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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: 650 636 925

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 ANGELA FERRANTE 

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 

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). 

Case: 19-30088 Doc# 13746 Filed: 05/17/23 Entered: 05/17/23 20:14:38 Page 1

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I, Angela Ferrante, hereby declare that the following is true and correct to the best of my 

knowledge, information and belief: 

1. I am a Managing Director of Kroll Settlement Administration LLC, an affiliate of Kroll 

Restructuring Administration LLC (formerly known as Prime Clerk) (collectively for purposes of this 

Declaration, “Kroll”). 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”), filed contemporaneously herewith1 in the chapter 11 cases (the “Chapter 11 Cases”) of 

PG&E Corporation and Pacific Gas and Electric Company, as debtors and reorganized debtors 

(collectively, the “Debtors” or the “Reorganized Debtors,” as applicable). In my current role as 

Managing Director, I am responsible for operations including but not limited to securities claims noticing 

and administration. 

2. Except as otherwise indicated herein, all facts set forth in this Declaration are based upon 

my personal knowledge, the knowledge of other Kroll professionals working under and alongside me on 

this matter, my discussions with the Reorganized Debtors’ personnel and the Reorganized Debtors’ 

various advisors, and my review of relevant documents and information. If called upon to testify, I would 

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

on behalf of the Reorganized Debtors. 

3. Kroll has been asked by the Reorganized Debtors and their counsel to assist with 

reviewing and analyzing the claims based on the purchase or acquisition of PG&E securities filed in the 

Chapter 11 cases. In furtherance of this work, Kroll has been assisting PG&E with collecting trading 

information pursuant to the Securities Procedures adopted by the Court from claimants who have filed 

Securities Claims. Specifically, Kroll has helped develop, distribute and sent Trading Information 

Request Forms (“TIRF”) to Securities Claimants to obtain the information necessary pursuant to the 

Securities Procedures. Kroll, on behalf of the Reorganized Debtors, also created and established, a web 

portal through which claimants could submit trading data in response to the TIRFs. The web portal was 

designed to allow claimants to submit information required by the Court under the Securities Procedures 

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

Motion.

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in an efficient and straightforward manner. The web portal also allows for identification of trading 

information deficiencies and allows claimants to correct those deficiencies by submitting additional 

information through the portal. 

A. The Trading Information Collection Process 

4. In accordance with Securities Procedures, Kroll began sending TIRFs on February 26, 

2021. Since then, Kroll has sent TIRFs to more than 5,396 Securities Claimants whose trading 

information was deficient for one or more reasons. Under the Securities Procedures, Securities Claimants 

were required to complete and return the trading information required by the TIRF no later than fortyfive (45) days after the mailing of the TIRF. 

5. Thousands of Securities Claimants failed to timely respond to the information requests. 

Kroll sent follow-up letters to claimants and also called and emailed claimants to seek to obtain responses 

to the TIRFs and the necessary trading information called for by the TIRFs. With respect to claimants 

who did not respond to this initial follow-up, Kroll and the Reorganized Debtors attempted to contact 

those claimants a second time (by sending an additional follow-up letter to every mailing and email 

address listed on the proof of claim) to remind them to provide the requested information. 

6. Despite Kroll and the Reorganized Debtors’ efforts to collect data from Securities 

Claimants, a substantial number of claimants have not responded to the TIRFs to date. Additionally, 

many of the claimants who responded did not provide complete data. Koll continues to solicit and receive 

data from Securities Claimants. This outreach includes sending follow-up emails detailing any 

outstanding requests or deficiencies in the data, and otherwise engaging in an ongoing dialogue to 

address any trading data deficiencies. The process for gathering all of the relevant information has been 

challenging, particularly with respect to larger claims, such as those submitted by institutional investors, 

for which there may be many thousands of transactions and various accounts. 

7. Since December 15, 2022, Kroll has sent out 432 trading information reminders, with the 

most recent reminder letter having been sent on May 5, 2023. Since December 15, 2022, Kroll has 

received trading information from Securities Claimants with respect to 33 claims filed by eight 

claimants. As of Friday, May 12, 2023, Kroll is still waiting to receive requested trading information 

with respect to 781 total claims for which a settlement offer is not currently pending. 

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B. Institutional Shareholder Services Bulk Filing

8. Institutional Shareholder Services (“ISS”) filed 29 proofs of claim in these cases. These 

claims were bulk proofs of claim on behalf of multiple claimants representing thousands of accounts. 

9. On March 12, 2021, Kroll sent ISS a TIRF for each of the bulk proofs of claim, which 

required ISS to provide trading information for those claimants on whose behalf ISS filed claims. While 

ISS initially contacted Kroll to work through logistics and related issues regarding potential submissions, 

ultimately, we became aware of a letter dated May 24, 2021 from ISS to each of the claimants on whose 

behalf they had filed informing them that ISS would take no further steps to complete the TIRFs and 

suggesting that these claimants hire separate counsel to prosecute their proofs of claim. Thereafter, 

various claimants previously included in a claim filed by ISS began filing amending proofs of claim, the 

most recent of which was filed on February 27, 2023. Many of the individual claimants in the original 

ISS bulk filings submitted trading data many months, and in some instances some more than a year, after 

the TIRFs were sent to ISS. Kroll is still waiting to receive requested trading information with respect 

to hundreds of claims that are related to the original ISS bulk filings. 

10. I also understand that many of the former ISS clients have retained RKS as counsel. RKS 

has filed amended proofs of claim on behalf of these clients and has submitted amended proofs of claim 

with respect to the former ISS bulk filings as recently as April 19, 2022. In addition, Kroll has received 

trading data from RKS for former ISS clients as late as October 14, 2022. 

[REMAINDER OF PAGE LEFT BLANK INTENTIONALLY] 

 

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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 New York, New York. 

/s/ Angela Ferrante

Angela Ferrante

Managing Director 

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