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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF KEVIN J. ORSINI IN 

SUPPORT OF MOTION OF DEBTORS 

PURSUANT TO 11 U.S.C. §§ 502(b)(9) AND 105(a), 

FED. R. BANKR. P. 2002, 3003(c)(3), 5005, AND 

9007, AND L.B.R. 3003-1 FOR ORDER (I) 

ESTABLISHING DEADLINE FOR FILING 

PROOFS OF CLAIM, (II) ESTABLISHING THE 

FORM AND MANNER OF NOTICE THEREOF, 

AND (III) APPROVING PROCEDURES FOR 

PROVIDING NOTICE OF BAR DATE AND 

OTHER INFORMATION TO ALL CREDITORS 

AND POTENTIAL CREDITORS 

Date: May 22, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

San Francisco, CA 94102

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). 

Case: 19-30088 Doc# 1785 Filed: 05/01/19 Entered: 05/01/19 15:36:01 Page 1 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Pursuant to 28 U.S.C. § 1746, I, Kevin J. Orsini, hereby declare as follows under penalty of 

perjury: 

I am a partner of Cravath, Swaine & Moore LLP (“Cravath”), a New York law firm with 

offices at 825 Eighth Avenue, New York, New York 10019. I am an attorney at law licensed to 

practice in the State of New York and also admitted to practice before this Court pro hac vice. 

Cravath is counsel to PG&E Corporation and Pacific Gas and Electric Company 

(collectively, “PG&E” or the “Debtors”) in the above-captioned chapter 11 cases (the “Chapter 

11 Cases”). I submit this Declaration in support of the Motion of Debtors Pursuant to 11 U.S.C. 

§§ 502(b)(9) and 105(a), Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 

for Order (i) Establishing Deadline for Filing Proofs of Claim, (ii) Establishing the Form and 

Manner of Notice Thereof, and (iii) Approving Procedures for Providing Notice of Bar Date and 

Other Information to all Creditors and Potential Creditors, filed on the date hereof (the “Bar Date 

Motion”).1

Prior to the commencement of the Chapter 11 Cases, Cravath was the Debtors’ lead counsel 

for, among other things, litigation and regulatory matters related to the wildfires that occurred in 

Northern California in 2017 and 2018. Cravath represented PG&E in connection with the 

prepetition lawsuits and claims related to the 2017 and 2018 Northern California Wildfires since 

the initial filing of those suits. Subject to this Court’s approval, Cravath has been retained to advise 

and represent the Debtors in the Chapter 11 Cases with respect to, among other things, (i) litigation 

matters relating to the 2017 and 2018 Northern California Wildfires as well as the 2015 Butte 

Wildfire (collectively, the “Northern California Wildfires”), (ii) claims allowance, claims 

estimation, and related settlement and plan of reorganization matters with respect to Wildfire 

Claims, and (iii) investigation and inquiries by regulators and prosecuting authorities related to the 

Northern California Wildfires, and advising the Debtors in connection with wildfire issues that have 

arisen or may arise in connection with their criminal probation from the San Bruno gas explosion. 

 

1

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

terms in the Bar Date Motion. 

Case: 19-30088 Doc# 1785 Filed: 05/01/19 Entered: 05/01/19 15:36:01 Page 2 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

In connection with the Debtors’ preparation of Schedule E/F, which was filed on March 14, 

2019 [Dkt. Nos. 900, 906], Cravath provided the Debtors with a list of all complaints related to the 

2017 and 2018 Northern California Wildfires. I understand that Schedule E/F also incorporates a 

list of all complaints that had been filed related to the 2015 Butte Wildfire and a list of individuals 

who may have contacted or corresponded with the Debtors through their claims management 

process regarding potential Wildfire Claims but who had not yet commenced formal litigation at 

the time of correspondence. The list of Wildfire Claims set forth in Schedule E/F reflects 

approximately 13,700 individual Known Wildfire Claimants. 

In addition to complaints that have been filed, I along with my colleagues at Cravath have 

identified sources in the possession of third parties that may provide Debtors with additional contact 

information, including mailing addresses, of holders of Wildfire Claims: (i) a database maintained 

by BrownGreer PLC, which lists persons or entities that have Wildfire Claims in connection with 

the prepetition State court litigation related to the 2017 Northern California Wildfires; (ii) contact 

information maintained by the subrogation insurance carriers for persons or entities that have filed 

insurance claims or have received payment under any insurance policy for damages arising out of 

or relating to a Wildfire Claim; and (iii) the GIS database managed by Northwest Aerial 

Reconnaissance, Inc., experts retained by Debtors in connection with prepetition State court 

litigation, which contains a list of all properties and property owners located within the 2017 

Northern California fire perimeters. In connection with the Bar Date Motion and the noticing 

procedures contemplated therein, the Debtors have made or will soon make requests to the 

appropriate parties for access to the information contained in the above-mentioned sources. 

Additionally, as set forth in the Bar Date Motion, the Wildfire Claimant Proof of Claim 

Form and Wildfire Subrogation Claimant Proof of Claim Form proposed by the Debtors request 

information I believe is important relating to the Wildfire Claims, including information to identify 

the relevant wildfire, the specifics of the type of loss or injury, the location of the loss or injury, the 

type of damages asserted, and (if applicable) whether the claim is covered by insurance and the 

details with respect thereto. I believe the information being requested is critical to assessing the 

Debtors’ aggregate liability, overall and for different categories of claims. For instance, identifying 

Case: 19-30088 Doc# 1785 Filed: 05/01/19 Entered: 05/01/19 15:36:01 Page 3 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

the relevant fire and the location of the loss or injury is necessary to ensure that liability findings 

made with respect to the individual fires are carried through to the corresponding claims. 

Information concerning the types of damages asserted is required to enable the Debtors and other 

parties to calculate an accurate measure of damages. Identifying whether a claim has been covered 

by insurance is required to value claims accurately and avoid any double-counting of losses 

recovered across the different categories of claimants (i.e., Wildfire Claimants and Wildfire 

Subrogation Claimants). I believe that obtaining this information will be essential to the claims 

estimation and resolution process whether the aggregate amount of liability relating to Wildfire 

Claims is established consensually—as is the Debtors’ hope—or otherwise. I further believe the 

information being requested is limited and has been tailored and organized in a streamlined manner 

so that providing the same will not impose any undue burden on any Wildfire Claimant. 

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

statements are true and correct. 

[Signature page on next page] 

 

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Dated: May 1, 2019 

 

 

/s/ Kevin J. Orsini

By: Kevin J. Orsini 

Title: Partner, Cravath Swaine & Moore LLP 

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