EXHIBIT 1 

Case: 19-30088 Doc# 4783-1 Filed: 11/15/19 Entered: 11/15/19 17:22:29 Page 1

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I 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA (SAN FRANC ISCO DIVISION) 

In re: I Bankruptcy Case 

No. 19·30068 (DM) 

PG&E CORPORATION, 

Debtor. 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

Proof of Claim (Fire Claim Related) 

Read the instructions before filing this claim fonn. This form Is for tort claimants who have a claim against the Debtors (i.e. PG&E 

Corporation and Pacific Gas and Electric Company) that arose prior to the Debtors filing for bankruptcy (I.e. prior to January 29, 2019) and 

that arose from, or relates to, a fire. 

CQ.2:'not use this form for non-fire claims. Non-fire tort claimants should use Fonn 410. 

Do NOT ftle a fraudulent claim. A person who files a fraudulent claim could be fined up to $500.000. imprisoned for up to 5 years. or both. 18 U S.C. §§ 

152. 157 and 3571 

Please type or print in the spaces below. Do NOT use red ink or pencil. 

Identify the Claim 

Who is the current 

creditor? Adventist Health System/West, a California religious non-profit corporation, and Feather River 

Hospital. a California religious non-profit corporation. d/b/a Adventist Health Feather River 

Name of the curreni credHors (the persons or enutles to be paio ror this claim) 

2 Has this claim been ~ No 

acquired from someone O Yes . From whom? else? -------------------------------- - -

3 Are you filing this claim ~ No 

on behalf of your 

family? 

A family 1s a group of two 

or more people related by 

birth, marriage. domestic 

partnership, or adoplion 

and residing together All 

such people are 

considered as members 

of one lam1ly. 

es 

If you checked "Yes", please provide the full name of each family member that you are fl ling on 

behalf of: 

4 . Where should notices Where should notices to the creditor be sent? 

I and payments to the 

creditor be sent? Advenust Health SystemNl/est 

Robert L Layton 

Where should payments to the creditor be sent? 

(if different) 

Name ____________ _____ _ 

Federal Rule of 

Bankruptcy Procedure 

{FRBP) 2002(9) 

Associate General Counsel 

Assistant Vice President 

ONE Adventist Health Way 

Roseville. California 95661 

Tel 916·406-1577 

Email laytonrl@ah org 

------------- ------ ® No 

Attorney Name (if applicable) - ---------

Attorney Bar Number (if applicable) - - ------

Street Address --------------- City _________________ _ 

State - ------ - --- ------ - Zip Code _ _ _______ _______ _ 

Phone Number _____________ ~ 

Email Address ---------------

5 Docs this claim amend 

one already filed? 0 Yes Clarm number on court claims registry {if known) - ---- Filed on------ MM / OO r YYYY 

6 Do you know 1f anyone ® No 

else has filed a proof O Yes. Who made the earlier filing? of claim for this claim? 

Proof of Claim (Fire Related) Page 1 

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jl' ~1· -...- • • •. 

Part2: . vo Information About the Claim as of the Date this Claim Form ls Filed . . 

7 What fire is the basis of 

your claim? 

Check all that apply. 

8 What are the loss 

localion(s) where you 

and/or your family 

su ffered harm? (e.g. 

home or business 

address, place of injury, 

place from which you 

were evacuated, if 

different? 

'9. How were you and/or 

your family harmed? 

Check all that apply 

10 What damages are you 

and/or your family 

claiming/seeking? 

Check all that apply 

'11 How much Is the claim? 

I 

I 

1i!l Camp Fire (2016) 

0 North Bay Fires (2017) 

U Ghost Ship Fire (2016) 

0 Butte Fire (2015) 

0 Other (please provide date and brief description of fire) --- ------------------

Localion(s): Feather River Hospital, 5974 Pentz Road, Paradise, California 95969 

and other locations in Paradise, Cal ifornia (see addendum). 

~ Property Damage (homes. structures. personal property. land. trees. landscaping. and all other property 

damage) 

® Owner C Renter 0 Occupant ~ Other (Please specify): See addendum 

Personal Injury 

Wrongful Death (if checked. please provide the name of the deceased) 

·"- Business Loss/Interruption 

·' Lost wages and earning capacity 

:J Loss of community and essential seNices 

Agricultural loss 

:,., Other (Please specify) . .:::S:..::e:..:e:....;a::.d=-d=-e=-n:.;.d=-=-um:..:..:..:.·--------------- - --------

~; Economic damages (including replacement cost of damaged property. diminution in value. loss of use. lost 

inventory. lost profits. and other economic damage) 

• Non-economic damages (including loss of society and support, loss of consortium. pain and suffering. emotional 

distress. annoyance and discomfort. and other non-economic damage) 

~.>( Punitive. exemplary. and statutory damages 

'. 7 Attorney's fees and litigation costs 

.-". Interest 

:-: Any and all other damages recoverable under California law 

..:. Other (Please specify): .:::S:..::e:..::e:..a::.d::::.d::::.e::::.n:.:.d::::.U::::.m:.;.:... ____________ _ _ _ _____ ___ _ 

.:.J 51 .012.061 .204: see addendum (optional) 

·· Unknown I To be determined at a later date 

Proof of Claim (Fire Related) Page 2 

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Sign Solow 

Tho person complotlng 

t this proof of clalm must 

I utgn and date It 

I FRBP 901 1 (b). 

Check the epproptiato box: 

0 I om the c1od~or 

® t am the crednor"s onorney or aull1onze-j ogent. 

11 ~o~ fi, ~ 111'

5 cJa.m Inf . . h. P f f Cl l h le t ·nto I dectrcni:ally l'RBP t na·,e examined the ormat1on m I JS roo o am ano ave a 1easoneb behe thel the 1 tma''Jon s true 

5005!3},2! a.1nc1 zcs cou11s eno coPect 

to cs1ao11sh IOCJI rvies t o~ dare unoer penalty or Pur]u•y tnat the foregoing is true and correct specifying what a S"1noture 

I ~ Executed on date October 1 7 2109 

1 A person who fi1011 o 

fraudulern claim could bo 

nned up to $500,000, 

lmpr1soned for up to 6 

years, or both. 

18 U.S.C. ~ 152, 157, and 

3571. 

Adventist Heolth System/West 

" t 

Tel: (91 6) 406-0000 

Email: WlngBD@ah.org 

Tel: (916) 406-0000 

Email: WingBD@ah.org 

95661 

Proof of Clnlm (Fire Rolnted) Page 3 

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Addendwn "A" to Proof of Claim of Adventist Health System/West and Feather River Hospital, 

d/b/a Adventist Health Feather River 

Adventist Health System/West ("Adventist Health"), a California religious nonprofit 

corporation, and Feather River Hospital, a California religious nonprofit corporation, d/b/a 

Adventist Health Feather River ("AHFR"), hereby submit this proof of claim, including this 

Addendum "A" to Proof of Claim and Addendum "B" attached hereto (together, the "Proof of 

Claim"). 

The claims of Adventist Health and AHFR, asserted jointly and severally by Adventist Health 

and AHFR (together, the "Claimants") against the estates of Debtor Pacific Gas and Electric 

Company and PG&E Corporation (together, the "Debtors") arise as a result of the following. 

I. THE CLAIMANTS 

1. Adventist Health is a faith-based, nonprofit integrated health delivery system headquartered 

in Roseville, California. It seeks to empower healthy communities and enhance the quality of 

life for those it services by improving access to comprehensive, quality health care services 

across multiple communities in California, Hawaii and Oregon. 

2. AHFR is part of the Adventist Health hospital system. Prior to the Camp Fire, AHFR was a 

100-bed acute care, community hospital with extensive operations in Butte County, but primarily 

in Paradise, California, including cancer, cardiology and a critical care unit, a diagnostic 

laboratory, an emergency department with connected MRI, CT and X-Ray services, an outpatient 

surgery center, home health and hospice services, hospital-based outpatient clinics, rural health 

clinics, and home oxygen, medical imaging, obstetrics, same-day and sleep medicine services. 

The hospital was staffed by nearly 200 physicians and advance practice professionals, 

approximately 1,200 employees and more than 400 volunteers. 

D. THE DEBTORS' LIABILITY TO THE CLAIMANTS 

1. Prior to the filing of the Debtors' chapter 11 cases on January 29, 2019 (the '~Petition Date"), 

and during the morning of November 8, 2019, a fire began near the community of Pulga in Butte 

County, California. According to the California Department of Forestry and Fire Protection 

("Cal Fire"), the fire was caused by electrical transmission lines owned and operated by the 

Debtors located· in the Pulga area. The fire rapidly burned into Pulga to the east and west into 

Concow, Paradise, Magalia and to the outskirts of Chico. Additionally, according to Cal Fire, a 

second fire began near the intersection of Concow Road and Rim Road, the cause of which was 

vegetation into electrical distribution lines, again owned and operated by the Debtors. This 

second fire was consumed by the initial fire near Pulga, and both such fires shall be referred to 

herein as the "Camp Fire." 

2. The Camp Fire burned thousands of acres of land and devastated the Town of Paradise and 

nearby communities. It also devastated the main campus of Feather River Hospital, located at 

5974 Pentz Road in Paradise (the "Main Hospital Campus"). Approximately 30 of the 

approximately 50 acres making up the developed portion of the Main Hospital Campus, plus 

another approximately 68 acres of AHFR's adjacent woodlands, were burned. The Camp Fire 

swept over large portions of the Main Hospital Campus, essentially destroying the Lower Level 

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of the hospital and all of the central utility plant, including the cooling tower yard and switchgear 

yard, and seriously damaging the Upper Level of the hospital. Multiple related hospital 

buildings, located closer to the woodlands, were also completely destroyed, while other related 

hospital buildings were heavily damaged. The damage and destruction done to the Main 

Hospital Campus was so extensive that it has rendered the Main Hospital Campus incapable of 

operation since the date of the fire, and the hospital and nearly all of the other services provided 

on the Main Hospital Campus remain closed. 

3. In addition to the Main Hospital Campus, the Camp Fire significantly damaged several of 

AHFR's other areas of operations in the town of Paradise, including Feather River Health 

Center, which had been one of the largest Rural Health Clinics in Adventist Health's system. 

While the Feather River Health Center has reopened, it has only limited services and is not 

equipped or staffed to handle patients with emergencies or other acute care needs, and must send 

them out of town to other facilities. 

4. The Camp Fire was a direct and legal result of the negligence, carelessness, recklessness, 

internal misconduct and/or unlawfulness of the Debtors, and each of them. Among other things, 

the Claimants are infonned and believe that the Debtors and each of them failed to: (a) comply 

with applicable statutory, regulatory, and/or professional standards of care; (b) timely and 

properly maintain, manage, inspect and/or monitor the power lines, electrical equipment, and/or 

adjacent vegetation owned by the Debtors or its affiliates; ( c) properly cut, trim, prune and/or 

otherwise keep vegetation at a sufficient distance to avoid foreseeable contact with power lines; 

( d) trim and/or prune vegetation so as to avoid the creation of a safety hazard within close 

proximity of the power lines of the Debtors and their affiliates; ( e) make the overhead lines safe 

under all conditions; (f) conduct adequate, prompt, proper, effective and/or frequent inspections 

and/or repairs of the electrical transmission lines, wires, and/or associated equipment; (g) design, 

construct, monitor, and/or maintain electrical transmission and/or distribution power lines in a 

manner that avoids the potential for fire by allowing vegetation to grow in an unsafe manner; (h) 

install equipment necessary and/or to inspect and/or repair installed equipment to prevent 

electrical transmission and distribution lines from improperly sagging, operating, and/or making 

contact with other metal wires placed on its poles and igniting fires; (i) keep equipment in a safe 

condition and/or manage equipment to prevent fire at all times; (j) failing to de-energize power 

lines during fire prone conditions; (k) failing to de-energize power lines after the ignition of ~e 

Camp Fire; andior (1) failing to properly train and supervise employees and/or agents responsible 

for maintenance and inspection of the distribution lines and/or vegetation areas near such lines. 

5. The Claimants assert that the damage incurred by the Claimants was legally and substantively 

caused by the actions of the Debtors in their installation," ownership, operation, use, control, 

management and/or maintenance of the power lines and other electrical equipment for a public 

use. The Claimants further have not received adequate compensation for the damage to and/or 

destruction of their real and personal property, thus constituting a taking or damaging of such 

property. 

6. The Claimants further assert that the Debtors and each of them acted wantonly, intentionally, 

unlawfully, carelessly, recklessly and/or negligently in failing to property inspect, manage, 

and/or control the power lines and other electrical equipment for a public use, and the vegetation 

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near its power lines along the real property which makes up the Main Hospital Campus and each 

of the other locations in which AHFR maintained operations. 

7. Based on all of the foregoing, the Claimants assert that the Debtors are jointly and severally 

liable for each other's wrongful acts and/or omissions, and are further liable to each of the 

Claimants pursuant to nwnerous causes of action, including negligence, inverse condemnation, 

public nuisance, private nuisance, premises liability, trespass, and violation of multiple statutes 

of the State of California, including, without limitation, Cal. Pub. Util. Code'§ 2106, Cal. H. & S. 

Code § 13007 and Cal. Bus. & Prof. Code § 17500. 

Ill. THE CLAIMANTS' DAMAGES AND RELATED EXPENSES 

The Claimants have lost the occupancy, possession, use, and/or enjoyment of their real and 

personal property, including the loss of their business operations at the Main Hospital Campus 

and each of AHFR's other locations, and the contributions which AHFR made as an important 

and integral part of the entire Adventist Health System. As a result of each of the Debtors' 

intentional, wrongful and negligent acts or omissions, the Claimants are entitled to recover from 

each of the Debtors amounts relating to, among other things, damages to real and personal 

property as well as lost profits in an amount of not less than $1,012,061,204 plus any related and 

other losses or other amounts (including fees and expenses, including, without limitation, 

attorneys' fees and expenses), as described below and as set forth on Addendum B attached 

hereto. 

Set forth below is a more detailed description of the nature and location of the damage and 

destruction done to the Claimants' operations by the Camp Fire, all of which were caused by the 

Debtors' intentional, wrongful and negligent acts or omissions. 

A. . Destroyed Buildings: 

1. Owing the fire event, the following buildings listed below were destroyed as a result of the 

Camp Fire: 

BUILDING NAME 

BioMed Storage and Workshop 

Canyon View Clinic 

Quality/Risk Management Building and Call 

Center 

Education and Training Building 

Ambulance Building 

Storage Facility 

Human Resources Building 

HVAC and Grounds Building and Yard 

Administrative Office 

Visiting Physicians Quarters 

Marketing Building 

Storage Building 

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STREET ADDRESS 

5724 Canyon View Drive 

5734 Canyon View Drive 

5810 Canyon View Drive 

5820 Canyon View Drive 

5824 Canyon View Drive 

5826 Canyon View Drive 

5839 Canyon View Drive 

5841 (A), (B) Canyon View 

Drive 

5845 Canyon View Drive 

5847 Canyon View Drive 

5849 Canyon View Drive 

5853 Canyon View Drive 

CITY 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

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Volunteers Building 

IT Garage/Storage 

Project Pl&nning Office 

5858 Canyon View Drive 

5960 Pentz Road 

~aradise 

Paradise 

6056 Pentz Road Paradise 

2. Additionally, the contents of all of the foregoing buildings were destroyed, including any 

medical equipment, medical supplies, furniture, office equipment or maintenance equipment or 

supplies located therein. 

B. Damaged Buildings: 

1. During the fire event, the buildings listed below were damaged to varying degrees as a result 

of the Camp Fire. In addition to the destruction of the Lower Level of the hospital and central 

utility plant described above, the Upper Level of the hospital was seriously damaged because hot 

embers penneated its roof (as they did to the roofs of several of the other buildings listed below), 

and pennitted water (through fire suppression activities and subsequent rain storms) to damage 

the structures and their interiors, which in turn caused mold and additional damage. 

BUILDING NAME 

Feather River Hospital/Main Hospital Building (Lower 

Level and Central Utility Plant essentially destroyed; 

Upper Level significantly damaged) 

Sewer Control Shed and Field (shed destroyed; sewer 

caps damaged) 

Accounting Office and Med Records 

Feather River Cancer Center 

Family Health Center 

Medical Records Storage Building 

Sleep Study Lab 

Outpatient Surgery Center 

Feather River Health Center - RHC, including 

Pharmacy 

Hospice Care Building 

Home Health, Home Oxygen and Storage Building 

Condominiums in Medical Office Building 

STREET ADDRESS 

5974 Pentz Road 

5974 Pentz Road 

5628 Canyon View Drive 

5629 Canyon View Drive 

5730 Canyon View Drive 

5843 Canyon View Drive 

1925 Peach Lane 

1933 Peach Lane 

5125 Skyway 

CITY 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

Paradise 

1289 Bille Road Paradise 

1295 Bille Road Paradise 

6283 Clark Road (Suites 1, Paradise 

4, 5, 6, 12, 13, 14 and 15) 

2. Service roads, parking lots and walkways throughout the Main Hospital Campus were 

damaged due to intense heat resulting from the fire event Additionally, heavy smoke penneated 

throughout the town of Paradise during and as a result of the Camp Fire, thereby requiring 

abatement or other smoke remediation to be done to AHFR's locations. Other temporary repairs 

also became necessary to mitigate further damage. This included roof patches, septic system 

patches and segregating the upper hospital (seriously damaged) from the lower hospital 

(essentially destroyed). One or more potable water container(s) were purchased in order to 

restore basic functions to the Feather River Health Clinic, as potable water was not available. 

3. Further, the contents of the buildings identified above, including medical equipment, medical 

supplies, furniture, office and maintenance equipment and supplies, were either damaged as a 

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result of the fire, and/or significantly affected by smoke. To the extent that they were 

salvageable, they had to be cleaned, repaired or otherwise remediated. Additionally, carpets or 

other flooring had to be cleaned or replaced, and walls had to be cleaned or repainted. 

C. Leased Locations 

Prior to the Camp Fire, AHFR leased the following locations for its operations: 

BUILDING NAME 

FR Specialty Services 

Feather River Urology 

Women's Health Center 

STREET ADDRESS 

6009 Pentz Road 

6480 Pentz Road 

6283 Clark Road (Suite 8) 

CITY 

Paradise 

Paradise 

Paradise 

During and after the Camp Fire, heavy smoke permeated these leased locations. As a result, the 

contents of each of the foregoing locations were significantly impacted and had to be cleaned, 

repaired or otherwise remediated, or were no longer usable and had to be destroyed. 

D. Other Damages 

The Claimants have incurred substantial additional damages as a result of the Camp Fire and the 

Debtors' wrongful acts which caused such fire. Such additional damages are itemized or 

identified on Addendum "B" hereto, and are further explained below: 

( 1) The Camp Fire cut off all utilities and water supplies to the Main Hospital 

Campus. As remediation began, the Claimants contracted to bring in rental equipment to restore 

basic functions, including portable lighting, hand washing stations, portable bathrooms, 

generators and multiple storage containers to salvage medical equipment. Several contractors 

were also hired to perform emergency work, including disposing of medical biohaz.ards (i.e., 

medications, sharp containers) and perishables, erosion control, supplying compressed gas for 

generators and potable drinking water. The damage done by the Camp Fire to the Main Hospital 

Campus also created potentially unsafe conditions to the public. Fencing was rented and large 

quantities of debris were removed. A security station was installed in a rented mobile trailer on 

the Main Hospital Campus and it has been, and continues to be, staffed 24 hours a day. 

(2) Similar remediation and security activities were completed for the Feather River 

·Health Center locations and, to the extent necessary, all other locations maintained by the 

Claimants in the town of Paradise. 

(3) Prior to the Camp Fire, the Main Hospital Campus contained formal landscaped 

areas and native trees around the buildings and parking lots. As a result of the Camp Fire, in 

excess of 200 individual landscaped trees were burned. Most are a complete loss and require 

removal. Additionally, adjacent to the Main Hospital Campus, the Claimants own a mixed 

woodland. An additional approximately 68 acres of that woodland was heavily damaged, 

resulting in the loss of hundreds of additional trees. The Claimants have incurred, and will 

continue to incur, substantial costs for cleanup and remediation of these areas. Pursuant to Cal. 

Civ. Code§ 3346 and Cal. Code Civ. Proc. § 733, the Claimants are entitled to recover three 

times their damages for these losses and expenses. 

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( 4) As a result of the Camp Fire, the Claimants were forced to incur the fees and 

expenses of attorneys and other professionals to advise them on their rights. Additionally, in the 

aftermath of the Camp Fire, the Claimants incurred numerous miscellaneous out-of-pocket 

expenses, including for additional labor and storage costs. 

(5) The Claimants provide a self-insured health plan for employees. Because of the 

cessation of health care services on the Main Hospital Campus and related facilities in the town 

of Paradise, . employees were forced to go to other facilities for their healthcare needs, thereby 

causing the Claimants to incur additional costs meeting those needs. 

(6) Claimant Adventist Health is self-insured for unemployment benefits. As a result 

of the Camp Fire, it has become obligated for additional unemployment claims. 

(7) As a result of the Camp Fire, Claimant Adventist Health has been or will be 

charged substantially higher insurance premiums for the period from October 1, 2019 to 

September 30, 2020 for less coverage, and will have to either pay massive additional premiums 

to obtain coverage similar to what it had previously, or accept substantially greater uninsured 

risk than it faced before the Camp Fire. 

(8) The Claimants are entitled to recover certain additional amounts from each of the 

Debtors in connection with the Camp Fire on and after the filing of this Proof of Claim, 

including, without limitation, any and all attorneys' and other consultants' and professionals' 

fees and expenses, future costs and repairs, further timber-related losses and expenses, insurancerelated costs, and punitive damages. The Claimants hereby reserve all rights to amend this Proof 

of Claim t~ assert additional claims against each of the Debtors. 

IV. RESERVATION OF RIGHTS 

1. This Proof of Claim is filed under the compulsion of the deadline set by the United States 

Bankruptcy Court for the Northern District of California in these cases for the assertion of 

prepetition claims against the Debtors. Each of the Claimants reserves, without limitation and to 

the fullest extent allowed by applicable law, the right to amend, modify, withdraw, renew, 

extend, restate and/or supplement, for any reason, this Proof of Claim and any of the claims set 

forth herein, including but not limited to, the recovery of any and all fees, expenses, and interest 

to which it may be entitled under applicable law. Each of the Claimants further reserves, without 

limitation, the right to assert any and all additional claims that either of the Claimants may have 

against either of the Debtors, to the fullest extent allowed by applicable law. 

2. In addition, each of the Claimants reserve, without limitation, all of its defenses and rights, 

procedural and substantive, and any and all setoff, offset, recoupment, and similar rights under 

any applicable contract, statute, common law or equitable principle, including any such right that 

arises post-petition, and shall not be deemed to have waived or released any claim by virtue of it 

not being liquidated or fixed herein. Each of the Claimants further expressly reserves its right to 

assert any and all indemnification and/or reimbursement claims that may exist or that may arise 

under any applicable law, including to the extent that either of the Claimants may become 

subject to any complaint or cross-complaint asserted or otherwise filed against it, or any other 

claim asserted against it by any person or entity. 

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3. The documents which evidence the facts and claims set forth herein are too voluminous to 

attach to this Proof of Claim at this time. Accordingly, the Claimants expressly reserve the right 

to attach, produce and/or rely upon additional docwnentation that supports their respective 

claims and any additional documents that may become available after further investigation or 

discovery, particularly in light of the minimal time afforded them to both discover and liquidate 

the extensive nature of the damages which occurred as a result of the Camp Fire. 

4. The filing of this Proof of Claim is not and shall not be deemed or construed as: 

(a) a waiver or release of the Claimants' right to trial by jury in this court or any other 

court in any proceeding as to any and all matters so triable herein, whether or not the 

same be designated legal or private rights or in any case, controversy, or proceeding 

related hereto, notwithstanding the designation or not of such matters as "core 

proceedings" pursuant to 28 U.S.C. § 157(b)(2), and whether such jury trial right is 

pursuant to statute or the United States Constitution; 

(b) consent by the Claimants to a jury trial in this court or any other court in any 

proceeding as to any and all matters so triable herein or in any case, controversy, or 

proceeding related hereto, pursuant to 28 U.S.C. § 157 or otherwise; 

( c) consent by the Claimants or waiver or release of the Claimants' right to have any 

and all final orders in any and all non-core matters or proceedings entered only after de 

novo review by a United States District Court Judge; 

( d) a waiver of the right to move to withdraw the reference with respect to the subject 

matter of the Proof of Claim, any objection thereto, or other proceeding which may be 

commenced in these cases against or otherwise involving the Claimants; 

(e) consent by the Claimants or release of the Claimants' right to contest the venue or 

jurisdiction of this Court over any bankruptcy case, adversary proceeding, contested 

matter, or other proceedings; 

(f) . an election of remedies; 

(g) a waiver of the Claimants' right to claim any prepetition or postpetition interest or 

all reasonable fees, costs, or charges under the Bankruptcy Code, including sections 503 

and 507 thereof; 

(h) a waiver of the Claimants' right to assert an administrative expense claim under 

Bankruptcy Code section 503(b) or otherwise; 

(i) a concession or admission by Claimant of facts with respect to any claims or 

alleged damages (or the amount thereof); 

(j) a waiver of any right to the subordination, in favor of the Claimants, of 

indebtedness or liens held by other creditors of the Debtors; 

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(k) a waiver of any right to arbitration or other alternative dispute resolution 

mechanism that is otherwise applicable; or 

(1) a waiver of any right of Claimant to have any liquidated portion of any claim 

determined by the Bankruptcy Court. 

5. Discovery is continuing with respect to the nature and extent of the Debtors' wrongful 

conduct and/or omissions and the damages incurred by the Claimants as a result thereof. 

Accordingly, the Claimants specifically reserve the right to assert any and all additional rights 

and claims that have arisen or may arise between or among the parties, including any rights or 

claims arising after the Petition Date or after the date of this Proof of Claim. The Claimants do 

not waive or release (and expressly reserve) any claim, right, or right of action, or any power or 

remedy, that any of the Claimants has or might have against the Debtors, the Debtors' estates, or 

any other person or entity, including but not limited to FM Global, any insurer of the· Debtors, or 

any other person, company or entity which may have provided any policy of insurance or other 

agreement to indemnify for losses related to the Camp Fire, regardless· of whether such claim, 

right, or action arises prior to, upon, or after the Petition Date or after the date of this Proof of 

Claim. 

6. This Proof of Claim is not intended to be, and shall not be construed as, an election of 

remedies, a waiver of any defaults or a waiver or limitation of any rights, remedies, claims, 

defenses, or interests of any of the Claimants, including but not limited to any right of setoff, 

offset, recoupment, a § 502(h) claim, or similar rights or defenses under any agreement, contract, 

statute, common law, or equitable doctrine. Nothing contained in this Proof of Claim shall limit 

the rights of the Claimants to file papers or pleadings, or commence any proceedings, or take any 

actions concerning its claims, liens or security interests. Claimant further reserves its right to 

pursue claims (including but not limited to the claims described herein) against any of the 

Debtors based upon additional or alternative legal theories. 

7. This Proof of Claim is filed by the Claimants against each of the Debtors. However, 

neither of the Claimants is seeking to recover more than 100% of its claim amount in the 

aggregate from the Debtors. 

8. The Claimants file this Proof of Claim without prejudice and in addition to any other 

claims of the Claimants that have been listed in any of the Debtors' schedules or may become 

listed in any of the Debtors' schedules. 

98745820.7 -8-

Case: 19-30088 Doc# 4783-1 Filed: 11/15/19 Entered: 11/15/19 17:22:29 Page 12

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Addendum "B" to Proof of Claim of Adventist Health System/West and Feather River Hospital 

d/b/a Adventist Health Feather River 

Loss/Expense Category Amount 

Costs to Clean-Up, Secure, Repair and Remediate Facilities After 

Fire (To Date): 

• Clean-up, immediate repairs and securing sites $ 3,198,557 

• Construction and further repairs completed to date $ 3,449,136 

Cost to Repair/Rebuild/Replace Facilities: 

• Construction and repairs not yet completed (including labor, $110,622,586 

material and related "soft" costs) 

Timber: 

• Value of lost landscape trees (including remediation costs) $ 875,158 

• Initial treatment and remediation of woodland trees $ 5,319,500 

• Additional damages per Cal. Civ. Code§ 3346 and Cal. Code $ 12,389,316 

Civ. Pro. § 733 

Loss of Inventory/Equipment/Contents of AHFR Locations $ 14,433, 149 

Loss of Surplus (Profit): 

• Loss of surplus (profit) ( 11/8/18 to 10/31/19) $ 16,223,272 

• Value of future lost surplus (profit) (11/19 to 12/24) $ 70,369,798 

• Operating losses ( 11/8/l8 to I 0/31/I9) $ 39,868,262 

• Value of future operating losses (11119 to 12/24) $ 61,663,375 

• Additional system-wide charges that cannot be avoided $ 25,463,291 

(11/8/18 to 10/31/19) 

• Value of future additional system-wide charges that cannot $ 99,386,397 

be avoided (11119 to 12/24) 

Other Miscellaneous Damages: 

• Professional fees and expenses as of October 16, 2019 $ 1,210,412 

(attorneys, consultants and other professionals) 

• Miscellaneous Out-of-Pocket Expenses $ 337,239 

• Additional employee health plan costs ( 1 1 /8/18 to 10/31 /19) $ 824,453 

• Value of future additional employee health plan costs (11/19 $ 936,493 

onwards) 

• Assistance to Camp Fire Assistance Fund (for employees) $ 500,000 

• Unemployment insurance claims (2/6/19 to 9/16/19) $ 1,215,722 

• Unemployment insurance claims (liability remaining) $ 1,579,826 . 

• Impact on insurance premiums and coverage on policy from $ 36, 164,660 

10/1/19 to 9/30/20) 

Subtotal $506,030,602 

Plus: 

Value of Lost Woodland Trees and Cost of Ongoing Mitigation TBD 

Needs 

Contribution and Indemnity Claims for Third Party Liabilities TBD 

Other unliquidated amounts TBD 

Punitive Damages $506,030,602 

Total Sl,012,061,204 

98745820.7 -9-

Case: 19-30088 Doc# 4783-1 Filed: 11/15/19 Entered: 11/15/19 17:22:29 Page 13

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Electronic Proof of Claim_PE!HA27397 

Final Audit Report 2019-10-18 

Created: 2019-10-18 

By: Prime Clerk E-Flling (efiling@prlmeclerk.com) 

Status: Signed 

Transaction ID: CBJCHBCAABAA5RaWYUFC2NqmGMqJ5Aa1dEYYGRykCF _k 

"Electronic Proof of Claim_PE!HA27397" History 

fJ Web Form created by Prime Clerk E-Filing (efiling@primecierk.com) 

2019-10-18- 3:17:08 PM GMT 

,:::: Bill Wing uames.copeland@nortonrosefulbright.com) uploaded the following supporting documents: 

, ; Attachment 

2019-10-18- 3:31:43 PM GMT 

h~ 

u Web Form filled in by Bill Wing Oames.copeland@nortonrosefulbright.com) 

2019-10-18- 3:31:43 PM GMT- IP address: 38.122.49.122 

~~o (User email address provided through API User-Agent: Mozilla/5.0 (Windows NT 10.0; Win64; x64) 

AppleWebKit/537.36 (KHTML, like Gecko) Chrome/72.0.3626.121 Safari/537.36) 

2019-10-18- 3:31:49 PM GMT- IP address: 38.122.49.122 

E) Signed document emailed to Prime Clerk E-Filing (efiling@primeclerk.com) and Bill Wing 

uames.copeland@nortonrosefulbright.com) 

2019-10-18- 3:31:49 PM GMT 

PnmeClerk ~ 

Case: 19-30088 Doc# 4783-1 Filed: 11/15/19 Entered: 11/15/19 17:22:29 Page 14

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