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DECLARATION OF ROBERT BRYSON

Bill Robins III, Esq. (SBN 296101)

Robert T. Bryson, Esq. (SBN 156953)

Rex Grady, Esq. (SBN 232236)

ROBINS CLOUD LLP

808 Wilshire Blvd., Suite 450

Santa Monica, California 90401

Telephone: (310) 929-4200

Facsimile: (310) 566-5900 

Attorneys for Creditor, Gail Mitcham

Matthew W. Grimshaw, Esq. (SBN 210424)

GRIMSHAW LAW GROUP, P.C.

26 Executive Park, Ste. 250

Irvine, California 92614

Telephone: (949) 734-0187

Facsimile: (208) 391-7860

Counsel for Robins Cloud LLP

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION, 

and

PACIFIC GAS AND ELECTRIC 

COMPANY

Debtors

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Case No. 19-30088 (DM)

Chapter 11

(Lead Case–Jointly Administered)

DECLARATION OF ROBERT 

BRYSON IN SUPPORT OF MOTION 

FOR ORDER AUTHORIZING 

WITHDRAWAL OF COUNSEL TO 

GAIL MITCHAM

Affects:

PG&E Corporation

Pacific Gas & Electric Company

Both Debtors

* All papers shall be filed in the Lead 

Case, No. 19-30088 (DM).

Case: 19-30088 Doc# 13070 Filed: 10/13/22 Entered: 10/13/22 17:28:15 Page 1

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DECLARATION OF ROBERT BRYSON

Declaration of Robert Bryson

I, Robert Bryson, say and declare as follows:

1. I am an individual over 18 years of age and competent to make this declaration.

2. I am an attorney with the law firm of Robins Cloud LP (the “Firm”), attorneys of 

record for Gail Mitcham (“Creditor”).

1 I am duly admitted to practice law before all courts of the 

State of California and before this court. 

3. I make this declaration in support of the Firm’s motion to be relieved as counsel 

to Creditor in the above-captioned bankruptcy case (“Motion”). The facts set forth below are true 

and within the scope of my personal knowledge, and if called upon to do so I could and would 

testify competently to these facts.

4. On January 29, 2019, Debtors filed voluntary petitions commencing their

bankruptcy cases. 

5. On October 16, 2019, the Firm filed Proof of Claim No. 30184 on behalf of Gail 

Mitcham (“Claim”), seeking damages from the North Bay Fire. Since the filing of the Claim, an 

irreconcilable difference has developed between Creditor and the Firm. As a result, the Firm 

notified Creditor that it must withdraw as counsel. 

6. To the extent that Creditor requests that the Firm turn over any files or 

information that he is entitled to, the Firm will cooperate and transmit such files.

7. The Firm will cause the Motion to be served on all of the addresses provided to 

the Firm by Creditor, including the following:

2810 Porter Creek Road

Santa Rosa, CA 95404

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

Executed on October 13, 2022.

Robert Bryson

1 The Firm retained Grimshaw Law Group, P.C. (“GLG”) to, among other things, assist it in filing 

this motion. GLG has no contractual or attorney/client relationship with Creditor.

Case: 19-30088 Doc# 13070 Filed: 10/13/22 Entered: 10/13/22 17:28:15 Page 2

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