Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

DECLARATION OF MARK J. SWEENEY 

IN SUPPORT OF VALERO’S MOTION 

TO FILE REDACTED DOCUMENT AND 

TO FILE DOCUMENTS UNDER SEAL 

[Related to Dkt No. 1862] 

Debtors.

 Affects PG&E Corporation 

 Affects Pacific Gas and Electric Company 

 Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

Case: 19-30088 Doc# 1972 Filed: 05/10/19 Entered: 05/10/19 10:50:08 Page 1 of

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Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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I, Mark J. Sweeney, hereby declare as follows: 

1. I am an attorney, licensed to practice in the State of California and admitted to practice 

before this Court. I am an employee of Pacific Gas and Electric Company (the “Utility”). I am 

authorized to submit this declaration in support of Valero Refining Company-California’s 

(“Valero’s”) Motion To File Redacted Document And To File Documents Under Seal; Declaration 

of Richard A. Lapping (the “Lapping Decl.”) (Dkt. No. 1862) (the “Sealing Motion”) on behalf of 

the Utility in the above-captioned chapter 11 cases (the “Chapter 11 Cases”). I have personal 

knowledge of the facts stated herein and, if called upon, I could and would competently testify 

thereto. 

2. On February 5, 2019, Valero filed a Motion for Relief from Stay (Dkt. No. 315) (the 

“Stay Motion”) along with the Declaration of John Cox (the “Cox Declaration”) (Dkt. No. 315-1) 

in support of the Stay Motion to allow the completion of pretrial proceedings, trial, post-trial 

motions and any appellate proceedings in or in connection with VALERO REFINING COMPANYCALIFORNIA, a Delaware corporation v. PACIFIC GAS & ELECTRIC COMPANY, a California 

corporation, pending as Case No. 2:17-cv-01350-TLN-EFB in United States District Court for the 

Eastern District of California before the Honorable Troy L. Nunley, United States District Judge 

(the “District Court Action”). 

3. PG&E produced to Valero in discovery in the District Court Action copies of two 

insurance policies (“Policies”) of PG&E, which were designated as “CONFIDENTIAL—

SUBJECT TO PROTECTIVE ORDER” under a protective order in the District Court Action. 

4. On April 29, 2019, the Court approved Valero and the Utility’s Stipulation for Order 

Approving Stipulated Protective Order and Authorizing Filing Under Seal (Valero Motion for Relief 

from Automatic Stay) (Dkt. No. 1752) (the “Protective Order”). That Protective Order provided 

that the protective order entered in the District Court Action would apply to the proceedings for the 

Stay Motion. 

5. On May 6, 2019, Valero filed its Sealing Motion, and filed conditionally under seal 

the following documents, pursuant to Bankruptcy Code § 107(b), 11 U.S.C., Federal Rule of 

Case: 19-30088 Doc# 1972 Filed: 05/10/19 Entered: 05/10/19 10:50:08 Page 2 of

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Bankruptcy Procedure 9018, the Court’s New District Wide Procedures for Electronically Filing 

Sealed and Redacted Documents, and District Court Civil Local Rule 79-5, made applicable by 

Bankruptcy Local Rule 1001-2(a): 

a. Exhibit 2 to the Lapping Decl., which is a copy of the unredacted version of 

Valero’s Motion for Relief from Stay, highlighted to indicate proposed redactions. 

Exhibit 2 is not filed in the public record of this case. 

b. Exhibits 3 and 4 to the Lapping Decl., which are true and correct copies of the 

Policies. Exhibits 3 and 4 are not filed in the public record of this case. 

6. Pursuant to Civil Local Rule 79-5, made applicable by Bankruptcy Local Rule 1001-

2(a), I make this declaration on behalf of the Debtors to establish that all designated material is 

sealable. Specifically, the Debtors request that Exhibits 2, 3, and 4 of the Lapping Decl. documents 

be maintained under seal. 

7. The Policies, which are attached as Exhibits 3 & 4 to the Lapping Decl., consist of and 

identify confidential, nonpublic, proprietary and highly sensitive business information, namely the 

details of the insurance coverage for certain claims against PG&E. The documents contain 

confidential information concerning the Debtors’ internal practices, business practices, competitive 

position, and financial state. This is sensitive information and public disclosure of this information 

presents a risk of undermining the Debtors’ litigation position and business relationships, would cause 

it harm with respect to its customers, would put the Debtors at a competitive disadvantage, and would 

needlessly impede the Debtors’ efforts towards a successful reorganization. 

8. Similarly, the proposed redactions in Exhibit 2 cite to and reference the details of the 

Policies, which as described above consist of and identify confidential, nonpublic, proprietary and 

highly sensitive business information. 

9. The Debtors have taken reasonable steps to preserve the confidentiality of information 

of the type contained, identified, or cited to in the exhibits sought to be sealed, including but not limited 

to designating the exhibits as “CONFIDENTIAL—SUBJECT TO PROTECTIVE ORDER” when 

produced in discovery in the District Court Action. 

Case: 19-30088 Doc# 1972 Filed: 05/10/19 Entered: 05/10/19 10:50:08 Page 3 of

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I declare under penalty of perjury that the foregoing is true and correct. 

Executed on May 10, 2019 

 By: _/s/ Mark J. Sweeney_________________ 

 MARK J. SWEENEY 

Case: 19-30088 Doc# 1972 Filed: 05/10/19 Entered: 05/10/19 10:50:08 Page 4 of

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