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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

Pursuant to 28 U.S.C. § 1746, I, James Mesterharm, state under penalty of perjury, that:

1. I am a Managing Director of AlixPartners, LLP (“AlixPartners”), which has a place of 

business at 909 Third Avenue, Floor 30, New York, New York 10022.

2. I am duly authorized to execute this second supplemental declaration on behalf of AP 

Services, LLC (“APS”), an affiliate of AlixPartners LLP.

3. Except as otherwise noted, I have personal knowledge of the matters set forth herein and, 

if called as a witness, would testify competently thereto.

4. I am filing this second supplemental declaration to supplement the disclosures that were 

included in my original declaration dated March 13, 2019 [ECF No. 867] and my supplemental 

declaration dated April 11, 2019 [ECF No. 1342]. 

5. Unless otherwise noted, references to AP below collectively refer to AP Holdings, LLP, 

APS, and each of their respective subsidiaries. APS wishes to disclose the following:

• Accenture, a professional to the Debtors, is a creditor, joint venture party, vendor, litigation party, 

material contract party, customer, director-affiliated company and professional to current and 

former AP clients in matters unrelated to the Debtors. Accenture is a current and former AP 

In re: 

PG&E CORPORATION,

 - and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

SECOND SUPPLEMENTAL DECLARATION OF 

JAMES MESTERHARM OF AP SERVICES, LLC 

Related Doc: Dkt. Nos. 867, 868, 1299, 1342

Case: 19-30088 Doc# 1773 Filed: 05/01/19 Entered: 05/01/19 09:43:16 Page 1 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

client in matters unrelated to the Debtors. Accenture is a former employer of current AP 

employees.

• Akin Gump Strauss Hauer & Feld (“Akin Gump”), a professional in this bankruptcy matter, is 

opposing counsel, counsel, a creditor and a professional to current and former AP clients in 

matters unrelated to the Debtor. Akin Gump is a current and former AP client in matters 

unrelated to the Debtor. Akin Gump is a vendor to AP.

• Baker & Hostetler LLP (“Baker & Hostetler”), a professional to the committee of unsecured 

creditors committee, is a professional, opposing counsel, and counsel to current and former AP 

clients in matters unrelated to the Debtors. Baker & Hostetler is a current AP client in matters 

unrelated to the Debtors. Baker & Hostetler is a vendor to AP.

• Centerbridge Partners, L.P., a notice of appearance party to the Debtors, and affiliates 

(“Centerbridge”) are adverse parties, parent companies, investors, shareholders, creditors, 

lenders, and litigation parties to current and former AP clients in matters unrelated to the Debtors. 

Centerbridge is a current and former AP client in matters unrelated to the Debtors. An AP board 

member is an investor in Centerbridge.

• KPMG LLP, a professional to the Debtors, and affiliates (“KPMG”) are professionals, adverse 

parties, vendors, material contract parties and creditors to current and former AP clients in 

matters unrelated to the Debtors. KPMG is a former AP client in matters unrelated to the Debtors. 

KPMG provides auditing services to AP. KPMG is a vendor to AP. KPMG is the former 

employer of several current AP employees.

• Lincoln Partners Advisors LLC, a creditor to the Debtors, is a professional to current and former 

AP clients in matters unrelated to the Debtors.

• Pension Benefit Guaranty Corporation (“PBGC”), a member to the committee of unsecured 

creditors, is a creditor, vendor and adverse party to current and former AP clients in matters 

unrelated to the Debtors. PBGC is a member of a UCC represented by AP in Bon-Ton Stores, 

Inc., The Great Atlantic & Pacific Tea Co. and VSI Liquidating Trust, bankruptcy matters 

unrelated to the Debtors.

• Perella Weinberg Partners, a professional in this bankruptcy matter, is a professional, vendor and 

creditor to current and former AP clients in matters unrelated to the Debtors.

• Sodexo, Inc., a notice of appearance party in this bankruptcy matter, and affiliates (“Sodexo”) 

are vendors and related parties to current and former AP clients in matters unrelated to the 

Debtors. Sodexo is a former AP client in matters unrelated to the Debtors. Sodexo is a vendor 

to AP.

• Western Asset Management Company, a member to the committee of unsecured creditors, is a 

lender, bondholder, noteholder, vendor, investor and creditor to current and former AP clients in 

matters unrelated to the Debtors.

• Willkie Farr & Gallagher, LLP (“Willkie Farr”), professional in this bankruptcy matter, is a 

professional, bondholder and counsel to current and former AP clients in matters unrelated to the 

Debtor. Willkie Farr is a current and former AP client in matters unrelated to the Debtor. Willkie 

Farr provides legal services to AP.

Case: 19-30088 Doc# 1773 Filed: 05/01/19 Entered: 05/01/19 09:43:16 Page 2 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

APS does not believe that the second supplemental disclosures above impact its 

disinterestedness. I continue to reserve the right to supplement APS’ disclosures in the event that APS 

discovers any additional connections that require disclosure. If any new material relevant facts or 

relationships are discovered or arise, APS will promptly file a supplemental declaration pursuant to 

Bankruptcy Rule 2014(a).

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

correct.

Dated: May 1, 2019 AP Services, LLC

 

James Mesterharm

Authorized Representative

Case: 19-30088 Doc# 1773 Filed: 05/01/19 Entered: 05/01/19 09:43:16 Page 3 of

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