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LOS 

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EXHIBIT 4

Case: 19-30088 Doc# 5345-4 Filed: 01/10/20 Entered: 01/10/20 15:13:20 Page 1

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82570 (Form 2570- Subpoena to Produce Documents, Information, or Objects or To Permit Inspection in a Bankruptcy Case or Adversary Proceeding) (12/15) 

UNITED STATES BANKRUPTCY COURT 

Northern District of California ---------------------

In re PG&E Corporation 

Debtor 

(Complete if issued in an adversary proceeding) 

Plaintiff 

V. 

Case No. 19-30088 (DM) 

Chapter ~11~----

Adv. Proc. No. ----------

Defendant 

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT 

INSPECTION OF PREMISES IN A BANKRUPTCY CASE (OR ADVERSARY PROCEEDING) 

To: ArborWorks, Inc. c/o Donald A. McIntyre, 6090 Keeble Lane, Camino, CA 95709 

(Name of person to whom the subpoena is directed) 

tz:I Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following 

documents, electronicall stored information, or ob ·ects, and to ermit inspection, copying, testing, or sampling of the 

material: See attachment Exhibit A 

PLACE DATE AND TIME 

Brid etMcCabec/oVeritext 1 Ca itolMall Suite240,Sacramento,CA95814 Januar 23 2020at 1:00PMPST 

D Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or 

other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party 

may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. 

PLACE I DATE AND TIME 

The following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are 

attached - Rule 45( c ), relating to the place of compliance; Rule 45( d), relating to your protection as a person subject to a 

subpoena; and Rule 45( e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not 

doing so. 

Date: 1/9/2020 

CLERK OF COURT 

Signature of Clerk or Deputy Clerk 

0 ~ 

Bridget S. McCabe 

The name, address, email address, and telephone number of the attorney representing (name o_f party) 

Official Committee of Tort Claimants , who issues or requests this subpoena, are: 

Bridget S. McCabe, 11601 Wilshire Blvd., Suite 1400, Los Angeles, CA 90025, bmccabe@bakerlaw.com, (310) 442-8844 

Notice to the person who issues or requests this subpoena 

If this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of 

premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is 

directed. Fed. R. Civ. P. 45(a)(4). 

Americnn LegnlNet, Inc, ~ www FormsWork.Flow.com ~,61 Case: 19-30088 Doc# 5345-4 Filed: 01/10/20 Entered: 01/10/20 15:13:20 Page 2

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B2570 (Form 2570 - Subpoena to Produce Documents, Information, or Objects or To Permit Inspection in a Bankruptcy Case or Adversary Proceeding) (Page 2) 

PROOF OF SERVICE 

(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) 

I received this subpoena for (name of individual and title, if any): 

on (date) -----

DI served the subpoena by delivering a copy to the named person as follows: 

________________ on (date) _________ ; or 

D I returned the subpoena unexecuted because: 

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the 

witness the fees for one day's attendance, and the mileage allowed by law, in the amount of$ 

My fees are$ for travel and $ ----- ____ for services, for a total of$ ____ _ 

I declare under penalty of perjury that this information is true and correct. 

Date: --------

Additional information concerning attempted service, etc.: 

Server's signature 

Printed name and title 

Server's address 

American LegnlNet, Inc. ~ www.FormsWorkFlow.com ~.l? Case: 19-30088 Doc# 5345-4 Filed: 01/10/20 Entered: 01/10/20 15:13:20 Page 3

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B2570 (Form 2570 - Subpoena to Produce Documents, Information, or Objects or To Permit Inspection in a Bankruptcy Case or Adversary Proceeding) (Page 2) 

Federal Rule of Civil Procedure 45( c ), ( d), ( e ), and (g) (Effective 12/1/13) 

(made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure) 

(c) Place of compliance. 

(1) For a Trial, Hearing, or Deposition. A subpoena may command a 

person to attend a trial, hearing, or deposition only as follows: 

(A) within 100 miles of where the person resides, is employed, or 

regularly transacts business in person; or 

(B) within the state where the person resides, is employed, or regularly 

transacts business in person, if the person 

(i) is a party or a party's officer; or 

(ii) is commanded to attend a trial and would not incur substantial 

expense. 

(2)For Other Discove,y. A subpoena may command: 

(A) production of documents, or electronically stored information, or 

things at a place within I 00 miles of where the person resides, is employed, 

or regularly transacts business in person; and 

(B) inspection of premises, at the premises to be inspected. 

(d) Protecting a Person Subject to a Subpoena; Enforcement. 

(1) Avoiding Undue Burden or Expense; Sanctions. A party or 

attorney responsible for issuing and serving a subpoena must take 

reasonable steps to avoid imposing undue burden or expense on a person 

subject to the subpoena. The court for the district where compliance is 

required must enforce this duty and impose an appropriate sanction -

which may include lost earnings and reasonable attorney's fees - on a 

party or attorney who fails to comply. 

(2) Command to Produce Materials or Permit inspection. 

(A) Appearance Not Required. A person commanded to produce 

documents, electronically stored information, or tangible things, or to 

permit the inspection of premises, need not appear in person at the place of 

production or inspection unless also commanded to appear for a deposition, 

hearing, or trial. 

(B) Objections. A person commanded to produce documents or tangible 

things or to permit inspection may serve on the party or attorney designated 

in the subpoena a written objection to inspecting, copying, testing or 

sampling any or all of the materials or to inspecting the premises - or to 

producing electronically stored information in the fonn or forms requested. 

The objection must be served before the earlier of the time specified for 

compliance or 14 days after the subpoena is served. If an objection is made, 

the following rules apply: 

(i) At any time, on notice to the commanded person, the serving party 

may move the court for the district where compliance is required for an 

order compelling production or inspection. 

(ii) These acts may be required only as directed in the order, and the 

order must protect a person who is neither a party nor a party's officer from 

significant expense resulting from compliance. 

(3) Quashing or Modifying a Subpoena. 

(A) When Required. On timely motion, the court for the district where 

compliance is required must quash or modify a subpoena that: 

(i) fails to allow a reasonable time to comply; 

(ii) requires a person to comply beyond the geographical limits 

specified in Rule 45(c); 

(iii) requires disclosure of privileged or other protected matter, if no 

exception or waiver applies; or 

(iv) subjects a person to undue burden. 

(B) When Permitted. To protect a person subject to or affected by a 

subpoena, the court for the district where compliance is required may, on 

motion, quash or modify the subpoena if it requires: 

(i) disclosing a trade secret or other confidential research, 

development, or commercial information; or 

(ii) disclosing an unretained expert's opinion or information that does 

not describe specific occurrences in dispute and results from the expert's 

study that was not requested by a party. 

(C) Specifying Conditions as an Alternative. In the circumstances 

described in Rule 45(d)(3)(B), the court may, instead of quashing or 

modifying a subpoena, order appearance or production under specified 

conditions if the serving party: 

(i) shows a substantial need for the testimony or material that cannot 

be otherwise met without undue hardship; and 

(ii) ensures that the subpoenaed person will be reasonably 

compensated. 

(e) Duties in Responding to a Subpoena. 

(1) Producing Documents or Electronically Stored Information. These 

procedures apply to producing documents or electronically stored 

information: 

(A) Documents. A person responding to a subpoena to produce 

documents must produce them as they are kept in the ordinary course of 

business or must organize and label them to correspond to the categories in 

the demand. 

(B) Form for Producing Electronically Stored Information Not 

Specified. If a subpoena does not specify a form for producing 

electronically stored information, the person responding must produce it in 

a form or forms in which it is ordinarily maintained or in a reasonably 

usable form or forms. 

(C) Electronically Stored information Produced in Only One Form. The 

person responding need not produce the same electronically stored 

information in more than one form. 

(D) Inaccessible Electronically Stored Information. The person 

responding need not provide discovery of electronically stored information 

from sources that the person identifies as not reasonably accessible because 

of undue burden or cost. On motion to compel discovery or for a protective 

order, the person responding must show that the information is not 

reasonably accessible because of undue burden or cost. If that showing is 

made, the court may nonetheless order discovery from such sources if the 

requesting party shows good cause, considering the limitations of Rule 

26(b)(2)(C). The court may specify conditions for the discovery. 

(2) Claiming Privilege or Protection. 

(A) Information Withheld. A person withholding subpoenaed 

information under a claim that it is privileged or subject to protection as 

trial-preparation material must: 

(i) expressly make the claim; and 

(ii) describe the nature of the withheld documents, communications, 

or tangible things in a manner that, without revealing information itself 

privileged or protected, will enable the parties to assess the claim. 

(B)lnformation Produced. If information produced in response to a 

subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that 

received the information of the claim and the basis for it. After being 

notified, a party must promptly return, sequester, or destroy the specified 

information and any copies it has; must not use or disclose the information 

until the claim is resolved; must take reasonable steps to retrieve the 

information if the party disclosed it before being notified; and may 

promptly present the information under seal to the court for the district 

where compliance is required for a determination of the claim. The person 

who produced the information must preserve the information until the claim 

is resolved. 

(g) Contempt. The court for the district where compliance is required - and 

also, after a motion is transferred, the issuing court - may hold in contempt 

a person who, having been served, fails without adequate excuse to obey 

the subpoena or an order related to it. 

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013) 

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SAN FRANCISCO

EXHIBIT A

DEFINITIONS

1. As used herein, the words "Document" and "Documents" mean each written, typed, 

printed, recorded, transcribed, taped, electronically stored, digitized, disked, filmed, or graphic 

matter of every kind, however produced or reproduced, including originals or copies of originals 

not in existence or available, all drafts or partial copies, wherever located, and including all 

Electronic Data, correspondence, letters, emails, memoranda, requests for information, reports, 

studies, tests, inspections, working papers, handwritten notes, diaries, charts, spreadsheets, 

photographs, sketches, drawings, blueprints, videos, graphs, indices, submittals, data sheets, 

databases, conversations, statements, minutes, notations (including notes or memorandum of 

conversations), telephone conversations in whatever form, suggestions, comments, instructions, 

warnings, notices, manuals, periodicals, pamphlets, brochures, catalogues, bulletins, schedules, 

invoices, and other documentation.

2. The term "Electronic Data" as used herein, shall be construed as the following types 

of electronic data and data compilations in the custody and/or control of the party responding to 

this Subpoena:

a. All electronic mail and information about electronic mail sent or received by 

the party responding to this Subpoena; 

b. All databases containing any reference and/or information;

c. All activity logs on any computer system which may have been used to 

process or store electronic data containing information;

d. All word processing files and file fragments, including metadata, containing 

information about the below listed subjects;

e. All electronic data files and file fragments created by application programs 

that process information requested herein;

f. All electronic data files and file fragments from electronic calendars and 

scheduling programs that contain information about the below-listed subjects; and

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g. All audio and video recordings sent, received, or stored by the party 

responding to this Subpoena that contains, references, or otherwise identifies information about the 

below listed subjects.

3. The terms "and" and "or" as used herein, shall, where the context permits, be 

construed to mean "and/or" as necessary to bring within the scope of the subpoena request.

4. The terms "You" and "Your" refer to the party responding to this Subpoena.

5. The term “PG&E” refers to PG&E Corporation and/or Pacific Gas & Electric 

Company. 

6. The term “Work” means any activity performed by You in fulfillment of Your 

duties, contractual or otherwise, to PG&E. 

7. The term "Communication(s)" means any transmission of information from one 

person or entity to another, including (without limitation) by personal meeting, conference, 

conversation, telephone, radio, electronic mail, teleconference, or any other method of 

communication or by any medium.

8. The term “Fires” means the fires that occurred in Northern California in 2015, 

2017 and 2018 listed below: 

1. Butte Fire (2015)

2. North Bay Wildfires (2017)

a. 37

b. Adobe

c. Atlas

d. Blue

e. Cascade

f. Cherokee

g. Honey

h. LaPorte

i. Lobo

j. Maacama / Youngs

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k. McCourtney

l. Norrbom

m. Nuns

n. Partrick

o. Pocket 

p. Point

q. Pressley

r. Pythian / Oakmont 

s. Redwood / Potter Valley

t. Sullivan 

u. Sulphur

v. Tubbs

3. Camp Fire (2018) 

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REQUEST FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1:

All Documents that constitute and/or memorialize any and all contracts and/or work 

agreements between You and PG&E, for the time period 2013 to the present. 

REQUEST FOR PRODUCTION NO. 2:

All Documents that constitute and/or memorialize, any and all indemnification and/or hold 

harmless agreements between You and PG&E, for the time period 2013 to the present. 

REQUEST FOR PRODUCTION NO. 3:

All Documents that constitute and/or, memorialize any and all reports, analyses, 

summaries, or descriptions of Your work for PG&E, for the time period 2013 to the present.

REQUEST FOR PRODUCTION NO. 4

All Documents that constitute and/or, memorialize Commercial General Liability insurance 

policies, including but not limited to all applications, declarations, policies and endorsements, for 

which You are an insured, for the time period 2013 to the present. Included in this request are all 

such policies whether insuring You alone, or You as well as others. 

REQUEST FOR PRODUCTION NO. 5:

All Documents that constitute and/or, memorialize Errors & Omissions/Professional 

Liability insurance policies, including but not limited to all applications, declarations, policies and 

endorsements, for which You are an insured, for the time period 2013 to the present. Included in 

this request are all such policies whether insuring You alone, or You as well as others.

REQUEST FOR PRODUCTION NO. 6:

All Documents that constitute and/or, memorialize Directors & Officers insurance policies, 

including but not limited to all applications, declarations, policies and endorsements, for which You 

are an insured, for the time period 2013 to the present. Included in this request are all such policies 

whether insuring You alone, or You as well as others.

REQUEST FOR PRODUCTION NO. 7:

All Documents that constitute and/or, memorialize Environmental/Pollution Liability 

insurance policies, including but not limited to all applications, declarations, policies and 

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endorsements, for which You are an insured, for the time period 2013 to the present. Included in 

this request are all such policies whether insuring You alone, or You as well as others.

REQUEST FOR PRODUCTION NO. 8:

All Documents that constitute and/or, memorialize insurance policies, not otherwise 

produced in response to Request Nos. 4-7, that You were contractually required to maintain 

pursuant to any contracts You had with PG&E, including but not limited to all applications, 

declarations, policies and endorsements, for which You are an insured, for the time period 2013 to 

the present. Included in this request are all such policies whether insuring You alone, or You as 

well as others.

REQUEST FOR PRODUCTION NO. 9:

All Documents that constitute and/or, memorialize other insurance policies, not otherwise 

produced in response to Requests 4-8, that provide defense coverage, indemnity, and/or other 

coverage of claims arising from or related to Your services or acts, including but not limited to all 

applications, declarations, policies and endorsements, for the time period 2013 to the present. 

Included in this request are all such policies whether insuring You alone, or You as well as others.

REQUEST FOR PRODUCTION NO. 10:

All Documents that constitute, refer or relate to notices of claims, tenders and coverage 

Communications—including but not limited to coverage positions and insurance analyses—

between You and any insurers for all such insurance policies subject to Request Nos. 4-9, for the 

time period 2013 to the present related, directly or indirectly, to the Fires and/or Your Work for 

PG&E.

REQUEST FOR PRODUCTION NO. 11:

All Documents that constitute, refer or relate to notices of claims, tenders and coverage 

Communications—including but not limited to coverage positions and insurance analyses—

between You and any insurance brokers or agents for all such insurance policies subject to Request 

Nos. 4-9, for the time period 2013 to the present related, directly or indirectly, to the Fires and/or 

Your Work for PG&E.

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REQUEST FOR PRODUCTION NO. 12:

All Documents that constitute, refer or relate to notices of claims, tenders and coverage 

Communications—including but not limited to coverage positions and insurance analyses—

between You and any insurers for all such insurance policies subject to Request Nos. 4-9, for the 

time period 2013 to the present related to work that You performed for any entity other than PG&E 

but that was the same or similar in nature to the Work you performed for PG&E.

REQUEST FOR PRODUCTION NO. 13:

All Documents that constitute, refer or relate to notices of claims, tenders and coverage

Communications—including but not limited to coverage positions and insurance analyses—

between You and any insurance brokers or agents for all such insurance policies subject to Request 

Nos. 4-9, for the time period 2013 to the present related to work that You performed for any entity 

other than PG&E but that was the same or similar in nature to the Work You performed for PG&E.

REQUEST FOR PRODUCTION NO. 14:

All Documents constituting, memorializing, or reflecting any payment of Your defense 

costs and/or indemnity and/or ultimate net loss, however it may be defined by any given policy, 

made by each insurance carrier subject to Request Nos. 4-9 for the time period 2013 to the present.

REQUEST FOR PRODUCTION NO. 15:

All Documents constituting, memorializing, or reflecting insurance policy limits remaining 

available for payment of covered claims under each policy where an insurance carrier has made a 

payment subject to Request No. 14.

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