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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)

David J. Richardson (SBN 168592)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Blvd., Suite 1400

Los Angeles, CA 90025-0509

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: drichardson@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 DAVID J. 

RICHARDSON IN SUPPORT OF 

MOTION TO FILE REDACTED 

DECLARATION OF JAMES 

DRINKHALL IN SUPPORT OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS’ MOTION PURSUANT TO 

11 U.S.C. §§ 105(a) AND 501 AND FED. 

R. BANKR. P. 3003(c) FOR ENTRY OF 

AN ORDER EXTENDING THE BAR 

DATE

Case: 19-30088 Doc# 4317 Filed: 10/18/19 Entered: 10/18/19 16:33:22 Page 1 of

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

- 2 -

DAVID J. RICHARDSON, under penalty of perjury, declares:

1. I am Counsel 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 TCC’s motion (“Redaction Motion”) for 

entry of an order authorizing the filing of the redacted declaration of James Drinkhall (“Drinkhall 

Declaration”) in support of the TCC’s Motion Pursuant to 11 U.S.C. §§ 105(A) and 501 and Fed. 

R. Bankr. P. 3003(C) for Entry of an Order Extending the Bar Date (“Bar Date Motion”).

3. After individuals’ attorneys brought facts and declarations to the TCC this month 

concerning various impairments and circumstances that have prevented individual claimants from 

filing claims prior to the claims bar date, lead trial counsel for the TCC conducted his own 

investigation by traveling this past weekend to the FEMA emergency housing site for Camp Fire 

survivors, together with investigator James Drinkhall (“Drinkhall”), where they interviewed 

survivors and corroborated the facts described in the victims’ Declarations. 

4. The Drinkhall Declaration contains the names and stories of these individual fire 

victims that Drinkhall interviewed, but also includes certain personal information that is relevant 

to the nature of the impairments discussed in the Bar Date Motion, but should be protected from 

disclosure with connection to their identities. These individuals’ names and identities are 

unnecessary for the general public to understand the scope of the problem identified in the Bar Date 

Motion.

5. Contemporaneously herewith, the TCC is transmitting and unredacted copy of the 

Drinkhall Declaration to the Debtors. 

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. 

Dated: Los Angeles

October 16, 2019 /s/ David J. Richardson

David J. Richardson

Case: 19-30088 Doc# 4317 Filed: 10/18/19 Entered: 10/18/19 16:33:22 Page 2 of

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