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l Robert A. Julian (SBN 88469) 

Cecily A. Dumas (SBN 111449) 

2 BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

3 San Francisco, CA 94111 

Telephone: 628.208.6434 

4 Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

5 Email: cdumas@bakerlaw.com 

6 Eric E. Sagerman (SBN 15549 

Lauren T. Attard (SBN 320898) 

7 BAKER & HOSTETLER LLP 

11601 Wilshire Boulevard, Suite 1400 

8 Los Angeles, CA 90025-0509 

Telephone: 310.820.8800 

9 Facsimile: 310.820.8859 

Email: esagerman(a),bakerla w .com 

10 Email: lattard@balcerlaw.com 

11 Counsel to the Official Committee ofTort Claimants 

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UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

o Affects PG&E Corporation 

o Affects Pacific Gas and Electric 

Company 

• Affects both Debtors 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

DECLARATION OF ROGER K. 

PITMANi M.D. IN SUPPORT OF 

OBJECT ON OF THE OFFICIAL 

COMMITTEE OF TORT 

CLAIMANTS TO THE DEBTORS' 

MOTION PURSUANT TO 11 U.S.C. 

§§ l0S(a) AND 502(c) FOR THE 

ESTABLISHMENT OF WILDFIRE 

CLAIMS ESTIMATION 

PROCEDURES (Dkt. No. 3091) 

* All papers shall be filed in the Lead 

25 Case, No. 19-30088 (DM) 

Date: August 14, 2019 

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

Place: United States Bankruptcy 26 

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Court 

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Courtroom 17, 16 Floor 

San Francisco, CA 94102 

Case: 19-30088 Doc# 3440 Filed: 08/07/19 Entered: 08/07/19 16:22:07 Page 1 of

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I, Roger K. Pitman, M.D., declare and state as follows: 

Qualifications 

1. I am a psychiatrist with over 50 years of experience practicing 

medicine. I have spent my career diagnosing, treating, and researching PostTraumatic Stress Disorder (PTSD) and other stress- and trauma-related mental 

disorders. I am the Director of the Post-Traumatic Stress Disorder Research 

Laboratory at the Massachusetts General Hospital, which performs 

psychobiological research into the assessment, pathophysiology, prevention and 

treatment of PTSD. I am a Professor of Psychiatry at the Harvard Medical School, 

where I supervise medical students, psychiatric residents, psychology trainees, and 

junior faculty. I am certified by the American Board of Psychiatry and Neurology 

in the Specialty of Psychiatry and the Subspecialty of Forensic Psychiatry. I am a 

Distinguished Life Fellow of the American Psychiatric Association. In 2004, I was 

awarded the International Society for Traumatic Stress Studies (ISTSS) Award for 

Outstanding Scientific Achievement in the Field of PTSD. In 2009, I was awarded 

the ISTSS Lifetime Achievement A ward. I have been listed in the Castle Connolly 

Top Doctors in America. 

2. In my role as Director of the PTSD Research Laboratory at 

Massachusetts General, my main duty is to conduct research into PTSD. I also treat 

patients. From 1973 to the present, I have practiced psychiatry at various 

institutions in the United States, including the Naval Regional Medical Center in 

Newport, Rhode Island ( 1973-1975), the VA Medical Center in Bedford, 

Massachusetts (1975-1978), the VA Medical Center in Memphis, Tennessee (1978-

1980), the VA Medical Center in Manchester, New Hampshire (1980-2000), the 

Clinical Research Center at the Massachusetts Institute of Technology (2000-2005), 

and the Massachusetts General Hospital in Boston, Massachusetts ( 1997 to the 

present). I have also maintained a part-time private practice in forensic psychiatry 

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since 1986. 

3. I have taught psychiatry since 1976, at Boston University School of 

Medicine (1976-1978), University of Tennessee Center for the Health Sciences 

( 1978-1980), Dartmouth Medical School ( 1981-1987), and Harvard Medical School 

( 1986-present ). I have served on a number of editorial boards and committees in 

the field. I collaborated with a group of advisors to author the chapter on PTSD in 

the Fourth Edition of the Diagnostic and Statistical Manual of Mental Disorders 

(DSM-4 ), which at the time was the authoritative diagnostic guide used by mental 

health professionals. I have published more than 150 peer-reviewed, research and 

academic articles and book chapters on PTSD and other trauma- and stress-related 

disorders. I am last (senior) author of the chapter on Trauma- and Stressor-Related 

Disorders in the current American Psychiatric Association Publishing Textbook of 

Psychiatry. 1 

4. I have been qualified by state and federal courts and courts-martial as 

an expert in the field of forensic psychiatry, and I have testified as an expert in 

psychiatry in depositions and trials in many litigations. If called upon, I could and 

would competently testify to the following. 

Background 

5. I have reviewed accounts of the fires and wildfires that destroyed areas 

of Northern California between 2016-2018 that are at issue in this matter, 

specifically, the fire referred to as the "Camp Fire" in 2018, the fires referred to as 

the "North Bay Fires" in 2017, and the fire referred to as the "Ghostship fire" in 

2016, which was a fire in a warehouse that killed 36 people ( collectively referred to 

as the "Fires"). I have reviewed coverage of the Fires from major newspapers and 

media outlets, such as the New York Times, the San Francisco Chronicle, the Los 

Angeles Times, Time Magazine, CNN, and ABC. I have reviewed narratives 

1 F.J. STODDARD, N.M. SIMON, R.K. PITMAN, Trauma- and Stressor-Related Disorders in 

TEXTBOOK OF PSYCHIATRY 393-436 (Am. Psychiatric Association Publishing 7th ed. 2019). 

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describing events that occurred during the Fires. I have also watched videos of 

Claimants escaping. Many of these Claimants appear to have physically 

encountered the Fires and even to have been surrounded by them, appear to have 

had seconds to flee the impending flames, appear to have been stuck in traffic with 

family members (some of whom were children or elderly), while they attempted to 

flee, and appear to have watched loved ones and others suffer or die from the Fires. 

6. Through these accounts and others, I understand that many Claimants 

experienced and/or witnessed a significant level of traumatic exposure, in which 

they either suffered or feared suffering burns on their body and/or believed they or 

family members would die or suffer serious physical injury as a result of the Fires. 

7. For example, I have read or viewed stories of: a woman who was 

overtaken with smoke and survived only by finding help from firefighters who were 

themselves stuck in traffic with flames blocking their escape (see 

https://www.cnn.com/2018/11/13/us/california-wildfires-woolsey-camp-hilltestimonies/index.html); a woman who fled on foot, abandoning her car in an 

intersection where cars were burning only to learn later that people were found 

burned to death in the same intersection (see 

https://www.cnn.com/2018/ I I /13/us/california-wildfires-woolsey-camp-hilltestimonies/index.html); a hospital worker who drove ICU and hospice patients 

through flames to safety (see https://time.com/5459508/paradise-survival-chaplaincamp-fire/); a police officer who rescued a woman from a wheelchair from the side 

of the road (see https://abc7news.com/video-first-responders-rescue-woman-tryingto-escape-camp-fire-in-a-wheelchair/4692057/); a married couple who tried to 

escape the flames that had overtaken their home by sheltering in their swimming 

pool ( only the husband survived) (see 

https://www.sfgate.com/bayarea/article/Forced-by-Wine-Country-fire-into-aswimming-pool-12274789.php); another married couple who attempted to shelter 

in their pool, submersing themselves and coming up for air repeatedly for many 

-4-

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hours while their home burned nearby, suffering from smoke inhalation (see 

https://abc7news.com/lawsuit-filed-against-pg-e-for-practices-causing-north-bayfires/2647696/; https://www.pressdemocrat.com/news/8772382-l81/im-not-surehow-you ); a family that was separated in the flames, the son died and the daughter 

and mother were stranded with the son's body while the father left for help (the 

daughter died weeks later as a result of her injuries) (see 

https://projects.sfchronicle.com/2019/redwood-fire-victims/); a father and young 

child who fled the Fires in their car, fighting traffic, all while the father attempts to 

calm his daughter by singing despite the extremely traumatic events unfolding 

outside their window (see https://www.youtube.com/watch?v=BYikUpSxORo); a 

bus driver who transported elderly people from a senior living center, driving 

through flames and smoke (see https://www.pressdemocrat.com/news/8397327-

18l/santa-rosa-bus-video-shows?artslide=2; see also https://abc?news.com/videoshows-santa-rosa-bus-rescuing-residents-from-north-bay-fires/356995 3/); a man 

who fled down a makeshift stairway while others were trapped inside a burning 

warehouse, who spent months in severe pain getting treatment for the bums on his 

body and smoke inhalation, some of the time in an induced coma (see 

https://www.mercurynews.com/2017/12/02/the-night-everything-changed-sammaxwell-rises-from-the-ashes-of-ghost-ship-a-new-man/); a man who lowered 

himself out of a burning warehouse with an electrical cord (see 

https://www.courthousenews.com/witnesses-recount-escapes-from-ghost-shipfire/); and a man who was on vacation and received a frantic phone call from his 

daughter who believed she was going to die (see 

https://time.com/5464667/paradise-wildfire-lawsuit-pge/). I understand these are 

only some of the events that occurred. 

Conclusions 

8. Several mental disorders may occur following a psychologically 

traumatic event such as the Claimants were exposed to when they escaped the Fires. 

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1 The most important of these is PTSD. PTSD represents a constellation of 

2 symptoms and signs including intrusive memories associated with the event, 

3 avoidance of such memories, negative alterations in cognition and mood, and 

4 hyperarousal, which confer clinically significant distress or impairment and last at 

5 least a month. Both the distress and impairment can be profound and long-lasting. 

6 9. In short, first, it is my understanding that a substantial portion of the 

7 Claimants in this case were exposed to the risk of death or serious physical injury, 

8 such as suffering burns or asphyxiation. Second, an additional, substantial portion 

9 of the Claimants witnessed exposure to the risk of death or serious physical injury 

1 O occurring to others, sometimes members of their immediate family. Third, an 

11 additional, substantial portion of the Claimants learned about exposure to the risk of 

12 death or serious physical injury having occurred to close relatives or friends. 

13 Fourth, an additional portion of the Claimants were involved in responding to the 

14 gruesome aftermath of the Fires. 

15 I 0. Each of the four categories itemized in 1 9 above meet the American 

16 Psychiatric Association's Diagnostic and Statistical Manual of Mental Disorders, 

17 Fifth Edition (DSM-5) PTSD diagnostic criterion A, which are as follows: 

18 "Exposure to actual or threatened death, serious injury, or section violence in one or 

19 more of the following ways": 

20 A. I: Directly experiencing the traumatic event(s). 

21 A.2: Witnessing, in person, the event(s) as it occurred to others. 

22 A.3: Learning that the traumatic event(s) occurred to a close family 

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member or close friend. In cases of actual or threatened death of a 

family member or friend, the event(s) must have been violent or 

accidental. 

A.4: Experiencing repeated or extreme exposure to aversive details of 

the traumatic event(s) (e.g., first responders collecting human 

remains ... ). 

-6-

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See Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition (DSM-5), 

atA.1-A.4. 

11. In order to be a candidate for the PTSD diagnosis, it is only necessary 

to satisfy one of the above-I isted criteria, A.1-A.4. In other words, a Claimant that 

fits into any of the above-listed four categories would be a candidate for the PTSD 

diagnosis. Claimants who were trapped by, encountered, or were forced to flee the 

Fires through flames and embers, who witnessed others being trapped by, 

encountering or fleeing the Fires through flames or embers, or who learned that a 

close friend or loved one was trapped by, encountered or was forced to flee the 

Fires through flames or embers would be candidates for PTSD. If a Claimant 

repeatedly witnessed the traumatic events, as would be the case with a first 

responder, he or she would also be a candidate for PTSD. 

13 

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12. It is well-established in the literature that a substantial portion of 

persons satisfying one of the four prongs of the requisite traumatic event above 

supra ,r 11, will go on to develop the necessary symptoms to meet the diagnostic 

16 criteria for PTSD and be so diagnosable. 

17 13. A substantial portion of persons who develop PTSD will, according to 

18 DSM-5, manifest physical symptoms, such as: (a) "marked physiological reactions 

19 to internal or external cues that symbolize or resemble an aspect of the traumatic 

20 events (i.e., traumatic reminders) (PTSD criterion B.5); (b) "exaggerated startle 

21 response" (PTSD criterion E.4); and/or (c) "sleep disturbance" (PTSD criterion 

22 E.6), which can include nightmares about the event, and insomnia or hypersomnia. 

23 14. In addition to these physical manifestations of PTSD documented in 

24 DSM-5, the vast PTSD research literature documents the presence of additional, 

25 acquired physiological, and hormonal abnormalities in this condition. Persons with 

26 PTSD and other trauma- and stress-related mental disorders may suffer from other 

27 physical symptoms, including but not limited to hypervigilance, irritable or 

28 aggressive behavior, rapid heart rate, loss of appetite and weight loss, physical 

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sensations of the trauma, and panic attacks of various degrees of severity. Some of 

these findings has emanated from work conducted by my team in the PTSD 

Research Laboratory at the Massachusetts General Hospital. 

15. It is now well established in the medical literature, based in part upon 

research from our laboratory, that PTSD is a brain disorder. Although some of the 

brain abnormalities found in PTSD likely existed prior to the traumatic event, some 

are acquired as the result of it. The latter include amygdala and anterior paralimbic 

hyperresponsivity, and medial prefrontal cortical hyporesponsivity, during mental 

imagery of the event, and diminished anterior cingulate cortex (and possibly 

hippocampal) volume and function. I have reviewed this literature.2 

16. Based on my understanding of the extreme conditions many of the 

Claimants were exposed to, it is my professional opinion that a substantial portion 

will have developed PTSD or another trauma- and stress-related mental disorder. 

Claimants who do not meet the full diagnostic criteria for PTSD, may still develop 

(a) "partial PTSD," "subsyndromal PTSD," or "subthreshold PTSD"; and/or (b) a 

DSM-5 Adjustment Disorder or other mental disorder, such as Major Depressive 

Disorder (MOD), or Anxiety Disorder. Persons in any of these groups often suffer 

from clinically significant distress and/or functional impairment and may also show 

some o the same physical manifestations as PTSD, which are described above, 

20 supra 1112-14. 

21 

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2 See, e.g., R.K. PITMAN, A.M. RASMUSSON, K.C. KOENEN, L.M. SHIN, S.P. ORR, M. W. 

28 GILBERTSON, M.R. MILAD & I. LIBERZON, Biological Sludies of Posl/raumalic Slress Disorder, in 

NATURE REVIEWS NEUROSCIENCE 13:769-787 (2012 ed.). 

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

the foregoing is true and correct and that this declaration was executed on the 1st 

day of August in Charlestown Massachusetts. 

Roger K. Pitman, M.D. 

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