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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

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

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

MILBANK LLP

Dennis F. Dunne (admitted pro hac vice)

Samuel A. Khalil (admitted pro hac vice)

55 Hudson Yards

New York, New York 10001-2163

Telephone: (212) 530-5000

Facsimile: (212) 530-5219

and 

Gregory A. Bray (SBN 115367)

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor

Los Angeles, CA 90067

Telephone: (424) 386-4000

Facsimile: (213) 629-5063

Attorneys for the Official Committee

of Unsecured Creditors

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION,

 - and -

PACIFIC GAS AND ELECTRIC COMPANY,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered)

DECLARATION OF KEVIN J. ORSINI IN 

SUPPORT OF JOINT BRIEF OF DEBTORS AND

THE OFFICIAL COMMITTEE OF 

UNSECURED CREDITORS AND 

SUPPLEMENTAL STATEMENT OF THE PG&E 

SHAREHOLDERS CONCERNING THE 

APPLICABILITY OF INVERSE 

CONDEMNATION

Date: November 19, 2019 

Time: 10:00 a.m.

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

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). 

Case: 19-30088 Doc# 4486 Filed: 10/25/19 Entered: 10/25/19 20:22:43 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. I submit this Declaration in Support of the Joint Brief of Debtors and

the Official Committee of Unsecured Creditors and Supplemental Statement of the PG&E 

Shareholders Concerning the Applicability of Inverse Condemnation (the “Motion”). I have personal 

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

2. Attached hereto as Exhibit A is a true and correct copy of Governor Newson’s Strike 

Force Report titled “Wildfires And Climate Change: California’s Energy Future”, (the “Strike Force 

Report”), dated April 12, 2019. 

3. Attached hereto as Exhibit B is a true and correct copy of a transcript of the relevant 

portions of the November 30, 2017 hearing of the California Public Utilities Commission (“CPUC”) 

that is posted on the CPUC’s website at http://www.adminmonitor.com 

/ca/cpuc/voting_meeting/20171116/. I confirm that Exhibit B accurately transcribes the CPUC 

Hearing Video beginning at the 12:45 minute mark and ending at the 34:14 minute mark. 

4. Attached hereto as Exhibit C is a true and correct copy of the Concurrence of President 

and Commissioner Michael Picker and Commissioner Martha Guzman Aceves with respect to the 

SDG&E Decision (the “CPUC Concurrence”).

5. Attached hereto as Exhibit D is a true and correct copy of the November 30, 2017, 

CPUC Decision Denying Application of San Diego Gas &Electric Company (“SDG&E”) for 

Authorization to Recover Costs Related to the 2007 Southern California Wildfires (Decision 17-11-

033) (the “SDG&E Decision”).

6. Attached hereto as Exhibit E is a true and correct copy of the July 12, 2018, CPUC 

Order Decision Denying Rehearing of Decision 17-11-033 (Decision 18-07-025).

7. Attached hereto as Exhibit F is a true and correct copy of the Final Report Of The 

Commission On Catastrophic Wildfire Cost And Recovery (the “Wildfire Commission Report”)

submitted by the Governor’s Office of Planning and Research, dated June 17, 2019. 

Case: 19-30088 Doc# 4486 Filed: 10/25/19 Entered: 10/25/19 20:22:43 Page 2 of

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8. Attached hereto as Exhibit G is a true and correct copy of the article Credit FAQ: Will 

California Still Have An Investment-Grade Investor-Owned Electric Utility? published by S&P Global 

Ratings, dated Feb. 19, 2019. 

9. Attached hereto as Exhibit H is a true and correct copy of the article S&P Downgrades 

PG&E Over Calif. Wildfire Risks by Nephele Kirong, published by S&P Global Market Intelligence, 

dated February 26, 2018.

10. Attached hereto as Exhibit I is a true and correct copy of the article S&P, Moody’s 

Downgrades PG&E, Pacific Gas And Electric Ratings On Wildfire Risks by Nephele Kirong, 

published by S&P Global Market Intelligence, dated November 16, 2018. 

11. Attached hereto as Exhibit J is a true and correct copy of the article PG&E Bonds Reach 

New Lows As S&P Cuts Five Notches To Junk by Molly Smith and Natalya Doris, published by 

Bloomberg, dated January 8, 2019. 

12. Attached hereto as Exhibit K is a true and correct copy of Opening Brief of Pacific Gas 

and Electric Company for the Application of Southern California Edison Company (U338E) for 

Authority to Establish Its Authorized Cost of Capital for Utility Operations for 2020 and to Partially 

Reset the Annual Cost of Capital Adjustment Mechanism, filed September 30, 2019 (Application 19-

04-014). 

13. Attached hereto as Exhibit L is a true and correct copy of Opening Brief of Southern 

California Edison Company for the Application of Southern California Edison Company (U338E) for 

Authority to Establish Its Authorized Cost of Capital for Utility Operations for 2020 and to Partially 

Reset the Annual Cost of Capital Adjustment Mechanism, filed September 30, 2019 (Application 19-

04-014). 

14. Attached hereto as Exhibit M is a true and correct copy of Opening Brief of San Diego 

Gas & Electric for the Application of Southern California Edison Company (U338E) for Authority to 

Establish Its Authorized Cost of Capital for Utility Operations for 2020 and to Partially Reset the 

Annual Cost of Capital Adjustment Mechanism, filed September 30, 2019 (Application 19-04-014). 

15. Attached hereto as Exhibit N is a true and correct copy of What is Cost of Capital 

(CoC)? published by the CPUC.

Case: 19-30088 Doc# 4486 Filed: 10/25/19 Entered: 10/25/19 20:22:43 Page 3 of

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16. Attached hereto as Exhibit O is a true and correct copy of the May 30, 2019, CPUC 

Guidance Decision on Wildfire Mitigation Plans Submitted Pursuant to Senate Bill 901 (Decision 19-

05-036).

17. Attached hereto as Exhibit P is a true and correct copy of the San Diego Gas & Electric 

Company Prepared Supplemental Testimony of Concentric Energy Advisors Wildfire Risk Premium 

(AB 1054), dated August 1, 2019 (Application 19-04-017). 

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

inquiry, the foregoing is true and correct.

Dated: October 25, 2019

/s/ Kevin J. Orsini

Kevin J. Orsini

Cravath, Swaine & Moore LLP

Case: 19-30088 Doc# 4486 Filed: 10/25/19 Entered: 10/25/19 20:22:43 Page 4 of

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