EXHIBIT C: 

Disclosure Statements 

for Proposed Mediators 

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 1

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Disclosure of Potential Conflicts – Judge William Cahill (Ret.)

The below is a list of potential conflicts provided by Hon. William Cahill (Ret.).

1. To the best of Judge Cahill’s knowledge and records, Judge Cahill has not had any 

relationship with Cravath, Swaine & Moore LLP, Keller Benvenutti Kim LLP, or Weil, 

Gotshal & Manges LLP over the last five years.

2. To the best of Judge Cahill’s knowledge and records, over the last five years, Judge Cahill 

has performed work as mediator for the Debtors and Reorganized Debtors in two 

mediations between April 2018 and April 2023.

3. To the best of Judge Cahill’s knowledge and records, over the last five years, Judge Cahill 

has performed work as mediator in five mediations between April 2018 and April 2023 in 

which Latham & Watkins LLP served as counsel for the defendants.

4. To the best of Judge Cahill’s knowledge and records, over the last five years, Judge Cahill 

has performed work as an arbitrator in one arbitration between April 2018 and April 2023 

in which Latham & Watkins LLP served as counsel for the defendants.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 2

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General Disclosures, Report A (MKT016A)

Slack, Richard vs.

This report includes General Disclosure of Client Activity from 04/10/2018 to 04/10/2023. Due to the confidential nature of 

mediations, only the number of mediations concerning the involved parties are listed. The number of cases listed below does not 

include the present case. All branches of counsel firms are included.

Panelist: William J. Cahill Reference #: 1100115707 4/10/2023

Debtor(s)

Cravath, Swaine & Moore LLP

No Address Listed

Cases heard with Cravath, Swaine & Moore LLP

No Cases to Report

Latham & Watkins LLP

No Address Listed

Cases heard with Latham & Watkins LLP

Arbitration

· Arbitration(s) - Closed cases 1

Mediations\Neutral Analysis\Other

· Mediation(s) - Closed cases 5

PG&E Corporation

No Address Listed

Cases heard with PG&E Corporation

Mediations\Neutral Analysis\Other

· Mediation(s) - Closed cases 2

The neutral practices in association with JAMS. Each JAMS neutral, including the neutral in this case, has an economic interest in the 

overall financial success of JAMS. In addition, because of the nature and size of JAMS, the parties should assume that one or more of 

the other neutrals who practice with JAMS has participated in an arbitration, mediation or other dispute resolution proceeding with 

the parties, counsel or insurers in this case and may do so in the future.

4/10/2023 Page 1 of 4

* "Matter(s) Assigned to Another Neutral" includes cases where the matter was moved to a different neutral.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 3

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General Disclosures, Report A (MKT016A)

Slack, Richard vs.

This report includes General Disclosure of Client Activity from 04/10/2018 to 04/10/2023. Due to the confidential nature of 

mediations, only the number of mediations concerning the involved parties are listed. The number of cases listed below does not 

include the present case. All branches of counsel firms are included.

Panelist: William J. Cahill Reference #: 1100115707 4/10/2023

Counsel for Debtor

Tobias S. Keller

Keller & Benvenutti

650 California St.

Suite 1900

San Francisco, CA 94108

Cases heard with Tobias S. Keller

No Cases to Report

Cases heard with Keller & Benvenutti

No Cases to Report

Jessica Liou

Weil Gotshal & Manges LLP

767 Fifth Ave.

New York, NY 10153

Cases heard with Jessica Liou

No Cases to Report

Matthew Goren

Weil Gotshal & Manges LLP

767 Fifth Ave.

New York, NY 10153

Cases heard with Matthew Goren

No Cases to Report

Richard W. Slack

Weil Gotshal & Manges LLP

767 Fifth Ave.

New York, NY 10153

The neutral practices in association with JAMS. Each JAMS neutral, including the neutral in this case, has an economic interest in the 

overall financial success of JAMS. In addition, because of the nature and size of JAMS, the parties should assume that one or more of 

the other neutrals who practice with JAMS has participated in an arbitration, mediation or other dispute resolution proceeding with 

the parties, counsel or insurers in this case and may do so in the future.

4/10/2023 Page 2 of 4

* "Matter(s) Assigned to Another Neutral" includes cases where the matter was moved to a different neutral.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 4

of 13
General Disclosures, Report A (MKT016A)

Slack, Richard vs.

This report includes General Disclosure of Client Activity from 04/10/2018 to 04/10/2023. Due to the confidential nature of 

mediations, only the number of mediations concerning the involved parties are listed. The number of cases listed below does not 

include the present case. All branches of counsel firms are included.

Panelist: William J. Cahill Reference #: 1100115707 4/10/2023

Cases heard with Richard W. Slack

No Cases to Report

Cases heard with Weil Gotshal & Manges LLP

No Cases to Report

Theodore Tsekerides

Weil Gotshal & Manges LLP

767 Fifth Ave.

New York, NY 10153

Cases heard with Theodore Tsekerides

No Cases to Report

The neutral practices in association with JAMS. Each JAMS neutral, including the neutral in this case, has an economic interest in the 

overall financial success of JAMS. In addition, because of the nature and size of JAMS, the parties should assume that one or more of 

the other neutrals who practice with JAMS has participated in an arbitration, mediation or other dispute resolution proceeding with 

the parties, counsel or insurers in this case and may do so in the future.

4/10/2023 Page 3 of 4

* "Matter(s) Assigned to Another Neutral" includes cases where the matter was moved to a different neutral.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 5

of 13
General Disclosures, Report A (MKT016A)

Slack, Richard vs.

This report includes General Disclosure of Client Activity from 04/10/2018 to 04/10/2023. Due to the confidential nature of 

mediations, only the number of mediations concerning the involved parties are listed. The number of cases listed below does not 

include the present case. All branches of counsel firms are included.

Panelist: William J. Cahill Reference #: 1100115707 4/10/2023

Other Disclosures

N/A

The neutral practices in association with JAMS. Each JAMS neutral, including the neutral in this case, has an economic interest in the 

overall financial success of JAMS. In addition, because of the nature and size of JAMS, the parties should assume that one or more of 

the other neutrals who practice with JAMS has participated in an arbitration, mediation or other dispute resolution proceeding with 

the parties, counsel or insurers in this case and may do so in the future.

4/10/2023 Page 4 of 4

* "Matter(s) Assigned to Another Neutral" includes cases where the matter was moved to a different neutral.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 6

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Disclosure of Potential Conflicts – Ambassador David Carden (Ret.)

The below is a list of potential conflicts by the Hon. David Carden (Ret.).

1. To the best of Ambassador Carden’s knowledge and records, Ambassador Carden has not 

performed any work for the Debtors or Reorganized Debtors over the last five years.

2. To the best of Ambassador Carden’s knowledge and records, Ambassador Carden has not 

performed any work for or with Cravath, Swaine & Moore LLP or Keller Benvenutti Kim 

LLP in the last five years.

3. Ambassador Carden previously served as a mediator in a 2022 mediation in which Weil, 

Gotshal & Manges LLP served as counsel for the defendant. A settlement was achieved as 

a result of this mediation.

4. Ambassador Carden previously served as a mediator in two mediations in which Latham 

& Watkins LLP served as counsel for the defendants in 2019 and 2021. A settlement was 

achieved as a result of this mediation.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 7

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Disclosure Statement – Michael D. Cooper, Esq.

Below are disclosures provided by Michael D. Cooper, Esq.

1. Mr. Cooper has worked with counsel for PG&E, as well as counsel for numerous claimants,

in his capacity as a mediator of general unsecured claims arising out of PG&E’s Chapter 

11 bankruptcy cases currently pending in the United States Bankruptcy Court for the 

Northern District of California.

2. Aside from the above, Mr. Cooper has done no work for, or on behalf of, any of the 

following entities in the past five years: PG&E Corporation; Pacific Gas and Electric 

Company; Weil, Gotshal & Manges LLP; Keller Benvenutti Kim LLP; Cravath, Swaine & 

Moore LLP; and Latham & Watkins LLP. In 2020, Mr. Cooper mediated a dispute in 

which Keller Benvenutti Kim LLP was representing parties.

3. Mr. Cooper is unaware of any other matters that could create a reasonable inference of bias

with respect to mediation of Securities Claims.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 8

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Disclosure Statement – Lizbeth Hasse, Esq.

Below are disclosures provided by Lizbeth Hasse, Esq.

1. Ms. Hasse mediated a matter involving Latham & Watkins LLP in July 2019, and she 

mediated a matter involving Weil, Gotshal & Manges LLP in November 2014.

2. Aside from the above, Ms. Hasse has done no work for, or on behalf of, any of the following 

entities in the past five years: PG&E Corporation; Pacific Gas and Electric Company; Weil, 

Gotshal & Manges LLP; Keller Benvenutti Kim LLP; Cravath, Swaine & Moore LLP; and

Latham & Watkins LLP.

3. Ms. Hasse is unaware of any other matters that could create a reasonable inference of bias

with respect to mediation of Securities Claims.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page 9

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Disclosure of Potential Conflicts – Mark Helm

The below is a list of potential conflicts provided by Mark Helm.

1. To the best of Mr. Helm’s knowledge and records, Mr. Helm has not had any relationship 

with Weil, Gotshal & Manges LLP, Latham & Watkins LLP, Cravath, Swaine & Moore 

LLP, or Keller Benvenutti Kim LLP over the last five years.

2. To the best of Mr. Helm’s knowledge and records, Mr. Helm has not performed any work 

for the Debtors or Reorganized Debtors over the last five years. 

3. Mr. Helm’s prior law firm, Munger Tolles & Olson LLP, did perform work for Pacific Gas 

and Electric Company (“PG&E”) in certain wildfire cases in the last five years while Mr. 

Helm was still a partner. Mr. Helm did not perform work on any of these matters.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page

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Disclosure Statement – Frederick D. Holden, Jr., Esq.

Below are disclosures provided by Frederick D. Holden, Jr., Esq.

1. Mr. Holden has done no work for, or on behalf of, any of the following entities in the past 

five years: PG&E Corporation; Pacific Gas and Electric Company; Weil, Gotshal & 

Manges LLP; Keller Benvenutti Kim LLP; Cravath, Swaine & Moore LLP; and Latham & 

Watkins LLP.

2. Over 10 years ago, while he was a partner at Orrick, Herrington & Sutcliffe LLP (“Orrick”), 

Mr. Holden handled a matter for PG&E, in which PG&E pursued claims for diverted 

charitable contributions. While Orrick handled numerous other matters for PG&E while

Mr. Holden was a partner there, to the best of his recollection, Mr. Holden did not work on 

any other matter for PG&E or any affiliate.

3. Mr. Holden is unaware of any other matters that could create a reasonable inference of bias

with respect to mediation of Securities Claims.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page

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Disclosure of Potential Conflicts – Judge Randall J. Newsome (Ret.)

The below is a list of potential conflicts provided by the Hon. Randall J. Newsome (Ret.).

1. In 2019, Judge Newsome was appointed as mediator by Judge Montali of the United States 

Bankruptcy Court, Northern District of California, to oversee the reorganization plan in the 

Pacific Gas and Electric Company’s (“PG&E”) Chapter 11 bankruptcy cases. In the course 

of assisting the parties to arrive at a consensual plan of reorganization, Judge Newsome

interacted with counsel from Weil, Gotshal & Manges LLP, Latham & Watkins LLP, 

Cravath, Swaine & Moore LLP, Keller Benvenutti Kim LLP (“PG&E Counsel Firms”), 

and many other law firms. 

2. Judge Newsome also worked with counsel for PG&E in connection with mediations of 

general unsecured claims and contested matters arising out of these cases. One notable 

contested matter involved the City of Santa Clara and the Debtors, who were represented 

by Weil. A settlement was achieved as a result of this mediation and the settlement was 

approved by Judge Montali.

3. To the best of Judge Newsome’s knowledge and records, other than matters arising in or 

related to these bankruptcy proceedings, Judge Newsome has no connections to the PG&E 

Counsel Firms and has not had any other relationship with them over the last five years.

4. To the best of Judge Newsome’s knowledge and records, other than the matters arising in 

or related to these bankruptcy proceedings, Judge Newsome has not performed any other 

work for the Debtors or Reorganized Debtors over the last five years.

5. To the best of Judge Newsome’s knowledge and records, insofar as he has been able to 

ascertain after reasonable inquiry, Judge Newsome is a “disinterested person” as defined 

in section 101(14) of the Bankruptcy Code.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page

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Disclosure Statement – Hon. Winifred Y. Smith (Ret.)

Below are disclosures provided by Hon. Winifred Y. Smith (Ret.).

1. Judge Smith has done no work for, or on behalf of, any of the following entities in the past 

five years: PG&E Corporation; Pacific Gas and Electric Company; Weil, Gotshal & 

Manges LLP; Keller Benvenutti Kim LLP; Cravath, Swaine & Moore LLP; and Latham & 

Watkins LLP.

2. Judge Smith is unaware of any other matters that could create a reasonable inference of 

bias with respect to mediation of Securities Claims.

Case: 19-30088 Doc# 13725-3 Filed: 05/11/23 Entered: 05/11/23 17:42:46 Page

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