1:12:03
What's the matter?
1:12:06
I don't know if we can pull this off.
1:12:10
This is a monster case.
We're up to 41 1 plaintiffs.
1:12:14
We've taken 1 62 declarations.
1:12:18
Probably hundreds more
out there have moved away.
1:12:22
We have to find them,
it's taking time.
1:12:25
Money's going out,
nothing's coming in.
1:12:27
I have to take a second mortgage.
1:12:29
-So?
-So!
1:12:34
I have to tell you.
1:12:36
I've been making inquiries
with other firms...
1:12:40
...bigger firms to share
some of the cost.
1:12:44
They all said no,
said they don't have it.
1:12:48
We got PG&E by the balls.
1:12:50
PG&E Hinkley, but nobody'll get rich
unless we pin this on Corporate...
1:12:54
-...in San Francisco.
-What do you mean?
1:12:56
PG&E Corporate claims they
didn't know about Hinkley.
1:13:00
They knew. They had to know.
1:13:02
Show me the document to prove it.
1:13:06
Then they didn't know. If so, we
can't hit them with punitive damages.
1:13:10
With punitive damages,
it's a sum of money that can...
1:13:14
...have some effect
on these people's lives.
1:13:19
So what do we do now?
1:13:25
Let's assume there are documents
connecting PG&E Hinkley and Corporate...
1:13:29
...and they know about them.
1:13:31
We take our 400 or so plaintiffs
and everything you've dug up...
1:13:36
...we file a lawsuit
to provoke a reaction.
1:13:39
See if they offer a reasonable
settlement, or throw more paper at us.
1:13:43
Sounds great. Let's do that.
1:13:45
There's a downside.
1:13:47
PG&E will submit a demurrer.
1:13:50
A list attacking each complaint...
1:13:52
...claiming that each cause
of action has no merit.
1:13:55
And if the judge agrees with them...
1:13:57
...he'll dismiss our case.
PG&E will have no reason to settle.