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28 BAKER

& HOSTETLER, LLP

ATTORNEYS AT LAW

SAB FRANCISCO, CA 

 

Robert A. Julian (SBN 99469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8875 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official 

Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 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) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

FIRST SUPPLEMENTAL VERIFIED 

STATEMENT OF CECILY A. DUMAS 

IN SUPPORT OF THE APPLICATION 

OF THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS PURSUANT TO 11 

U.S.C. § 1103 AND FED. R. BANKR. P. 

2014 AND 5002, FOR AN ORDER 

AUTHORIZING RETENTION AND 

EMPLOYMENT OF BAKER & 

HOSTETLER, LLP, EFFECTIVE AS OF 

FEBRUARY 15, 2019 

Case: 19-30088 Doc# 1998 Filed: 05/14/19 Entered: 05/14/19 14:32:42 Page 1 of

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BAKER 

&

HOSTETLER, LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA 

- 2 - 

CECILY A. DUMAS, under penalty of perjury, declares: 

1. I am a partner in the Financial Restructuring Group of Baker & Hostetler, LLP 

(“Baker” or the “Firm”), counsel to the Official Committee of Tort Claimants (the “Committee”) 

of PG&E Corporation (the “Holding Company”) and Pacific Gas and Electric Company (the 

“Utility,” and collectively with the Holding Company, the “Debtors”) in these chapter 11 cases 

(the “Cases”). 

2. I submit this First Supplemental Verified Statement (“First Supplemental

Statement”) pursuant to section 1103(b) of title 11 of the United States Code, 11 U.S.C. §§ 101-

1532 (as amended, the “Bankruptcy Code”), and Rules 2014 and 5002 of the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”). This First Supplemental Statement updates 

Baker’s disclosures of connections set forth in the “DECLARATION OF CECILY A. DUMAS 

IN SUPPORT OF THE APPLICATION OF THE OFFICIAL COMMITTEE OF TORT 

CLAIMANTS PURSUANT TO 11 U.S.C. § 1103 AND FED. R. BANKR. P. 2014 AND 5002, FOR 

AN ORDER AUTHORIZING RETENTION AND EMPLOYMENT OF BAKER & HOSTETLER, 

LLP, EFFECTIVE AS OF FEBRUARY 15, 2019” (the “2014 Statement”). 

3. Unless otherwise stated in this First Supplemental Statement, I have knowledge of 

the facts set forth herein and, if called as a witness, I would testify thereto. Certain of the 

disclosures set forth herein relate to matters not within my personal knowledge, but rather within 

the personal knowledge of other attorneys and employees at Baker and are based on information 

provided by them to me. 

Background

4. On January 29, 2019 (the “Petition Date”), the Debtors filed voluntary petitions 

for relief under chapter 11 of the Bankruptcy Code (the “Cases”) in the United States Bankruptcy 

Court for the Northern District of California (the “Court”). On January 31, 2019, the Court entered 

an order consolidating the Cases for joint administration [ECF 207]. 

5. The Debtors continue to manage their assets and operate their businesses as 

debtors-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee 

has been appointed in the Cases. 

Case: 19-30088 Doc# 1998 Filed: 05/14/19 Entered: 05/14/19 14:32:42 Page 2 of

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BAKER 

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HOSTETLER, LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA 

- 3 - 

6. On February 15, 2019, the Office of the United States Trustee (“U.S. Trustee”)

filed an Appointment of the Official Committee of Tort Claimants [ECF 453]. Following the 

resignation of Richard Heffern from the original committee and the addition of Tommy Wehe, on 

February 21, 2019, the U.S. Trustee filed the Amended Appointment of the Official Committee of 

Tort Claimants [ECF 530]. The members of the Committee are: (i) GER Hospitality, LLC, in its 

capacity as an individual claimant; (ii) Kirk Trostle; (iii) Tommy Wehe; (iv) Angelo Loo; (v) 

Karen K. Gowins; (vi) Agajanian, Inc.; (vii) Susan Slocum; (viii) Samuel Maxwell; (ix) Karen 

Lockhart; (x) Wagner Family Wines-Caymus Vineyards; and (xi) Gregory Wilson. 

7. The Committee conducted a meeting on February 15, 2019, at which the Committee 

duly selected Baker as counsel to represent it during the pendency of the Cases. The Court 

approved Baker’s employment as counsel to the Committee by order dated April 10, 2019 [ECF 

1331]. 

Supplemental Disclosures 

8. Approximately 17 years ago, in 2001, the Utility’s predecessor commenced chapter 

11 case no. 01-30923 (“First Bankruptcy Case”) and confirmed a plan of reorganization in that 

case in 2003. The Firm makes the following supplemental disclosures concerning connections of 

attorneys of the Firm relating to the First Bankruptcy Case prior to such attorneys’ affiliation with 

the Firm.1 

9. In 2008, Friedman & Springwater LLP f/k/a Friedman Dumas & Springwater LLP 

(“F&S”), was engaged by the reorganized debtor in the First Bankruptcy Case to assist it in 

connection with an attorney fee dispute with Travelers Casualty & Surety Co. of America. I 

assisted F&S in the Travelers engagement, and, to the best of my recollection given the intervening 

decade, billed fewer than 25 hours to the matter. In addition to the foregoing, and based upon my 

recollection, F&S may have represented the reorganized Utility in non-public matters that are 

wholly unrelated to these Cases at or about the same time as the foregoing representation. F&S’s 

 

1

 In connection with my transition to the Firm from Pillsbury Winthrop Shaw Pittman LLP in early 2019, I was 

required to re-register with the Court’s electronic filing system, also known by the shorthand of “CM/ECF.” 

Pursuant to the CM/ECF procedures, my assistant prepared numerous notices to be removed from the CM/ECF 

notification list for inactive matters, including the First Bankruptcy Case. The re-registration process triggered a 

notice for removal of my name as counsel to PG&E in that case. 

Case: 19-30088 Doc# 1998 Filed: 05/14/19 Entered: 05/14/19 14:32:42 Page 3 of

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ATTORNEYS AT LAW

SAN FRANCISCO, CA 

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engagement with respect to the fee dispute was concluded before the San Bruno gas pipeline 

explosion and all the wildfires caused by the Debtors, and it preceded the filing of these Cases by 

a decade. I concluded my affiliation with F&S in 2012. 

10. In the First Bankruptcy Case, PG&E Corporation (which did not file for 

bankruptcy) was represented by Dewey Ballantine LLP (“Dewey”) as co-counsel to Weil Gotshal 

& Manges LLP. Jorian Rose, a partner of Baker who is currently assisting the Firm in representing 

the Committee, was employed by Dewey as a junior associate and performed assignments in 

connection with the anticipated filing by the Utility. Mr. Rose left Dewey around the time the 

First Bankruptcy Case. Given the intervening 17 years, Mr. Rose has no specific recollection of 

the assignments he may have worked on while at Dewey in connection with the First Bankruptcy 

Case. 

11. Jerry Bloom, Counsel to the Firm, as a partner of White & Case, represented Delta 

Power, the co-chair of the official committee of unsecured creditors in the First Bankruptcy Case. 

Milbank Tweed Hadley & McCloy LLP, which represents the Official Committee of Unsecured 

Creditors in these Cases, also represented the committee in the First Bankruptcy Case. 

12. To the best of my knowledge, no other attorneys of Baker participating in the Firm’s 

representation of the Committee worked on the First Bankruptcy Case or represented the Debtors 

or their predecessors in either instance while affiliated with a prior firm. 

13. In addition to the foregoing, the Debtors have identified Burns & McDonnell 

Engineering Inc as a vendor in these Cases. A Baker partner now represents Burns & McDonnell 

Engineering Company Inc. in unrelated matters. 

Baker’s Disinterestedness 

14. To the best of my knowledge and except as otherwise set forth in my first 

declaration and herein, the partners, counsel, associates and employees of Baker: (i) do not have 

any connection with the Debtors, their known creditors, other known or potential parties in interest, 

their respective attorneys or accountants or other professionals, the U.S. Trustee for Region 17 or 

any person employed in the San Francisco office of the U.S. Trustee, or any United States 

Case: 19-30088 Doc# 1998 Filed: 05/14/19 Entered: 05/14/19 14:32:42 Page 4 of

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ATTORNEYS AT LAW

SAN FRANCISCO, CA 

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Bankruptcy Judge for the Northern District of California; and (ii) do not represent any other entity 

having an adverse interest in connection with these Cases. 

 Pursuant to 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing is true 

and correct. 

Executed on May 14, 2019 

/s/ Cecily A. Dumas_______ 

Cecily A. Dumas 

Case: 19-30088 Doc# 1998 Filed: 05/14/19 Entered: 05/14/19 14:32:42 Page 5 of

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