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CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019 

Tel: 212 474 1000 

Fax: 212 474 3700 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@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,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF JANE KIM IN SUPPORT 

OF EX PARTE MOTION OF DEBTORS 

PURSUANT TO B.L.R. 9006-1 REQUESTING 

ORDER SHORTENING TIME FOR HEARING 

ON APPLICATION OF DEBTORS PURSUANT 

TO 11 U.S.C. § 327(a) AND FED. R. BANKR. P. 

2014(a) AND 2016 FOR AUTHORITY TO 

RETAIN AND EMPLOY COMPASS 

LEXECON, LLC AS ECONOMIC 

CONSULTANTS TO DEBTORS NUNC PRO 

TUNC TO PETITION DATE 

Related Document: Dkt. 1756 

[No hearing requested]

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# 1760 Filed: 04/29/19 Entered: 04/29/19 18:39:40 Page 1 of

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I, Jane Kim, do hereby declare under penalty of perjury as follows: 

1. I am a partner at Keller & Benvenutti LLP, attorneys for PG&E Corporation and 

Pacific Gas and Electric Company, as debtors and debtors in possession (collectively, “PG&E” or 

the “Debtors”). 

2. I submit this declaration in support of the Motion of the Debtors (the “Motion to 

Shorten”), pursuant to Rule 9006-1 of the Bankruptcy Local Rules for the United States Bankruptcy 

Court for the Northern District of California, for entry of an order shortening time for a hearing on 

May 9, 2019, at 9:30 a.m. (the “Omnibus Hearing”), on the Application of the Debtors Pursuant to 

11 U.S.C. § 327(a) and Fed. R. Bankr. P. 2014(a) and 2016 for Authority to Retain and Employ 

Compass Lexecon, LLC, Nunc Pro Tunc to the Petition Date (the “Application”), filed 

contemporaneously herewith. The Debtors request that written objections, if any, be due by 4:00 pm 

on May 6, 2019. 

3. On April 29, 2019, at 12:30 p.m. (Pacific Time), I sent an e-mail to Timothy Laffredi 

for the Office of the United States Trustee inquiring as to whether the United States Trustee would 

consent to notice being shortened on the Application as set forth above. As of the filing of this 

declaration, I have not received a response. 

4. Ample cause exists to hear the Application on shortened time at the Omnibus Hearing 

on May 9, 2019, at 9:30 a.m. On April 24, 2019, the Court held a hearing (the “April 24 Hearing”) 

at which it considered the relief requested in the Application of the Official Committee of Unsecured 

Creditors for Entry of an Order Pursuant to 11 U.S.C. §§328(a) and 1103 and Fed. R. Bankr. P. 

2014(a) for Authorization to Retain and Employ FTI Consulting, Inc. as Financial Advisor Nunc Pro 

Tunc to February 12, 2019 (the “FTI Retention Application”) [Dkt. No. 1212], filed by the Official 

Committee of Unsecured Creditors (the “Creditors Committee”). 

5. At the April 24 Hearing, the Debtors reiterated the concerns stated in their statement 

of non-opposition with respect to the FTI Retention Application [Dkt. No. 1560], that Compass not 

be disqualified from engagement by the Debtors by reason of FTI’s retention by the Creditors 

Committee in light of the affiliation between FTI and Compass. Accordingly, the Court reserved 

decision and continued the hearing on the FTI Retention Application to the hearing on May 9, 2019, 

Case: 19-30088 Doc# 1760 Filed: 04/29/19 Entered: 04/29/19 18:39:40 Page 2 of

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at 9:30 a.m. (Pacific Time), to allow the Debtors to file the Application and have it heard on 

shortened notice at the same hearing, to avoid, in the Court’s own words, “this potential of the 

[Debtors’] own interests being jeopardized by whatever legal consequences of not letting the 

[Debtors] hire and retain Compass” as a result of FTI’s retention by the Creditors Committee. 

6. Hearing the Application at the Omnibus Hearing will not have any effect on the 

current schedule for these Chapter 11 Cases. 

 

I declare under penalty of perjury that, to the best of my knowledge and after reasonable 

inquiry, the foregoing is true and correct and that this declaration was executed at San Francisco, 

California, on April 29, 2019. 

/s/ Jane Kim

Jane Kim 

Case: 19-30088 Doc# 1760 Filed: 04/29/19 Entered: 04/29/19 18:39:40 Page 3 of

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