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 BAKER

& HOSTETLER LLP

ATTORNEYS AT LAW

SAB FRANCISCO, CA 

 

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: 310.442.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants

IN THE 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 

Case No.: 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

DECLARATION OF LARS H. FULLER 

IN SUPPORT OF MOTION FOR 

PROTECTIVE ORDER 

Date: June 26, 2019 

Time: 9:30 a.m. PT 

Place: United States Bankruptcy Court 

Courtroom 17, 16th Floor 

San Francisco, CA 94102 

Objection Deadline: June 19, 2019

 

Case: 19-30088 Doc# 2420 Filed: 06/05/19 Entered: 06/05/19 20:12:18 Page 1 of

2
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

BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA 

- 2 - 

LARS H. FULLER, declares as follows under penalty of perjury:

I am an attorney at Baker & Hostetler LLP, counsel to the Official Committee of Tort 

Claimants in the above-captioned chapter 11 cases of PG&E Corporation and Pacific Gas and 

Electric Company. I have personal knowledge of the facts stated herein and as to those matters, I 

believe them to be true. If called upon to testify, I could and would competently do so. 

1. I make this declaration in support of the Motion for Protective Order (“Motion”). 

2. I have personal knowledge of communications with counsel for the Debtors 

regarding conferral over the relief sought in the Motion. The recitation in the Motion summarizing 

those communications is true and accurate. 

3. Attached hereto as Exhibit 1 is a true and correct copy of the form “Stipulated 

Protective Order for Standard Litigation” provided by the U.S. District Court for the Northern 

District Court on its website (https://www.cand.uscourts.gov/model-protective-orders). Attached 

hereto as Exhibit 2 is a true and correct copy of the Stipulated Protective Order Between Debtor 

and Official Committee of Unsecured Creditors entered on June 13, 2016 as Docket No. 202 in 

Case No. 16-30063 (In re Yellow Cab Cooperative, Inc.). 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed this 5th day of June 2019, 

 /s/ Lars H. Fuller 

By: LARS H. FULLER 

Case: 19-30088 Doc# 2420 Filed: 06/05/19 Entered: 06/05/19 20:12:18 Page 2 of

2