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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@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 LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors 

and Debtors in Possession 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

- and - 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

 Affects PG&E Corporation 

 Affects Pacific Gas & Electric Company 

 Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

 Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

SUPPLEMENTAL DECLARATION OF 

GREGG M. FICKS IN SUPPORT OF 

APPLICATION PURSUANT TO 11 U.S.C. 

§ 327(e) AND FED. R. BANKR. P. 2014(a) 

AND 2016 FOR ORDER AUTHORIZING 

THE DEBTORS TO EMPLOY COBLENTZ 

PATCH DUFFY & BASS LLP AS SPECIAL 

COUNSEL NUNC PRO TUNC TO THE 

PETITION DATE

Date: July 9, 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# 2888 Filed: 07/08/19 Entered: 07/08/19 11:21:16 Page 1 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

I, Gregg M. Ficks, declare: 

1. I am a partner at the law firm of Coblentz Patch Duffy & Bass LLP (“Coblentz” or 

the “Firm”), resident in Coblentz’s San Francisco office located at One Montgomery Street, Suite 

3000, San Francisco, CA 94104. I am a member in good standing of the State Bar of California, and 

of this Court. I submit this Supplemental Declaration in connection with the Application1 of the 

above-captioned debtors and debtors in possession (collectively, “PG&E” or the “Debtors”), for an 

order, pursuant to section 327(e) of title 11 of the United States Code (the “Bankruptcy Code”) and 

Rules 2014(a) and 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), 

approving the employment and retention of Coblentz as one of the Debtors’ special counsel 

effective nunc pro tunc to January 29, 2019 (the “Petition Date”). Unless otherwise stated in this 

Declaration, I have personal knowledge of the matters set forth herein. 

2. I have reviewed the Objections and Joinder [Docket Nos. 2834, 2837, and 2841] 

regarding the Application filed by the Official Committee of Tort Claimants (the “TCC”) and the 

Plaintiffs’ Executive Committee appointed by the Alameda County Superior Court in Case No. 

RG16843631 and related cases. 

3. As I disclosed in my initial Declaration [Docket No. 2596] in support of the 

Application: 

Coblentz represents the City of Oakland, California (the “City”) in a 

series of civil actions pending in Alameda County Superior Court 

arising from the Ghost Ship fire, titled Gregory et al. v. Chor Nar Siu 

Ng, et al. (Case No. RG 16843631 and related cases) (the “Oakland 

Warehouse Fire Litigation”). Debtor Pacific Gas and Electric 

Company is a co-defendant in the Oakland Warehouse Fire Litigation. 

Should any adversity arise between the City and Debtor Pacific Gas 

and Electric Company in the Oakland Warehouse Fire Litigation, 

Coblentz will not advise or represent the City regarding any matters 

for which any such adversity has arisen, and the City will need to rely 

on other counsel to advise and represent it regarding any such matters 

should it require counsel. 

Declaration at page 7, line 27, through page 8, line 4. 

4. While the City of Oakland and the Utility are both defendants in the Oakland 

 

1

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

terms in the Application. 

Case: 19-30088 Doc# 2888 Filed: 07/08/19 Entered: 07/08/19 11:21:16 Page 2 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Warehouse Fire Litigation, they are not cross-defendants against each other. As indicated in my 

initial Declaration (and consistent with the Utility’s pre-petition written waiver regarding this issue), 

should any adversity or conflict of interest arise between the Utility and the City of Oakland in the 

Oakland Warehouse Fire Litigation, Coblentz would not advise or represent the City of Oakland 

against the Utility in connection with any such matters for which they become adverse. Coblentz 

also will not represent the Utility in connection with any such matters. 

5. Statements in the Application and my initial Declaration indicating that the scope of 

services Coblentz will provide to the Debtors during the course of these Chapter 11 Cases will 

include “other legal services as requested by the Debtors during the pendency of their Chapter 11 

Cases, to the extent Coblentz agrees to perform such work” as referenced in the TCC’s Opposition, 

do not mean, and were not intended to imply, that Coblentz will perform services for the Debtors in 

connection with the Oakland Warehouse Fire Litigation. It will not. Further to the TCC’s 

comments, Coblentz confirms it will not represent the Debtors in matters relating to the Oakland 

Warehouse Fire Litigation, including in connection with claims estimation and the claims process, 

and it will not share with the Debtors any non-public information regarding the Oakland Warehouse 

Fire Litigation that is not already in the Debtors’ possession, custody, or control. 

6. Coblentz represents Caymus Vineyards in matters that are unrelated to the Debtors 

and these Chapter 11 Cases. Coblentz has not advised Caymus Vineyards regarding the Debtors and 

these Chapter 11 Cases, and will continue to not advise Caymus Vineyards regarding such matters 

during the course of Coblentz’s employment as special counsel in these Chapter 11 Cases, if 

Coblentz is so appointed. 

7. Coblentz has, and has had, various “Lincoln” entity clients in matters that are 

unrelated to the Debtors and these Chapter 11 Cases. Lincoln Partner Advisors LLC is not 

Coblentz’s client, and to the best of Coblentz’s knowledge, has not been Coblentz’s client in the 

past. Coblentz does not advise, represent, or share information with Lincoln Partner Advisors LLC. 

8. Based on the foregoing, and based on the contents of my initial Declaration, I believe 

Coblentz is qualified to serve as special counsel to the Debtors under section 327(e) of the 

Case: 19-30088 Doc# 2888 Filed: 07/08/19 Entered: 07/08/19 11:21:16 Page 3 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Bankruptcy Code and to be paid from these estates, that Coblentz’s retention as special counsel in 

connection with the matters described in the Application is in the best interest of the Debtors, the 

estates, and their creditors, and that Coblentz’s retention should be approved under section 327(e) of 

the Bankruptcy Code. 

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. 

Dated: July 8, 2019 

San Francisco, California 

/s/ Gregg M. Ficks 

Gregg M. Ficks 

Case: 19-30088 Doc# 2888 Filed: 07/08/19 Entered: 07/08/19 11:21:16 Page 4 of

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