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Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice) 

MILBANK LLP 

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 

Counsel for the Official Committee 

of Unsecured Creditors

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) 

SUPPLEMENTAL DECLARATION OF 

SAMUEL E. STAR IN CONNECTION 

WITH THE RETENTION AND 

EMPLOYMENT OF FTI CONSULTING, 

INC. AS FINANCIAL ADVISOR TO THE 

OFFICIAL COMMITTEE OF 

UNSECURED CREDITORS NUNC PRO 

TUNC TO FEBRUARY 12, 2019

Re: Dkt. No. 2252

Case: 19-30088 Doc# 2820 Filed: 07/02/19 Entered: 07/02/19 11:49:13 Page 1 of

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I, Samuel E. Star, pursuant to 28 U.S.C. § 1746, to the best of my knowledge and belief, and 

after reasonable inquiry, declare that the following is true and correct: 

I am a Senior Managing Director of FTI Consulting, Inc. (together with its wholly owned 

subsidiaries, contractors and employees, “FTI”), an independent global business advisory firm and I 

am duly authorized to make this supplemental declaration (the “Supplemental Declaration”) on behalf 

of FTI. 

On April 3, 2019, the Official Committee of Unsecured Creditors (the “Committee”) in these 

chapter 11 cases (the “Chapter 11 Cases”) of the above-captioned debtors and debtors-in-possession 

(collectively, the “Debtors”) submitted the Application of the Official Committee of Unsecured 

Creditors for Entry of an Order Pursuant to 11 U.S.C. §§ 328(a) and 1103 and Fed. R. Bankr. 

P. 2014(a) for Authorization to Retain and Employ FTI Consulting, Inc. as Financial Advisors Nunc 

Pro Tunc to February 12, 2019 [Dkt. No. 1212] (the “Application”).1 Attached to the Application as 

Exhibit B was the Declaration of Samuel E. Star in Support of Application of the Official Committee of 

Unsecured Creditors for Entry of an Order Pursuant to 11 U.S.C. §§ 328(a) and 1103 and Fed. R. 

Bankr. P. 2014(a) for Authorization to Retain and Employ FTI Consulting, Inc. as Financial Advisor 

Nunc Pro Tunc to February 12, 2019 (the “Star Declaration”). The Star Declaration was submitted in 

support of the Application to, among other things, provide disclosures pursuant to title 11 of the United 

States Code §§ 101 et seq. (the “Bankruptcy Code”), the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”) and the Bankruptcy Local Rules for the United States Bankruptcy Court for the 

Northern District of California (the “Local Rules”). 

I am submitting this Supplemental Declaration in connection with FTI’s retention to, among 

other things, provide additional disclosures pursuant to the Bankruptcy Code, the Bankruptcy Rules, and 

the Local Rules. Except as otherwise set forth herein, the Star Declaration is expressly incorporated 

 

1

 Capitalized terms used but not otherwise defined herein shall have the meaning ascribed to them 

in the Application.

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herein. Unless otherwise stated in this Supplemental Declaration, I generally have personal knowledge 

of the matters set forth herein and, if called as a witness, I would competently testify thereto.2 

SUPPLEMENTAL DECLARATION

1. Subsequent to the filing of the Star Declaration, FTI received an expanded list of parties 

in interest from the Debtors. Attached hereto as Schedule A is a list of any relationship between FTI 

and any additional actual or potential parties-in-interest (collectively, the “Potential Parties-inInterest”) that have been subsequently identified by the Debtors in the Chapter 11 Cases. FTI 

compared the names of each of these additional Potential Parties-in-Interest to the names contained in 

a database maintained by FTI of current and former clients and other relationships. 

2. Based on all of the foregoing, to the best of my knowledge and except as otherwise 

noted, FTI does not represent any entity having an adverse interest in connection with these cases, and 

therefore believes it continues to be eligible to represent the Committee. It is FTI’s policy and intent 

to update and expand its ongoing relationship search for additional parties in interest in an expedient 

manner. To the extent FTI discovers any new material relevant facts bearing on the matters described 

herein during the period of FTI’s employment, FTI will amend and supplement the information 

contained in this Supplemental Declaration to disclose any additional facts and will promptly file a 

further supplemental declaration pursuant to Bankruptcy Rule 2014(a). 

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

correct to the best of my knowledge and belief. 

Dated: July 2, 2019 

 New York, NY Respectfully submitted, 

 

 By: /s/ Samuel E. Star 

 Samuel E. Star 

 Senior Managing Director 

 

2

 Certain of the disclosures set forth herein relate to matters within the knowledge of other 

employees at FTI and are based on information provided by them.

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EAST\166951353.2

Schedule A 

(Relationships With Potential Parties in Interest 

Supplemental Declaration) 

 

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EAST\166951353.2

Entity with which FTI has a 

connection Nature of connection 

Accenture 

Accenture is a current client of one or more business units of 

FTI in matters unrelated to the Debtors and these Chapter 11 

Cases. 

Akin, Gump, Strauss Hauer 

& Feld 

Akin, Gump, Strauss Hauer & Feld is a current client of one or 

more business units of FTI in matters unrelated to the Debtors 

and these Chapter 11 Cases. 

Akin, Gump, Strauss Hauer 

& Feld 

Akin, Gump, Strauss Hauer & Feld is a current client of one or 

more business units of FTI in matters unrelated to the Debtors 

and these Chapter 11 Cases. 

ARB ARB is a former client of one or more business units of FTI in 

matters unrelated to the Debtors and these Chapter 11 Cases. 

Baker & Hostetler 

Baker & Hostetler is a current client of one or more business 

units of FTI in matters unrelated to the Debtors and these 

Chapter 11 Cases. 

Deutsche Bank National 

Trust Company and Deutsche 

Bank Trust Company 

Americas 

Deutsche Bank National Trust Company and Deutsche Bank 

Trust Company Americas is a current client of one or more 

business units of FTI in matters unrelated to the Debtors and 

these Chapter 11 Cases. 

Granite Construction 

Incorporated 

Granite Construction Incorporated is a current client of one or

more business units of FTI in matters unrelated to the Debtors 

and these Chapter 11 Cases. 

Itron Itron is a former client of one or more business units of FTI in 

matters unrelated to the Debtors and these Chapter 11 Cases. 

KPMG KPMG is a current client of one or more business units of FTI 

in matters unrelated to the Debtors and these Chapter 11 Cases.

McKinsey 

McKinsey is a current client of one or more business units of 

FTI in matters unrelated to the Debtors and these Chapter 11 

Cases. 

Milbank, Tweed, Hadley & 

McCloy 

Milbank, Tweed, Hadley & McCloy is a current client of one 

or more business units of FTI in matters unrelated to the 

Debtors and these Chapter 11 Cases. 

NextEra Energy 

NextEra Energy is a former client of one or more business 

units of FTI in matters unrelated to the Debtors and these 

Chapter 11 Cases. 

Sodexo Sodexo is a current client of one or more business units of FTI

in matters unrelated to the Debtors and these Chapter 11 Cases.

State Farm Mutual 

Automobile Insurance 

Company 

State Farm Mutual Automobile Insurance Company is a 

current client of one or more business units of FTI in matters 

unrelated to the Debtors and these Chapter 11 Cases. 

TALX TALX is a former client of one or more business units of FTI 

in matters unrelated to the Debtors and these Chapter 11 Cases.

Travelers Insurance 

Travelers Insurance is a current client of one or more business

units of FTI in matters unrelated to the Debtors and these 

Chapter 11 Cases. 

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EAST\166951353.2

Entity with which FTI has a 

connection Nature of connection 

Willis Towers Watson US 

Willis Towers Watson US is a current client of one or more 

business units of FTI in matters unrelated to the Debtors and 

these Chapter 11 Cases. 

Willkie Farr & Gallagher 

Willkie Farr & Gallagher is a current client of one or more 

business units of FTI in matters unrelated to the Debtors and 

these Chapter 11 Cases. 

Wilson Sonsini 

Wilson Sonsini is a current client of one or more business units 

of FTI in matters unrelated to the Debtors and these Chapter 11

Cases. 

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