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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Richard W. Slack (pro hac vice) 

(richard.slack@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER BENVENUTTI KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Thomas B. Rupp (#278041) 

(trupp@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 636-9251 

Attorneys for Debtors and Reorganized Debtors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 (Lead Case) (Jointly Administered) 

DECLARATION OF RICHARD W. SLACK IN 

SUPPORT OF REORGANIZED DEBTORS’ MOTION 

FOR ENTRY OF AN ORDER (I) APPROVING 

SETTLEMENTS RESOLVING DISPUTES WITH 

CERTAIN INSURERS, AND (II) GRANTING 

RELATED RELIEF 

Date: October 27, 2022 

Time: 11:00 am (Pacific Time) 

Place: (Tele/Videoconference Only) 

 United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

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). 

Case: 19-30088 Doc# 13016 Filed: 09/29/22 Entered: 09/29/22 16:46:13 Page 1

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

 Pursuant to section 1746 of title 28 of the United States Code, I, Richard W. Slack hereby 

declare under penalty of perjury and state: 

1. I am a member of Weil, Gotshal & Manges LLP, counsel for Pacific Gas and 

Electric Company (the “Utility”) and PG&E Corporation (“PG&E” and, together with the Utility, the 

“Debtors” or “Reorganized Debtors,” as applicable). I am admitted to this Court pro hac vice and 

respectfully submit this declaration in support of the Reorganized Debtors’ motion seeking approval of 

two settlement agreements with PG&E’s directors and officers liability insurers [Docket No. [ ]] (the 

“9019 Motion”). 

2. Attached as Exhibit A is a true and correct copy of the Settlement and Release 

Agreement between the Reorganized Debtors, PG&E’s insurance carriers that issued certain 2017 and 

2018 directors and officers liability insurance policies, and certain individual former directors and 

officers of the Debtors. 

3. Attached as Exhibit B is a true and correct copy of the Settlement and Release 

Agreement between the Reorganized Debtors, PG&E’s insurance carriers that issued certain 2017 

directors and officers liability insurance policies, and certain individual former directors and officers of 

the Debtors. 

4. Attached as Exhibit C is a true and correct copy of the Reorganized Debtors’ 

proposed order granting the relief sought in the 9019 Motion. 

5. Attached as Exhibit D is a true and correct copy of the Settlement and Release 

Agreement between the Reorganized Debtors, the PG&E Fire Victim Trust, and certain individual former 

directors and officers of the Debtors in an action captioned Trotter v. Williams, et al., Lead Case No. 

CGC-17-562591, (S.F. Super. Ct.) (the “D&O Action”). 

Dated: September 29, 2022 

New York, New York 

/s/ Richard W. Slack 

Richard W. Slack 

Case: 19-30088 Doc# 13016 Filed: 09/29/22 Entered: 09/29/22 16:46:13 Page 2

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