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BROWN RUDNICK LLP

David J. Molton (SBN 262075)

(DMolton@brownrudnick.com)

Eric R. Goodman (admitted pro hac vice)

(EGoodman@brownrudnick.com) 

Seven Times Square

New York, New York 10036

Telephone: (212) 209-4800

Facsimile: (212) 209-4801

BROWN RUDNICK LLP

Joel S. Miliband (SBN 077438)

(JMiliband@brownrudnick.com)

2211 Michelson Drive, Seventh Floor

Irvine, California 92612

Telephone: (949) 752-7100

Facsimile: (949) 252-1514

Attorneys for Fire Victim Trustee

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andCase No. 19-30088 (DM)

Chapter 11

(Lead Case) 

(Jointly Administered)

DECLARATION OF CATHY 

YANNI IN SUPPORT OF EX 

PARTE MOTION OF THE FIRE 

VICTIM TRUSTEE TO REDACT 

PERSONAL ADDRESS FROM 

ENGAGEMENT LETTER TO BE 

FILED WITH COURT

[No Hearing Requested]

PACIFIC 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).

I, Cathy Yanni, hereby declare under penalty of perjury that the following is true to the best 

of my knowledge, information, and belief:

1. I became Successor Trustee of the PG&E Fire Victim Trust (“Trustee”) on July 1, 

2022, pursuant to Section 5.2(d) of the Fire Victim Trust Agreement [Docket No. 8750-1). I am 

Case: 19-30088 Doc# 12965-1 Filed: 09/15/22 Entered: 09/15/22 15:16:40 Page 1

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duly authorized to make this Declaration (the “Declaration”) on behalf of the PG&E Fire Victim 

Trust (the “Trust,” and its beneficiaries, the “Fire Victims”). Unless otherwise stated in this 

Declaration, I have knowledge of the facts set forth herein and, if called as a witness, I would testify 

thereto.

2. I am an attorney at law licensed to practice law in the state of California. Since 1998 

I have been a neutral with JAMS, which specializes in the resolution of claims and legal disputes 

by providing efficient, cost-effective and impartial ways of overcoming barriers at any stage of 

conflict. I have extensive experience resolving mass tort claims, and have acted as a special master, 

mediator and administrator in multiple cases involving tens of thousands of claims, including claims 

for personal injury, property damage and business loss.

3. Prior to becoming Trustee, I served as the Court-appointed Claims Administrator for 

the Trust under the Debtors’ and Shareholder Proponents’ Joint Chapter 11 Plan of Reorganization 

Dated June 19, 2020 [Docket No. 8048] and, prior to that, pursuant to this Court’s Order Granting 

Application of The Official Committee of Tort Claimants Pursuant to 11 U.S.C. Sections 1103 and 

363 and Fed. R. Bankr. P. 2014 and 5002 to Retain and Employ Cathy Yanni as Claims 

Administrator Nunc Pro Tunc to January 13, 2020 dated April 14, 2020 [Docket No. 6759]. Before

serving as the Claims Administrator, I served as the Court-appointed Administrator of the Wildfire 

Assistance Program pursuant to this Court’s Supplemental Order (A) Approving Appointment of 

Administrator and Establishing Guidelines for the Wildfire Assistance Program and (B) Granting 

Related Relief dated June 5, 2019 [Docket No. 2409].

4. I submit this Declaration in support of the Ex Parte Motion of the Fire Victim Trustee 

to Redact Personal Address from Engagement Letter to be Filed with the Court (the “Motion”), 

filed concurrently herewith, which seeks authority to redact a personal address from an engagement 

letter to be filed with the Court as directed by the Order on Motion for Reconsideration [Docket 

No. 12929].

5. I am generally knowledgeable and familiar with the day-to-day operations of the 

Trust, including the Trust’s entry into the engagement letter referenced in the Motion. I am 

authorized to submit this Declaration on behalf of the Trust. 

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6. The facts set forth in this Declaration are based upon my personal knowledge, my 

review of relevant documents, and information provided to me by the Trust’s legal advisors. If called 

upon to testify, I would testify to the facts set forth in this Declaration. 

7. I believe that disclosing the personal address of the Authorized Agent could subject 

him to unsolicited contact that may be perceived as intrusive or harassing as a result of his 

connection to the Trust and to the third-party litigation that was a subject of the Motion of William 

B. Abrams Pursuant to Federal Rule of Bankruptcy Procedure 2004 for Entry of an Order 

Authorizing Discovery and Hearings Regarding the Administration of The Fire Victim Trust [Dkt. 

No. 12440] and the Motion for Reconsideration and Related Relief from the Order Granting Motion 

of the Fire Victim Trustee to File Redacted Versions of Certain Retention Agreements Until 

Litigation Related to Such Retention Agreements is Finally Resolved and Pursuant to Federal Rule 

of Civil Procedure 59(e).

8. In addition, I believe that the personal information sought to be redacted from the 

engagement letter is wholly irrelevant to the “provisions for compensation” that the Trust was 

directed to file. 

9. For these reasons, I believe the redaction of the personal address of the Authorized 

Agent is warranted. 

I declare under penalty of perjury, as set forth in 28 U.S.C. § 1746, that the foregoing is true 

and correct to the best of my knowledge, information, and belief. 

Executed this 15th day of September, 2022, in San Francisco, California. 

By: 

Cathy Yanni, in her capacity as 

Trustee of the PG&E Fire Victim Trust

Case: 19-30088 Doc# 12965-1 Filed: 09/15/22 Entered: 09/15/22 15:16:40 Page 3

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