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

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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,

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

SUPPLEMENTAL DECLARATION OF 

JANAIZE MARKLAND IN SUPPORT OF 

D&O INSURANCE MOTION 

Date: July 9, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

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# 2883 Filed: 07/08/19 Entered: 07/08/19 09:54:50 Page 1 of

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

I, Janaize Markland, pursuant to section 1746 of title 28 of the United States Code, hereby 

declare under penalty of perjury that the following is true and correct to the best of my knowledge, 

information, and belief: 

1. I hold the position of Senior Director, Enterprise and Operational Risk Management 

& Insurance at Pacific Gas and Electric Company (the “Utility”), as debtor and debtor-inpossession (and together with PG&E Corporation, the “Debtors”), in the above-captioned Chapter 

11 Cases (the “Chapter 11 Cases”). 

2. Except as otherwise indicated herein, the facts set forth in this Declaration are based 

upon my personal knowledge, my review of relevant documents, and information provided to me 

by the Debtors’ employees, insurance brokers, and legal, restructuring, and financial advisors. If 

called upon to testify, I would testify competently to the facts set forth in this Declaration. I am 

authorized to submit this Declaration on behalf of the Debtors. 

3. This Supplemental Declaration is submitted in further support of the Motion 

Pursuant to 11 U.S.C. §§ 105(a) and 363(b) and Fed. R. Bankr. P. 2002 and 6004(h) Authorizing 

Debtors to Purchase Directors and Officers Insurance (the “Motion”),1 and the Debtors’ Reply in 

Support of the D&O Insurance Motion and Response to Objection of the Official Committee Of 

Unsecured Creditors (the “Reply”). 

 

1

 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such 

terms in the Motion. 

Case: 19-30088 Doc# 2883 Filed: 07/08/19 Entered: 07/08/19 09:54:50 Page 2 of

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4. In the course of my employment by the Debtors, it is my responsibility to stay 

apprised of and evaluate the status of coverage of the Debtors and their directors and officers under 

the D&O insurance policies. 

5. I obtain this knowledge through reviewing correspondence received from the 

Debtors’ D&O insurers, and communicating with others who communicate with the Debtors’ 

D&O insurers regarding coverage issues, including the Debtors’ internal and external counsel, and 

their insurance broker, Marsh. 

6. Attached to this Declaration as Exhibit A is the following correspondence sent by 

the Debtors’ D&O primary insurers to the Debtors’ legal department regarding notices of claims 

made, coverage, and reservations of rights in respect of derivative actions filed against the Debtors 

and their officers and directors arising from the 2018 wildfires: 

a. letter from Bailey Cavalieri on behalf of Associated Electric & Gas Insurance 

Services Limited and AEGIS Insurance Services, Inc. (collectively “AEGIS”) 

to the Utility, dated January 23, 2019; and 

b. letter from Bailey Cavalieri on behalf of AEGIS to the Utility, dated May 10, 

2019. 

(collectively, the “AEGIS Letters”) 

7. AEGIS is the Debtors’ primary D&O insurer under the 2017 Policies and the 2018 

Policies. I was provided these letters, as well as other correspondence from the Debtors’ insurers, 

by the Debtors’ legal department and reviewed each of them in the ordinary course of my 

employment shortly after their receipt. 

8. Each of the AEGIS Letters contains a statement that AEGIS is provisionally treating 

certain claims noticed by the Debtors relating to the 2018 wildfires as a single claim along with 

claims previously noticed by the Debtors in relation to the 2017 wildfires. 

9. The AEGIS Letters provided to me by the Debtors’ legal department, together with 

discussions with Marsh and the Debtors’ internal and external counsel, are the basis for the 

Case: 19-30088 Doc# 2883 Filed: 07/08/19 Entered: 07/08/19 09:54:50 Page 3 of

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

statements in paragraph 10 of my Declaration dated June 10, 2019, to which I testified in my 

deposition with respect to the D&O insurers treating claims arising from the 2017 and 2018 

wildfires as a single claim, and that one carrier had indicated an intention to do so. 

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