1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Berman and Todderud LLP

701 Fifth Avenue, Suite 4200

Seattle, WA 98104

BERMAN AND TODDERUD LLP

Stan Berman 

(stan@btlawllp.com)

Eric Todderud

(eric@btlawllp.com) 

701 Fifth Avenue, Suite 4200

Seattle, WA 98104

Tel: (206) 262-7682

Special Counsel 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.

 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)

CERTIFICATION OF ERIC TODDERUD IN 

SUPPORT OF FIRST INTERIM FEE 

APPLICATION OF BERMAN AND 

TODDERUD LLP FOR ALLOWANCE AND 

PAYMENT OF COMPENSATION (FEBRUARY 

1, 2019 THROUGH MAY 31, 2019) 

Date: TBD

Time: TBD

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Judge: Hon. Dennis Montali 

Objection Deadline: November 12, 2019 4:00 p.m. (Pacific Time)

I, Eric Todderud, hereby certify as follows: 

1. I am attorney licensed to practice law in the State of Washington. I am a partner in the law 

firm of Berman and Todderud LLP (the “Firm”), special counsel for the Debtors and am authorized 

to make this Declaration in that capacity. Except as otherwise indicated, all statements in this 

Case: 19-30088 Doc# 4384 Filed: 10/22/19 Entered: 10/22/19 13:47:23 Page 1 of

4
2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Declaration are based on my personal knowledge, and, if called upon to do so, I could and would 

testify competently thereto. 

2. I make this Declaration in support of the First Interim Fee Application of Berman and 

Todderud LLP for Allowance and Payment of Compensation and Reimbursement of Expenses 

(February 1, 2019 Through May 31, 2019) (the “Interim Fee Application”).1 I am an attorney 

designated by the Firm to sign the Interim Application on its behalf. 

3. Pursuant to the Northern District Guidelines, I certify that: 

a. I have read the Interim Fee Application. 

b. To the best of my knowledge, information and belief formed after reasonable 

inquiry, the compensation and expense reimbursement sought in the Interim Fee Application 

are in conformity with the Northern District Guidelines except as otherwise indicated in the 

Interim Fee Application. 

c. The compensation requested in the Interim Fee Application has been billed at rates 

and in accordance with practices no less favorable than those currently employed by the Firm 

and generally accepted by the Firm’s clients. 

4. There is no agreement or understanding between Berman and Todderud and any other 

person other than the partners of the Firm for the sharing of compensation to be received for services 

rendered in these cases. 

5. As required by the Northern District Guidelines, the Firm has sent monthly billing 

statements to Pacific Gas and Electric Company for legal work commencing on February 1, 2019. I 

certify that the Debtors, counsel for the Creditors Committee and the TCC, and the U.S. Trustee are 

each being provided with a copy of the Interim Fee Application in accordance with the Interim 

Compensation Order. 

6. Attached hereto as Exhibit A is a true and correct copy of a letter transmitting the Interim 

Fee Application to Debtors and advising them of their rights to review and object to the 

1 To the extent not otherwise defined herein, capitalized terms shall have the meanings set forth in the Interim Fee 

Application. 

Case: 19-30088 Doc# 4384 Filed: 10/22/19 Entered: 10/22/19 13:47:23 Page 2 of

4
3

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

compensation and expense reimbursement sought therein. To the best of my knowledge, 

information, and belief, this letter was transmitted to the Debtors by electronic mail on October 22, 

2019.

7. The Firm responds to the questions identified in the UST Guidelines as follows: 

Question 1: Did Berman and Todderud agree to any variations from, or alternatives 

to, Berman and Todderud’s standard or customary billing rates, fees or terms for services 

pertaining to this engagement that were provided during the Interim Fee Period? If so, please 

explain. 

Answer: Yes. Berman and Todderud have agreed to substantially discount their 

attorney fees to Debtor Pacific Gas and Electric Company as part of their negotiated 

agreement for legal services. 

Question 2: If the fees sought in the Interim Fee Application as compared to the fees 

budgeted for the time period covered by the Interim Fee Application are higher by 10% or 

more, did Berman and Todderud discuss the reasons for the variation with the client? 

Answer: The fees sought in the Interim Fee Application are not higher than those 

budgeted.2 

Question 3: Have any of the professionals included in the Interim Fee Application 

varied their hourly rate based on geographic location of the Chapter 11 Cases? 

Answer: No. 

Question 4: Does the Interim Fee Application include time or fees related to 

reviewing or revising time records or preparing, reviewing or revising invoices? If so, please 

quantify by hours and fees. 

Answer: No. The Interim Fee Application does not include fees for reviewing and 

revising time records and preparing and reviewing invoices in connection with the 

preparation of the Firm’s monthly fee statements. 

2 See Interim Application, Case Background and Status § D.

Case: 19-30088 Doc# 4384 Filed: 10/22/19 Entered: 10/22/19 13:47:23 Page 3 of

4
4

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Question 5: Does the Interim Fee Application include time or fees for reviewing 

time records to redact any privileged or other confidential information? If so, please quantify 

hours and fees. 

Answer: No. 

Question 6: Does the Interim Fee Application include any rate increases since 

Berman and Todderud’s retention in this case? If so, did the client review and approve those 

rate increases in advance? Did the client agree when retaining the law firm to accept all 

future rate increases? 

Answer: No. The Interim Fee Application does not include any rate increases since 

the Firm’s retention. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct. 

Executed this 22nd day of October 2019, in Seattle, Washington.

BERMAN AND TODDERUD LLP

/s/ Eric Todderud_________

Eric Todderud

Case: 19-30088 Doc# 4384 Filed: 10/22/19 Entered: 10/22/19 13:47:23 Page 4 of

4