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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

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice)

(pzumbro@cravath.com)

Kevin J. Orsini (pro hac vice)

(korsini@cravath.com)

Omid H. Nasab (pro hac vice)

(onasab@cravath.com)

David A. Herman (pro hac vice)

(dherman@cravath.com)

825 Eighth Avenue

New York, NY 10019

Tel: 212 474 1000

Fax: 212 474 3700

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

- and -

PACIFIC GAS AND ELECTRIC

COMPANY

Debtors.

Bankruptcy Case No. 19 - 30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

DECLARATION OF KEVIN J. ORSINI IN 

SUPPORT OF DEBTORS’ MOTION 

PURSUANT TO 11 U.S.C. §§ 105(a) AND 

502(c) FOR THE ESTABLISHMENT OF 

WILDFIRE CLAIMS ESTIMATION 

PROCEDURES

Date: August 14, 2019

Time: 9:30 a.m. PST

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Objection Deadline: August 7, 2019

 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# 3092 Filed: 07/18/19 Entered: 07/18/19 22:54:12 Page 1 of

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Pursuant to 28 U.S.C. § 1746, I, Kevin J. Orsini, hereby declare under penalty of perjury as follows:

1. I am a Member of Cravath, Swaine & Moore LLP (“Cravath”), counsel to Pacific Gas 

and Electric and PG&E Corporation (collectively, “PG&E” or the “Debtors”) in the above-captioned 

Chapter 11 Cases. I am admitted to practice in the State of New York and am admitted to practice 

before this Court pro hac vice. (See Dkt. No. 88). I submit this Declaration in Support of the Debtors’ 

Motion Pursuant to 11 U.S.C. §§ 105(a) and 502(c) for the Establishment Of Wildfire Claims 

Estimation Procedures (the “Motion”). I have personal knowledge of the facts set forth in this 

declaration except as otherwise stated.

2. Cravath represented the Debtors in prepetition litigation in California state court 

relating to the 2017 North Bay Wildfires (the “North Bay Fires”), including in consolidated 

proceedings under the caption California North Bay Fires Cases, JCCP No. 4955 (Cal. Super. Ct.). 

As trial counsel handling that litigation, I have personal knowledge of the status of discovery and other 

proceedings as they existed as of January 29, 2019, the date the Debtors filed their voluntary petitions 

for relief in these Chapter 11 Cases (the “Petition Date”). As of the Petition Date, many significant 

depositions related to questions of liability had not yet been scheduled. In addition, as of the Petition 

Date, no discovery related to damages had been conducted.

3. I am familiar with the results of investigations carried out by the California Department 

of Forestry and Fire Protection (“CAL FIRE”) concerning the impact of the North Bay Fires. Based 

on the figures reported by CAL FIRE in the incident descriptions for the (1) Adobe; (2) Atlas; (3) 

Blue; (4) Cascade; (5) Cherokee; (6) Highway 37; (7) Honey; (8) La Porte; (9) Lobo; (10) Maacama; 

(11) McCourtney; (12) Norrbom; (13) Nuns; (14) Oakmont/Pythian; (15) Partrick; (16) Pocket; (17) 

Point; (18) Potter/Redwood; (19) Pressley; (20) Sullivan and (21) Sulphur Fires, the aggregate number 

of structures damaged in those fires was approximately 1,026, the aggregate number of structures 

destroyed was approximately 2,597, and the aggregate number of fatalities was 22. 

4. Attached hereto as Exhibit A is an audio file containing a true and correct copy of a 

video recording of the November 30, 2017, hearing of the California Public Utilities Commission 

Case: 19-30088 Doc# 3092 Filed: 07/18/19 Entered: 07/18/19 22:54:12 Page 2 of

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(“CPUC”) that is posted on, and which was downloaded from, the CPUC’s website at 

http://www.adminmonitor.com/ca/cpuc/voting_meeting/20171116/.1

5. Attached hereto as Exhibit B is a true and correct copy of the November 30, 2017,

CPUC Decision Denying Application of San Diego Gas &Electric Company (“SDG&E”) for 

Authorization to Recover Costs Related to the 2007 Southern California Wildfires (Decision 17-11-

033) (the “SDG&E Decision”).

6. Attached hereto as Exhibit C is a true and correct copy of the Concurrence of President 

and Commissioner Michael Picker and Commissioner Martha Guzman Aceves with respect to the 

SDG&E Decision.

7. Attached hereto as Exhibit D is a true and correct copy of the January 12, 2012, CPUC 

Decision Adopting Regulations to Reduce Fire Hazards Associated with Overhead Power Lines and 

Communications Facilities (Decision 12-01-032).

8. Attached hereto as Exhibit E is a true and correct copy of the April 19, 2012, CPUC 

Decision Granting Petition to Modify Decision 09-09-030 and Adopting Fire Safety Requirements for 

SDG&E (Decision 12-04-024).

9. Attached hereto as Exhibit F is a true and correct copy of the Application of SDG&E 

for Review of its Proactive De-Energization Measures and Approval of Proposed Tariff Revisions, 

filed December 22, 2008, (Application 08-12-02).

I declare under penalty of perjury that, to the best of my knowledge and after reasonable 

inquiry, the foregoing is true and correct.

 1 Copies of the audio file will be provided to counsel for the Official Committee of Tort Claimants, the Official 

Committee of Unsecured Creditors, the United States Trustee and any party in interest who requests in writing a copy 

from the Debtors. 

Case: 19-30088 Doc# 3092 Filed: 07/18/19 Entered: 07/18/19 22:54:12 Page 3 of

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Case: 19-30088 Doc# 3092 Filed: 07/18/19 Entered: 07/18/19 22:54:12 Page 4 of

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