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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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 Boulevard

Suite 1400

Los Angeles, CA 90025

Telephone: 310.820.8800

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

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

□ 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)

DECLARATION OF BRENDAN J. 

MURPHY IN SUPPORT OF MOTION 

OF OFFICIAL COMMITTEE OF TORT 

CLAIMANTS PURSUANT TO 

BANKRUPTCY SECTIONS 105(a) AND 

107(b) AND BANKRUPTCY RULE 9018 

FOR ENTRY OF AN ORDER 

AUTHORIZING THE FILING UNDER 

SEAL OF THE UNREDACED 

DECLARATION OF BRENT C. 

WILLIAMS (Related to Dkt. No. 1777)

Case: 19-30088 Doc# 2024 Filed: 05/15/19 Entered: 05/15/19 16:16:04 Page 1 of

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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1. I, Brendan J. Murphy, am a Managing Director at Lincoln Partners Advisors LLC 

(“Lincoln”), which has its principal office at 500 West Madison Street, Suite 3900 Chicago, IL. I 

am authorized to execute this declaration on behalf of Lincoln. Unless otherwise stated in this 

declaration, I have personal knowledge of the facts set forth herein.

2. I am making this declaration in support of the Official Committee of Tort Claimants’ 

Motion (“Motion”) for Entry of an Order Authorizing the Filing Under Seal of the Unredacted 

Declaration of Brent C. Williams (“Unredacted Declaration”). Capitalized terms used but not 

defined herein shall have the same meaning ascribed to them in the Motion.

3. The TCC wishes to file the Unredacted Declaration in support of their Objection to 

the Debtors’ Wildfire Assistance Program Motion. 

4. In order to better understand how the Debtors determined the amount of the fund 

proposed in the Wildfire Assistance Program Motion, I provided a list of questions to the Debtors 

on Monday, May 6, 2019. 

5. On Friday May 10, 2019 the Debtors responded to our questions, attached to the 

Unredacted Declaration as Exhibit C (“Debtors’ Responses”). Those responses were marked 

“Highly Confidential – Professionals’ Eyes Only.”

6. Portions of the Unredacted Declaration are based upon the information provided in 

the Debtors’ Responses. The portions of the Unredacted Declaration and Exhibit C to the 

Unredacted Declaration, which are based upon the Debtors’ Responses, have been redacted in the 

version of the declaration filed on the docket in support of the Objection. 

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

is true and correct. Executed on May 15, 2019.

Brendan J. Murphy

Case: 19-30088 Doc# 2024 Filed: 05/15/19 Entered: 05/15/19 16:16:04 Page 2 of

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