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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) 

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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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) 

DECLARATION OF RICHARD W. SLACK 

IN SUPPORT OF DEBTORS’ OBJECTION 

TO MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ENTRY OF A PROTECTIVE ORDER 

Date: June 26, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: June 19, 2019 

 4:00 p.m. (Pacific Time) 

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# 2657 Filed: 06/19/19 Entered: 06/19/19 16:10:37 Page 1 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

I, Richard Slack, 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 am a partner with Weil, Gotshal & Manges LLP, counsel to Pacific Gas and Electric 

Company (the “Utility”) and its parent, PG&E Corporation, both Debtors and Debtors in Possession in 

the above-captioned chapter 11 reorganization cases. I submit this declaration in support of the 

Debtors’ Objection to Motion of the Official Committee of Tort Claimants for Entry of a Protective 

Order (the “Objection”) for entry of the amended proposed protective order annexed to the Objection 

as Exhibit A (the “Amended Protective Order”). The matters stated herein are based upon my 

personal knowledge (including from a review of our firm’s relevant books and records and certain 

publicly filed documents in these Cases), and if called as a witness I can and would testify to them on 

that basis. 

2. In addition to the protective orders attached to the Declaration of Richard W. Slack in 

Support of Motion for Entry of Protective Order Pursuant to Fed. R. Bankr. P. 7026 and 9014(c) and 

11 U.S.C. § 105(a) Governing Discovery Materials and Other Information, dated June 7, 2019 [Docket 

No. 2460], attached as Exhibits A through D are additional protective orders that require the party 

challenging a confidentiality designation to prosecute its own challenge, rather than burdening the 

designating party with filing a motion regarding such a challenge: 

 Attached as Exhibit A is a true and correct copy of Protective Order Regarding the 

Disclosure and Use of Discovery Materials; Sciacca v. Apple, Case No. 5:18-cv-3312-

LHK (Oct. 25, 2018), ECF No. 48. 

 Attached as Exhibit B is a true and correct copy of the United States District Court for 

the Southern District of California’s Model Protective Order, available at 

https://www.casd.uscourts.gov/_assets/pdf/forms/Model%20Protective%20Order.pdf. 

 Attached as Exhibit C is a true and correct copy of the Stipulation and Model 

Protective Order of United States Magistrate Judge Ona T. Wan of the United States 

District Court for the Southern District of New York, available at 

http://www.nysd.uscourts.gov/cases/show.php?db=judge_info&id=1512. 

Case: 19-30088 Doc# 2657 Filed: 06/19/19 Entered: 06/19/19 16:10:37 Page 2 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

 Attached as Exhibit D is a true and correct copy of Stipulation and Order Regarding 

Confidential Information, Appendix A to the Individual Practice Rules of United States 

Magistrate Judge Anne Y. Shields of the United States District Court for the Eastern 

District of New York, available at https://img.nyed.uscourts.gov/rules/AYS-MLR.pdf. 

Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the foregoing is true and 

correct, and that this declaration is executed on June 19, 2019. 

 

 /s/ Richard W. Slack___________

Richard W. Slack 

Case: 19-30088 Doc# 2657 Filed: 06/19/19 Entered: 06/19/19 16:10:37 Page 3 of

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