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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO 

EXHIBIT H

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DocuSign Envelope ID: 369F6750-B22A-48AB-BDE9-A88D1 B48FE5F 

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I, ELIZABETH "LIBBY" ANDRESEN, pursuant to 28 U.S.C. § 1746, declare as follows: 

1. Until November 8, 2018, I lived in Paradise, California, in a single-family home 

3 with my mother, brother, nephew, son, and daughter-in-law. 

4 2. At approximately 7:30 a.m. on November 8, 2018, without any warning, flaming 

5 embers began dropping from the sky onto our two-acre property, setting off ground fires on 

6 impact. Within moments, a tornado-like wind, filled with burning embers, ripped through the 

7 property, setting the ground and trees on fire. 

8 3. I ran back into the house, rounded up the family and pets, and jumped into a car 

9 with my son, daughter in-law, and four of our pets. My brother loaded our 85-year-old mother into 

10 his car ( along with our two other pets) and evacuated alongside us. 

11 4. Shortly after we evacuated, our home-along with almost everyone else's in 

12 Paradise-burned the ground. 

13 Since that day, my life has been a living hell. 

14 

5. 

6. It began with me spending 32 days in a shelter taking care of my 85-year old 

15 mother and eleven other seniors who contracted norovirus while in the shelter and sharing a single 

16 working toilet. I can only describe this experience as a complete loss of human dignity for my 

17 mother and the other senior citizens. (I, too, ended up contracting norovirus in the shelter.) 

18 7. After the shelter, my mother and I moved into an RV at the Silver Dollar 

19 Fairgrounds. It was there that we learned that my mother has terminal cancer in her pancreas, 

20 colon, spleen, kidney, and lung. So she had to go through several procedures, including biopsies, 

21 while we were sharing a leaky, dilapidated, rat-infested motor home in the middle of a hastily22 constructed refugee camp. 

23 8. My mother and I are now living in a HUD housing in Chico, which is all that we 

24 can afford. Because it's an upstairs unit without an elevator, my mother-who struggles to walk 

25 and puts herself in serious danger every time she has to go up or down stairs-is only able to leave 

26 the house for her medical appointments. 

27 9. Like most of the other fire victims I know, we desperately need emergency 

28 financial assistance. 

DECL. OF ELIZABETH "LIBBY" ANDRESEN CASE No. 19-BK-30088 (DM) 

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DocuSign Envelope ID: 369F6750-B22A-48AB-BDE9-A88D1 B48FE5F 

10. For one thing, we need to be able to afford to rent a ground-level apartment, so that 

2 I can more easily get my mother to her appointments and so that my mother doesn't have to risk 

3 falling every time she leaves the house. 

4 11. We also need to purchase all sorts of medical equipment for my mother that we 

5 cannot currently afford, like prescription glasses (which burned in fire, and which Medicare won't 

6 cover), a wheelchair, a walker, a shower chair, a commode, and adult diapers. 

7 12. We also need to purchase a car that I can easily assist my mother getting into and 

8 out of. (Our regular car burned in the fire, and while we were recently fortunate enough to be 

9 gifted a truck, it's a completely impractical, I-ton diesel-engine behemoth that I struggle mightily 

10 to load my mother into and out of.) 

11 13. I also need to purchase business supplies so that I can start working again. (Before 

12 the fire, I owned and operated a residential and commercial cleaning business, and I plan to re13 start that business as soon as I can afford the necessary supplies.) 

14 14. I understand it may be a long time before we recover everything that we are owed. 

15 But in the meantime, ifwe receive at least some emergency financial assistance, we'll be able to 

16 start putting at least some pieces of our life back together. 

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I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. Executed on April 29, 2019, at Chico, California. 

Gr%~ 

~ 'llat9&ttt1~tbby" Andresen 

DECL. OF ELIZABETH "LIBBY" ANDRESEN 2 CASE No. l 9-BK-30088 (DM) 

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DocuSign Envelope ID: 45698488-A 1 E7-4271-AE2E-E11 C227BB264 

I, LANDON ANDRESEN, pursuant to 28 U.S.C. § 1746, declare as follows: 

1. On November 8, 2018, I was living in Paradise, California, with my mother, my 

grandmother, my uncle, my cousin, and my wife, Estefania, who was then eight and a half 

months pregnant. 

2. At approximately 7:30 a.m. on November 8, 2018, without any warning, flaming 

embers began dropping from the sky onto our two-acre property, setting off ground fires on 

impact. Within moments, a tornado-like wind, filled with burning embers, ripped through the 

property, setting the ground and trees on fire . 

3. I called 911 for help, but the operator told me all of Paradise was on fire and that I 

had to "get out of Paradise now." There was not going to be any help on the way. I immediately 

ran back to the house to warn my family, grabbed our most vital papers, and with my mother, 

pregnant wife, and four pets jumped into a car to evacuate. My uncle, along with my 85-year old 

grandmother and other two pets, evacuated in a second car. 

4. Shortly after we evacuated, our home-along with almost everyone else's in 

Paradise-burned to the ground. 

5. We found a pet-friendly shelter (a converted church gymnasium) where we could 

stay, but because the smoke was so thick and norovirus had spread throughout the shelter, I had 

to move with my pregnant wife (who was due in two weeks) to the pastor's office in a separate 

area. 

6. At the shelter, my wife went into labor. We took her to Enloe Medical Center, 

where our beautiful daughter was born. 

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7. Because there was no way we could bring our daughter back to the shelter, where 

norovirus was still spreading and people were deathly ill, a very kind family gifted us free rent in 

an apartment for 6 months. The apartment is in Sacramento, more than two hours away from my 

family, but I had to do what was best for my wife and daughter. 

8. So on the day that my wife and daughter left the hospital, we moved to 

Sacramento without our family or any financial help. 

9. It is now almost six months later, and our apartment will no longer be free starting 

next month. We're not going to be able to afford to live in this apartment for very long. While I 

was able to find a job at a lumber yard (my old job was lost due to the fire), the pay is not enough 

to afford the home and also care for our daughter, who is now five months old. The apartment 

costs three times more than the rent we paid in Paradise. 

10. Because our baby is still nursing and unable to go to day care, my wife must stay 

home to care for her full-time, and so she cannot work. 

11. To add to our struggle, when we tried to visit our family for Easter, we were in a 

car accident and totaled our Volvo. We now have only one car, which I must use to get to the 

lumber yard. My wife has no car she can use while caring for our baby. 

12. Now, our money is running out and we don't know what we're going to do next 

month, since we won't be able to afford rent once our lease is up. All of the money we have is 

put towards caring for our five-month-old baby, and there is simply not enough money to get by 

as new parents. 

13. I understand it may be a long time before we recover everything that we are owed. 

But in the meantime, if we receive at least some immediate financial assistance, we' 11 be able to 

start putting at least some pieces of our life back together. 

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DocuSign Envelope ID: 45698488-A 1 E7-4271-AE2E-E11 C227BB264 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. Executed on April 29, 2019, at Sacramento, California. 

[

DocuSigned by: 

~6793499 ... 

Landon Andresen 

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DocuSign Envelope ID: 01 0AFD46-448D-4B31-97E5-3263915BF5BF 

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I, PAUL ANDRESEN, pursuant to 28 U.S.C. § 1746, declare as follows: 

1. Until November 8, 2018, I lived in Paradise, California, in a single-family home 

3 with my mother, sister, son, nephew, and nephew's wife. 

4 2. At approximately 7:30 a.m. on November 8, 2018, without any warning, flaming 

5 embers began dropping from the sky onto our two-acre property, setting off ground fires on 

6 impact. Within moments, a tornado-like wind, filled with burning embers, ripped through the 

7 property, setting the ground and trees on fire. 

8 3. We all evacuated immediately-me with our 85-year-old mother and two of our 

9 pets in one car, and the rest of the family (except my son, who was in Oroville) in another. 

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4. Shortly after we evacuated, our home-along with almost everyone else's in 

Paradise-burned the ground. 

5. After spending a month living in a tent at a shelter, and then two months at the 

13 Silver Dollar Fairgrounds, I'm now living with my son Brandon in a 27-foot trailer in Chico. We 

14 are struggling to make ends meet. 

15 6. I'm a general contractor and home inspector by trade, and I lost a lifetime 's worth 

16 of tools-approximately $50,000 worth-in the Camp Fire. Because most ofmy work was in the 

17 Paradise area, I also lost essentially my entire clientele. 

18 7. I'm now trying to get back into business, but can't afford to buy a whole new set of 

19 tools for contracting work, and am struggling to generate home inspection business in Chico. 

20 8. My son, who is a full-time college student at Butte College, also lost all his 

21 belongings-including his laptop and college textbooks-in the fire, and we aren't able to afford 

22 to replace everything he lost. 

23 10. I understand it may be a long time before we recover everything that we are owed. 

24 But in the meantime, if we receive at least some emergency financial assistance, we' ll be able to 

25 start putting at least some pieces of our life back together. 

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* 

DECL. OF PAUL ANDRESEN 

* * 

CASE No. l 9-BK-30088 (DM) 

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I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. Executed on April 29, 2019, at Chico, California. 

~ DocuSigned by: 

Paul 

~ Andresen 

DECL. OF PAUL ANDRESEN 2 CASE No. l 9-BK-30088 (DM) 

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1 DECbaRATION OP Tracv Lvnne Ambrister 

2 l, Tracy Lynne Arnbrister, make this decraratlon based upon my personal knowledge. I am 

3 over the age of 18, am competent to testify, and do so as follows: 

4 At the time of the North Bay Fires I lived In Santa RO!a, CA. My primary and only 

5 residence was destroyed in toe fire. I lost my home and all of my possessions. And I had no 

6 insurance. 

7 Immediately prior to the fire I lived with my son who was twelve years old at the time, in a 

8 house on a larger property, where we malntairied a sense of privacy and comfort. The home had a 

9 separate, private entranc:e; a bedroom; our furniture; and all of our clothe.s, belongings, and 

10 memorabilia. My son and I had our own beds and own rooms. We had one bathroom, a kitchen, 

11 extended living space, an outdoor patio, and a backyard. In our monthly rent, water, cable, 

12 garbage disposal, and an other utilities were Included. 

13 Since the fire, my son and I were forced out of our home with no family or support system 

14 nearby. We had nowhere to 90, no clothes, shoes, or basic toiletries. We ultimately had no choice 

15 but to seek help from my son'$ peternel grandfather. We stayed on the floor there for the initial 

16 seventeen days and borrowed belongings. Thereafter, I found an apartment that is costing me 

17 $700 more a month for a smaller unit with no privacy. I have given the one bed we have to my 

18 son and I sleep on the sofa or the floor. We have received some donated plates, cups, and 

19 silverware and very limited clothes. As a result of all this Immediate and unexpected loss, we are 

20 continuously under extreme financial pressure and burden and have difficulty making ends meet. 

21 In addition to the Increase In our monthly rental payments, I now also pay for all the individual 

22 utilities. The financial burden has had a domino effe~ OI" my abl!lty to replace our belongings, 

23 timely payments, and my credit. The car I used to escape the fires needs repair, but only once our 

24 immediate needs are r:net can I consider that expense. Aside from the livelihood we have lost, my 

25 son and I are suffering from the emotional distress of trying to escape the fires unscathed. I have 

26 panic attacks and anxiety but cannot afford to seek out treatment or help and my son has been 

27 silently coping, but would also benefit from professional guidance and/or counseling. 

28 lt is imperative that I receive funds immediately to obtain stable and habitable housing, buy 

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food, clothes and other basic life necessities, and to Just generally get back on my feet. 

I declare under penalty of perjury under the laws of the State of California that the above is 

true and correct and that If called to do so, would competently so testify. Executed on this~ 

day of April, 2019 at ltJ11t!AfJ/Ut....) San Francisco, California. 

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April 29, 2019 

This fire has caused me so many problems that it's almost unreal. I lost 35 years of my life 

when this fire took out my home. Like many others, now I have been forced to move away because 

of the high cost of new homes in California, especially for the ones near Paradise. 

I am on Social Security Disability and have a very limited income. I lost my security that I had 

established by purchasing my home. I thought I did a good job making sure I was secure for the rest 

of my life and this fire destroyed all that. I knew I could cover my expenses for the rest of my life with 

the purchase of this home. That has all changed now. 

So many things I had acquired over the years are gone. I have no records of my past life 

before the fire. All the tools that I have acquired as an aircraft mechanic and pilot over the years are 

gone. My classic Dodge pickup that was fully restored is gone. It took me 20 years to get it in classic 

car shape. Educational records, awards, musical instruments, military records, and certifications 

vanished. 

My health has even suffered from this incident. I have lost 30 pounds from the stress and the 

fact that I have been homeless for several months. My relationship with a good lady suffered from all 

the stress and not knowing where I was going to live and what I was going to do. I never realized how 

much stress could affect the body and emotions until I actually had to experience it for myself. 

After the fire, I had no place to go. I temporarily moved in with my son in Texas because I was 

tired of living in my car. I have now purchased a home in Texas because I cannot afford to return to 

Paradise. 

All the friendships I had established have been cast to the four winds. I am having to try and 

start over in an area where I know absolutely no one. My son is my closest family and he's still three 

hours driving time away from me because of the new cost of living that has been thrust upon me. 

I worked very hard to establish my life there in California, and was very happy with the home 

and the community that we chose for ourselfs. Starting over at 59 years old really sucks. I will survive 

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but it's been very difficult. When I learned PG&E started this fire I thought to myself what a total 

disregard for life and property these people showed towards the local residents of the area. As if we 

didn't matter. 

I am still feeling the effects of what this fire and the people responsible for it have done to my 

life and I probably will for a long time. I really notice it when I go to repair something and I don't have 

the tools or materials to do it. Something I used to take for granted. Starting over with nothing but 

the clothes on you back and the car you escape from the flames in is not a lot. All the lost records, 

pictures, possessions and friendships have been my devastating reality. 

PG&E should be held responsible for their actions that caused this devastating fire – for all 

the people who were suddenly made homeless, turning their lives upside down, and destroying their 

lives and property. I am one of them. Many people were like me on fixed incomes and will never get 

back what we once had. I would like that security back for us all. 

Thank you for your time and consideration in this matter. 

Sincerely, 

Kevin Burnett 

Camp Fire Survivor 

Marshall, Texas 

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_DECLARATION OF ROBERT DEWALT 

I, Robert DeWalt, make this declaration based upon my personal knowledge. I am over the 

age of 18, am competent to testify and do so as follows: 

At the time of the Camp Fire I lived in Paradise, California. My primary and only residence 

was destroyed in the fire. My family and I lost our home, and all of our possessions. And we had no 

insurance. 

Immediately prior to the fire I lived at 1429 West Dottie Lane in Paradise, California with my 

wife Marie and several of our adult children . We lost the double-wide two bedroom, one bathroom 

home we rented, the one bedroom, one bathroom granny unit, and a fifth wheel trailer that 

comfortable housed our family on a half-acre lot. We knew we were in trouble by 9:00a.m. the 

morning of the fire. Everyone loaded up, and we fled the property by 9:15 a.m. as the fire barreled 

toward us. Not only did we lose our homes and everything that we owned, we also became stuck in 

traffic during out evacuation. The flame caught up with us, and we feared for our lives as we 

moved slowly through a tunnel of fire for nearly an hour as we attempted to get to safety. 

Since the fire, my family has been dispersed. My wife Marie and I stayed at my sister's 

house for a few weeks after the fire, while our children stayed with other family members. On 

Thanksgiving, Marie and I moved into a travel trailer on a friend's property outside of Chico. On 

December 29, 2018, we moved our trailer to a permanent RV parking spot in Oroville, where we 

have been since. Our children continue to bounce around, staying with friends or family that are 

able to take them in. We have lost the security and comfort that we had created in our home, and 

our new normal costs us all of our income, with little capacity to look toward the future. 

It is imperative that we receive funds immediately to obtain stable and habitable housing, 

buy food, clothes and other basic life necessities, and to just generally get back on our feet. 

I declare under penalty of perjury under the laws of the State of California that the above is 

true and correct and that if called to do so, would competently so testify. Executed on this 28th day 

of April, 2019 at 330 Wall Street, Suite 20, Chico, California. 

Robert DeWalt 

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DECLARATION OF LEE ANN ESTEP 

 I, Lee Ann Estep, make this declaration based upon my personal knowledge. I am over the 

age of 18, am competent to testify and do so as follows: 

 At the time of the Camp Fire I lived in Oroville, CA. My primary and only residence was 

destroyed in the fire. I lost my home, and all of my possessions. And I had no insurance. 

 Immediately prior to the fire I lived in a house with my three children. It had a nice yard 

and could accommodate my two dogs and three cats. Everyone had their own room. 

 Since the fire, I have been living in Oroville. Immediately following my evacuation we 

stayed in Oroville for about one week in an RV. After moving around for about 3 weeks I found a 

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th wheel and was able to return with my three kids. The 5th wheel is much smaller with much less 

privacy for everyone. Additionally, one of my sons is autistic and the complete destruction of his 

surroundings and routine has been devastating. Fortunately, we were able to parked the trailer 

behind my work, where we have stayed for about 6 months. The 5th wheel runs off of a generator 

which we need to run 24 hours a day and it burns through 5 gallons of gas/day. With gas prices 

going up this has been extremely challenging. 

 It is imperative that I receive funds immediately to obtain stable and habitable housing, buy 

food, clothes and other basic life necessities, and to just generally get back on my feet. 

 I declare under penalty of perjury under the laws of the State of California that the above is 

true and correct and that if called to do so, would competently so testify. Executed on this ____ day

of April, 2019 at Oroville, California. 

 _________________________________________ 

 LEE ANN 

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1 DECLARATION OF SIMMON FLAGG 

2 I, Simon Flagg, make this declaration based upon my personal knowledge. I am over the age 

3 of 18, am competent to testify, and do so as follows : 

4 At the time of the Camp Fire I lived in Paradise, California. My primary and only residence 

5 was destroyed in the fire. I lost my home, and all of my possessions. And I had no insurance. 

6 Immediately prior to the fire I lived at 5020 Edgewood Lane in Paradise with my fiance, 

7 Cammie Sarmiento, a roommate, and our pets. We rented a three bedroom house on a 20 acre 

8 ranch where we lived, and I worked. I operated an art and jewelry design studio in the garage. I 

9 am also a certified diver, and all of my equipment was stored at the home. 

10 We fled our home as the fire approached on November 9th, 2018. Cammie and I got 

11 separated. Cammie was still recovering from pair of back surgeries she had endured about two 

12 months earlier, but was able to leave the property before the fire cut off their road. Cut off from 

13 the road, I fled on foot down the side of the canyon, across it, and back up the other side. 

14 Since the fire, we lived with a friend in Chico for two weeks, then we moved in with my 

15 mother in Forest Ranch of February 1st. On February 1st, Cammie's mother lent us a fifth wheel 

16 trailer that the Paradise City Counsel allowed us to place on the back five acres of our rental 

17 property away from the destroyed structures. We pay $15 a day to run a generator, $200 each 

18 time we need water delivered to fill up our water tank, and on May pt, we will resume paying rent 

19 to the property owner. 

20 Cammie's recovery from back surgery was difficult before the fire, but the constant moving, 

21 uncomfortable settings, and extra care has been challenging and uncomfortable for us both. She is 

22 on disability, and my income stream was destroyed in the fire. I briefly found work on a road crew, 

23 only to lose it when PG&E declared bankruptcy. I am dedicating all of my energy that isn't focused 

24 on Cammie's recovery and the fire on seeking new employment. 

25 It is imperative that we receive funds immediately to obtain stable and habitable housing, 

26 buy food, clothes and other basic life necessities, and to just generally get back on our feet. 

27 I declare under penalty of perjury under the laws of the State of California that the above is 

28 true and correct and that if called to do so, would competently so testify. Executed on this 25th day 

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DECLARATION OF ISA JACOBY

I, Isa Jacoby, make this declaration based upon my personal knowledge. I am 

over the age of 18, am competent to testify and do so as follows:

At the time of the North Bay Fires, I lived in Glen Ellen, California. My primary 

and only residence was destroyed in the fire. I lost my home, my catering business, my 

rental income, and all of my possessions. I had no insurance coverage.

Immediately prior to the fire, I lived at 2775 Cavedale Road in Glen Ellen, 

California, which was my primary residence, as well as my rental property, and the 

location where I performed work for my catering business. On my .7 acre property was 

my 1,200 square foot home with a deck, a 1,000 square foot apartment, a barn, and 

several sheds. My property, at which I lived for 25 years in the hills of Glen Ellen, had 

olive trees and a small vineyard, and also had an open view that overlooked the Valley of 

the Moon to Mt. Tamalpais. I did not have a mortgage on my property, and a young 

couple with a baby lived in the apartment on my property and paid $1,000 in rent each 

month. My livelihood depended on my property, and my home was comfortable, private 

and stable. 

Since the fire, I have been living off and on with my mother in a small townhome 

located in Sonoma, California, and have also stayed with friends in Sebastopol, 

California. I am grateful to my mother and friends for allowing me to stay with them but, 

at those locations, I felt uncomfortable not to have my own space.

FEMA provided me with a lump sum of $30,000 to $35,000 in assistance, which I 

used to purchase a 25-foot trailer for my property. Unfortunately, there were no 

additional funds for me to utilize to purchase personal possessions or to assist me with 

my business. Due to the Nuns Fire, I lost all of my business equipment, as well as the 

space that I used to conduct my catering business. In order to earn an income, I must 

now rent a kitchen space or only take jobs that have a kitchen available to use. This, in 

addition to no longer receiving rental income, has caused my work to be sporadic and 

has significantly lowered my overall earnings.

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Temporary power, for which I spent $5,000 to obtain, was restored to my 

property in February 2019; however, I still do not have running water. I have a natural 

spring that I share with a neighbor that I am able to use with a hose, but my trailer does 

not have a filtration system to rid the spring water of sediment. Therefore, I do not have 

a working shower or restroom on my property. I have been residing at my property since 

February 2019, but have been required to travel between my trailer and the residence 

occupied by my mother in order to shower. The once vast view of green trees and 

hillsides now appears to be darkened and burnt. Due to the loss of my home and rental 

income, and the substantial decline in my work and business earnings, my life continues 

to be a challenge and I feel insecure, anxious and uncertain about what my future holds.

It is imperative that I receive funds immediately to obtain stable and habitable 

housing, buy food, clothes and other basic life necessities, and to just generally get back 

on my feet.

I declare under penalty of perjury under the laws of the State of California that 

the above is true and correct and that if called to do so, would competently so testify. 

Executed on this 30th day of April, 2019 at Sonoma, California.

_________________________________________

Isa Jacoby

 Isa Jacoby

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