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WEIL, GOTSHAL & MANGES LLP 

Richard W. Slack (pro hac vice) 

(richard.slack@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 KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Thomas B. Rupp (#278041) 

(trupp@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized 

Debtors 

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 KEITH E. 

EGGLETON IN SUPPORT OF REORGANIZED 

DEBTORS’ OMNIBUS MOTION TO ENFORCE THE 

DISCHARGE AND INJUNCTION PROVISIONS OF 

PLAN AND CONFIRMATION ORDER AGAINST 

CERTAIN PENDING ACTIONS 

Date: May 24, 2023 

Time: 10:00 a.m. (Pacific Time) 

Place: (Tele/Videoconference Only)

 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# 13742 Filed: 05/17/23 Entered: 05/17/23 15:14:49 Page 1

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I, Keith E. Eggleton, 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 member of Wilson Sonsini Goodrich & Rosati, P.C. (“WSGR”), counsel 

for Pacific Gas and Electric Company and PG&E Corporation (together, the “Debtors” or as reorganized 

pursuant to the Plan, the “Reorganized Debtors”) as defendants in a number of California state court 

actions relating to the 2017 North Bay Fires and 2018 Camp Fire. I am licensed to practice law in the 

State of California and am admitted to practice before this Court. 

2. I am authorized to submit this Supplemental Declaration (the “Declaration”) on 

behalf of the Reorganized Debtors in support of the Reorganized Debtors’ Omnibus Motion to Enforce 

the Discharge and Injunction Provisions of Plan and Confirmation Order Against Certain Pending 

Actions (the “Motion”).1 The facts set forth in this Declaration are based upon my personal knowledge 

and my review of relevant documents. If called upon to testify, I would testify competently to the facts 

set forth in this Declaration. 

3. Since filing the Motion, counsel for the Reorganized Debtors received positive 

informal responses from two attorneys for the State Court Plaintiffs. 

4. The first was from Christian Krankemann, counsel in eleven known Pending 

Actions in Sonoma County Superior Court. I believe Plaintiffs in those actions have now filed requests 

for dismissal, and the dockets reflect that those eleven Pending Actions in Sonoma County Superior 

Court have been dismissed. 

5. The second was from Larry Peluso, counsel in one known Pending Action 

pending in San Francisco Superior Court. Mr. Peluso has informed my firm that he is attempting to file 

papers requesting dismissal of his Pending Action in San Francisco County Superior Court. 

6. To my knowledge, two other attorneys (John Meyer and Cecelia Fusich)—cocounsel in one known Pending Action in Butte County Superior Court—did not respond formally or 

1

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

the Motion. 

Case: 19-30088 Doc# 13742 Filed: 05/17/23 Entered: 05/17/23 15:14:49 Page 2

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informally to the Motion. 

7. After the Motion was filed, while preparing for a court hearing in the Robinson

Pending Action involving State Court Plaintiffs represented by Richards Willis PC, I discovered a new 

action against the Debtors that I believe is asserting what would be Fire Victim Claims as defined in the 

Plan. This case is pending in the San Francisco Superior Court as Johnson, et al. v. PG&E Corporation, 

et al., Case No. CGC-19-579965. Richards Willis PC is counsel for the plaintiffs in this action. I do not 

believe the Debtors were ever served with a summons in this action. 

8. The Robinson and Johnson cases were both scheduled for order to show cause 

hearings on May 2, 2023, concerning potential dismissal of the cases. 

9. Shortly before the hearings, the plaintiffs in those cases filed the statements 

attached as Exhibit A hereto. 

10. In response, the San Francisco County Superior Court canceled the order to show 

cause hearings and scheduled case management conferences “for status report re bankruptcy” for 

September 6, 2023. 

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

and correct to the best of my knowledge, information, and belief. 

Dated: May 17, 2023 

Palo Alto, California 

/s/Keith E. Eggleton____________ 

Keith E. Eggleton 

Case: 19-30088 Doc# 13742 Filed: 05/17/23 Entered: 05/17/23 15:14:49 Page 3

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