHIBIT D

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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

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 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

NOTICE OF DEBTORS’ DESIGNATION 

OF CLAIMS FILED BY THE UNITED 

STATES OF AMERICA, THE STATE OF 

CALIFORNIA AND ADVENTIST 

HEALTH SYSTEM AS UNLIQUIDATED 

AND SUBJECT TO ESTIMATION 

UNDER SECTION 502(c) OF THE 

BANKRUPTCY CODE 

Date: December 17, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

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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PLEASE TAKE NOTICE that on January 29, 2019, PG&E Corporation and Pacific Gas 

and Electric Company, as debtors and debtors in possession (collectively, the “Debtors”) in the 

above-captioned chapter 11 cases, each filed a voluntary petition for relief under chapter 11 of title 

11 of the United States Code with the United States Bankruptcy Court for the Northern District of 

California (San Francisco Division) (the “Court”). 

PLEASE TAKE FURTHER NOTICE that on July 18, 2019, the Debtors filed Debtors’ 

Motion Pursuant to 11 U.S.C. §§ 105(a) and 502(c) for the Establishment of Wildfire Claims 

Estimation Procedures, (Dkt. 3091) (the “Estimation Motion”). The Estimation Motion sought 

to establish the framework under which the Debtors aggregate liability for all contingent and/or 

unliquidated claims arising out of the 2015, 2017 and 2018 Northern California Wildfires (the 

“Wildfires” and the “Wildfire Claims”1

). 

PLEASE TAKE FURTHER NOTICE that on August 21, 2019, the Court found that 

“[b]ecause it would be impossible to liquidate thousands of tort claims in a matter or months, or 

possibly years, [the Debtors] need[] to implement the bankruptcy procedure for estimation of its 

unliquidated claims for its reorganization purposes.” (Dkt. 3648, Recommendation for Withdrawal 

of Reference of Proceeding In Part at 3.) Judge James Donato of the United States District Court 

for the Northern District of California (the “District Court”), accepted the Court’s 

recommendation and ordered “the partial withdrawal of the reference of the Section 502(c) 

estimation of unliquidated claims arising from the . . . [W]ildfires.” (Dist. Ct. Dkt. 2, Order 

Adopting Recommendation for Withdrawal of Reference of Proceeding In Part; Order of 

Assignment at 1.) 

PLEASE TAKE FURTHER NOTICE that at the October 23, 2019 Omnibus Hearing, 

the Debtors discussed with the Court a briefing schedule on the issue of whether claims asserted by 

the United States of America (including any department, agency or instrumentality thereof, 

1 As used in this notice and the Estimation Motion, the terms “Wildfires” and “Wildfire

Claims” refer to the 2015 Butte Fire, the 2018 Camp Fire and the following 2017 North Bay 

Wildfires: (1) Adobe; (2) Atlas; (3) Blue; (4) Cascade; (5) Cherokee; (6) Highway 37; 

(7) Honey; (8) La Porte; (9) Lobo; (10) Maacama; (11) McCourtney; (12) Norrbom; (13) Nuns; 

(14) Oakmont/Pythian; (15) Partrick; (16) Pocket; (17) Point; (18) Potter/Redwood; (19) Pressley; 

(20) Sullivan; (21) Sulphur and (22) Tubbs. 

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the “U.S.A.”), the State of California, (including any department, agency or instrumentality thereof, 

the “State”), and Adventist Health System/West and Feather River Hospital d/b/a Adventist Health 

Feather River (“Adventist”) (collectively with the Debtors, the “Parties”), are unliquidated and 

subject to estimation under section 502(c) of title 11 of the United States Code (the “Bankruptcy 

Code”). (Oct. 23, 2019 Hr’g Tr. at 45:18-55:20.) 

PLEASE TAKE FURTHER NOTICE that on October 31, 2019, the Court entered the 

Order Establishing Pre-Confirmation Briefing and Hearing Schedule for Certain Legal Issues

(Dkt. No. 4540) (the “Order”). The Order requires the Debtors to file a designation on 

November 1, 2019, notifying the U.S.A., the State and Adventist, which of their asserted claims 

the Debtors contend are unliquidated and subject to estimation under section 502(c) of the 

Bankruptcy Code. (Dkt. No. 4540 at 2-3.) 

PLEASE TAKE FURTHER NOTICE that in accordance with the Order, the Debtors 

contend the following claims asserted by the U.S.A., the State and Adventist are unliquidated and 

subject to estimation: 

Entity2 Fire(s) Alleged Damages

Alleged Claim 

Amount

Federal Emergency 

Management 

System (FEMA)

Butte Public and individual 

assistance, 

administrative costs

$160,598,290.22

FEMA Camp Public and individual 

assistance, 

administrative costs

$2,552,285,006.62

FEMA North Bay Fires Public and individual 

assistance, 

administrative costs

$1,227,587,473.81

U.S. Department of 

Agriculture, Forest 

Service

El Portal Suppression costs 

and interest and 

penalties

$9,895,433.64

U.S. Department of 

Agriculture, Forest 

Service

El Portal Damage to public 

lands 

$19,466,029.49

2

 On information and belief of the Debtors, each entity listed (other than Adventist) is a 

department, agency or instrumentality of the U.S.A. or the State. 

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Entity2 Fire(s) Alleged Damages

Alleged Claim 

Amount

U.S. Department of 

Agriculture, Forest 

Service

Railroad Suppression costs $21,029,700.59

U.S. Department of 

Agriculture, Forest 

Service

Railroad Damage to public 

lands 

$76,554,779.95

U.S. Department of 

the Interior - 

Bureau of Land 

Management

Butte Damage to public 

lands 

$31,469,881.00

U.S. Department of 

the Interior - 

Bureau of Land 

Management

Butte Damage to public 

lands 

$31,469,881.00

U.S. Department of 

the Interior - 

Bureau of Land 

Management

Camp Damage to public 

lands 

$7,721,234.36

U.S. Department of 

the Interior - 

Bureau of Land 

Management

Murphy Suppression costs $81,167.00

U.S. Department of 

the Interior - 

National Park 

Service

Atlas Suppression costs $9,368.42

U.S. Department of 

the Interior - 

National Park 

Service

Butte Suppression costs $33,749.97

U.S. Department of 

the Interior - 

National Park 

Service

El Portal Suppression costs $3,763,144.49

U.S. Department of 

the Interior - 

National Park 

Service

Murphy Suppression costs $14,170.15

U.S. Department of 

the Interior - 

National Park 

Service

Railroad Suppression costs $90,415.07

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Entity2 Fire(s) Alleged Damages

Alleged Claim 

Amount

U.S. Department of 

the Interior - 

National Park 

Service

Tubbs Suppression costs $102,302.81

U.S. on behalf of 

its Environmental 

Protection Agency 

& Department of 

Interior 

N/A Future costs (labor, 

oversight, regulatory 

compliance) 

associated with 

cleanup of hazardous 

materials

Undetermined

U.S. Small 

Business 

Administration

Camp Administrative, travel 

and subsidy costs 

$27,774,829.00

U.S. Small 

Business 

Administration

North Bay Fires Administrative, travel 

and subsidy costs 

$11,641,027.00

Adventist Health 

System 

Camp Property damage, 

business loss, lost 

wages and earning 

capacity, punitive 

damages, attorney’s 

fees

$1,012,061,204

California 

Department of 

Developmental 

Services 

Camp, Nuns 

Norrbom 

Evaluation and care 

of individuals with 

developmental 

disabilities and 

property damage

$5,091,429.65

California 

Department of 

Forestry and Fire 

Protection

415 Suppression, 

administrative, 

accounting and 

investigation costs

$6,043.70

California 

Department of 

Forestry and Fire 

Protection

Almond Suppression, 

administrative, 

accounting and 

investigation costs

$20,546.16

California 

Department of 

Forestry and Fire 

Protection 

Atlas, Adobe, 

Norrbom, Nuns, 

Partrick, Pocket, 

Pressley, 

Pythian/Oakmont

Suppression, 

administrative, 

accounting and 

investigation costs 

$117,504,408.91

California 

Department of 

Forestry and Fire 

Protection

Benson Suppression, 

administrative, 

accounting and 

investigation costs

$125,730.70

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Entity2 Fire(s) Alleged Damages

Alleged Claim 

Amount

California 

Department of 

Forestry and Fire 

Protection

Bissett Suppression, 

administrative, 

accounting and 

investigation costs

$1,685.80

California 

Department of 

Forestry and Fire 

Protection

Blue Suppression, 

administrative, 

accounting and 

investigation costs

$172,621.03

California 

Department of 

Forestry and Fire 

Protection

Butte Suppression, 

administrative, 

accounting and 

investigation costs

$104,545,284.20

California 

Department of 

Forestry and Fire 

Protection

Camp Suppression, 

administrative, 

accounting and 

investigation costs

$109,506,276.63

California 

Department of 

Forestry and Fire 

Protection

Cascade, La Porte, 

Lobo and 

McCourtney 

Suppression, 

administrative, 

accounting and 

investigation costs

$11,224,238.65

California 

Department of 

Forestry and Fire 

Protection

Cienega Suppression, 

administrative, 

accounting and 

investigation costs

$29,000,000.00

California 

Department of 

Forestry and Fire 

Protection

Corrine Suppression, 

administrative, 

accounting and 

investigation costs

$9,222,550.71

California 

Department of 

Forestry and Fire 

Protection

Country Suppression, 

administrative, 

accounting and 

investigation costs

$79,985.64

California 

Department of 

Forestry and Fire 

Protection

Harney Suppression, 

administrative, 

accounting and 

investigation costs

$5,162.11

California 

Department of 

Forestry and Fire 

Protection

Honey Suppression, 

administrative, 

accounting and 

investigation costs

$1,104,743.07

California 

Department of 

Forestry and Fire 

Protection

N/A Post-petition attorney 

fees 

$82,857.25

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Entity2 Fire(s) Alleged Damages

Alleged Claim 

Amount

California 

Department of 

Forestry and Fire 

Protection

Northridge Suppression, 

administrative, 

accounting and 

investigation costs

$4,235.29

California 

Department of 

Forestry and Fire 

Protection

Parkfield Suppression, 

administrative, 

accounting and 

investigation costs

$578,375.16

California 

Department of 

Forestry and Fire 

Protection

Saddle Suppression, 

administrative, 

accounting and 

investigation costs

$28,347.48

California 

Department of 

Forestry and Fire 

Protection

Sawmill Suppression, 

administrative, 

accounting and 

investigation costs

$3,524,693.08

California 

Department of 

Forestry and Fire 

Protection

Soda Suppression, 

administrative, 

accounting and 

investigation costs

$40,426.77

California 

Department of 

Forestry and Fire 

Protection

Sulfur Suppression, 

administrative, 

accounting and 

investigation costs

$2,925,443.59

California 

Department of 

Forestry and Fire 

Protection

Table Suppression, 

administrative, 

accounting and 

investigation costs

$109,753.52

California 

Department of 

Forestry and Fire 

Protection

Zenon Suppression, 

administrative, 

accounting and 

investigation costs

$174,341.81

California 

Department of 

Parks and 

Recreation

Camp Supplies $14,914.95

California 

Department of 

Parks and 

Recreation

Camp Event permit for 

power restoration 

$4,900.00

California 

Department of 

Parks and 

Recreation

Camp Mitigation labor $5,691.33

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Entity2 Fire(s) Alleged Damages

Alleged Claim 

Amount

California 

Department of 

Parks and 

Recreation

Camp Voyager cost for fuel 

used for mitigation 

$235.62

California 

Department of 

Parks and 

Recreation

Camp Labor costs $122,102.52

California 

Department of 

Parks and 

Recreation

Camp Travel expenses for 

employees 

$3,407.08

California 

Department of 

Parks and 

Recreation

Nuns and Tubbs Loss of revenue at 

State Parks that were 

closed as a result of 

the fires

$225,000.00

California 

Department of 

Parks and 

Recreation

Nuns and Tubbs Fire rehabilitation $1,025,000.00

California 

Department of 

Parks and 

Recreation

Nuns and Tubbs Property damage $8,580,898.00

California 

Department of 

Parks and 

Recreation

Nuns and Tubbs Staff costs for 

property protection, 

safety, staffing and 

field patrols

$1,029,600.00

California 

Department of 

Toxic Substances 

Control 

Butte, Camp, 

Cascade, Laporte, 

Lobo, McCourtney, 

Redwood Valley 

and Sulphur

Environmental 

obligations and 

liabilities 

$7,166,391.29

California 

Department of 

Transportation

Camp Emergency response, 

cleanup and repairs 

of infrastructure

$217,044,048.00

California 

Department of 

Transportation

North Bay Fire Emergency response, 

cleanup and repairs 

of infrastructure

$7,587,178.97

California 

Department of 

Water Resources

N/A Bond costs charged 

to PG&E customers 

Additional Funds

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Entity2 Fire(s) Alleged Damages

Alleged Claim 

Amount

California 

Governor's Office 

of Emergency 

Services

Butte Public assistance $106,638,695.00

California 

Governor's Office 

of Emergency 

Services

Camp Public assistance $2,345,617,675.00

California 

Governor's Office 

of Emergency 

Services

North Bay Fires Public assistance $346,933,590.00

California State 

University, Chico 

Camp Property damage, 

loss of income, 

emergency operation 

center costs and labor 

costs

$273,460.26

Department of 

Veterans Affairs of 

the State of 

California

Camp, Butte and 

Nuns 

Property damage and 

debris removal 

$10,878,747.41

PLEASE TAKE FURTHER NOTICE that, for completeness, the Debtors have 

included in the foregoing list of claims all claims asserted against the Debtors that arise from a 

wildfire, including claims that do not arise from the Wildfires that are subject to the estimation 

proceedings before the District Court (the “Additional Wildfire Claims”3

). The Debtors are not 

seeking to estimate the Additional Wildfire Claims in the estimation proceedings before the 

District Court, but reserve all rights related to the allowance or disallowance of the Additional 

Wildfire Claims and the determination of the amounts thereof. 

PLEASE TAKE FURTHER NOTICE that claims filed against the Debtors in the 

above-captioned chapter 11 cases are still being processed and the Debtors hereby reserve their 

3

 The wildfires underlying the Additional Wildfire Claims include, but are not limited to, the 

following wildfires: (1) 415, (2) Almond, (3) Benson, (4) Bissett, (5) Cienega, (6) Corrine, 

(7) Country, (8) El Portal, (9) Harney, (10) Murphy, (11) Northridge, (12) Parkfield, 

(13) Railroad, (14) Saddle, (15) Sawmill, (16) Soda, (17) Table, and (18) Zenon. 

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rights to supplement the foregoing list of claims after reviewing any additional claims asserted by 

the U.S.A., the State and Adventist after such claims are processed. 

PLEASE TAKE FURTHER NOTICE that the foregoing list designating claims as 

unliquidated does not constitute an admission on the part of the Debtors that any such claims 

should be allowed in the amounts specified or in any amount at all. The Debtors hereby reserve 

all rights to object to any and all claims in the foregoing list on any ground contemplated by 

section 502(b) of the Bankruptcy Code or any other applicable law. 

PLEASE TAKE FURTHER NOTICE that copies of the pleadings and other documents 

for the above-captioned cases can be viewed and/or obtained: (i) by accessing the Court’s 

website at http://www.canb.uscourts.gov, (ii) by contacting the Office of the Clerk of the Court at 

450 Golden Gate Avenue, San Francisco, CA 94102, or (iii) from the Debtors’ notice and claims 

agent, Prime Clerk LLC, at https://restructuring.primeclerk.com/pge or by calling (844) 339-4217 

(toll free) for U.S.-based parties; or +1 (929) 333-8977 for International parties or by e-mail at: 

pgeinfo@primeclerk.com. Note that a PACER password is needed to access documents on the 

Court’s website. 

Dated: November 1, 2019 

WEIL, GOTSHAL & MANGES LLP 

CRAVATH, SWAINE & MOORE LLP 

KELLER & BENVENUTTI LLP 

/s/ Paul H. Zumbro 

Paul H. Zumbro 

Counsel for the Debtors and Debtors in Possession 

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