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UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

- and - 

PACIFIC GAS AND ELECTRIC 

COMPANY

Debtors.

Bankruptcy Case No. 19 - 30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF KEVIN J. ORSINI IN 

SUPPORT OF DEBTORS’ OBJECTION TO 

THE AMENDED MOTION OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS FOR RELIEF FROM 

AUTOMATIC STAY TO PERMIT STATE 

COURT JURY TRIAL OF 2017 TUBBS 

WILDFIRE CLAIMS AND THE MOTION OF 

THE AD HOC GROUP OF SUBROGATION 

CLAIM HOLDERS FOR RELIEF FROM THE 

AUTOMATIC STAY 

Date: July 24, 2019 

Time: 9:30 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

 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). 

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) 

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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019

Tel: 212 474 1000 

Fax: 212 474 3700 

Case: 19-30088 Doc# 3105 Filed: 07/19/19 Entered: 07/19/19 15:37:40 Page 1 of

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Pursuant to 28 U.S.C. § 1746, I, Kevin J. Orsini, hereby declare under penalty of perjury as follows: 

1. I am a Member of Cravath, Swaine & Moore LLP (“Cravath”), counsel to Pacific Gas 

and Electric and PG&E Corporation (collectively, “PG&E” or the “Debtors”) in the above-captioned 

chapter 11 cases. I am admitted to practice in the State of New York and am admitted to practice 

before this Court pro hac vice. See Dkt. No. 88. I submit this Declaration in Support of the Debtors’ 

Objection to the Amended Motion of the Official Committee of Tort Claimants for Relief from 

Automatic Stay to Permit State Court Jury Trial of 2017 Tubbs Wildfire Claims and the Motion of the 

Ad Hoc Group of Subrogation Claim Holders for Relief from the Automatic Stay (the “Objection”). I 

have personal knowledge of the facts set forth in this declaration except as otherwise stated. 

2. Cravath represented the Debtors in prepetition litigation in California state court 

relating to the 2017 North Bay Wildfires (the “North Bay Fires”), including in consolidated 

proceedings under the caption California North Bay Fires Cases, JCCP No. 4955 (Cal. Super. Ct.). 

As trial counsel handling that litigation, I have personal knowledge of the status of discovery and other 

proceedings as they existed as of January 29, 2019, the date the Debtors filed their voluntary petitions 

for relief in these cases (the “Petition Date”). As of the Petition Date, many significant depositions 

related to questions of liability had not yet been scheduled. In addition, as of the Petition Date, no 

discovery related to damages had been conducted. 

3. I am familiar with the results of investigations carried out by the California Department 

of Forestry and Fire Protection (“Cal Fire”) concerning the impact of the North Bay Fires. Based on 

the figures reported by CAL FIRE in the incident descriptions for the (1) Adobe; (2) Atlas; (3) Blue; 

(4) Cascade; (5) Cherokee; (6) Highway 37; (7) Honey; (8) La Porte; (9) Lobo; (10) Maacama; (11) 

McCourtney; (12) Norrbom; (13) Nuns; (14) Oakmont/Pythian; (15) Partrick; (16) Pocket; (17) Point; 

(18) Potter/Redwood; (19) Pressley; (20) Sullivan; and (21) Sulphur Fires, the aggregate number of 

structures damaged in those fires was approximately 1,026, the aggregate number of structures 

destroyed was approximately 2,597, and the aggregate number of fatalities was 22. 

4. Attached hereto as Exhibit A is a true and correct copy of the October 22, 2018, Joint 

Case Management Conference Statement in the California North Bay Fire Cases, JCCP 4995 (Cal. 

Super. Ct.). 

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5. Attached hereto as Exhibit B is a true and correct copy of the November 2, 2018, Case 

Management Order No. 4 in the California North Bay Fire Cases, JCCP 4995 (Cal. Super. Ct.). 

6. Attached hereto as Exhibit C is a true and correct copy of the December 24, 2018, Joint 

Submission re: Proposed Case Management Orders 5 and 6 re: Individual Cases Including: CMO 

Compliance, Case Specific Discovery, Production of Claim Files, and Trial Selection and Preference 

Motions in the California North Bay Fire Cases, JCCP 4995 (Cal. Super. Ct.). 

7. Attached hereto as Exhibit D is a true and correct copy of the Certified Transcript of 

the December 28, 2018 Coordination Proceedings in the California North Bay Fire Cases, JCCP 4995 

(Cal. Super. Ct.). 

8. Attached hereto as Exhibit E is a true and correct copy of the December 28, 2018, 

General Order re: Case Reassignment of the California North Bay Fire Cases, JCCP 4995 (Cal. 

Super. Ct.) to Judge A.C. Massullo (effective January 22, 2019). 

9. Attached hereto as Exhibit F is a true and correct copy of the December 31, 2018 Order 

Denying Without Prejudice Pamela Fowler’s Motion for Trial Preference in the California North Bay 

Fire Cases, JCCP 4995 (Cal. Super. Ct.). 

10. Attached hereto as Exhibit G is a true and correct copy of the December 31, 2018, Case 

Management Order 6 re: Preference Case Protocol in the California North Bay Fire Cases, JCCP 

4995 (Cal. Super. Ct.). 

I declare under penalty of perjury that, to the best of my knowledge and after reasonable 

inquiry, the foregoing is true and correct. 

Dated: July 19, 2019 

/s/ Kevin J. Orsini

Kevin J. Orsini 

Cravath, Swaine & Moore LLP

Case: 19-30088 Doc# 3105 Filed: 07/19/19 Entered: 07/19/19 15:37:40 Page 3 of

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