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JENNER & BLOCK LLP 

Randall E. Mehrberg 

353 N. Clark Street 

Chicago, IL 60654 

Tel: 312 840 7505 

rmehrberg@jenner.com 

Special Corporate Defense & Energy Counsel 

for Debtors and Debtors in Possession 

IN THE UNITED STATES BANKRUPTCY COURT 

 FOR THE 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 & Electric Company 

 X Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM).

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

SECOND SUPPLEMENTAL 

DECLARATION OF RANDALL E. 

MEHRBERG IN SUPPORT OF 

APPLICATION PURSUANT TO 11 

U.S.C. § 327(e) AND FED. R. BANKR. P. 

2014(a) AND 2016 FOR ORDER 

AUTHORIZING THE DEBTORS TO 

RETAIN JENNER & BLOCK LLP AS 

SPECIAL CORPORATE DEFENSE 

COUNSEL NUNC PRO TUNC TO THE 

PETITION DATE 

I, Randall E. Mehrberg, hereby declare: 

I am a partner of Jenner & Block LLP (“Jenner & Block” or the “Firm”), a law firm with 

offices in Chicago, Illinois; New York, New York; Washington, D.C.; Los Angeles, California; 

and London, United Kingdom. I am currently resident in Jenner & Block’s Chicago office, located 

at 353 North Clark Street, Chicago, IL 60654. I am a member in good standing of the bar of the 

State of Illinois, and there are no disciplinary proceedings pending against me. 

I submit this second supplemental declaration (the “Second Supplemental Declaration”) 

to supplement my original declaration (the “Original Declaration”) and first supplemental 

Case: 19-30088 Doc# 4803 Filed: 11/18/19 Entered: 11/18/19 17:51:21 Page 1 of

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declaration (the “First Supplemental Declaration”) filed in connection with the Application1 of 

the above-captioned debtors and debtors in possession (collectively, the “Debtors”), for an order, 

pursuant to section 327(e) of title 11 of the United States Code (the “Bankruptcy Code”) and 

Rules 2014(a) and 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), 

approving the retention of Jenner & Block as the Debtors’ special corporate defense and energy 

counsel effective as of January 29, 2019 (the “Petition Date”). Unless otherwise stated in this 

Supplemental Declaration, I have personal knowledge of the facts set forth herein. 

To the extent that any information disclosed herein requires subsequent amendment or 

modification upon Jenner & Block’s completion of further analysis or as additional information 

regarding creditors and other parties in interest becomes available, one or more supplemental 

declarations will be submitted to the Court reflecting the same. 

JENNER & BLOCK’S DISINTERESTEDNESS AND CONNECTIONS 

My Original Declaration set forth information about Jenner & Block’s disinterestedness 

and connections with parties in interest in these Chapter 11 Cases. 

Since the filing of my Original Declaration and First Supplemental Declaration, Jenner & 

Block began representing the following parties in interest or affiliates of parties in interest in 

matters unrelated to the Debtors’ cases: 

Name of Entity Searched Name of Entity and/or Affiliate 

of Entity that is a Jenner & 

Block Client 

Client 

Status 

Relationship to 

Debtors 

Forefront Power LLC Mitsui & Co. Current Contract 

Counterparty

Targray Industries Targray Technology 

International, Inc. Current Otherwise Related Party

Eaton Corporation Eaton Corporation Current Vendor

Mediacom Communications Mediacom Communications Current Utility Provider

1 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to 

such terms in the Application. 

Case: 19-30088 Doc# 4803 Filed: 11/18/19 Entered: 11/18/19 17:51:21 Page 2 of

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I continue to believe that: none of Jenner & Block or any partner in, counsel to, or associate 

of Jenner & Block represents any entity in or in connection with these Chapter 11 Cases other than 

the Debtors; Jenner & Block and I do not hold or represent an interest adverse to the Debtors; and 

neither Jenner & Block nor any of its attorneys, including me, (i) is a creditor, equity security 

holder, or insider of the Debtors, (ii) has been, within two years before the date of the filing of the 

petition, a director, officer, or employee of the Debtors, or (iii) has any interest materially adverse 

to the interests of the estate or any class of creditors by reason of any direct or indirect relationship 

to, connection with, or interest in, the Debtors, or for any other reason. 

Jenner & Block’s practices encompass the representation of many diverse clients, some of 

which may be or may become creditors or parties in interest. To the extent that, during or at the 

conclusion of Jenner & Block’s employment in these Chapter 11 Cases, it discovers any facts 

bearing on matters described in this Second Supplemental Declaration, Jenner & Block will 

supplement the information contained in this Second Supplemental Declaration. 

Based on the foregoing, I believe that Jenner & Block is a “disinterested person,” as defined 

in section 101(14) of the Bankruptcy Code, and does not hold or represent an interest adverse to 

the Debtors, as required by section 327(e) of the Bankruptcy Code, and that Jenner & Block’s 

partners, associates, and special attorneys do not hold or represent any interest adverse to the 

Debtors or their estates. Accordingly, I submit that Jenner & Block is not disqualified for 

employment by the Debtors under section 327(e) of the Bankruptcy Code. 

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, information, and belief. 

Dated: November 18, 2019 

Chicago, Illinois 

 

 Randall E. Mehrberg 

Case: 19-30088 Doc# 4803 Filed: 11/18/19 Entered: 11/18/19 17:51:21 Page 3 of

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