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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

EXHIBIT 3

STRUNK DECLARATION 

Case: 19-30088 Doc# 2306-6 Filed: 05/31/19 Entered: 05/31/19 13:27:55 Page 1

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

LOS ANGELES

Robert A. Julian (SBN 99469) 

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. 

□ 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 PHILIP R. 

STRUNK IN SUPPORT OF OBJECTION 

OF THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS TO MOTION OF 

THE DEBTORS FOR ORDER (I) 

ESTABLISHING DEADLINE FOR 

FILING PROOFS OF CLAIM, 

(II) ESTABLISHING THE FORM AND 

MANNER OF NOTICE THEREOF, AND 

(III) APPROVING PROCEDURES FOR 

PROVIDING NOTICE OF BAR DATE 

AND OTHER INFORMATION TO ALL 

CREDITORS AND POTENTIAL 

CREDITORS (DKT. NO. 1784) 

Date: June 11, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: May 28, 2019

Case: 19-30088 Doc# 2306-6 Filed: 05/31/19 Entered: 05/31/19 13:27:55 Page 2

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ATTORNEYS AT LAW

LOS ANGELES

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PHILIP R. STRUNK declares as follows under penalty of perjury: 

1. I am a Partner at BrownGreer PLC (“BrownGreer”). I have experience as a 

lawyer handling class action settlements and notices; as a claims administrator designing and 

implementing class action settlements, notice plans, and notices to claimants and counsel; and 

as a project team leader working in support of courts, administrators, trustees, and special 

masters involved in multiple claim proceedings. I have personal knowledge of the facts stated 

herein except as to matters where I indicate otherwise, and as to those matters, I believe them to be 

true. 

2. I make this declaration in support of the Objection of the Official Committee of Tort 

Claimants to Motion of the Debtors for Order (I) Establishing Deadline for Filing Proofs of Claim, 

(II) Establishing the Form and Manner of Notice Thereof, and (III) Approving Procedures for 

Providing Notice of Bar Date and Other Information to All Creditors and Potential Creditors, filed 

concurrently herewith. 

3. BrownGreer has specialized in settlement administration since it was founded in 

2002. We are experienced in the legal and administrative aspects of the design, approval, and 

implementation of settlement programs, as well as the operation of claims facilities to provide 

damages payments or other benefits for the resolution of multiple claims through class action 

settlement, bankruptcy reorganization, voluntary agreement, or other aggregation vehicles. As 

part of our work, BrownGreer regularly handles complex and confidential case-specific 

information in class action or mass tort contexts (for example, federal MDLs or California 

JCCPs). BrownGreer is often appointed by a supervising court to perform the functions 

described above. BrownGreer and its principals have performed crucial administration, 

information management, or claim evaluation roles in more than 75 major programs involving 

approximately 31 million class members and the disposition of over $33 billion in payments to 

qualifying claimants. A few examples of these engagements include: 

a. In re Oil Spill by the Oil Rig “Deepwater Horizon” in the Gulf of Mexico, 

on April 20, 2010, MDL Docket No. 2179 (E.D. La.), in which BrownGreer served the Claims 

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LOS ANGELES

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Administrator in processing hundreds of thousands of claims resulting in payments of more than 

$11.6 billion. 

b. In re A.H. Robins Company Inc., Debtor (In re Dalkon Shield Claimants 

Trust), MDL Docket No. 211 (Bankr. E.D. Va.), in which the principals of BrownGreer 

administered the settlement program created in the Chapter 11 bankruptcy proceeding of the A.H. 

Robbins Company to resolve claims arising from the use of Dalkon Shield intrauterine devices, 

evaluating over 300,000 claims and distributing more than $3 billion. 

c. In re Vioxx Products Liability Litigation, MDL Docket No. 1657 (E.D. La.), 

a $4.85 billion voluntary settlement program to resolve approximately 60,000 claims arising from 

the use of prescription painkillers. 

d. In re Chinese-Manufactured Drywall Products Liability Litigation, MDL 

Docket No. 2047 (E.D. La.), a $721 million class action settlement and remediation program 

addressing approximately 25,000 homes containing defective drywall manufactured in China. 

e. In re National Football League Players’ Concussion Injury Litigation, MDL 

Docket No. 2323 (E.D. Pa), an uncapped class action settlement fund to resolve claims by retired 

National Football League players relating to repetitive head impacts, with payable awards of $657 

million to date. 

f. In re DePuy Orthopaedics, Inc., ASR Hip Implant Products, MDL Docket 

No. 2197 (N.D. Ohio), a voluntary settlement program for claims relating to metal-on-metal hip 

implant devices, in which BrownGreer has reviewed over 10,000 claims and distributed over $3 

billion. 

4. On December 31, 2018, Judge Curtis Karnow in JCCP No. 4955, California North 

Bay Fire Cases, issued Case Management Order 5, entitled “Collection and Production of Case 

Management Order Compliance Information and Subrogation Files.” That Order appointed 

BrownGreer to collect and organize case-specific information of common interest to plaintiffs’ 

counsel in a central repository to facilitate and track compliance with previously established Case 

Management Orders in that case. The Court’s appointment followed BrownGreer’s efforts to 

confirm compliance with previous case management orders entered with the JCCP court, including 

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LOS ANGELES

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CMO 1, which addressed the damage claims set forth in the Notice of Adoption and Short Form 

Complaints, and CMO 2, which addressed witness specific information. BrownGreer worked with 

the individual law firms representing plaintiffs to compile compliance reports. I am informed and 

believe that these reports were provided to PG&E. BrownGreer’s efforts on these tasks were 

substantial, literally hundreds of hours, and took place during the months before the entry of CMO 

5 in December of 2018. 

5. In collecting the plaintiff-specific data, BrownGreer consulted and collaborated with 

lead attorneys representing both individual plaintiffs and subrogation plaintiffs alleging Fire 

Claims. This data has been provided to BrownGreer on a confidential basis by attorneys engaged 

in the representation of claimants who allege Fire Claims. The individual law firms are able to 

upload information to the BrownGreer Portal via authorized usernames and secure login passwords. 

Some of the material uploaded to the secure BrownGreer Portal contains sensitive, private, and 

personal data relating to the individual Fire Claimants, including medical and insurance 

information. As of January 18, 2019, there were approximately 3,200 individuals or entities in the 

secure BrownGreer Portal, all with Fire Claims arising from the 2017 North Bay Fires. Later in 

January 2019, PG&E announced it was declaring bankruptcy. 

6. Following PG&E’s bankruptcy filing, plaintiffs’ firms have continued to upload 

information into the secure BrownGreer Portal. This includes information about claimants whose 

Fire Claims arise from the 2018 Camp Fire and the 2015 Butte Fire. Since PG&E filed for 

bankruptcy, no attorney uploading information to the BrownGreer portal has given permission for 

that information or data to be provided to PG&E. 

7. As of May 30, 2019, BrownGreer houses data on: 

a. 11,347 claimants whose Fire Claims arise from the 2017 North Bay Fires; 

b. 10,098 claimants whose Fire Claims arise from the 2018 Camp Fire; and 

c. 143 claimants whose claims arise from the 2015 Butte Fire. 

d. 76 claimants who allege a Fire Claim, but who have not yet identified the 

Fire that gave rise to their claim. 

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LOS ANGELES

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8. I declare under penalty of perjury that the foregoing is true and correct. 

Executed this 30th day of May, 2019, 

at Richmond, Virginia, 

___________________ PHILIP R. STRUNK 

Case: 19-30088 Doc# 2306-6 Filed: 05/31/19 Entered: 05/31/19 13:27:55 Page 6

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