TOGUT, SEGAL & SEGAL LLP

One Penn Plaza, Suite 3335

New York, NY 10119

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TOGUT, SEGAL & SEGAL LLP 

Albert Togut (admitted pro hac vice)

(altogut@teamtogut.com) 

Kyle J. Ortiz (admitted pro hac vice)

(kortiz@teamtogut.com) 

Amy M. Oden (admitted pro hac vice)

(adoen@teamtogut.com)

Amanda C. Glaubach (admitted pro hac vice)

(aglaubach@teamtogut.com) 

One Penn Plaza, Suite 3335

New York, New York 10119 

Tel: (212) 594-5000

Fax: (212) 967-4258 

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SCHNADER HARRISON SEGAL & LEWIS LLP

George H. Kalikman

650 California Street, 19th Floor

San Francisco, CA 94108-2736

Direct (415) 364-6734

(gkalikman@schnader.com)

Attorneys for Compass Lexecon, LLC

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)

STATEMENT OF ADEL TURKI 

REGARDING CRAVATH, SWAINE & 

MOORE LLP’S CONTINUED 

RETENTION AND EMPLOYMENT OF

COMPASS LEXECON, LLC AS 

ECONOMIC CONSULTANTS

(Re: Docket Nos. 1756 and 1842)

Debtors.

 ̈ Affects PG&E Corporation 

 ̈ Affects Pacific Gas and Electric Company 

þ Affects both Debtors

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

Case: 19-30088 Doc# 2247 Filed: 05/28/19 Entered: 05/28/19 15:58:34 Page 1 of

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I, Dr. Adel Turki, being duly sworn, state the following under penalty of perjury:

1. I am a Senior Managing Director of Compass Lexecon, LLC (“Compass”) a leading 

economic consulting firm. Compass is currently the economic consultant to Cravath, Swaine & 

Moore LLP (“Cravath”), lead coordinating counsel for all wildfire-related issues involving the 

above-captioned debtors and debtors in possession (the “Debtors”). I am authorized to make this 

declaration on behalf of Compass. Unless otherwise stated, I have personal knowledge of the facts 

set forth herein.

2. I attended the hearing (the “Hearing”) on May 22, 2019 to consider the Debtors’ 

Application Pursuant to 11 U.S.C. § 327(a) and Fed. R. Bankr. P. 2014(a) and 2016 for Authority to 

Retain and Employ Compass Lexecon, LLC as Economic Consultants to the Debtors Nunc Pro Tunc 

to Petition Date [Docket No. 1756] (the “Application”). I also reviewed all of the court filings made 

by Compass’s counsel, Togut, Segal & Segal LLP (the “Togut Firm”). At the Hearing, the Court 

stated that consistent with (i) the statements filed by the Togut Firm and (ii) Debtors’ Supplemental 

Statement Regarding Debtors’ Application Pursuant to 11 U.S.C. § 327(a) and Fed. R. Bankr. P. 

2014(a) and 2016 for Authority to Retain and Employ Compass Lexecon, LLC as Economic 

Consultants to the Debtors Nunc Pro Tunc to Petition Date [Docket No. 2072] (the “Debtors’

Statement,” and together with the statements filed by the Togut Firm, the “Statements”), the 

Debtors’ may withdraw the Application and Compass can continue to be employed by Cravath. The 

Court also asked that Compass file this statement confirming that Compass adopts the statements 

made by the Togut Firm, and by Cravath in the Debtors’ Statement and will agree to act in 

accordance with the Statements.

3. I, on behalf of Compass, hereby adopt the representations of counsel set forth in the

Statements and agree to act consistently with the Statements.

4. Additionally, Compass shall provide reasonable notice to Cravath, the Debtors, and 

the U.S. Trustee of any increase of the hourly rates listed in my declaration dated April 29, 2019 (the 

“Turki Declaration”) and my declaration dated May 3, 2019 (the “Supplemental Turki Declaration”).

5. Compass shall conduct an ongoing review of its files to ensure that no conflicts or 

other disqualifying circumstances exist or arise. To the extent that any new material facts or 

Case: 19-30088 Doc# 2247 Filed: 05/28/19 Entered: 05/28/19 15:58:34 Page 2 of

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relationships bearing on matters described in the Turki Declaration during the period of Compass’s 

retention by Cravath are discovered or arise, Compass will file a supplemental declaration.

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

correct to the best of my knowledge and belief. 

Dated: May 28, 2019

/s/ Adel Turki

Adel Turki

Senior Managing Director

Compass Lexecon, LLC 

Case: 19-30088 Doc# 2247 Filed: 05/28/19 Entered: 05/28/19 15:58:34 Page 3 of

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