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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

 

Robert A. Julian (SBN 88469) 

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 ROBERT A. 

JULIAN IN SUPPORT OF MOTION OF 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS FOR RELIEF 

FROM AUTOMATIC STAY TO 

PERMIT STATE COURT JURY TRIAL 

OF 2017 TUBBS WILDFIRE CLAIMS 

Date: July 23, 2019 

Time: 9:30 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 2844 Filed: 07/02/19 Entered: 07/02/19 18:16:23 Page 1 of

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ROBERT A. JULIAN, under penalty of perjury, declares: 

1. I am a partner at Baker & Hostetler LLP, counsel to the Official Committee of Tort 

Claimants of PG&E Corporation and Pacific Gas and Electric Company (collectively, “PG&E” or 

the “Debtors”) in these chapter 11 cases. 

2. I submit this Declaration in support of the Motion of the Official Committee of Tort 

Claimants for Relief from Automatic Stay to Permit State Court Jury Trial of 2017 Tubbs Wildfire 

Claims (“Motion”). 

3. Unless otherwise stated in this Declaration, I have personal knowledge of the facts 

set forth herein. 

4. Attached hereto as EXHIBIT A is a true and correct copy of the report issued by 

the California Department of Insurance, “North Bay Insured Losses from the October 2017 

Wildfires,” dated January 31, 2018, available at http://www.insurance.ca.gov/0400-news/0100-

press-releases/2018/upload/nr013-2018NorthBayFireUpdate013118.pdf. 

5. Attached hereto as EXHIBIT B is a true and correct copy of the report issued by 

the California Department of Insurance, “North Bay Insured Losses from the October 2018 

Wildfires,” dated April 30, 2019, available at http://www.insurance.ca.gov/0400-news/0100-pressreleases/2019/upload/nr041-19InsuredLosses2018Wildfires050819.pdf. 

6. Attached hereto as EXHIBIT C is a true and correct copy of PG&E’s Form 10-Q, 

for the period ended March 31, 2019 from the Debtors’ website. 

7. Attached hereto as EXHIBIT D is a true and correct copy of the press release issued 

by the California Department of Insurance, “Valley and Butte fires cause an estimated $1 billion in 

insurance losses,” dated Jan. 25, 2016.1 

8. Attached hereto as EXHIBIT E is a true and correct copy of a letter, dated Feb. 6, 

2019, from the CPUC to Hon. William H. Alsup as part of the PG&E criminal case, Case No. 14-

CR-00175-WHA. 

 

1

 Originally available at http://www.insurance.ca.gov/0400-news/0100-press-releases/2016/release009-16.cfm. I 

pulled the report from this site as well. Because the original link no longer works, the attached copy of the press 

release is from the Wayback Machine, which is a free service provided by the Internet Archive (archive.org), “a 

nonprofit organization dedicated to archiving the Internet and other digital materials, and providing public access to 

these records.” See The Internet Archive’s Policy for Responding to Information Requests, https://archive.org/legal/. 

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9. Attached hereto as EXHIBIT F is a true and correct copy of the Judicial Caseload 

Profile, California Northern, During the 12-Month Periods Ending March 31, 2014 Through 2019, 

available at page 66 of the following PDF: https://www.uscourts.gov/statistics/table/na/federalcourt-management-statistics/2019/03/31-1. 

10. Attached hereto as EXHIBIT G is a true and correct copy of PG&E’s Form 8-K, 

dated January 13, 2019. 

11. Attached hereto as EXHIBIT H is a true and correct copy of a May 28, 2019 email 

from Eric Goodman of Baker to Debtors’ counsel Kevin Orsini requesting the Debtors to produce 

PG&E’s prior Settlement Data (including subrogation insurers’ settlement data) of claims arising 

out of the 2015 Butte fire and the San Bruno explosion and all data that PG&E has used or may use 

to estimate tort claims, including, without limitation, data used to estimate tort claims for SEC 

filings and board reports, including without limitation the Debtors’ SEC disclosures that the 

Debtors’ losses on the fires could exceed $30 billion. Attached hereto as EXHIBIT I is a true and 

correct copy of the TCC’s May 31, 2019 notice of deposition and request for production of the 

same document data on June 6, 2019. The Debtors did not produce any of the data or documents 

in response to the TCC’s May 28 and 31 requests. 

12. Attached hereto as EXHIBIT J is a true and correct copy of In re Pac. Gas & Elec. 

Co., Case No. 01-30923 DM, PG&E’s Motion for Order Determining Procedures for Estimating 

Certain Claims for Plan Feasibility Purposes, Dkt. No. 5008, (Bankr. N.D. Cal. Mar. 1, 2002). 

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

correct to the best of my knowledge and belief. 

Executed on July 2, 2019 

 /s/ Robert A. Julian 

By: Robert A. Julian 

Case: 19-30088 Doc# 2844 Filed: 07/02/19 Entered: 07/02/19 18:16:23 Page 3 of

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