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Dario de Ghetaldi - Bar No. 126782
Amanda L. Riddle - Bar No. 215221
2 Clare Capaceioli Velasquez - Bar No. 290466
COREY, LUZAICH, DE GHETALD!, NASTARJ & RIDDLE LLP
3 700 EI Camino Real
P.O. Box 669
4 Millbrae, California 94030-0669
Telephone: (650) 871-5666
5 Facsunile: (650} 871-4144
deg@coreylaw.com
6 alr@coreylaw.com

OCT 2 6Z015
CLERK OF THE COURy
DY;_

BOWMAN t.IU

ocpwy (.'Jerk

Michael S. Danko Bar No. 1I1359

Kristine K. Meredith Bar No. 158243
8 DANKO MEREDITH
333 Twin Dolphin Drive, Suite 145
9 Redwood Shores, CA 94065
Telephone: (650) 453-3600
lO Facsimile: (650) 394-8672
mdanko@dankolaw.eom
11 kmeredith@dankolaw.com
12

Attorneys for Plaintiffs Stephanie Mathes and Karen Goldsmith

13
SUPERJOR COURT OF THE STATE OF CALIFORNIA
14
COUNTY OF SAN FRANCISCO
15

CGC-15-548619

16
STEPHANIE MATHES and KAREN
17 GOLDSMITH, individually and as
Successors-in-Interest to the Estate of OWEN
18 GOLDSMITH, deceased, and STEPHANIE
MATHES, as representative of the Estate of
19 OWEN GOLDSMITH, deceased,
Plaintiffs,

20
vs.

22

PG&E CORPORATION, a California

Corporation, PACIFIC GAS & ELECTRIC
COMPANY, a California Corporation,
ACRT, Inc., a Corporation, TREES, INC., a
Corporation, and DOES 1-50, inclusive,

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25

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Defendants.

CASE NO.

COMPLAINT FOR:
1.

2.

3.

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27
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COMPLAINT

Scanned by CamScanner

NEGLIGENCE: WRONGFUL
DEATH
STRICT LIABILITY:
WRONGFUL DEATH
SURVIVAL ACTION

Plaintiffs STEPHANIE MATHES and KAREN GOLDSMITH, individually and as

2

Successors-in-Interest to the Estate of OWEN GOLDSMITH, deceased, and STEPHANIE

MATHES, as representative of the Estate of OWEN GOLDSMITII, deceased, bring this action

for damages against Defendants PG&E CORPORATION, a California Corporation, PACIFIC

GAS & ELECTRIC COMPANY, a California Corporation (collectively "PG&E"), a

Corporation, ACRT, INC., TREES, INC., a Corporation, and DOES 1-50, inclusive, as follows:

I. INTRODUCTION

7
8

1.

PG&E has a long history of failing to maintain its infrastructure and making poor

decisions that result in safety lapses. These safety lapses have led to disasters that result in

10

wrongful death, personal injury, and destruction of property. In this case, PG&E failed to

11

properly inspect its electrical lines and maintain the surrounding vegetation, by its own acts or

12

through the acts of its agents. As a result, on the afternoon of September 9, 2015, a tree struck a

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12,000-volt PG&E power line on Butte Mountain Road, in Jackson, California. Sparks flew and

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ignited what has since been named "The Butte Fire."

15

2.

Over the next week, the Butte Fire spread rapidly, causing extensive damage

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within Amador and Calaveras Counties. Over 4,000 firefighters battled the blaze. The fire was

17

not reported contained until October 1, 2015. The Butte Fire burned more than 70,000 acres,

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destroying and damaging 475 residences, 343 outbuildings, and 45 other structures. The fire also

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left tens of thousands of dead or dying trees, and the risk of water pollution and erosion in its

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wake. Two people lost their lives as a result of the Butte Fire and thousands of residents and

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property owners were significantly burdened.

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3.

One of those residents was Owen Goldsmith. Owen Goldsmith was found in his

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home by firefighters on September 15, 2015, having perished in the Butte Fire. At the time of his

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death, Owen Goldsmith, 82, lived in the home he owned in Mountain Ranch, Calaveras County.

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Born in Borger, Texas, Owen Goldsmith served as a staff sergeant in the United States Air Force

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from 1951 to 1955. He went on to graduate magna cum laude in music at then~San Francisco

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State College and got his master's degree in music from the college in 1965. Owen Goldsmith

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was a prolific music composer, having taught choir and orchestra to high school and college
2
COMPLAINT

students. Mr. Goldsmith had two beloved daughters: Plaintiffs Stephanie Mathes and Karen
2

Goidsmith.
4.

In this ease, PG&E and its agents ACRT, Inc., and Trees, Inc., negligently

maintained and operated its electrical infrastructure, and failed to maintain the surrounding

vegetation within the applicable regulations and law. As a result, hundreds of residents lost their

homes, Owen Goldsmith lost his life, and Plaintiffs Stephanie Mathes and Karen Goldsmith lost

their father.

II. JURISDICTION AND VENUE

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10

5.

This Court has personal jurisdiction over Defendants. PG&E Corporation and

Pacific Gas & Electric Company are incorporated in California and have and continue to do

11 significant business in California so as to render the exercise of jurisdiction over it by the

12

California courts consistent with traditional notions of fairness and substantial justice. Defendant

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ACRT, Inc., is a privately owned corporation conducting business in California as a utility

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vegetation management contractor. Defendant Trees, Inc., is a privately owned corporation

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conducting business in California as a tree maintenance corporation for utility companies. In

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addition, a substantial part of the events that caused Plaintiffs' injuries occurred in the County of

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San Francisco, within the State of California.

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6.

The amount of controversy exceeds the jurisdictional minimum of this Court.

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7.

Venue is proper in this County as Defendants perform business in this County,

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with at least two of them having their principal plaee of business in this County, and a substantial

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part of the events, acts, omissions, and transactions complained of herein occurred in this

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County.

III. THE PARTIES

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8.

Plaintiff Stephanie Mathes is the loving daughter of Owen Goldsmith. She brings

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certain claims herein, specified below, as the natural daughter of Owen Goldsmith, pursuant to

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Code of Civil Procedure 377.60. Additionally, on October 26, 2015, Plaintiff Stephanie

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Mathes filed with the Superior Court of California, County of Calaveras, the Estate of Owen

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Goldsmith. In the filing, Plaintiff Stephanie Mathes seeks to have the Court appoint her as the
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COMPLAl:-.IT

administrator of the Estate of Owen Goldsmith. She is thus lawfully entitled to pursue all claims
2

and causes of action for damages, loss, or destruction of assets of the Estate pursuant to Code of

Civil Procedure 377.30.

9.

Plaintiff Karen Goldsmith is the loving daughter of Owen Goldsmith. She brings

certain claims herein, specified below, as the natural daughter of Owen Goldsmith, pursuant to

Code of Civil Procedure 377.60.

I 0.

Owen Goldsmith was the natural father of Plaintiffs Stephanie ~athes and Karen

Goldsmith. At the time of his death, he owned and occupied 6003 Eagle View Drive, Mountain

Ranch, California.'

10

IL

Defendant PG&E Corporation, is incorporated in California and based in San

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Francisco, California. At all times mentioned herein, it has acted to provide electrical services to

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members of the public in California, including, Amador and Calaveras Counties.

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12.

Defendant Pacific Gas & Electric Company, a subsidiary corporation of PG&E

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Corporation, is incorporated in California and based in San Francisco, California. It is one of the

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largest combination natural gas and electric utilities in the United States. At all times herein

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mentioned, Pacific Gas & Electric Company provided electric service to millions of customers in

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Northern and Central California, including to the residents of Amador and Calaveras Counties,

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through its electric transmission and distribution systems.

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13.

Defendant ACRT, Inc., is utility vegetation management company, doing business

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all over the United States. Plaintiffs are informed and believe that at all times mentioned herein,

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ACRT, Inc., was the agent of PG&E and acting within the course and scope of that agency.

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14.

Defendant Trees, Inc., is one of the largest utility vegetation management service

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companies in the United States. Plaintiffs are informed and believe that at all times mentioned

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herein, Trees, Inc., was the agent of PG&E and acting within the course and scope of that agency.

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15.

The true names and capacities, whether individual, corporate, associate or

otherwise of1he Defendants sued herein as DOES 1 through 50 are unknown to Plaintiffs who

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As of September 9, 201 the property was held by Owen L. Goldsmith, Trustee of the
Owen L. Goldsmith Trust, dated May 3, 1996.
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COMPLAJNT

therefore sue said Defendants by such fictitious names. Plaintiffs will amend this complaint to
2

show their true names and capacities when the same are ascertained. Plaintiffs are informed and

believe and thereon allege that each of said fictitious Defendants is in some manner negligently

and/or legally responsible for the occurrences herein alleged, and that Plaintiffs' damages as

herein alleged were legally caused by such Defendants, and each of them.

16.

Plaintiffs are informed and believe and thereon allege that at all times herein

mentioned, Defendants, and each of them, were the partners, principals, agents, employees,

servants and joint venturers of each other Co-defendants, and in doing the things hereinafter

mentioned were acting within the course and scope of their authority and relationship as such

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partners, principals, agents, employees, servants and joint venturers with the permission,

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knowledge, and consent of each other co-Defendants.

IV. THE FACTS

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17.

PG&E' s safety record is an abomination. PG&E has

and continues to ~put its

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own profits before the safety of the California residents whom it serves. The Butte Fire fell on

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the fifth year anniversary of the rupture and explosion of PG&E' s 30-inch

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pipeline under a residential neighborhood in San Bruno, California. That explosion and ensuing

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fire killed eight people, injured dozens of others, and destroyed and damaged I 00 homes. The

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neighborhood still has not fully recovered from the horrifying experience. The CPUC fined

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PG&E $1.6 billion for safety violations that lead to the San Bruno Explosion.

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18.

transmission

In the years prior to the San Bruno Explosion, PG&E had several other incidents

that caused injury and death to California residents, and destroyed properties:
a.

1981: A PG&E gas main in downtown San Francisco exploded, forcing

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30,000 people to evacuate. It took workers nine hours to shut off the gas

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main' s manual shut off valves and stop the flow of gas that continued to

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feed the flames in the interim.

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b.

1992: Two people were killed and three others were injured when a PG&E

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gas line exploded in Santa Rosa. The pipeline was improperly marked,

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failing to give proper notice to contractors working in the area. A

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COMPLAINT

contractor hit the pipe with a backhoe, causing the pipe to leak several
months later.

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c.

1998: A CPUC report found that PG&E had misdirected $77.6 million that

was to be used to trim trees near power lines, which, as we know from the

instant case, is a necessary part of preventing wildfires, and redirected it

into corporate profits.

d.

1997: A Nevada County jury found PG&E guilty of 739 misdemeanor

counts of criminal negligence for a pattern of tree-trimming violations that

sparked a devastating 1994 wildfire in the Sierras. The fire burned down a

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schoolhouse and 12 homes near the scenic Gold Rush town of Rough and

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Ready.

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e.

1999: A rotten pine, which the government said PG&E should have

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removed, fell on a power line, starting the Pendola Fire. It burned for 11

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days and scorched 11, 725 acres, mainly in the Tahoe and Plumas national

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forests. PG&E paid a $14.75 million settlement to the U.S. Forest Service

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in 2009. That year, the utility also reached a $22.7 million settlement with

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the CPUC after regulators found PG&E had not spent money earmarked

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for tree trimming and removal toward those purposes.

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f.

2003: One third of San Francisco lost power following a fire at PG&E's

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Mission District Substation. The fire burned for nearly two hours before

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PG&E workers arrived on the scene to discover the damage.

g.

financial district, severely burning a woman who had been walking by.

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2005: A PG&E electrical transformer exploded beneath the San Francisco

h.

2008: An explosion and fire caused by a natural gas leak destroyed a

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residence in Rancho Cordova, California, killing one person, injuring five

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others and causing damage to several other nearby homes. The cause of

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the explosion was the use of a section of unmarked and out-of-

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COMPLA!NT

specification pipe with inadequate wall thickness that allowed gas to leak

from a mechanical coupiing instalied approximately two years earlier.

19.

Two years ago, PG&E and its contractors agreed to pay a $50.5 million to settle

claims over the Power Fire of2004 that burned 13,000 acres of Eldorado National Forest, and a

2008 blaze known as the Whiskey Fire that burned more than 5,000 acres of Mendocino National

Forest.

20.

As part of its system of providing electricity to members of the public in Amador

and Calaveras Counties, PG&E owned, installed, constructed, operated and maintained overhead

power lines, together with supporting poles and appwienances, throughout Amador and

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Calaveras Counties, for the purpose of conducting electricity for delivery to the members of the

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general public. Such lines existed near Butte Mountain Road, east of Jackson, California.

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21.

Electrical infrastructure is inherently dangerous and hazardous. The transmission

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and distribution of electricity requires an increased level of care in line with the increased risk of

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danger. Defendants, and each of them, had a duty to properly maintain and repair the electric

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transmission lines and to keep vegetation properly trimmed and maintained so as to prevent it

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coming in contact with power lines. In the construction, repair, maintenance and operation of the

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power lines, Defendants, and each of them, had an obligation to comply with legal standards,

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statutes and regulations, including, but not limited to Public Resource Code 4292, Public

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Resource Code 4293, CPUC General Order No. 95, and CPUC General Order No. 165.

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Defendants, and each of them, were aware that these requirements were the minimum standards

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to be followed, and that they were required to consider the surrounding circumstances when

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determining how to keep the lines safe. Defendants, and each of them, were further aware that a

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failure to do so constituted negligence and would expose members of the general public to risk of

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death or injury.

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22.

At all times herein mentioned, Defendants, and each of them, were aware that

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California continues to face one of the most severe droughts in history. In January 2015,

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Governor Jerry Brown declared a State of Emergency and directed state officials to take all

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necessary actions to prepare for water shortages. In addition, 2015 brought record temperatures.

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COMPLAINT

As a result, the danger of wildfires in the state became increasingly known. Such conditions,
2

along with above-cited regulations and guidelines regarding management of power lines and

vegetation in the vicinity of overhead electrical lines, put Defendants on notice that they needed

to properly maintain both PG&E's electrical infrastructure and the surrounding vegetation that

could impact it.

efforts last year as the drought worsened.

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8
9
10
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23.

In fact, the CPUC called on utilities to step up their vegetation management

Defendants failed to heed these obvious warnings and foreseeable risks, and meet

their obligations to properly maintain, repair, and inspect their power lines, and properly maintain
in accordance with regulations and the circumstances - the trees and other vegetation
surroundings PG&E's power lines.
24.

Plaintiffs are informed and believe that on September 9, 2015, a tree that had been

12

negligently maintained by PG&E and/or ACRT, Inc., and/or Trees, Inc., struck a 12,000-volt

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overhead power line that was owned and operated by PG&E. The resulting fire spread rapidly,

14

ultimately burning over 70,000 acres, destroying and damaging 4 7 5 residences, 343 outbuildings,

15

and 45 other structures. The fire also left tens of thousands of dead or dying trees, and the risk of

16

water pollution and erosion, in its wake. Two people lost their lives and thousands of residents

17

and property owners were significantly burdened.

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25.

Plaintiffs' father, Owen Goldsmith, lost his life to the Butte Fire. In addition,

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Owen Goldsmith's real and personal property, including five acres of heavily vegetated land,

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were destroyed.

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26.

As firefighters battled the blaze, PG&E acknowledged that it was likely that a tree

had made contact with the PG&E line in the vicinity of the ignition point. The CPlJC followed
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up PG&E's release with a statement that Cal Fire had narrowed the Butte Fire investigation to a

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single tree, and that Cal Fire had taken custody of the tree and the power line conductor.

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26

27.

Defendants' failures showed a conscious disregard for human life and were a

substantial factor in the fire and the death of Owen Goldsmith. Plaintiffs are informed and
believe that Defendants, and each of them, knew of the dangerous condition of PG&E's electrical

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infrastructure, the condition of the property, including the surrounding circumstances such as the
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COMPLAfNT

drought, high temperatures, and flammable vegetation surrounding PG&E's electrical

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infrastructure, ali of which resulted in the ignition and spread of the Butte Fire, and acted

recklessly and with careless and conscious disregard to human life and safety, ignoring the

obvious risks present, including warnings related to the specific tree at issue and the 12,000 volt

5 power-line in its vicinity. As a result, and to ensure that Defendants make public safety a priority
6

in the future, this action seeks punitive and exemplary damages against Defendants.

V. FIRST CAUSE OF ACTION

(Negligence - Wrongful Death Pursuant to C.C.P. 377.60, et seq.)

28.

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Plaintiffs hereby reallege and incorporate by reference each and every allegation

contained above as though the same were set forth herein in full.
29.

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Defendants, and each of them, breached their duties and obligations and (1) failed

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to comply with all applicable standards, statutes and regulations; (2) failed to timely and properly

13

maintain the subject overhead power line; (3) failed to properly maintain, including, but not

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limited to, trimming and pruning, all surrounding vegetation so as to prevent it from making

15

contact with the subject power line; (4) failed to take in to account all surrounding circumstances

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when maintaining the subject overhead power line and the surrounding vegetation.
30.

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As a direct, proximate, and legal result of the negligence of Defendants, and each

18

of them, and the resulting Butte Fire, Decedent Owen Goldsmith suffered burns and injuries,

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which resulted in his death.

31.

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As a direct, legal and proximate result of the incident described above, and the

death of her father, Decedent Owen Goldsmith, Plaintiff Stephanie Mathes has sustained a loss of
love, companionship, comfort, affection, society, solace, training and/or moral support.
32.

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As a direct, legal and proximate result of the incident described above, and the

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death of her father, Decedent Owen Goldsmith, Plaintiff Karen Goldsmith has sustained a loss of

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love, companionship, comfort, affection, society, solace, training and/or moral support.

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COMPLAIN1

VII. SECOND CAUSE OF ACTION

(Strict Liability- Wrongful Death Pursuant to C.C.P. 377.60, et seq.)

3
4

33.

Plaintiffs hereby reallege and incorporate by reference each and every allegation

contained above as though the same were set forth herein in full.
34.

Plaintiffs are informed and believe that the electrical line that is the subject of this

action was a 12,000-volt electrical transmission line. The electrical lines were located in and ran

through populated and highly vegetated areas. The area was also subject to and affected by the

California drought, high temperature, and flammable timber and vegetation. As such, Plaintiffs

are informed and believe that Defendants, and each of them, knew that the operation of the

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electrical transmission line was an ultra hazardous activity because any failure would result in

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serious injury and death.

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35.

Defendants, and each of them, are strictly liable for damage, injury and/or death

resulting from a failure of the subject line.

36.

As alleged herein, Decedent Owen Goldsmith lost his life, and Plaintiffs suffered

injury and damage as a result of Defendants' ultra-hazardous activity.

37.

The ultra-hazardous activity of Defendants, and each of them, was a substantial

factor in causing the injury and damage suffered by Plaintiffs.

3 8.

As a direct, legal and proximate result of the incident described in the preceding

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paragraphs, and the death of Decedent Owen Goldsmith, Plaintiffs have sustained a loss of love,

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companionship, comfort, affection, society, solace, training and/or moral support. The injury and

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damage suffered by Plaintiffs is of a kind to be expected as a result of ultra-hazardous activity.

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VIII. THIRD CAUSE OF ACTION

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(Survival Action Pursuant to C.C.P. 377.20, et seq. & Punitive Damages)

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25

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39.

Plaintiffs hereby reallege and incorporate by reference each and every allegation

contained above as though the same were set forth herein in full.
40.

As a direct result of the above-described incident and the failures of Defendants,

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and each of them, Decedent Owen Goldsmith suffered damage to his real and personal property.

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Additionally, Mr. Goldsmith lived for a period of time after being initially injured and he
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COMPLAINT

suffered injury and damages prior to his death. The Decedent sustained said damages in an
2

amount according to proof. Plaintiffs Stephanie Mathes and Karen Goldsmith are Decedent's

children and the successors in interest to Decedent, and Plaintiff Stephanie Mathes seeks to have

the court appoint her as representative of the Estate of Owen Goldsmith, for the purposes of

bringing an action under C.C.P. 377.30 for any and all damages suffered by Owen Goldsmith

prior to his death for, including but not limited to, damage to his real and personal property, and

his land and vegetation, as well as punitive damages. Decedent Owen Goldsmith would have

been entitled to recover any such damages under the causes of action for, inter alia, inverse

condemnation, negligence, negligence per se, and violations of statute and regulations.

IO

41.

The actions of these Defendants did in fact result in the death of Owen Goldsmith.

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Defendants, and each of them, failed to properly inspect, operate, and maintain the subject

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overhead power line. Defendants, and each of them, knew that in light of the surrounding

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drought conditions, including, but not limited to,

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vegetation came in contact with the power lines a fire was the likely result. Defendants, and each

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of them, further knew that a resulting fire was likely to pose a risk of serious injury or death to

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the general public, including the Decedent.

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42.

tinder~like

vegetation, that in the event that the

As detailed in IV, supra, PG&E's safety record is inexcusably dire. PG&E has

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had several other incidents that caused injury and death to California residents, and destroyed

19

properties, and has been subject to numerous penalties, including, but not limited to record fines

20

following the San Bruno Explosion, as a result of their failure to comply with safety standards,

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rules and regulations. Despite these fines and punishments, Defendants have failed to modify

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their behavior, continuing their practice of placing their own profits over safety and conducting

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their business with a conscious disregard for the safety and well-being of the public and property.

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As a result, in August of this year, the California Public Utilities Commission voted unanimously

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for an investigation into the corporate culture of PG&E to determine if PG&E's representations

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that safety was its priority matches PG&E's long-term practices.

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43.

Plaintiffa are informed and believe that the Butte Fire was the result of PG&E's

continued practice of prioritizing profits over safety, wherein they failed to properly maintain and
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COMPLAlNT

inspect their power lines, and the surrounding vegetation, knowing that the likely result was a fire
2

that would pose risk of serious injury and/or death, and damage to property. Even following the

fire, PG&E continues to fail in its obligations to the victims of the Butte Fire, cutting down trees

that it claims are fire damaged and letting those trees fall and remain in the toxic ash from the

fire, entering residents' property without permission, leaving trunks and trimmings on residents'

property, closing roads to perform work without any notice, and failing and refusing to

coordinate with the governmental agencies responsible for the clean up of the disaster.

8
9

44.

At all times prior to the subject incident, the conduct of Defendants, by act and/or

omission, demonstrated a wanton and/or reckless indifference for the required maintenance of

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PG&E' s electrical infrastructure and the surrounding vegetation, as well as a conscious disregard

11

for and a foreseeable risk of serious injury and death of others, including Owen Goldsmith. The

12

wrongful conduct of Defendants was more than just inadvertence, error of judgment or

13

negligence. Rather, Defendants conduct was despicable and showed malice as defined by Civil

14

Code 3294. The state has an extremely strong interest in imposing sufficiently high punitive

15

damages in actions where the malicious conduct of the defendants leads to the wrongful death of

16

one of its citizens. As a result, Plaintiffs request that the trier of fact, in the exercise of sound

17

discretion of the rights and safety of others, such that additional damages for the sake of example

18

and sufficient to punish said Defendants for their despicable conduct, in an amount reasonably

19

related to Plaintiffs' actual damages and Defendants' wealth, yet sufficiently large enough to be

20

an example to others and to deter Defendants and others from engaging in similar conduct in the

21

future.

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IX. PRAYER FOR RELIEF

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WHEREFORE, Plaintiffs pray judgment against Defendants, and each of them, as

24

follows:

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a.

For general damages in an amount according to proof;

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b.

For special damages in an amount according to proof;

27

c.

For the pecuniary value of the loss of companionship, comfort, affection, society,

28

care, solace and/or moral support;

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COMPLAJNT

d.

as aliowed under California Civil Code 3346;

For treble or double damages for wrongful injuries to timber, trees, or underwood,

e.

For punitive and exemplary damages in an amount according to proof under

California Public Utilities Code 2106, and as otherwise allowed by law;

f.

For prejudgment interest;

g.

For attorneys fees, expert fees, and consultant fees as allowed by law and Code of
Civil Procedure 1021.9, and costs of suit herein incurred; and

h.

For such other and further relief as the Court may deem appropriate.

Dated: October 26, 2015

10
COREY, LUZAICtl.z DE GHETALDI, NAST ARI

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/
I

& RIDDLE LLP

By:~--A AN..

LE, ESQ.,
Attorneys for Plaintiffs
Stephanie Mathes and Karen Goldsmith

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COMPLAINT