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WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

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,

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).

Bankruptcy Case 

No. 19 -30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

FIRST SUPPLEMENTAL DECLARATION 

OF TOBIAS S. KELLER PURSUANT TO 

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

P. 2014(a) AND 2016 ON BEHALF OF 

KELLER & BENVENUTTI LLP 

Case: 19-30088 Doc# 2042 Filed: 05/16/19 Entered: 05/16/19 12:20:01 Page 1 of

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I, Tobias S. Keller, hereby declare pursuant 28 U.S.C. § 1746: 

1. I am a partner of the firm of Keller & Benvenutti LLP (the “Firm”), a law firm with 

offices at 650 California Street, Suite 1900, San Francisco, California 94108. 

2. I submit this Declaration as a supplement to my declaration dated March 13, 2019 

[Docket No. 870] (the “Original Declaration”) in support of the Application of Debtors Pursuant to 11 

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

& Benvenutti LLP as Co-Counsel for the Debtors Nunc Pro Tunc to the Petition Date.1

3. As anticipated in the Original Declaration, this declaration is submitted to supplement 

information disclosed in the Original Declaration; as additional information regarding parties in 

interest becomes available, a further supplemental declaration will be submitted to the Court reflecting 

such amended, supplemented or otherwise modified information. 

4. Since the filing of the Original Declaration, additional developments at the Firm and in 

the Chapter 11 Cases require the supplemental disclosures set forth in the following paragraphs. 

5. Berry Spears Joins the Firm as Of Counsel. Effective April 1, 2019, Berry Spears 

joined the Firm as an “of counsel” attorney. Mr. Spears is an attorney based in Austin, Texas, and had 

not been employed by a law firm on the Petition Date or at any time thereafter through and including 

April 1, 2019. Mr. Spears previously had been a partner at other law firms including, most recently,

Locke Lord LLP and Norton Rose Fulbright US LLP. Although he does not recall representing any of 

the following entities in connection with matters involving the Debtors, at prior firms (but not after he 

left those firms), Mr. Spears represented several parties in interest in the Chapter 11 Cases, as follow: 

a. Banking Institutions. Mr. Spears represented several banking institutions and/or 

their affiliates, whether in the capacity as a direct lender or an agent for itself and/or 

other lenders, as follow: Bank of America, N.A.; Bank of America Merrill Lynch; 

Bank of New York Mellon; BNP Paribas; Citibank, N.A.; JPMorganChase Bank, 

N.A.; Wells Fargo Bank, N.A.; CIBC (New York Branch); and US Bank, N.A. 

 

1

 Capitalized terms used but not otherwise herein defined have the meanings ascribed to such terms in 

the Original Declaration. 

Case: 19-30088 Doc# 2042 Filed: 05/16/19 Entered: 05/16/19 12:20:01 Page 2 of

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b. Contract Counterparties. Mr. Spears represented several contract counterparties 

and/or their affiliates, as follow: Anadarko; Apache Corp.; CIBC; Chevron USA; 

Conoco Phillips Company; Salt River Project; and Shell Energy. 

c. Insurers. Mr. Spears represented several insurers and/or their affiliates, as follow: 

Chubb National Insurance Company; Swiss Re; and Zurich Insurance Co. 

d. Other Parties in Interest. Mr. Spears represented vendors and/or their affiliates as 

follow: ATT Corp.; Baker Hughes; and Dell Financial Services. 

6. Newly Identified Professionals. We have become aware that certain professionals with 

which the Firm has contacts have been retained, or seek to be retained, by non-Debtor parties, as 

follow: 

a. Development Specialists, Inc. By order dated May 10, 2019, the Tort Claimants’ 

Committee retained Development Specialists, Inc. (“DSI”) as financial advisor. The 

Firm (i) previously represented DSI in its capacity as assignee for the benefit of 

creditors of Stion Corp., and (ii) presently represents DSI Assignments, LLC, an 

affiliate of DSI in its capacity as assignee for the benefit of creditors of Loyal3 

Holdings. One of the firm’s partners, Peter Benvenutti, previously represented DSI 

or affiliated entities in other matters. To the best of the Firm’s knowledge, none of 

these representations involved or involve any dispute with a Debtor. 

b. Scott McNutt/McNutt Law Group LLP. I am informed and believe that the 

proposed fee examiner, the Hon. Bruce Markell, proposes to employ as counsel 

Scott McNutt, Esq.2

 Mr. McNutt’s law firm, McNutt Law Group, LLP3, previously 

employed an associate currently employed by the Firm, Thomas Rupp. I am further 

informed and believe that there are unresolved disputes as between Mr. Rupp and 

McNutt Law Group, LLP and/or Mr. McNutt related to his employment at that firm. 

 

2

 There is another “Scott McNutt” identified in Schedule G as a contract counterparty. I do not 

believe that this is the same person as Mr. McNutt, the attorney. 

3

 It is my understanding that the McNutt Law Group, LLP and its partners are no longer 

practicing law as a firm. 

Case: 19-30088 Doc# 2042 Filed: 05/16/19 Entered: 05/16/19 12:20:01 Page 3 of

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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 May 16, 2019. 

 

/s/ Tobias S. Keller

Tobias S. Keller 

Case: 19-30088 Doc# 2042 Filed: 05/16/19 Entered: 05/16/19 12:20:01 Page 4 of

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