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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@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 LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

- and –

PACIFIC GAS AND ELECTRIC 

COMPANY, 

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).

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

SUPPLEMENTAL DECLARATION OF 

TIMOTHY GILLAM IN SUPPORT OF THE 

APPLICATION OF DEBTORS FOR 

AUTHORITY TO RETAIN DELOITTE & 

TOUCHE LLP FOR INDEPENDENT AUDIT 

AND ADVISORY SERVICES NUNC PRO 

TUNC TO THE PETITION DATE 

Related: Docket No. 2197 

Date: July 24, 2019 

Time: 9:30 a.m. (Pacific Time) 

 Place: United States Bankruptcy Court, 

Courtroom 17, 16th Floor 

 San Francisco, CA 94102

Case: 19-30088 Doc# 3128 Filed: 07/22/19 Entered: 07/22/19 15:26:28 Page 1 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

I, Timothy Gillam, under penalty of perjury, declares as follows: 

1. I am a partner of the firm of Deloitte & Touche LLP (“Deloitte & Touche”),

which has an office at 555 Mission Street, Suite 1400, San Francisco, California 94105. I am duly 

authorized to make and submit this supplemental declaration (the “Supplemental Declaration”) on 

behalf of Deloitte & Touche as independent auditor and advisor for PG&E Corporation (“PG&E 

Corp.”) and Pacific Gas and Electric Company (the “Utility” and together with PG&E Corp., the 

“Debtors”) in further support of the Application of Debtors for Authority to Retain Deloitte & Touche 

LLP for Independent Audit and Advisory Services Nunc Pro Tunc to the Petition Date 

(the “Application”).1 

Nunc Pro Tunc Relief is Warranted 

2. The employment of Deloitte & Touche nunc pro tunc to the Petition Date is

warranted under the circumstances of these Chapter 11 Cases so that Deloitte & Touche may be 

compensated for the services it has performed for the Debtors since the Petition Date. Since the Petition 

Date, Deloitte & Touche has worked in good faith with the Debtors and their counsel to identify the 

services that the Debtors believe are necessary to be continued post-petition, has run an extensive 

connections check, has prepared this Declaration and assisted the Debtors in preparation of the 

Application, and has worked with the Debtors to respond to questions from the U.S. Trustee and other 

parties on the Application and Deloitte & Touche’s retention. 

3. Immediately after the chapter 11 filing – before any retention application was

filed – Deloitte & Touche continued to perform necessary work for its longstanding audit client. These 

services include, but are not limited to, the following: 

• auditing the Debtors’ financial statements as of and for the year ended December 31,

2018;

• auditing the internal control over financial reporting, as of December 31, 2018,

contained within the Debtors’ Form 10-K, which was filed on February 28, 2018;

1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in 

the Application. 

Case: 19-30088 Doc# 3128 Filed: 07/22/19 Entered: 07/22/19 15:26:28 Page 2 of

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