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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

 

Robert A. Julian (SBN 88469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP

11601 Wilshire Boulevard 

Suite 1400 

Los Angeles, CA 90025 

Telephone: 310.820.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors 

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered) 

□ 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) 

DECLARATION OF STEVEN M. 

CAMPORA IN SUPPORT OF MOTION 

OF THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS FOR RELIEF 

FROM AUTOMATIC TO PERMIT 

STATE COURT JURY TRIAL OF 2017 

TUBBS WILDFIRE CLAIMS 

Date: July 23, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 2845 Filed: 07/02/19 Entered: 07/02/19 18:18:08 Page 1 of

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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I, Steven M. Campora, declare the following under penalty of perjury pursuant to 28 USC 

section 1746: 

1. I have personal knowledge of the facts set forth in this declaration. 

2. I am a member of the State Bar of California and a partner with the law firm of 

Dreyer Babich Buccola Wood Campora LLP (“Law Firm”). 

3. In September 2015, a wildfire ignited and spread in Amador and Calaveras Counties 

in Northern California that CalFire reported destroyed 549 homes, and other outbuildings and 

commercial properties (the “2015 Butte Fire”). 

4. Hundreds of individuals sued Pacific Gas & Electric Company (“PG&E”) in the 

Superior Court of California for the Counties of Calaveras and San Francisco, for damages and 

losses they suffered as a result of the loss of their residences, property, and personal injuries they 

alleged were caused by PG&E’s contribution to the ignition of 2015 Butte Fire (“2015 Butte Fire 

Litigation”). Those cases became the Butte Fire JCCP venued in Sacramento, California. 

5. My firm and I, together with three other firms, represented approximately 1200 

individuals in the 2015 Butte Fire Litigation. I am a Liaison Counsel in the JCCP action and I led 

most of the discovery on behalf of the individual Plaintiffs. 

6. Every one of our clients alleged substantial damage claims against PG&E with 

respect to the property damage, economic losses, loss of use and enjoyment, and/or emotional 

distress damages suffered as a result of PG&E’s actions or inactions that contributed to the 2015 

Butte Fire. 

7. The Law Firm and I did not represent any clients with claims against PG&E for only 

smoke damage. 

8. PG&E litigated my clients’ claims in the Butte Fire Litigation through discovery of 

the documents that supported their claims and written discovery. I am also aware that PG&E 

deposed numerous individual plaintiffs as their cases neared trial. 

9. As part of my representation, I was involved in opposing writs filed by PG&E with 

the Third District Court of Appeal and requests for relief in the California Supreme Court. 

Case: 19-30088 Doc# 2845 Filed: 07/02/19 Entered: 07/02/19 18:18:08 Page 2 of

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10. I requested a trial by jury for some of our clients' claims against PG&E in the 2015 

Butte Fire Litigation. However, the claims of my clients were ultimately settled short of trial. 

11. Some of my clients' cases were settled on the eve of trial. 

12. PG&E never actually tried any of my clients' cases and I am unaware of PG&E 

taking any case, arising from the Butte Fire, to trial. 

13. The 20 I 5 Butte Fire Litigation and settlement process had been ongoing for 

approximately three years at the time PG&E filed for bankruptcy protection. There are some Butte 

Fire victims whose cases have not been resolved. 

I declare under penalty of perjury that the foregoi 

Executed on June 24t1i , 2019 at Sacramento, C ifo 

true and correct. 

Steven . Campora 

Dreyer Babich Buccola Wood & Campora LLP 

20 Bicentennial Circle 

Sacramento, CA 95826 

Tel: (916) 379-3500 

Fax: (916)379-3599 

Email: scampora@dbbwc.com 

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Case: 19-30088 Doc# 2845 Filed: 07/02/19 Entered: 07/02/19 18:18:08 Page 3 of

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