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Kevin J. Lamb, SBN 125710

E-Mail: klamb@lkfirm.com

Michael K. Slattery, SBN 107303

E-Mail: mslattery@lkfirm.com

Thomas G. Kelch, SBN 100709

E-Mail: tkelch@lkfirm.com

LAMB & KAWAKAMI LLP

333 South Grand Avenue, Suite 4200

Los Angeles, California 90071

Telephone: (213) 630-5500

Facsimile: (213) 630-5555

Attorneys for AD HOC CALIFORNIA

PUBLIC ENTITIES COMMITTEE

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors,

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

VERIFIED STATEMENT OF THE 

AD HOC CALIFORNIA PUBLIC 

ENTITIES COMMITTEE 

PURSUANT TO BANKRUPTCY 

RULE 2019 ☐ Affects PG&E Corporation

☐ Affects Pacific Gas and Electric 

Company

☒ Affects Both

*All papers shall be filed in the Lead 

Case, 19-30088 (DM)

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Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”) the Ad Hoc California Public Entities Committee (the “Ad 

Hoc Committee”), composed of the California counties listed in Exhibit 1, and 

having claims as public entities against PG&E Corporation and Pacific Gas and 

Electric Company (the “Debtors”) more fully described in Exhibit 1, by and 

through its undersigned counsel, hereby submits this verified statement (“Verified 

Statement”), and in support thereof, states as follows:

1. In January, 2019, the California County Counsel Association, which 

monitors developments in the law and new cases which affect the interests of 

California counties, formed the Ad Hoc Committee. On March 22, 2019, the Ad 

Hoc Committee engaged Lamb & Kawakami LLP (“L&K”) to represent it in 

connection with these chapter 11 cases. Individual members of the Ad Hoc 

Committee joined the committee and engaged L&K on various dates due, in part, 

to the fact that public entities require approval of boards or other governmental 

bodies to retain counsel.

2. As of the date of this Verified Statement, L&K represents only the Ad 

Hoc Committee and certain individual members of the committee. L&K does not 

represent or purport to represent any other entities in connection with the Debtors’ 

chapter 11 cases and does not undertake to represent the interest of, and are not

fiduciaries to any other entities. Each member of the Ad Hoc Committee is aware 

of and has consented to the L&K group representation. Members of the AD Hoc 

Committee do not represent or purport to represent any other entities in connection 

with the Debtors’ chapter 11 cases, but are public entities that provide services to 

the public within their jurisdictions.

3. The members of the Ad Hoc Committee have claims of various types 

arising from their relationship with the Debtors as public entities. Pursuant to 

Bankruptcy Rule 2019, a list of names, addresses and the disclosable economic 

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interests in relation to the Debtors as of June 11, 2019, is attached as Exhibit 1. The 

Ad Hoc Committee members hold numerous and varied types of economic 

interests in relation to the Debtors including claims of the kinds more fully 

described in Exhibit 1. 

4. The information set forth in Exhibit 1, which has been reviewed and

approved by the Ad Hoc Committee, is intended only to comply with Bankruptcy 

Rule 2019 and is not intended for any other purpose. L&K does not make any 

representation regarding the validity, amount, allowance, or priority of such 

economic interests and reserves all rights with respect thereto. 

5. There is no written instrument which authorizes the Ad Hoc

Committee to act. The Ad Hoc Committee has acted and will continue to act with 

the consent of its members. 

6. Nothing contained in the Verified Statement or Exhibit 1 should be

construed as a limitation on, or waiver of, any rights of any member of the Ad Hoc 

Committee to assert, file and/or amend their claims in accordance with applicable 

law and any orders entered in these chapter 11 cases. 

7. The Ad Hoc Committee does not, by filing this Verified Statement nor

any subsequent appearance, pleading, claim or suit, submit to the jurisdiction of the 

Bankruptcy Court or intend that this Verified Statement constitute a waiver of any 

of its rights: (i) to have final orders in core and non-core matters entered only after 

de novo review by a District Judge; (ii) to have any final order entered by, or other 

exercise of the judicial power of the United States performed by, an Article III 

court; (iii) to trial by jury in any proceeding so triable in these cases, or any 

controversy or proceeding related to these cases; (iv) to have the reference 

withdrawn by the District Court in any matter subject to mandatory or 

discretionary withdrawal; (v) to any objection to the jurisdiction of the Bankruptcy 

Court; or (vi) to assert any other rights, claims, actions, defenses, setoffs or 

recoupments to which the County is or may be entitled, in law or in equity, all of 

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which rights, claims, actions, defenses, setoffs and recoupments the County 

expressly reserves. 

8. L&K reserves the right to amend and/or supplement this Verified

Statement in accordance with the requirements of Bankruptcy Rule 2019. 

DATED: June 18, 2019 Respectfully submitted,

LAMB & KAWAKAMI LLP

MICHAEL K. SLATTERY

THOMAS G. KELCH

By: /s/ Michael K. Slattery

Michael K. Slattery

Attorneys for the Ad Hoc California 

Public Entities Committee

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VERIFICATION 

I, Rita L. Neal, declare: 

6 1. I am the San Luis Obispo County Counsel and the Chair of the Ad Hoc 

7 California Public Entities Committee for the PG&E CORPORATION and 

8 PACIFIC GAS AND ELECTRIC COMPANY bankruptcy cases; 

9 2. I have read the foregoing Verified Statement of the Ad Hoc California 

1 o Public Entities Committee Pursuant to Bankruptcy Rule 20 I 9 and know the 

11 contents of the Statement; 

12 3. The contents of the Statement are true of my own knowledge, except as to 

13 those matters which are therein stated on information and belief, and, as to 

14 those matters, I believe them to be true. 

15 

16 Executed on June'12019, at San Luis Obispo, California. 

17 

18 I declare under penalty of perjury that the foregoing is true and correct. 

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RitaL. Neal 

Chair of the Ad Hoc California 

Public Entities Committee 

Case: 19-30088 Doc# 2578 Filed: 06/18/19 Entered: 06/18/19 13:57:00 Page 5 of

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Exhibit 1

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Names and Addresses of Committee Members

Member Name Address Disclosable Economic 

Interest

County of San Luis Obispo 1055 Monterey Street 

Ste. D320 

San Luis Obispo, CA 93408 

General Claimsi

County of Sonoma 575 Administration Drive 

Room 105-A 

Santa Rosa, CA 95403

General Claims

Wildfire Claimsii

County of Marin 3501 Civic Center Drive 

Ste. 275

San Rafael, CA 94903

General Claims

County of Calaveras 891 Mountain Ranch Road

San Andreas, CA 95249

General Claims

County of Monterey 168 West Alisal Street, 3rd fl. 

Salinas, CA 93901

General Claims

County of San Benito Office of the County Counsel, 

481 4th St. Fl. 2 

Hollister, CA 95023-3840 

General Claims

County of San Joaquin 44 North San Joaquin Street

Sixth Floor, Suite 679

Stockton, CA 95202

General Claims

County of Tulare 2900 W. Burrel Avenue 

Visalia, CA 93291

General Claims

County of Fresno 2220 Tulare St, Fifth Floor 

Fresno, CA 93721

General Claims

County of Mariposa 5100 Bullion Street, 2nd fl. 

Mariposa, CA 95338

General Claims

County of Tuolumne 2 S. Green Street 

Sonora, CA 95370

General Claims

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Member Name Address Disclosable Economic 

Interest

County of Yolo 625 Court St., Ste. 201 

Woodland, CA 95695

General Claims

County of Alameda 1221 Oak Street, Suite 450 

Oakland, CA 94612

General Claims

County of Madera 200 West 4th St

Madera, CA 93637

General Claims

County of El Dorado 330 Fair Lane 

Placerville, CA 95667

General Claims

County of Stanislaus 1010 10th St., #6400

Modesto, CA 95354

General Claims

 

 

i

The economic interests of members of the Committee include several types of existing and potential claims against 

PG&E described below. These claims vary from member to member of the Committee. The members will to the 

extent possible calculate the amounts of these claims in Proof of Claim forms filed by the claims bar date. The types 

of claims the members generally hold or may hold include (these claims are referred to as “General Claims”):

a. Claims for real property taxes, franchise fees, and utility users’ taxes collected by PG&E;

b. Claims for damage to public property from PG&E’s operations;

c. Claims for failure to restore public property after excavation of public property to service PG&E’s 

underground facilities;

d. Claims for performance of obligations to move utility lines underground pursuant to Public Utilities 

Commission Rule 20 A;

e. Claims arising from breach of contract between PG&E and a particular member;

f. Claims for failure to perform obligations under state or federal law, including obligations to make monetary 

payments; 

g. Breach of obligations to provide electric power and natural gas to public facilities operated by the 

members;

h. Claims for indemnity for any obligations paid by members as a result of any failure of performance, default 

or other harm caused by PG&E.

With respect to members where wildfires occurred, members hold or may hold claims additional to General Claims 

including claims of the following kinds (these claims are referred to as “Wildfire Claims”):

a. Damage to public services and infrastructure including public buildings, revenue generating public assets 

and services, roads, bridges, sidewalks, culverts, drains, storm and water systems (both damage to and 

contamination of such systems), traffic lights, stop signs, public landscaping, art, lost capacities in 

reservoirs, water storage and landfills;

b. Increased costs from workers’ compensation claims and overtime, and from increased use and need for law 

enforcement, emergency response personnel, and other public safety services;

c. Claims for indemnity for any payments made by members as a result of damage caused by wild fires.

ii See definition in Endnote i above.

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