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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) 

Gabrielle L. Albert (#190895) 

(galbert@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) 

DECLARATION OF ROBB MCWILLIAMS 

IN SUPPORT OF MOTION FOR ENTRY OF 

AN ORDER FURTHER EXTENDING 

DEADLINE FOR THE REORGANIZED 

DEBTORS TO OBJECT TO CLAIMS AND 

FOR RELATED RELIEF 

Response Deadline: 

May 31, 2023, 4:00 p.m. (PT) 

Hearing Information If Timely Response Made:

Date: June 7, 2023 

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

Place: (Tele/Videoconference Appearances 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). 

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I, Robb C. McWilliams, hereby declare that the following is true and correct to the best of my 

knowledge, information and belief: 

1. I am a Partner and Managing Director at the firm of AlixPartners, LLP, which is an 

affiliate of both AlixPartners, LLC and AP Services, LLC (collectively, “AlixPartners”). AlixPartners 

provided interim management services to Pacific Gas and Electric Corporation and Pacific Gas and 

Electric Company, as debtors and reorganized debtors (collectively, the “Debtors,” and as reorganized 

pursuant to the Plan, the “Reorganized Debtors”) in the above-captioned chapter 11 cases (the 

“Chapter 11 Cases”). AlixPartners continues to assist the Reorganized Debtors in resolving the Chapter 

11 General Claims while also providing support with respect to the Securities Claims. I submit this 

Declaration in support of the Motion for Entry of an Order Further Extending Deadline for the 

Reorganized Debtors to Object to Claims and for Related Relief (the “Motion”).1

2. In my current position, I am responsible for overseeing the bankruptcy case management 

component of AlixPartners’ assignment to assist the Reorganized Debtors with various matters related 

to these Chapter 11 Cases. My areas of responsibility include the effort by AlixPartners, in coordination 

with the Reorganized Debtors, to review and assess the validity of all claims asserted against the Debtors, 

other than (a) Fire Claims and Subrogation Wildfire Claims and (b) providing support with respect to 

Securities Claims. I am generally familiar with the Reorganized Debtors’ day-to-day operations, 

financing arrangements, business affairs, and books and records. Except as otherwise indicated herein, 

all facts set forth in this Declaration are based upon my personal knowledge, the knowledge of other 

AlixPartners professionals working under and alongside me on this matter, my discussions with the 

Reorganized Debtors’ personnel and the Reorganized Debtors’ various other advisors, and my review of 

relevant documents and information prepared by the Reorganized Debtors. If called upon to testify, I 

would testify competently to the facts set forth in this Declaration. I am authorized to submit this 

Declaration in support of the Motion. 

1

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

the Motion. 

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3. A team of AlixPartners professionals under my supervision has been actively involved in 

the claims review and reconciliation process since shortly after the filing of these Chapter 11 Cases. 

AlixPartners initially assisted the Debtors in the preparation of their bankruptcy schedules based on the 

Debtors’ books and records. AlixPartners also has coordinated with the Debtors in reconciling and 

reviewing filed proofs of claim with claims reflected in the Debtors’ schedules and books and records. 

AlixPartners has developed and maintains a claims reconciliation database and various data management 

applications that are used by the Reorganized Debtors and AlixPartners, among other things, to identify 

both valid claims as well as claims that are not valid in whole or in part and the appropriate grounds for 

objection to such claims. AlixPartners has been supporting, and will continue to support, the efforts of 

the Reorganized Debtors and their counsel to resolve disputed claims, including by formal objections as 

necessary. 

4. The Debtors began the process of gathering and consolidating information relating to 

their liabilities when preparing their schedules and statements of financial affairs, long before any Proofs 

of Claim were filed in these Chapter 11 Cases. As indicated in the Initial Extension Motion, more than 

22,440 Proofs of Claim had been scheduled or filed against the Debtors, asserting over $68.4 billion in 

the aggregate (not including Claims listed in the Debtors’ schedules as contingent, unliquidated, and/or 

disputed).2 The reconciliation, resolution, and distributions of the claims have required extensive efforts 

by the Reorganized Debtors’ team of advisors, attorneys, and personnel. 

5. As of Friday, May 12, 2023, the Reorganized Debtors have successfully expunged 

through objection, reduced through settlement, reconciled and allowed, or otherwise resolved 

approximately 19,672 claims asserting approximately $61.1 billion in claims, representing 

approximately 89% of the total dollar amount of claims asserted in these Chapter 11 Cases (including 

2

 Since the First Extension Motion, the Reorganized Debtors received approximately 1,630 additional 

untimely Claims asserting approximately $500 million in aggregate claims. This brings the total number 

of Proofs of Claim filed or scheduled against the Debtors to more than 24,000 in count, asserting 

approximately $68.9 billion in aggregate claims. These figures and the other discussed exclude 

approximately 87,800 Fire Victim Claims and Subrogation Wildfire Claims, which will be resolved by 

the Fire Victim Trust and Subrogation Wildfire Trust, respectively, in accordance with the Plan. 

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Securities Claims, but excluding Fire Victim Claims and Subrogation Wildfire Claims). 

A. The General Claims

6. Resolved Claims. The Debtors and Reorganized Debtors have undertaken extensive 

efforts to resolve certain General Claims through negotiated settlements, including through the General 

Claims Procedures further described below. These negotiation efforts have yielded the settlement of 

approximately 2,366 General Claims, totaling over $5.6 billion in asserted claim amounts (plus 

unliquidated amounts), both within and separate from the General Claims Procedures discussed below. 

Approximately 44 of those General Claims have been settled during the Fifth Extension Period. Another 

9,510 of the General Claims were resolved through omnibus objections filed since the Effective Date, 

as well as related claim withdrawals and the expungement of late-filed claims. 

7. Claims Litigated Outside of the Bankruptcy Court. Currently approximately 38 General 

Claims are being litigated in non-bankruptcy fora, pursuant to order of the Court modifying the automatic 

stay or Plan Injunction. Pursuant to the Third Extension Order, such Claims are deemed to have been 

objected to for purposes of the Plan’s definition of “Allowed.” Plan, Section 1.7(f). 

8. Recategorized Claims. In March 2023, the Fire Victim Trustee and the Reorganized 

Debtors identified eight claims, which had been preliminary identified as Fire Victim Claims but did not 

in fact constitute Fire Victim Claims. The Reorganized Debtors have filed objections to all eight of these 

Recategorized Claims and those objections are pending as of the date of this motion. 

9. Remaining Claims. Since the Effective Date, the Reorganized Debtors have successfully 

resolved 99% of the General Claims. There currently remain approximately 84 General Claims that are 

unresolved. Of the remaining 84 General Claims that are unresolved, most are either 

indemnification/subrogation claims that will not be known or liquidated until the conclusion of the 

underlying disputes or claims where the parties are attempting to resolve the dispute without the need 

for court intervention. 

B. The Securities Claims

10. Settlement Offers. AlixPartners has set up a web site to manage the settlement offer 

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process for Securities Claims. Typically when offers are sent to holders of Securities Claims, 

AlixPartners provides a unique login and password that allows the claimant to review the offer and 

respond to the offer on-line. As a result, AlixPartners is able to monitor which claimants have reviewed 

their offers online as well as the responses, if any, to the offers. 

11. The Securities Procedures have been effective in resolving Securities Claims. As of 

Friday May 12, 2023, the Reorganized Debtors have extended settlement offers pursuant to the Securities 

Procedures with respect to 4,997 Securities Claims. Settlement offers were made with respect to 3,597 

Securities Claims during the Fifth Extension Period. The Reorganized Debtors have now made 

settlement offers to approximately 72 percent of all Securities Claims that have not been expunged, 

disallowed, or withdrawn. 

12. The response to the settlement offers continues to be positive. As a result of the settlement 

offers, 2,580 Securities Claims have been settled. During the Fifth Extension Period, settlement offers 

have been accepted with regard to 1,552 Securities Claims. Overall, the rate of acceptance on settlement 

offers remains very high. As of Friday, May 12, 2023, 90 percent of the settlement offers opened and 

viewed on the settlement web portal have been accepted. As of Friday, May 12, 2023, only 136 

settlement offers, relating to 147 claims, have been declined.3 As of Friday May 12, 2023, 2,270 

Securities Claims which have received settlement offers have not either accepted or declined those 

offers. Most of these settlement offers are either unopened (we have, on behalf of the Reorganized 

Debtors sent reminders to claimants with unopened offers) or are in the process of active negotiations 

between claimants and the Reorganized Debtors under the Securities Procedures. 

13. Omnibus Objections. As of Friday, May 12, 2023, the Reorganized Debtors have filed 21 

Securities Claims Omnibus Objections to the Securities Claims, resulting in the disallowance and 

expungement of 1,805 Securities Claims. 

3

 After May 12, 2023, we have received (as of 10:30AM ET on May 17, 2023) notice that 322 Securities 

Claimants represented by RKS have declined offers without making counter-offers under the Securities 

Procedures. Thus, of the total number of claims outright denying settlement offers under the Securities 

Procedures, 74 percent of those claims are by claimants represented by RKS. 

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14. Claims Resolved Through Other Means. As of the date of this Motion, the Reorganized 

Debtors have expunged 72 Securities Claims through omnibus objections under the General Claims 

Procedures, an employee claims objection, and stipulations filed with the Court. An additional 201 

Securities Claims have been withdrawn. 

15. Total Resolved Securities Claims. 8,848 Securities Claims have been submitted in the 

Chapter 11 Cases. Of these claims, approximately 4,574 were filed as of the Extended Bar Date. An 

additional approximately 4,274 Securities Claims have been submitted following the Extended Bar Date, 

some as amendments of prior claims. The Reorganized Debtors have resolved through settlements, 

omnibus motions or otherwise, more than half of the total Securities Claims submitted – approximately 

4,650 Securities Claims, representing $1.5 billion in face value. The graph attached hereto as Exhibit A

provides a summary of Securities Claims resolved since the Effective Date and progress made during 

the Fifth Extension Period. 

16. Remaining Claims. Of the approximately 4,200 Securities Claims that remain unresolved, 

the Reorganized Debtors have made settlement offers with respect to 2,417 claims. As of May 12, 2023, 

2,270 of those offers remain pending. Over 97% of the unresolved potential damage amount resides in 

approximately 94 individual claimants or affiliated groups of claimants. 

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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, information, and belief. 

Executed May 17, 2023 in Dallas, Texas. 

/s/ Robb McWilliams

Robb McWilliams

 Managing Director 

 

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