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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 to the 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.

□ 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)

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

DECLARATION OF NATHANIEL 

BROWN IN SUPPORT OF MOTION OF 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS 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

Date: November 13, 2019

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Objection Deadline: November 6, 2019

Case: 19-30088 Doc# 4303 Filed: 10/18/19 Entered: 10/18/19 15:47:40 Page 1 of

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Steven J. Skikos (SBN 148110) 

Gregory T. Skikos (SBN 176531) 

Matthew J. Skikos (SBN 269765) 

SKIKOS, CRAWFORD, SKIKOS & JOSEPH

One Sansome Street, Suite 2830 

San Francisco, CA 94104 

Telephone: 415-546-7300 

Facsimile: 415-546-7301 

sskikos@skikos.com 

gskikos@skikos.com 

mskikos@skikos.com 

Attorneys for Declarant

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

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Bankr. Case No. 19-30088-DM

DECLARATION OF NATHANIEL 

BROWN IN SUPPORT OF MOTION TO

EXTEND CLAIMS BAR DATE 

Date: TBD

Time: TBD

Place: United States Bankruptcy Court

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

I, Nathaniel Brown, declare as follows: 

1. I am over 18 years of age. I have personal knowledge of the facts contained in this

declaration, and if called as a witness, I could and would testify competently thereto.

2. My family and I rented a home on Dana Circle in Magalia, California, north of

Paradise. I am a volunteer fire fighter and sheriff’s deputy. I have been working with

Case: 19-30088 Doc# 4303 Filed: 10/18/19 Entered: 10/18/19 15:47:40 Page 2 of

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the developmentally handicapped since August of 2017. 

3. On the morning of the fire, my wife Sara was at work. I waited for her at home with

our two boys, ages 6 and 9, so we could evacuate together as a family. Once she got

home, she and I took our younger son in one car, and Sara’s mother took our older

son in another car.

4. Before long we got separated. Our car was about eight cars back from my mother-inlaw’s and they got through before the fire closed around us.

5. My wife and I got trapped in the parking lot of Optimo restaurant. One of the

deputies recognized me and asked me to help. He had me put on my sheriff’s

uniform. I helped with emergency response and crowd control during the fire. There

were flames all around us. We saw dead bodies when we left the parking lot. We

thought we were going to die. My wife has also been a firefighter for 15 years. She

tried to keep people calm in the parking lot while the fire was burning around us.

6. But worse than anything, I was separated from my younger son and mother-in-law

for 10 hours. I thought the fire got my son. Even though I am a volunteer firefighter

and tried to keep calm, it is difficult to put into words the experience of believing that

my child could be dead somewhere out there in the fire.

7. Our home was partially damaged in the Camp Fire that occurred on November 8,

2018. Our home was not burned, but the fire burned close to our house. After the

fire, our family was displaced for several months before being able to our home in

Magalia.

8. A lot of people have left. Most people who had lived below us on the hill have left

the area. My wife kept contact with people who were in the parking lot. Some

people moved away because they couldn’t afford to stay. Many people didn’t know if

their properties were salvageable.

9. Up until the fire, my wife and I were both employed at California Vocations in

Paradise, a facility for adults with developmental disabilities. The facility was

Case: 19-30088 Doc# 4303 Filed: 10/18/19 Entered: 10/18/19 15:47:40 Page 3 of

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destroyed in the fire. We were offered replacement positions, but the commute would 

be several hours each day, and the pay would not make up for the cost in gas. It 

would have also been impossible for us to care for our children at the same time.

10. Today, my wife and I are both still out of full-time work. We did not have insurance.

Our car has been repossessed. Our family is suffering from the emotional effects of

the fire and struggling to stay on our feet. We are struggling to keep up and our

commute is long.

11. I heard something about PG&E; that they might be filing for bankruptcy or that they

were talking about it. Later, someone told me that PG&E is trying to get out of this

and not pay anyone by filing for bankruptcy. I do not recall receiving a notice from

PG&E that we could file a claim in the bankruptcy court and recover money for our

losses. I don’t know many people who know about the bankruptcy or the claims date.

12. You would think that after what we went through, PG&E would have a team calling

the fire victims to assist them get their claims on file. Instead, PG&E filed for

bankruptcy and we thought that was the end for all of us. No one ever told us

differently. I didn’t know about my ability to file a claim or the deadline until the

last week of August. I found out that I needed to file a claim from my brother in law,

not from PG&E.

13. PG&E should be doing more to tell people the truth that there is actually money to

pay claims. I don’t think my wife and I are alone. I think about all the people who

left Magalia and what they don’t know. Instead, PG&E is standing by waiting for

the clock to run out on us survivors.

I declare under penalty of perjury that the foregoing is true and correct. Executed this

6th day of October, 2019 in Magalia, California.

 ____________________________ 

Nathaniel Brown

Case: 19-30088 Doc# 4303 Filed: 10/18/19 Entered: 10/18/19 15:47:40 Page 4 of

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