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Jane Luciano, Esq. CA. SBN 124263

Luciano Law

9000 Crow Canyon Road

Suite S #168

Danville, CA 94506

(925) 216-6030

William D. McCann, Esq SBN NV 12038

P.O. Box 370

Genoa, Nevada 89411

Pro Haec Vice in Butte County Superior Court Cases

Attorneys for Plaintiffs and Claimants Liza Sims, individually and 

Thomas and Jaydene Gardner

UNTIED STAES BANKRUPCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

 In re: 

 Bankr. Case No. 19-30088 (DM)

 PG&E CORPOIRATION, Chapter 11

 (Lead Case) (Jointly Administered)

 

 -and- 

 DECLARATION OF WILLIAM D.

 PACIFIC GAS AND ELECTRIC MCCANN IN SUPPORT OF 

 PLAINTIFFS OBJECTION

 COMPANY TO PG AND E MOTION TO

TO DEFEAT PLAINTIFFS’

CLAIMS FOR PUNITIVE

DAMAGES

Debtors. 

 Hearing: May 24, 2023

 Time: 10:00 am

 Via Tele-video conference

 X Affects Both Debtors 

 US Bankruptcy Court

 Courtroom 17, 16th Floor

 San Francisco, CA 94102

 [Relates to Dkt. 13685, both Liza Sims

 and Thomas and Jaydene Gardner case]

_____________________________________________

Case: 19-30088 Doc# 13713 Filed: 05/10/23 Entered: 05/10/23 07:20:45 Page 1

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DECLARATION OF WILLIAM D. MCCANN. ESQ IN SUPPORT OF OBJECTION

I, William D. McCann, declare:

1. I am competent to make this declaration and have actual knowledge of the facts which

follow.

2. Since shortly after the so-called Camp Fire in Butte County, California, I became counsel 

to Liza Sims and her now deceased Mother, who became residents of Douglas County, 

Nevada, where I maintain an office. I thereafter became counsel pro haec vice with Jane 

Luciano, Esq. on behalf of Ms. Sims and her now deceased mother, in Liza Sims v. PG 

and E, Butte County Superior Court Case No. 19CV01700 and Thomas and Jaydene 

Gardner v. PG and E, Butte County Superior Court Case No. 19CV00379.

3. During my work for these clients over the last 5 years, I have become familiar with the 

fact patterns generic to the causation of various California fires caused and/or allegedly 

caused by errors and omissions by the utility known as PG & E, including but not limited 

to the so-called San Bruno Fire, the criminal case, plea, and conditions of probation 

imposed by Hon. William Alsup arising therefrom, the rulings concerning violation of 

conditions of probation in that case, the so-called Butte Fire of 2015, and the findings of 

Cal Fire with respect to the causation thereof, the so-called Camp Fire of 2018, the 

finding of Cal Fire with respect to the causation thereof, and most recently, the Transcript 

of the Grand Jury of the County of Butte, California, finding criminal liability in PG and 

E for causing multiple deaths as a result of the Camp fire, specifically:

 https://interactive.abc10.com/pdfs/KXTV_PGE_Grand_Jury_Binder.pdf

Case: 19-30088 Doc# 13713 Filed: 05/10/23 Entered: 05/10/23 07:20:45 Page 2

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4. Among the duties owed my clients and owed the tribunals before which I appear on their 

behalf is the determination of the nature and type of damages to which my clients might

be entitled. My review of the fact patterns generic to the causation of the Camp Fire 

reveals the inescapable conclusion that PG and E engaged in “willful blindness” as to the 

dangers to human life presented by its failure to maintain the equipment through which it 

delivers energy, and in the case of the Camp Fire, failure to control flammable vegetation 

within the proximity of its equipment. This “willful blindness” was embodied in 

intentional corporate decisions at board of directors’ level to place profits before safety, 

which decisions consistently occurred during, at least, two decades prior to the date of the 

Camp Fire.

5. Thus, it is my duty to seek an award of damages by way of punishment and example 

against this entity, which engaged in conduct beyond “recklessness” and/or “gross 

negligence” which proximately resulted in damage to my clients. This duty is pursued in

good faith.

I declare under penalty of perjury pursuant to the laws of the State of California the 

foregoing to be true and correct.

May 10, 2023

/s/William D. McCann/s/

William D. McCann

 Declarant

Case: 19-30088 Doc# 13713 Filed: 05/10/23 Entered: 05/10/23 07:20:45 Page 3

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