1

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

SULLIVAN HILL REZ & ENGEL Electronically Filed 05/15/19

A Professional Law Corporation

James P. Hill, SBN 90478

Christopher V. Hawkins, SBN 222961

600 B Street, Suite 1700

San Diego, California 92101

Tel: (619) 233-4100

Email: hill@sullivanhill.com

hawkins@sullivanhill.com

Gerald Singleton, SBN 208783

John C. Lemon, SBN 175847

SINGLETON LAW FIRM, APC

450 A Street, 5th Floor

San Diego, CA 92101

Tel: (619) 771-3473

Email: gerald@slffirm.com

john@jcl-lawoffice.com

Attorneys for SLF Fire Victim Claimants

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION,

and

PACIFIC GAS AND ELECTRIC 

COMPANY

Debtors

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

Case No. 19-30088 (DM)

Chapter 11

(Lead Case–Jointly Administered)

DECLARATION OF GERALD SINGLETON 

IN SUPPORT OF OBJECTION BY THE 

SINGLETON LAW FIRM FIRE VICTIM 

CLAIMANTS TO PG&E’S EXCLUSIVITY 

MOTION (DOC. 1795)

Date: May 22, 2019

Time: 9:30 a.m. (Pacific)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Hon. Dennis Montali

Opposition Deadline: May 15, 2019, 4 p.m. (PDT)

Affects:

PG&E Corporation

Pacific Gas & Electric Company

Both Debtors

* All papers shall be filed in the Lead Case,

 No. 19-30088 (DM).

Case: 19-30088 Doc# 2019-1 Filed: 05/15/19 Entered: 05/15/19 15:56:36 Page 1

of 3
2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

I, Gerald Singleton, state and declare as follows:

1. I am an attorney duly licensed to practice law in the states of California and Texas, the 

United States Supreme Court, the Ninth Circuit Court of Appeals, and all District Courts in the State 

of California. I am the senior partner of the Singleton Law Firm, APC, and am counsel for the SLF 

Fire Victim Claimants (“SLF Claimants”).

2. I make this declaration in support of the Objection by the Singleton Law Firm Fire 

Victim Claimants to PG&E’s Exclusivity Motion (“Objection”). All capitalized terms not otherwise 

defined herein shall have the meanings ascribed to them in the Objection. I have personal knowledge 

of the facts set forth in this declaration, and if called as a witness, I could and would testify 

competently to those facts.

3. Although the Singleton Law Firm represents over 4,700 victims, the PG&E 

bankruptcy attorneys have stated that they will speak only to counsel for the Tort Claims Committee

and there has been no substantive communications with counsel for the SLF Fire Victim Claimants.

4. Because PG&E has refused to communicate substantively with counsel the SLF Fire 

Victim Claimants, there has made no progress in negotiations. However, based on communications 

with other lawyers in this proceeding, it appears that PG&E is trying to negotiate a matrix to facilitate 

mass settlements (akin to a class action) rather than settling claims on an individual basis. 

5. Mass settlement is not in the best interest of the fire victims. The Singleton Firm has 

settled well over one thousand fire cases – including over 700 from the Butte Fire with PG&E – and 

is uniquely credentialed to appreciate that the fire victims must maintain the right to have their cases 

handled individually. Taking a one-size-fits-all approach and resolving these claims en masse would 

be a windfall to PG&E at the expensive of these victims, who still deserve to be made whole –

PG&E’s elective bankruptcy notwithstanding.

6. The Butte Fire occurred in 2015. The Singleton Firm still represents over 700 

individual victims (in more than 300 cases) who have been waiting since 2015 and who were on the 

cusp of being compensated for their losses when PG&E elected to declare bankruptcy. 

7. As PG&E’s Chief Financial Officer admitted in his sworn testimony at the Creditor’s 

Hearing on April 29, even taking the worst current projections for its fire losses into account ($30 

Case: 19-30088 Doc# 2019-1 Filed: 05/15/19 Entered: 05/15/19 15:56:36 Page 2

of 3
Case: 19-30088 Doc# 2019-1 Filed: 05/15/19 Entered: 05/15/19 15:56:36 Page 3

of 3