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DECLARATION OF CHRISTINE MOUNTAIN

I, Christine Mountain, make this declaration based upon my personal knowledge. I am over the 

age of 18, am competent to testify and do so as follows:

At the time of the Camp Fire I lived in Paradise, CA. My primary residence was destroyed in the 

fire. I lost my home, and all of my possessions. And I am underinsured and unable to rebuild.

Immediately prior to the fire I lived in a 1700 sq. ft, 3 bedroom, 2 bath residence on nearly an 

acre. I had electricity, water, heating, and cooking capabilities. The home was surrounded with 

different trees and plants grown by myself, including a small orchard with my own fruits and vegetables 

and grapefruit trees I grew from the seed that were just beginning to produce fruit. This was my 

residence for 16 years and housed many priceless family heirlooms and valuable paintings that cannot 

be replaced. As just a few examples, an 1800’s English Armoire, my Grandmother’s Victrola, my 

grandmother’s wedding locket and engagement ring, my mother’s wedding ring, jewelry, and her 

treasured inlaid French Provençal end tables, my father’s prized accordion with inlaid mother of pearl, 

my Uncle’s WWII casket flag, and my own wedding dress, wedding album, baby book, and my 

Sheriff’s Office uniforms and equipment from a beloved career are all gone. 

Starting November 8, 2018, I evacuated to a Home Depot parking lot in Chico, CA and other 

evacuees filtered in shortly after. While there I resided in my RV which had no heat, no cooking, no 

electricity, and no water. I was using bottled water, making basic sandwiches, and eating fast-food as a 

result. I had cancer only two years ago and should be eating nourishing, fresh meals, not going through 

drive-thrus and skipping meals. It got dark early, and having no electricity left me cold and unable to do 

much other than go immediately to sleep at sundown. For the first 21 days in the Home Depot parking 

lot, I was in the same clothes, too numb and shocked to care about fashion. I had no access to a shower; 

the most I could do was start the motor home to heat water in a bowl to bathe. Throughout this time my 

nine pets (eight cats, one dog) were also in the RV. On December 17, 2018 I left the Home Depot 

parking lot after a notice to vacate was given to those who sheltered themselves there. 

I was then given temporary housing, first at the Ramada Hotel in Chico, CA. However, I had to 

frequently move back and forth from being in a hotel room to being in the hotel parking lot in my RV 

waiting for possible vacancies, bouncing between rooms and my RV every few days. I was then placed 

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1 DECLARATION OF KEVIN MULDER 

2 I, Kevin Mulder, make this declaration based upon my personal knowledge. I am over the 

3 age of 18, am competent to testify and do so as follows: 

4 At the time of the Camp Fire I lived in Concow, California. My primary and only residence 

5 was destroyed in the fire. I and my family lost our home, and all of our possessions. And we had 

6 no insurance. 

7 Immediately prior to the fire I lived at 4200 Wilfern Road in Concow, California with my wife 

8 Starla and our sons, Kailyb (15) and Jaymin (11). We owned a 10-acre share of a 43-acre parcel 

9 where we lived off-the-grid for ten years. We had created a modest home life surrounded by trees 

10 and mountains where we lived off the land and took care of all of our own needs. We possessed 

11 special equipment to produce our own food, cared for a robust garden, which included fruit and nut 

12 trees, used a recycled a shipping container to store our things, and maintained a water tank and 

13 gravity fed lines to supply our water. We didn't need anyone else to maintain our self-sufficient 

14 lifestyle until the Camp Fire took our home and everything we had created there. 

15 I was on the property the morning of the fire while my wife was in Chico with our sons. At 

16 7:20a.m. I realized that the fire was within 100 yards of the home. I grabbed our dog and a few 

17 belongings and fled. As I pulled away, our home was already in flames. As Concow was engulfed in 

18 fire around, I had no choice but to drive through harrowing tunnels of flame to escape. 

19 I met up with Starla and our sons later that day. Since the fire, my whole family has been 

20 living in my mother-in-law's Chico home. Having to depend on family, the government and charity 

21 to get by only adds to the stress we feel every day. We miss the independence that we enjoyed as 

22 a family. 

23 It is imperative that we receive funds immediately to obtain stable and habitable housing, 

24 buy food, clothes and other basic life necessities, and to just generally get back on our feet. 

25 I declare under penalty of perjury under the laws of the State of California that the above is 

26 true and correct and that if called to do so, would competently so testify. Executed on this 29th day 

27 of April, 2019 at 330 Wall Street, Suite 20, Chico, California. 

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1 DECLARATION OF Kenneth Nelsen 

2 I, Kenneth Nelsen, make this declaration based upon my personal knowledge. I am over the 

3 age of 18, am competent to testify and do so as follows; 

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At·: the time of the North Bay Fires I lived in Santa Rosa, CA. My primary and only 

residence .wa:> des\royed .In the fire. I lost my home, and all of my possessions. And I had no 

Insurance. ' •\ '• 

Immediately prior to the fire I lived in a 60 foot mobile home in Journey's End Mobile ~~me . ' ~ 

Park. I had extensive personal property lncludlng toiletries, clothes, shoes, furniture, memor'.iihllia, . .': '··~·:~ ·~: .-: ,, •;•,!.'·•.~>.:~"· • . 

l)', • 

and other belongings. I lived in the comfort and privacy of my own home and space and X 

. . :f 

maintained my independence. I also kept select valuable art pieces, a watch, my high,.~cho?~ ring, 

and a collection of model airplanes and aircraft , which were all destroyed by the fires. j •' ·~ : ~ ' 

Since the fire, I was forced out of my home and had nowhere to go. I have resorted fo ;~· i •. t 

11:.*ing in various motels which has be~n extremely expensive. I barely escaped with my car ~nd .. ~. 

have ·not been able to replace all my toiletries, clothes, shoes, furniture, memorabilia and:•otM'e.r 

f, 

"" ' belongings. I do not have a kitchen, appliances, furniture, or a bed of nw own to sleep on. Due to , .. '" ., ... ~,,.. \ 

the'e"xtreme a'~d unexpected losses, l have been under financial pressur~ and burden. 

Additionally, as a result of trying to escape the fires unscathed, I have emotionally been coping 

with anxiety and difficulty sleeping. 

It Is Imperative that I receive funds immediately to obtain stable and habitable housing, buy 

food, clothes and other b;;isic life necessities, and to just generally get back on my feet. 

I declare. under penalty of perjury under the. laws of the State of California that the above is 

true and correct and that lfcalled'to do so, would competently so testify. Executed on thii:L9' day 

2:3 ; o(April, 2019 at J·D:-1° AfV". 

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San Francisco, California. 

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April 30, 2019 

To whom it may concern, 

As a law enforcement officer of 18 years, many times we are tasked with 

placing our own lives in peril, in order to save others we do not even know. On 

November 8th, 2018, this was yet another one of those occasions. I humbly 

thank you in advance for taking the time to read of this account: 

In the early morning hours of that day, a raging fire broke out in the area of 

Pulga, CA. While on duty, I received a call to respond to Paradise, CA, to assist 

both Paradise Police and the Butte County Sheriff's Dept. in evacuating the 

residents of the area. 

As my family and I resided in Paradise, and due to the speed in which the 

fire was claiming acreage, I only had just enough time to call and/or text my 

fiancée (who suffers from multiple sclerosis) to tell her to evacuate the area with 

our 5 year old foster child. As I was on duty and ordered across town, I was 

unable to get them to safety myself. Luckily they escaped physically unharmed. 

My first task during the fire was to help with evacuation of an assistedliving facility behind the Feather River Hospital complex on Pentz Road, which 

was completely across town from our residence. Upon my arrival, the fire was 

within 500 yards of attacking the facility. Day had been turned into night, as the 

thick black smoke was blotting out the sun. We were successful in evacuating 

the elderly and disabled, but the fire had reached the hospital and that facility, 

and due to burning clumps of debris falling from the sky and embers being 

dispersed by the high winds, the fire was already burning and consuming 

structures all around us as it continued to rapidly spread throughout the area. 

Once we evacuated the facility, traffic became utterly gridlocked in all 

directions. I immediately took action and was able to get the gridlocked traffic 

flowing in the only two directions possible. No sooner had I emptied the facility, 

active fire was within 50 yards of my location claiming structures. After traveling 

no more than a mile or so, I rescued two disabled women and one of their 

boyfriends who were attempting to escape on foot, as their vehicle and house 

had already caught fire. I then attempted our escape by driving westbound on 

Pentz Road literally driving through active fire across the road and wind-blown 

sheets of burning embers. At times, my visibility was limited to ten feet in front of 

my vehicle and around us we saw fully-engulfed utility poles and structures. 

We made our way on the last known acceptable route (Pierson Road), as 

all other roads were blocked. Just at the point where I felt we may successfully 

escape the area, my patrol vehicle was struck by a fleeing motorist traveling the 

opposite direction, rendering my patrol vehicle inoperable. I now had to deal with 

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the fact that not only was I trapped in a worse area that we had seemingly 

escaped before; I also knew I had my civilian passengers with me, two of which 

were disabled. Amidst the flames, embers, and smoke, I quickly acted by 

flagging down other civilian vehicles whom were able to drive my passengers 

and the driver that struck my vehicle to safety. Unfortunately, there was no 

additional room in those vehicles to escape myself, and I ordered them out of the 

area. 

I then noticed there was a sheriff’s patrol vehicle, behind my patrol vehicle, 

and a deputy who was offering assistance. Although, he and I (and the nurses 

who were with him) entered his vehicle, his patrol vehicle would not start. The 

decision was made to abandon the vehicle and to hike back the way we had 

come. We walked about a quarter of a mile fully exposed to the firestorm. Where, 

as luck would have it, I heard the sound of dozer coming towards us. This dozer 

was followed by a large fire engine where we were all able to pile in. It was not a 

moment too soon, as my body started to feel like it was quitting on me. A video 

taken by the bodycam of the sheriff’s deputy that captured our escape made the 

news (https://www.latimes.com/local/lanow/la-me-ln-lawman-escapes-deadlyfire-video-20181129-story.html). 

While all this was transpiring, my family and I lost absolutely everything we 

ever possessed, as our property was essentially incinerated. We had only been 

able to enjoy home ownership for 11 months, and on November 8th, everything 

was violently taken from us. We lost irreplaceable family heirlooms, eclectic 

collections, the drafts of the book I was writing, my paintings, and photos of our 

family. I will never be able to get any of those things back. I also lost all the 

inventory and tools for my side business of vintage auto restoration. 

I was not a wealthy man before the fire, and certainly am not any better off 

since losing everything. Before the fire I was fortunate to have a home and a 

mortgage, which my salary could afford. Now, my family and I live in a trailer. 

There is no housing affordable available in the Chico area, or anywhere close to 

where we lived that is anything remotely similar to what we lost. The prices of 

everything in the surrounding are significantly higher than what I am able to 

afford. 

Although I recognize we are some of the lucky ones and there are many 

who are worse off than we are, it appears we are now forced to leave the area, 

rather than stay in Paradise as we intended just 11 months before the fire. In all 

the areas within two to three hours’ drive, even the house prices there (similar to 

what we lost) are $150,000 dollars higher than what we lost. My mortgage in 

Paradise was comfortable, housing elsewhere in these areas are not. 

Our lives have been completely upset by the Camp Fire. We were only 

just getting settled into our home and the fire turned our hopes and dreams to 

ash. The right thing now would be for PG&E, at a minimum, to start to make 

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people whole for what they did. People need to get back into a home and to start 

to rebuild their lives. 

Sincerely, 

Nicholas D. Powell 

Camp Fire Survivor 

Chico, California 

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-1-

DECLARATION OF JUDY SIMMONS

DECLARATION OF JUDY SIMMONS 

 I, Judy Simmons, declare as follows: 

1. I am a plaintiff in a lawsuit against the Debtors filed in the Superior Court of 

California, County of San Francisco, Case number CGC-18-571822.

2. At the time of the Camp Fire, and on November 8, 2018, my husband and I resided in 

our two-bedroom, two-bathroom, 1,700-square foot home located at 5529 Edgewood Lane, 

Paradise, CA 95969. My husband and I also ran our respective businesses out of our home. I am a 

mortgage broker and my husband owns a pest and termite control company. 

3. As a result of the Camp Fire on or about November 8, 2018, our home, our 

belongings, and the majority of our business equipment was destroyed. We had recently remodeled 

our kitchen at an approximate cost of $60,000. 

4. Following the fire, my husband and I have been unable to secure permanent housing 

despite having a policy of insurance that covered our home, contents, and additional living 

expenses. Since the time of the Camp Fire, we have lived in fifteen (15) different hotel rooms in 

three different cities. Living in a small hotel room and attempting to run our respective businesses 

from those hotel rooms has proved to be extremely difficult, uncomfortable, and financially 

burdensome. Each time we were forced to relocate to a new hotel room we were required to 

reconfigure our business computers and equipment. This instability has resulted in tens of 

thousands of dollars of lost revenue. 

5. We have been the victims of theft and burglary while living in these various different 

hotel rooms. 

6. We finally secured a rental home in Paradise on approximately April 24, 2019. 

Approximately two (2) weeks later we discovered there was no potable water on the property and 

we were forced to return to a hotel. 

DocuSign Envelope ID: A470A57C-90A2-42B4-8871-C2FC7B871B13

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DECLARATION OF JUDY SIMMONS

7. I understand this Court approved the Debtors plan to pay $235,000,000 in bonuses to

approximately 10,000 of its employees, while many wildfire victims, including myself and my 

husband, remain homeless. 

8. Our policy of insurance for additional living expenses runs out on November 8, 2020.

I, Judy Simmons, hereby declare under penalty of perjury of the laws of the United States 

that I have read the foregoing Declaration and know its contents. The same is true of my own 

personal knowledge, except for those matters stated on information and belief which I believe to be 

true. If called to testify as a witness, I could do so competently. 

Executed on _______________, at __________________________, California 

By: __________________________ 

Judy Simmons 

DocuSign Envelope ID: A470A57C-90A2-42B4-8871-C2FC7B871B13

5/10/2019 Paradise 

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DECLARATION OF BRENDA TUCKER

I, Brenda Tucker, make this declaration based upon my personal knowledge. I am over the 

age of 18, am competent to testify and do so as follows:

At the time of the Camp Fire I lived in Oroville, CA. My primary and only residence was 

destroyed in the fire. I lost my home, and all of my possessions. And I had no insurance.

Immediately prior to the fire I rented a mobile home located at 14749 Northwood Drive 

Magalia, CA 95954, where I lived with my son and nephew. 

Immediately after evacuating with my son and nephew, I went to my niece’s house in 

Oroville. We then went to the Grizzly evacuation center. We then went to my niece’s house in 

Oroville, where we have stayed ever since. While our home at 14749 Northwood Drive Magalia, CA 

95954 did not burn down, we have been unable to return because it has been declared a hazard 

zone. 

It is imperative that I receive funds immediately to obtain stable and habitable housing, buy 

food, clothes and other basic life necessities, and to just generally get back on my feet.

I declare under penalty of perjury under the laws of the State of California that the above is 

true and correct and that if called to do so, would competently so testify. Executed on this ____ day 

of April, 2019 at Oroville, California.

_________________________________________

Brenda Tucker

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