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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

Robert A. Julian (SBN 88469)

Cecily A. Dumas (SBN 111449)

BAKER & HOSTETLER LLP

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: 628.208.6434

Facsimile: 310.820.8859

Email: rjulian@bakerlaw.com

Email: cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Boulevard

Suite 1400

Los Angeles, CA 90025

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel for Official Committee of Tort Claimants

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

□ 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)

DECLARATION OF KODY KLEBER IN 

SUPPORT OF MOTION OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS FOR ENTRY OF AN 

ORDER AUTHORIZING THE FILING 

OF A REPLY IN SUPPORT OF 

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

TO COMPEL PRODUCTION OF 

THIRD-PARTY CONTRACTOR 

DOCUMENTS

Case: 19-30088 Doc# 3627 Filed: 08/20/19 Entered: 08/20/19 19:54:55 Page 1 of

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

- 2 -

KODY D. L. KLEBER, under penalty of perjury, declares:

1. I am a partner at Baker & Hostetler LLP, counsel to the Official Committee of Tort 

Claimants (the “TCC”) of PG&E Corporation and Pacific Gas and Electric Company (the 

“Debtors”) in these chapter 11 cases.

2. I submit this Declaration in support of the Motion of the Official Committee of Tort 

Claimants for Entry of an Order Authorizing the Filing Under Seal of a Reply in Support of Motion 

of the Official Committee of Tort Claimants to Compel Production of Third-Party Contractor 

Documents (“Sealing Motion”).

3. The TCC wishes to file a Reply in Support of Motion of the Official Committee of 

Tort Claimants to Compel Production of Third-Party Contractor Documents (the “Reply”). 

Throughout the Reply, the TCC cites and attaches documents designated as “Contractor 

Confidential” under the Confidentiality and Protective Order, entered by this Court on July 1, 2019 

[Docket No. 2807-1]. The confidential documents are necessary in demonstrating to the Court 

specific deficiencies in Debtors’ productions.

4. On Tuesday, August 20, 2019, counsel for the TCC asked counsel for the Debtors 

to remove confidentiality designations for the confidentially-designated documents referenced and 

attached in the Reply. As of the time of the filing of the Reply and the Sealing Motion, the TCC 

has not reached an agreement with the Debtors to waive confidentiality designations. 

Pursuant to 28 U.S.C. §1746, I declare under penalty of perjury under the laws of the United States 

of America that the foregoing is true and correct to the best of my knowledge and belief. 

Executed on August 20, 2019 /s/ Kody D. L. Kleber

By: Kody D. L. Kleber

Admitted Pro Hac Vice

Case: 19-30088 Doc# 3627 Filed: 08/20/19 Entered: 08/20/19 19:54:55 Page 2 of

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