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UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

- and - 

PACIFIC 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 PAUL H. ZUMBRO 

IN SUPPORT OF 

RETAINED PROFESSIONALS’ JOINT 

RESPONSE TO MOTION TO APPROVE 

FEE PROCEDURES AND FEE 

EXAMINER PROTOCOL

 

CRAVATH, SWAINE & MOORE LLP 

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019 

Tel: 212 474 1000 

Fax: 212 474 3700 

Attorneys for Debtors 

and Debtors in Possession 

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 

Case: 19-30088 Doc# 4065 Filed: 10/01/19 Entered: 10/01/19 22:02:42 Page 1 of

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I, Paul Zumbro, hereby declare that: 

1. I am a partner with Cravath, Swaine & Moore LLP (“Cravath”), and involved 

in Cravath’s representation of PG&E Corporation and Pacific Gas and Electric Company (collectively, 

the “Debtors”) in connection with the above-captioned chapter 11 cases (the “Chapter 11 Cases”). 

2. I respectfully submit this Declaration in support of the Retained Professionals’ 

Joint Response to Motion to Approve Fee Procedures and Fee Examiner Protocol dated October 1, 

2019 (the “Response”). 

3. Attached hereto as Exhibit A is a true and correct copy of the markup of edits 

to the Fee Examiner Protocol [Docket No. 3762, Ex. A] proposed jointly by the Retained Professionals 

as set forth in the Response. 

4. Attached hereto as Exhibit B is a true and correct copy of the revised 

Fee Examiner Protocol incorporating the edits proposed in Exhibit A. 

5. Certain of Cravath’s timekeepers listed in Cravath’s First Interim 

Fee Application [Docket No. 3683] were law clerks during the period addressed by the First Interim 

Fee Application (the “Cravath Law Clerks”). 

6. The educational requirements to become a law clerk at Cravath are the same as 

those for associates, including, at a minimum, a law degree. 

7. All of the Cravath Law Clerks listed in Cravath’s First Interim Fee Application 

passed the Bar Examination prior to starting work at Cravath, and all have since been admitted to the 

Bar. 

8. Prior to their admission to the Bar, Cravath Law Clerks worked under the direct 

supervision of partners and associates, all of whom are New York-licensed attorneys. 

9. Cravath Law Clerks have not argued in Court or taken depositions in these 

Chapter 11 Cases. 

Case: 19-30088 Doc# 4065 Filed: 10/01/19 Entered: 10/01/19 22:02:42 Page 2 of

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I declare under penalty of perjury under the laws of the United States of America that 

the foregoing is true and correct. 

Dated: October 1, 2019 

New York, New York 

 /s/ Paul H. Zumbro 

 Paul H. Zumbro 

Case: 19-30088 Doc# 4065 Filed: 10/01/19 Entered: 10/01/19 22:02:42 Page 3 of

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