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BAKER

& HOSTETLER LLP

ATTORNEYS AT LAW

SAB FRANCISCO, CA

Robert A. Julian (SBN 88469)

Cecily A. Dumas (SBN 111449)

BAKER & HOSTETLER LLP

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: 628.208.6434

Facsimile: 310.820.8859

Email: rjulian@bakerlaw.com

Email: cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Blvd., Suite 1400

Los Angeles, CA 90025-0509

Telephone: 310.442.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel for Official 

Committee of Tort Claimants

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)

VERIFIED STATEMENT OF CECILY 

A. DUMAS IN SUPPORT OF 

APPLICATION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ENTRY OF AN ORDER (I) 

CONFIRMING THE SCOPE OF 

EMPLOYMENT OF BAKER & 

HOSTETLER LLP, OR 

ALTERNATIVELY (II) AMENDING 

THE ORDER APPROVING 

APPLICATION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO 11 U.S.C. § 1103 AND 

FED. R. BANKR. P. 2014 AND 5002, 

FOR AN ORDER AUTHORIZING 

RETENTION AND EMPLOYMENT OF 

BAKER & HOSTETLER LLP, 

EFFECTIVE AS OF FEBRUARY 15, 

Case: 19-30088 Doc# 4019 Filed: 09/26/19 Entered: 09/26/19 16:14:15 Page 1 of

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA

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2019 (DOC. NO. 1331) (THE 

“RETENTION ORDER”) 

Date: October 22, 2019 

Time: 10:00 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Objections Due: October 15, 2019

 4:00 p.m. (Pacific Time)

CECILY A. DUMAS, under penalty of perjury, declares:

1. I am a Partner in the Financial Restructuring Group of Baker & Hostetler LLP 

(“Baker” or the “Firm”), counsel to the Official Committee of Tort Claimants (the “TCC”) of 

PG&E Corporation and Pacific Gas and Electric Company (the “Debtors”) in these chapter 11 

cases (the “Cases”).

2. I submit this verified statement (“Verified Statement”) pursuant to section 1103(b) 

of title 11 of the United States Code, 11 U.S.C. §§ 101-1532 (as amended, the “Bankruptcy 

Code”), and Rules 2014 and 5002 of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”) in support of the contemporaneously-filed Application (the “Application”) 

of the Official Committee of Tort Claimants for Entry of an Order (i) Confirming the Scope of 

Employment of Baker & Hostetler LLP, or Alternatively (ii) Amending the Order Approving 

Application of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. § 1103 and Fed. 

R. Bankr. P. 2014 and 5002, For an Order Authorizing Retention and Employment of Baker & 

Hostetler LLP, Effective as of February 15, 2019 (the “Retention Order”). This Verified 

Statement also serves as my second supplement to my initial and first verified statements, filed on 

March 18, 2019 [Dkt. No. 935] and May 14, 2019 [Dkt. No. 1998] in support of the Application 

of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. § 1103 and Fed. R. Bankr. P. 

2014 and 5002, For an Order Authorizing Retention and Employment of Baker & Hostetler LLP, 

Effective as of February 15, 2019 [Dkt. No. 934] (the “Original Application”).

3. Unless otherwise stated in this Verified Statement, I have knowledge of the facts 

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

Case: 19-30088 Doc# 4019 Filed: 09/26/19 Entered: 09/26/19 16:14:15 Page 2 of

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA

- 3 -

disclosures set forth herein relate to matters not within my personal knowledge, but rather within 

the personal knowledge of other attorneys and employees at Baker and are based on information 

provided by them to me.

The Need for the Relief Requested in the Application

4. The Application seeks either (i) confirmation that the scope of the Retention Order 

includes Baker’s representation of the TCC in connection with the California North Bay Fire 

Cases, JCCP 4955 (the “State Court Litigation”), or alternatively (ii) an amendment of the 

Retention Order to expressly provide that Baker is authorized to represent the TCC in the State 

Court Litigation, effective as of August 21, 2019.

5. The TCC has requested that Baker draft pleadings and memoranda in connection 

with the State Court Litigation, assist in discovery and participate in the litigation to the extent 

necessary to protect the TCC and all Tubbs fire victims’ interests. Baker anticipates that some of 

the pleadings and memoranda may be filed by the plaintiffs in the State Court Litigation. The 

TCC believes that under the terms of the Retention Order Baker may represent the TCC in 

connection with the State Court Litigation in order to protect the interests of the TCC. The State 

Court Litigation involves claims estimation, confirmation issues, and potential compromise of 

controversies, all of which come within the scope of the Retention Order. Moreover, Baker is 

authorized to represent the TCC at hearings and other proceedings before tribunals other than this 

Court. Baker is also authorized to bring, or participate-in, objections or estimation proceedings 

with respect to claims and interests.

6. At the time the Original Application was filed, Baker anticipated that all estimation 

proceedings would take place between the Debtors and the TCC in this Court. Due to the entry of 

the Order Granting the Motion of the Official Committee of Tort Claimants for Relief from 

Automatic Stay [Dkt. No. 3644] (the “Stay Relief Order”), some of the estimation will essentially 

take place in the State Court Litigation, in which the TCC is not a party but has significant interests. 

7. Out of an abundance of caution, the TCC seeks entry of an order confirming that 

Baker may represent the TCC and its interests in the State Court Litigation. Alternatively, if the 

Court determines that the present scope of the Retention Order does not include Baker’s and the 

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA

- 4 -

TCC’s participation in the State Court Litigation, the TCC requests that the Court enter an order 

amending the Retention Order to authorize Baker to represent the TCC and its interests in 

connection with the State Court Litigation, nunc pro tunc to August 21, 2019.

8. In addition, there will be a number of expert witnesses that will be employed in 

connection with the State Court Litigation, as well as in connection with any proceedings in this 

Court or the District Court. Baker intends to employ the experts required for the State Court 

Litigation in accordance with the procedures established with the U.S. Trustee, the Debtors and 

the Official Committee of Unsecured Creditors and memorialized by letter dated July 3, 2019. 

Pursuant to the procedures, expert costs will be reflected on Baker’s invoices, fee statements and 

fee applications as a cost and paid as a pass through cost by Baker. Some of the aforementioned 

expert witnesses have or will be retained by counsel for the State Court Litigation plaintiffs, but 

will be paid in accordance with the aforementioned letter dated July 3, 2019.

Supplemental Disclosures

9. Baker makes the following supplemental disclosures concerning its connections 

with creditors or other parties in interest in these Cases:

10. The Debtors have identified Simpson, Gumpertz & Heger as a vendor in these 

Cases, and identified The Vanguard Group, Inc. as a significant shareholder and significant holder 

of voting securities in these Cases. Baker partners now represent Simpson, Gumpertz & Heger 

and The Vanguard Group in unrelated matters.

Baker’s Disinterestedness

11. To the best of my knowledge and except as otherwise set forth in my initial and 

first verified statements and herein, the partners, counsel, associates and employees of 

Baker: (i) do not have any connections with the Debtors, their known creditors, other known or 

potential parties in interest, the U.S. Trustee for Region 17 or any person employed in the San 

Francisco office of the U.S. Trustee, or any United States Bankruptcy Judge for the Northern

[remainder of page intentionally left blank]

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO, CA

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District of California, and (ii) do not represent any other entity having an adverse interest in 

connection with these Cases.

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.

Executed on September 25, 2019.

/s/ Cecily A. Dumas

Cecily A. Dumas

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