1 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 155496) 

Lauren T. Attard (SBN 320898) 

7 BAKER & HOSTETLER LLP 

11601 Wilshire Boulevard, Suite 1400 

8 Los Angeles, CA 90025 

Telephone: 310.820.8800 

9 Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

10 Email: lattard@bakerlaw.com 

11 Counsel for Official Committee of Tort Claimants 

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UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

14 In re: 

15 PG&E CORPORATION 

16 -and17 PACIFIC GAS AND ELECTRIC 

COMPANY, 

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Debtors 

o Affects PG& E Corporation 

o Affects Pacific Gas and Electric Company 

• Affects both Debtors 

* All papers shall be filed in the Lead Case, 

25 No. 19-30088 (DM) 

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Case No. 19-30088 (DM) 

Chapter 11 

(Lead_ Case) 

(Jointly Administered) 

DECLARATION OF FRANK M. PITRE 

IN SUPPORT OF THE MOTION OF 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS FOR AN ORDER 

DETERMINING PROCEDURES FOR 

PRESERVING JURY TRIAL RIGH'rS 

Case: 19-30088 Doc# 3480 Filed: 08/08/19 Entered: 08/08/19 18:17:02 Page 1 of

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1 I, Frank M. Pitre, declare the following under penalty of perjury pursuant to 28 U.S.C. 

2 section 1746: 

3 1. I submit this declaration in support of the motion of the Official Committee of Tort 

4 Claimants for an order determining procedures for jury trial rights. I have personal knowledge of 

5 the facts set forth in this declaration. 

6 2. I am a member of the State Bar of California and a partner in the law firm of 

7 Cotchett, Pitre & McCarthy, LLP. 

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3. After the 2017 North Bay fires occurred, individual victims filed personal injury, 

wrongful death, and property damage civil actions for damages suffered in or by reason of the fires 

against Pacific Gas ~ Electric Company ("PG&E") in Sonoma and Napa Counties. The litigation 

was eventually coordinated in a Judicial Council Coordination Proceeding entitled California North 

Bay Fire Cases, JCCP No. 4955, in the Superior Court of California for the County of San 

Francisco. I am one of the three co-lead counsel in the litigation. 

4. My clients and many other victims of PG&E will be filing claims in the bankruptcy. 

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Many clients and lawyers of victims are concerned that filing a claim or uploading information to 

the BrownGreer database will deprive them of any jury trial rights they may have _under existing 

17 law. 

18 5. On August 2, 2019, as part of my negotiations with Kevin Orsini, counsel to the 

19 Debtors, regarding submission of data to the BrownGreer database, I requested that Mr. Orsini to 

20 stipulate that that uploading information into the Brown Greer database will not constitute a waiver 

21 of any jury trial rights. The email chain is attached hereto as Exhibit A. 

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6. On August 3, 2019, Mr. Orsini declined to enter that stipulation. See Exhibit A. 

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1 7. After further discussion about the issue, on August 3, 2019, Mr. Orsini suggested 

2 filing a motion that raises the jury trial issue and that the Debtors would respond in due course. Id 

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I ~eclare under penalty of perjury that the foregoing is true and correct. 

Executed on August 8, 2019. 

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