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BAKER 

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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: 310.820.8859

Email: rjulian@bakerlaw.com

Email: cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Boulevard, Suite 1400

Los Angeles, CA 90025

Telephone: 310.820.8800

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

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

□ 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)

DECLARATION OF MICHAEL A. 

KELLY IN SUPPORT OF THE 

OPPOSITION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

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]

Date: August 14, 2019

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Case: 19-30088 Doc# 3436 Filed: 08/07/19 Entered: 08/07/19 16:13:52 Page 1 of

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I, Michael A. Kelly, declare the following under penalty of perjury pursuant to 28 U.S.C. 

section 1746:

1. I submit this Amended Declaration in support of the Opposition of the Official 

Committee of Tort Claimants to the Debtors’ motion to establish wildfire claims estimation 

procedures [Dkt. No. 3091]. I have personal knowledge of the facts set forth in this declaration.

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

Melodia, Kelly & Schoenberger. 

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.

4. The judge assigned to the California North Bay Fire Cases, Judge Curtis Karnow, 

entered Case Management Order No.1, dated March 6, 2018, attached hereto as Exhibit A, which 

appointed me and Frank Pitre as two of the three co-lead counsel in the litigation and an Executive 

Committee leadership team of lawyers representing the individual plaintiffs.

5. Attached hereto as Exhibit B is a true and correct copy of the Superior Court’s Case 

Management Order No. 2 in the North Bay Fire Cases, JCCP 4955.

6. Attached hereto as Exhibit C is a true and correct copy of the Superior Court’s Case 

Management Order No. 3 in the North Bay Fire Cases, JCCP 4955.

7. Attached hereto as Exhibit D is a true and correct copy of the Superior Court’s Case 

Management Order No. 4 in the North Bay Fire Cases, JCCP 4955.

8. Attached hereto as Exhibit E is a true and correct copy of the Superior Court’s Case 

Management Order No. 5 in the North Bay Fire Cases, JCCP 4955.

9. Attached hereto as Exhibit F is a true and correct copy of the Superior Court’s Case 

Management Order No. 6 in the North Bay Fire Cases, JCCP 4955.

Case: 19-30088 Doc# 3436 Filed: 08/07/19 Entered: 08/07/19 16:13:52 Page 2 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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10. Attached hereto as Exhibit G is a true and correct copy of a Camp Fire complaint 

in Williams v. PG&E, Case No. 18CV03993 (Super. Ct. Cal.).

11. Attached hereto as Exhibit H is a true and correct copy of a letter, dated August 1, 

2019, from Kevin Orsini, counsel to the Debtors.

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

Executed on August 6, 2019.

Michael A. Kelly

Walkup, Melodia, Kelly & Schoenberger 

650 California Street, 26th Floor

San Francisco, CA 94108

Tel: (415) 981-7210

Fax: (415) 391-6965

Email: mkelly@walkuplawoffice.com 

Case: 19-30088 Doc# 3436 Filed: 08/07/19 Entered: 08/07/19 16:13:52 Page 3 of

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