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44553.00001

Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice) 

MILBANK LLP 

55 Hudson Yards 

New York, New York 10001-2163 

Telephone: (212) 530-5000 

Facsimile: (212) 530-5219 

and 

Gregory A. Bray (SBN 115367) 

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor 

Los Angeles, CA 90067 

Telephone: (424) 386-4000 

Facsimile: (213) 629-5063 

Counsel for the Official Committee 

of Unsecured Creditors

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) 

FIRST SUPPLEMENTAL DECLARATION 

OF THOMAS R. KRELLER IN 

CONNECTION WITH THE OFFICIAL 

COMMITTEE OF UNSECURED 

CREDITORS’ RETENTION OF 

MILBANK LLP 

Re: Docket No. 1210 & 1766 

 I, THOMAS R. KRELLER, being duly sworn, state the following under the penalty of 

perjury: 

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1. I am an attorney admitted to practice in the State of California and a partner in the 

Financial Restructuring Group of Milbank LLP (“Milbank”), counsel to the Official Committee of 

Unsecured Creditors (the “Committee”) of PG&E Corporation and Pacific Gas and Electric 

Company (the “Debtors”). Milbank maintains an office at, among other places, 2029 Century Park 

East, 33rd Floor, Los Angeles, California, 90067-3019. There are no disciplinary proceedings 

pending against me. 

2. Unless otherwise stated in this declaration (the “First Supplemental Declaration”), 

I have personal knowledge of the matters set forth herein and, if called as a witness, I would testify 

thereto. Certain of the disclosures set forth herein relate to matters not within my personal 

knowledge, but rather within the personal knowledge of other attorneys and employees of Milbank 

who have acted at my direction and under my supervision, and are based on information provided 

by them to me. 

3. On April 3, 2019, I executed and filed my initial declaration (the “Initial 

Declaration”) [Docket No. 1210] in support of the Application of the Official Committee of 

Unsecured Creditors Pursuant to 11 U.S.C. §§ 328(a) and 1103(a) and Fed. R. Bank. R. 2014 and 

2016 for Authority to Retain and Employ Milbank LLP as Counsel, Effective as of February 12, 

2019, dated April 3, 2019 (the “Application”)1 [Docket No. 1208] to, among other things, provide 

certain disclosures required by the Bankruptcy Code, the Bankruptcy Rules and the Local Rules. 

This Declaration has been prepared in accordance with the Initial Declaration, which provides that 

Milbank will supplement the disclosures in the Initial Declaration to the extent required as a result 

of any new material relevant facts or relationships becoming available during these Chapter 11 

Cases. 

 

1

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

Application.

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SUPPLEMENTAL DECLARATION 

4. Following the filing of the Initial Declaration, Milbank received from the Debtors 

an expanded list of parties in interest (the “Potential Parties-in-Interest”). Milbank compared this 

list with the names contained in the database of current and former clients and other relationships 

maintained by Milbank in the ordinary course of its business. In addition, to the extent a search 

had not already been performed on such party, Milbank also searched the parties listed in the: 

(i) First Supplemental Declaration and Disclosure of Stephen Karotkin Pursuant to 11 U.S.C. 

§ 327(a) and Fed. R. Bankr. P. 2014(a) and 2016 on Behalf of Weil, Gotschal & Manges LLP

[Docket No. 1861]; and (ii) Second Supplemental Declaration and Disclosure of Stephen Karotkin 

Pursuant to 11 U.S.C. § 327(a) and Fed. R. Bankr. P. 2014(a) and 2016 on Behalf of Weil, 

Gotschal & Manges LLP [Docket No. 1950]. 

5. In addition, Milbank has continued to monitor its new client database to enable 

prompt disclosure of any information that is contrary or otherwise pertinent to any statements made 

in the Initial Declaration. 

6. Based on these searches and ongoing monitoring, Milbank has identified certain 

additional Potential Parties-in-Interest that have connections with Milbank. A list of all such 

connections is attached hereto as Schedule A. 

7. Milbank also searched whether any of the relationships listed in the Initial 

Declaration had changed since its filing. To the best of my knowledge, information, and belief, 

there have been no such changes. 

8. Based on all of the foregoing, to the best of my knowledge and except as otherwise 

noted herein and in the Initial Declaration, Milbank does not represent any entity having an adverse 

interest in connection with these cases, and therefore continues to be eligible to represent the 

Committee. Milbank will continue to monitor its connections to the Debtors, their creditors and 

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other parties in interest in these cases. If any additional relationships are discovered or arise which 

were not disclosed herein or in the Initial Declaration, Milbank will promptly supplement its 

disclosure to the Court. 

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. 

Executed on August 5, 2019, Los Angeles, CA 

/s/ Thomas R. Kreller 

Thomas R. Kreller 

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44553.00001

SCHEDULE A 

Additional Potential Parties-in-Interest

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Party Name Relationship to the Debtors2 Relationship to Milbank3

Angelo, Gordon & Co., L.P 2019 Statement Parties 

(Member of Ad Hoc 

Committee of Senior 

Unsecured Noteholders) / 

Unsecured Noteholder 

Current client on a matter 

unrelated to the Debtors or 

the Chapter 11 cases.

Centerview Partners LLC Official Committee of 

Unsecured Creditors – 

Professionals and Members

Former client on a matter 

unrelated to the Debtors or 

the Chapter 11 cases. 

KPMG Debtors’ Professionals Current client on a matter 

unrelated to the Debtors or 

the Chapter 11 cases 

 

2

 The Relationship to the Debtors is correlated with the categories of relationships from the Debtors’ disclosure 

lists. Where a Party was listed in multiple categories, each category is indicated. 

3

 A “current client” is an entity for which there are, as of the date hereof, active matters on which Milbank is 

engaged; a “former client” is an entity for which there were no active matters as of the date hereof, but there 

may in the future be active matters. Use of the word “potential” before such designations signifies entities 

for which Milbank was unable to determine whether the similarities of names was a coincidence or whether 

the party in interest is related to a client in Milbank’s databases. Milbank does not represent any “potential” 

clients in matters related to the Chapter 11 cases. Please note that the identification of a party in interest on 

Schedule A is not an admission of a conflict, disabling or otherwise.

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