BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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Case: 19-30088 Doc# 2306-7 Filed: 05/31/19 Entered: 05/31/19 13:27:55 Page 1

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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 Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8875 

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 

16 In re: Bankruptcy Case 

No. 19-30088 (DM) 

17 PG&E CORPORATION 

Chapter 11 

18 -and- (Lead Case) 

(Jointly Administered) 

19 PACIFIC GAS AND ELECTRIC 

COMPANY, DECLARATION OF ALISON E. CORDOVA 

20 Debtors. IN SUPPORT OF OBJECTION OF THE 

OFFICIAL COMMITTEE OF TORT 

21 o Affects PG&E Corporation CLAIMANTS TO MOTION OF THE 

DEBTORS FOR ORDER (I) ESTABLISHING 

22 o Affects Pacific Gas and Electric Company DEADLINE FOR FILING PROOFS OF

CLAIM, (II) ESTABLISIDNG THE FORM 

23 • Affects both Debtors AND MANNER OF NOTICE THEREOF, 

AND (III) APPROVING PROCEDURES FOR 

24 *All papers shall be filed in the Lead Case, PROVIDING NOTICE OF BAR DATE 

No. 19-30088 (DM) AND OTHER INFORMATION TO ALL 

25 CREDITORS AND POTENTIAL 

CREDITORS (DKT. NO.1784) 

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Case: 19-30088 Doc# 2306-7 Filed: 05/31/19 Entered: 05/31/19 13:27:55 Page 2

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1 I, ALISON E. CORDOVA, declare: 

2 1. I am a partner with the Law Firm of Cotchett, Pitre & McCarthy LLP. I have been

3 involved with litigation, on behalf of fire victims and against Pacific Gas and Electric Company, 

4 since 2015. I, along with my partner Frank M. Pitre, served as co-lead counsel for the North Bay 

5 Fires JCCP. We were also involved as co-liaison counsel for the Butte Fire JCCP and served on 

6 the Executive Committee. I am duly admitted to practice law in California. 

7 2. In connection with my leadership responsibilities and in connection with my

8 representation of fire victims against PG&E, I have spoken with hundreds of fire victims related to 

9 the circumstances sun-ounding their discovery of a fire and how they managed to escape it, along 

10 with any and all damages suffered. These conversations occur either during the intake process, 

11 during the discovery phase (as part of completing a CMO order related to liability or damages 

12 discovery), or during the mediation phase of the case. Specifically, since 2015, I have personally 

13 spoken with over 300 fire victims in these context and related to their fire evacuation story. 

14 3. In regard to the North Bay Fires, I personally participated in the intake of over 100

15 fire victim clients. Based on my personal discussions with hundreds of clients and counsel for 

16 hundreds more, many of these victims either: I) do not know which fire destroyed their residence; 

17 2) believe a different fire than the one Cal Fire deemed responsible had destroyed their residence;

18 and/or 3) are unclear which fire to list because their home was in an area where multiple fires 

19 converged. In my professional experience, I believe asking Fire Claimants to identify the specific 

20 fire responsible for the destruction of their home or property will result in confusion and 

21 inaccurate responses. 

22 I declare under penalty of perjury under the laws of California that the foregoing is true 

23 and correct, and that this declaration was executed on May 31, 2019. 

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ALISON E. CORDOVA 

Case: 19-30088 Doc# 2306-7 Filed: 05/31/19 Entered: 05/31/19 13:27:55 Page 3

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