1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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: 310.820.8859

Email: rjulian@bakerlaw.com

Email: cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

David J. Richardson (SBN 168592)

Lauren T. Attard (SBN 320898)

BAKER & HOSTETLER LLP

11601 Wilshire Blvd., Suite 1400

Los Angeles, CA 90025-0509

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: drichardson@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 RICHARD 

BARTON IN SUPPORT OF MOTION OF 

THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS PURSUANT TO 11 

U.S.C. §§ 105(a) AND 501 AND FED. R. 

BANKR. P. 3003(c) FOR ENTRY OF AN 

ORDER EXTENDING THE BAR DATE

Date: November 13, 2019

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Objection Deadline: November 6, 2019

Case: 19-30088 Doc# 4299 Filed: 10/18/19 Entered: 10/18/19 15:37:05 Page 1 of

4
1 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Steven J. Skikos (SBN 148110) 

Gregory T. Skikos (SBN 176531) 

Matthew J. Skikos (SBN 269765) 

SKIKOS, CRAWFORD, SKIKOS & JOSEPH

One Sansome Street, Suite 2830 

San Francisco, CA 94104 

Telephone: 415-546-7300 

Facsimile: 415-546-7301 

sskikos@skikos.com 

gskikos@skikos.com 

mskikos@skikos.com 

Attorneys for Declarant

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

Bankr. Case No. 19-30088-DM

DECLARATION OF RICHARD 

BARTON IN SUPPORT OF MOTION TO

EXTEND CLAIMS BAR DATE 

Date: TBD

Time: TBD

Place: United States Bankruptcy Court

 Courtroom 17, 16th Floor San Francisco, CA 94102 

I, Richard Barton, declare as follows: 

1. I am over the age of 18. I have personal knowledge of the facts contained in this

declaration, and if called as a witness, I could and would testify competently thereto. I

worked in law enforcement for 24 years.

2. I was a first responder paramedic prior to being in law enforcement. I worked as a

Case: 19-30088 Doc# 4299 Filed: 10/18/19 Entered: 10/18/19 15:37:05 Page 2 of

4
2 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

D.A. investigator in Butte County. I now run advanced classes for peace officers

throughout the state on child abuse investigation and adult sexual assault

investigations.

3. I owned my home on Berkshire Way in Paradise, California. I had lived in Paradise

for 15 years before the fire destroyed our town. My home was completely burned by

the Camp Fire that occurred on November 8, 2018. On the morning of the fire, I was

out of the area. I was running a child abuse investigation class in Carmel, California.

In addition to my home, I lost all my belongings, my cat, and my community. I had an 

extensive collection of model railroads.

4. I’m writing this declaration not for myself. I have an attorney. I’m writing this for

others who do not have the same access to trusted information or the same

experiences that I have had.

5. My lot was approximately 1/2 acres of forested land. After the fire, PG&E had a

logging company enter my property without authorization. The company removed a

significant percentage of the trees on my land. I did not approve this, and the

company did not call me until after the trees had been logged. The company did send

me an email. I went to my property and the lot had already been already cleared.

Some trees on my property were probably dead from the fire, but others were alive,

including my 200-year-old pine. Many of the trees the logging company took were

not near the utility line and were healthy. I don’t understand why they couldn’t work

with me on this. I don’t understand why PG&E’s company would log my healthy

trees without my permission and further devastate my lot unless PG&E wanted to

discourage me from rebuilding.

6. In my communication with my insurance company, my adjusters never disclosed that 

it was trying to recover money from PG&E for the payments it was making to fire 

survivors. My adjusters never told me they were settling with PG&E. 

Case: 19-30088 Doc# 4299 Filed: 10/18/19 Entered: 10/18/19 15:37:05 Page 3 of

4
3 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

7. My property has now been cleaned and certified by the county. However, most of the

trees are gone. The properties around me haven’t been cleaned.

8. One of the problems with notice from PG&E is that PG&E is not trusted. I do not recall

receiving a notice about the bankruptcy from PG&E in the mail. However, I do remember

when the San Bruno explosion took place and, as a first responder, I thought about the

first responders there and the hazards they faced. I remember PG&E’s apology ads and

how PG&E said that they were going to change and prioritize safety inspections of gas

lines. Reading the papers later, I learned about PG&E executives getting bonuses and

raises. PG&E didn’t learn after San Bruno, or after the other fires. Why would anything

from them be trusted now? People need information from a trusted source.

9. None of the fire victims should be precluded from recovering for their losses, but

they need more time to learn the facts about this bankruptcy and to be given a fair

opportunity to participate in the process.

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

6th day of October, 2019 in Chico, California.

 ____________________________ 

Richard Barton

Case: 19-30088 Doc# 4299 Filed: 10/18/19 Entered: 10/18/19 15:37:05 Page 4 of

4