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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 

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 JOE ECHOLS IN 

SUPPORT OF CPSI REDACTION MOTION 

[No Hearing Requested] 

 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# 3180 Filed: 07/24/19 Entered: 07/24/19 17:00:35 Page 1 of

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

I, Joe Echols, pursuant to section 1746 of title 28 of the United States Code, hereby declare under 

penalty of perjury that the following is true and correct to the best of my knowledge, information, and 

belief: 

1. I am a Manager, Encroachment Management, in the Land Department at Pacific 

Gas and Electric Company (the “Utility” and, together with PG&E Corporation, the “Debtors”). I joined 

the Utility in 2010 and held a number of positions in the Utility, including Manager, Land Department 

& Community Pipeline Safety Initiative, and Supervisor, Land Department. I am a certified Senior Right 

of Way professional. 

2. I am knowledgeable and familiar with the Utility’s day-to-day operations and, 

specifically, the Utility’s Community Pipeline Safety Initiative (the “CPSI”) program. I am authorized 

to submit this Declaration (the “Declaration”) on behalf of the Debtors in support of the Motion to 

Redact Documents Filed in Support of CPSI Agreement Assumption Motion (the “Redaction Motion”). 

The facts set forth in this Declaration are based upon my personal knowledge, my review of relevant 

documents, and information provided to me by the Debtors’ other employees or the Debtors’ legal, 

restructuring, and financial advisors. If called upon to testify, I would testify to the facts set forth in this 

Declaration. 

3. The background to the CPSI Program is set out in my declaration submitted in 

support of the Second Omnibus Motion of the Debtors Pursuant to 11 U.S.C § 365(a), Fed. R. Bankr. P. 

6006, and B.L.R. 6006-1 (i) Approving the Utility’s Assumption of Contracts in Connection with the 

Community Pipeline Safety Initiative and (ii) Granting Related Relief (the “Motion”).1

4. As set forth in the Motion, the Debtors are seeking authority to assume certain 

agreements entered into with landowners in connection with the CPSI program, which agreements 

provide the Utility necessary access to land on which the Utility’s gas transmission pipelines are located 

to carry out critical vegetation removal and other clearing projects. The projects carried out as part of 

the CPSI program occasionally require that trees and other vegetation be cleared or otherwise removed 

to ensure the Utility and emergency services providers can access the Utility’s gas transmission 

 

1

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

in the Motion. 

Case: 19-30088 Doc# 3180 Filed: 07/24/19 Entered: 07/24/19 17:00:35 Page 2 of

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

pipelines, making the program a potential target of activists in the communities in which the projects 

are carried out. On several occasions in the past, the publicly disclosed information of participants in 

the CPSI program has been used by activists to make unsolicited contact with those property owners in 

an effort to discourage them from participating in the CPSI program. 

5. I believe that if the Personal Information (as defined in the Redaction Motion) is 

not redacted from documents relating to the CPSI Program filed publicly with the Bankruptcy Court, 

activists could use the information to contact the counterparties and attempt to undermine the CPSI 

program. Accordingly, the limited redactions sought in the Redaction Motion are reasonable, 

appropriate, and in the best interests of the public. 

[Remainder of this page is intentionally left blank] 

 

Case: 19-30088 Doc# 3180 Filed: 07/24/19 Entered: 07/24/19 17:00:35 Page 3 of

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

Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury, that the foregoing is 

true and correct to the best of my knowledge, information, and belief, and that this declaration was 

executed at San Ramon, California on July 24, 2019. 

/s/ Joe Echols

Joe Echols

Case: 19-30088 Doc# 3180 Filed: 07/24/19 Entered: 07/24/19 17:00:35 Page 4 of

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