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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

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)

DECLARATION OF JANET LODUCA IN 

SUPPORT OF THE APPLICATION PURSUANT 

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

2014(a) AND 2016 FOR ORDER AUTHORIZING 

THE DEBTORS TO RETAIN COBLENTZ PATCH 

DUFFY & BASS LLP AS SPECIAL COUNSEL 

NUNC PRO TUNC TO THE PETITION DATE

Date: July 9, 2019 

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

Place: United States Bankruptcy Court 

Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: July 2, 2019 at 4:00 p.m. (PT)

Case: 19-30088 Doc# 2597 Filed: 06/18/19 Entered: 06/18/19 18:33:16 Page 1 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Pursuant 28 U.S.C. § 1746, I, Janet Loduca, hereby declare as follows:

On January 29, 2019 (the “Petition Date”), PG&E Corp. and Pacific Gas and Electric 

Company (the “Utility”), as debtors and debtors in possession (collectively, “PG&E” or the 

“Debtors”) each commenced with this Court a voluntary case under chapter 11 of title 11 of the 

United States Code (the “Bankruptcy Code”). I submit this Declaration in support of the Debtors’ 

Application (the “Application”)1, pursuant to section 327(e) of the Bankruptcy Code and Rule 

2014(a) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), for authority to 

employ and retain Coblentz Patch Duffy & Bass LLP (“Coblentz” or the “Firm”) as special counsel 

to the Debtors effective nunc pro tunc as of January 29, 2019. 

This Declaration is provided pursuant to Paragraph D.2 of the U.S. Trustee Guidelines for 

Reviewing Applications for Compensation and Reimbursement of Expenses Filed under 11 U.S.C. § 

330 by Attorneys in Larger Chapter 11 Cases, effective November 1, 2013 (the “Fee Guidelines”). 

Except as otherwise indicated herein, the facts set forth in this Declaration are based upon my 

personal knowledge, information provided to me by the Debtors’ employees or advisors, or my 

opinion based upon knowledge and experience as Senior Vice President and General Counsel. I am 

authorized to submit this Declaration on behalf of the Debtors.

The Debtors recognize that a comprehensive review process is necessary when selecting and 

managing chapter 11 counsel to ensure that their bankruptcy professionals are subject to the same 

client-driven market forces, security, and accountability as professionals in non-bankruptcy 

engagements. Coblentz has extensive experience advising and representing the Debtors on various 

matters related to their real estate transactions and related matters. Specifically, Coblentz has 

advised the Debtors for over 30 years on issues related to Debtors’ the acquisition of improved and 

unimproved properties, the disposition of surplus properties, and the negotiation of all types of 

leases. Based on its experience and relationship with the Debtors, I believe that Coblentz is well 

qualified to perform the services described herein and in the Application efficiently and effectively.

 1 Capitalized terms used but not otherwise defined herein shall have the same meanings ascribed to 

such terms in the Application.

Case: 19-30088 Doc# 2597 Filed: 06/18/19 Entered: 06/18/19 18:33:16 Page 2 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Coblentz has confirmed to me that the Firm has not varied its PG&E billing rates or the 

material terms of this engagement because of these bankruptcy cases or the geographic location of 

these bankruptcy cases. Coblentz has advised me that its current customary U.S. hourly rates range 

from $525 to $1,100 for partners, $540 to $925 for counsel, $375 to $525 for associates, and $165 to 

$395 for paraprofessionals, which rates all have been reduced in accordance with the terms of this 

engagement. It is my understanding that Coblentz reviews and adjusts its billing rates annually, 

typically on or around January 1 of each year. Coblentz has advised me that it will inform the 

Debtors of any adjustment to its existing rate structure.

I am informed by Coblentz that its attorneys’ billing rates are aligned with, or are below, the 

billing rates of its peer firms. To the extent that there is any disparity in such rates, however, I 

nevertheless believe that Coblentz’s retention by the Debtors is warranted in these cases for the 

reasons set forth in the Debtors’ Application. 

I understand that Coblentz’s fees and expenses will be subject to periodic review on a 

monthly, interim, and final basis during the pendency of these Chapter 11 Cases by, among other 

parties, a fee examiner or fee committee (if appointed), the Office of the United States Trustee and 

the Debtors, and in accordance with the terms of the Bankruptcy Code, the Bankruptcy Rules, the 

Bankruptcy Local Rules, and any orders of the Court governing the procedures for approval of 

interim compensation of professionals retained in these Chapter 11 Cases.

As Senior Vice President and General Counsel, I supervise and manage legal fees and 

expenses incurred by the Debtors’ outside counsel. Either I or a senior lawyer in our legal 

department reviews the Debtors’ outside counsel invoices and authorizes all legal fees and expenses 

prior to the payment of such fees to outside counsel. In so doing, I assure that all requested fees and 

expenses are reasonable and correspond with necessary or beneficial services rendered on behalf of 

the Debtors and their estates. The aforementioned review and approval process does not differ when 

the Debtors employ outside counsel for non-bankruptcy matters. Moreover, Coblentz has informed 

me that the Debtors will be provided with the opportunity to review all invoices and request 

adjustments to such invoices to the extent that the Debtors determine that such adjustments are 

necessary and appropriate, which requests will be carefully considered by Coblentz. 

Case: 19-30088 Doc# 2597 Filed: 06/18/19 Entered: 06/18/19 18:33:16 Page 3 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

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

inquiry, the foregoing is true and correct.

Dated: June 18, 2019 

Case: 19-30088 Doc# 2597 Filed: 06/18/19 Entered: 06/18/19 18:33:16 Page 4 of

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