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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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: 310.820.8869

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: 310.442.8875

Facsimile: 310.820.8869

Email: esagerman@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel to the 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)

DECLARATION OF LAUREN T. 

ATTARD IN SUPPORT OF EX PARTE 

APPLICATION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO B.L.R. 9013-1(c) FOR 

ENTRY OF AN ORDER AUTHORIZING 

OVERSIZE BRIEFING FOR 

OPPOSITION TO THE DEBTORS’ 

MOTION PURSUANT TO 11 U.S.C. 

§§ 105(a) AND 502(c) FOR THE 

ESTABLISHMENT OF WILDFIRE 

CLAIMS ESTIMATION PROCEDURES 

[Dkt. No. 3091]

Case: 19-30088 Doc# 3445 Filed: 08/07/19 Entered: 08/07/19 16:54:55 Page 1 of

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BAKER 

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ATTORNEYS AT LAW

SAN FRANCISCO

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Lauren T. Attard, under penalty of perjury, declares:

1. I am an attorney at Baker & Hostetler, LLP (“Baker Hostetler”), counsel to the 

Official Committee of Tort Claimants (hereafter, the “TCC”) in the above captioned chapter 11 

cases of PG&E Corporation and Pacific Gas and Electric Company (collectively, the “Debtors” or 

“PG&E”). 

2. I submit this Declaration in support of the Ex Parte Application of the Official 

Committee of Tort Claimants Pursuant to B.L.R. 9013-1(c) for Entry of an Order Authorizing 

Oversize Briefing for the Opposition to the Debtors’ Motion Pursuant to 11 U.S.C. §§ 105(a) and 

502(c) for the Establishment of Wildfire Claims Estimation Procedures [Dkt. No. 3091] (the 

“Application”). The Application is filed concurrently herewith.

3. Unless otherwise stated in this Declaration, I have personal knowledge of the facts 

set forth herein.

4. On July 18, 2019, the Debtors filed the Motion Pursuant to 11 U.S.C. §§ 105(a) and 

502(c) for the Establishment of Wildfire Claims Estimation Procedures (the “Estimation 

Motion”). 

5. On July 24, 2019, the Court held a status conference on the Estimation Motion, the 

TCC’s Motion for Relief from the Automatic Stay to Permit State Court Jury Trial of 2017 Tubbs 

Wildfire Claims [Dkt Nos. 2842, 2904], and the Motion of the Ad Hoc Group of Subrogation Claim 

Holders for Relief from the Automatic Stay [Dkt No. 2863]. At the status conference, the Court 

stated that it recognized the complexity of the issues raised by the parties in their respective motions 

and the interplay of the relief sought in each. July 24, 2019 Hrg. Tr. at 18. The Court provided 

comments to the motions and requested clarification on various issues, which the Court directed 

the parties to address in their responsive briefing. Id. at 19-28.

6. The TCC now seeks to file its opposition to the Estimation Motion (the 

“Opposition”). 

7. To adequately respond to the complex issues raised in the Estimation Motion and 

address the Court’s questions and comments that must be considered in conjunction with the relief 

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ATTORNEYS AT LAW

SAN FRANCISCO

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requested by the Debtors, the TCC respectfully submits it is necessary for the TCC to exceed the 

25-page limit. 

8. I do not believe that the relief requested herein will prejudice the Debtors or 

interested parties, nor do I believe the relief requested on behalf of the TCC is extraordinary or 

unreasonable in light of the circumstances. 

9. The TCC therefore respectfully requests that the Court enter an order allowing the 

TCC to file an opposition to the Estimation Motion that exceeds 25 pages.

10. Prior to filing the Application, I contacted Kevin Orsini, counsel for the Debtors, to 

inquire whether Debtors would oppose or have no objection to the relief sought therein. Mr. Orsini 

responded today that the Debtors consent to the relief requested herein. 

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 August 7, 2019 

By: /s/ Lauren T. Attard

Lauren T. Attard

Case: 19-30088 Doc# 3445 Filed: 08/07/19 Entered: 08/07/19 16:54:55 Page 3 of

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