1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

44553.00001

Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice)

MILBANK LLP

55 Hudson Yards

New York, New York 10001-2163

Telephone: (212) 530-5000

Facsimile: (212) 530-5219

and

Gregory A. Bray (SBN 115367)

Thomas R. Kreller (SBN 161922) 

MILBANK LLP

2029 Century Park East, 33rd Floor

Los Angeles, CA 90067

Telephone: (424) 386-4000

Facsimile: (213) 629-5063

Counsel for the Official Committee

of Unsecured Creditors

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

 Debtors.

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

 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)

DECLARATION OF GREGORY A. BRAY 

IN SUPPORT OF MOTION OF THE 

OFFICIAL COMMITTEE OF 

UNSECURED CREDITORS FOR AN 

ORDER AUTHORIZING THE FILING OF 

A SUPPLEMENTAL OBJECTION 

UNDER SEAL

[No Hearing Requested]

Case: 19-30088 Doc# 2877 Filed: 07/05/19 Entered: 07/05/19 16:46:47 Page 1 of

3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

2

I, Gregory A. Bray, pursuant to section 1746 of title 28 of the United States Code, hereby 

declare under penalty of perjury that the following is true and correct to the best of my knowledge, 

information and belief:

1. I am an attorney admitted to practice in the State of California and I am a partner 

in the Financial Restructuring Group of the firm Milbank LLP (“Milbank”), counsel to the Official 

Committee of Unsecured Creditors (the “Creditors’ Committee”) of the above-captioned debtors 

and debtors in possession (collectively, the “Debtors”). Milbank maintains an office at, among 

other places, 2029 Century Park East, 33rd Floor, Los Angeles, California, 90067-3019. There are 

no disciplinary proceedings pending against me.

2. I am duly authorized to make this declaration on behalf of Milbank in support of 

the Motion of the Official Committee of Unsecured Creditors for an Order Authorizing the Filing 

of a Supplemental Objection Under Seal, filed concurrently herewith (the “Motion to Redact”). 

The facts set forth in this declaration are based upon my personal knowledge, my review of 

relevant documents, or information provided to me by other advisors to the Creditors’ Committee, 

including other attorneys at Milbank. If called upon to testify, I would testify competently to the 

facts set forth in this Declaration.

3. As stated, this declaration is submitted in support of the Motion to Redact, which 

seeks authority to file under seal portions of the Creditors’ Committee’s supplemental objection 

(the “Supplemental Objection”) to the Debtors’ Motion Pursuant to 11 U.S.C. §§ 363 and 105(a) 

and Fed. R. Bankr. P. 6004 Authorizing Debtors to Purchase Directors and Officers Insurance

(the “D&O Motion”) [Docket No. 2471], which supplemental objection is filed 

contemporaneously herewith.

4. In particular, the Creditors’ Committee took the deposition of Janaize Markland, 

the Debtors’ declarant in support of the D&O Motion, on July 3, 2019. The Debtors designated 

Case: 19-30088 Doc# 2877 Filed: 07/05/19 Entered: 07/05/19 16:46:47 Page 2 of

3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

3

the transcript of the deposition as “confidential” pursuant to the Order Governing Discovery by 

and Among Debtors, Official Committee of Unsecured Creditors, and Official Committee of Tort 

Claimants entered by the Court on July 1, 2019 (“Protective Order”) [Docket No. 2807]. The 

Protective Order governs the production, review, disclosure, and handling of any information 

exchanged by and among the Official Committee of Tort Claimants (the “TCC”), the Creditors’ 

Committee, and the Debtors in these chapter 11 cases.

I declare under penalty of perjury that the foregoing is true and correct to the best of my 

knowledge and belief. 

Executed on July 5, 2019, Los Angeles, CA

/s/ Gregory A. Bray 

Gregory A. Bray

Case: 19-30088 Doc# 2877 Filed: 07/05/19 Entered: 07/05/19 16:46:47 Page 3 of

3