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1 DECLARATION OF ROBERT BRYSON

Bill Robins III, Esq. (SBN 296101) 

Robert T. Bryson, Esq. (SBN 156953) 

Rex Grady, Esq. (SBN 232236) 

ROBINS CLOUD LLP 

808 Wilshire Blvd., Suite 450 

Santa Monica, California 90401 

Telephone: (310) 929-4200 

Facsimile: (310) 566-5900 

Attorneys for Creditor, Sherry Mitcham

Matthew W. Grimshaw, Esq. (SBN 210424) 

GRIMSHAW LAW GROUP, P.C.

26 Executive Park, Ste. 250 

Irvine, California 92614 

Telephone: (949) 734-0187 

Facsimile: (208) 391-7860 

Counsel for Robins Cloud LLP 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION, 

and 

PACIFIC GAS AND ELECTRIC 

COMPANY

 Debtors

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Case No. 19-30088 (DM)

Chapter 11

(Lead Case–Jointly Administered)

DECLARATION OF ROBERT 

BRYSON IN SUPPORT OF MOTION 

FOR ORDER AUTHORIZING 

WITHDRAWAL OF COUNSEL TO 

SHERRY MITCHAM 

Affects: 

PG&E Corporation

Pacific Gas & Electric Company

Both Debtors

* All papers shall be filed in the Lead 

Case, No. 19-30088 (DM).

Case: 19-30088 Doc# 13074 Filed: 10/13/22 Entered: 10/13/22 17:36:31 Page 1

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2 DECLARATION OF ROBERT BRYSON

Declaration of Robert Bryson

I, Robert Bryson, say and declare as follows: 

1. I am an individual over 18 years of age and competent to make this declaration.

2. I am an attorney with the law firm of Robins Cloud LP (the “Firm”), attorneys of 

record for Sherry Mitcham (“Creditor”).

1

 I am duly admitted to practice law before all courts of 

the State of California and before this court. 

3. I make this declaration in support of the Firm’s motion to be relieved as counsel 

to Creditor in the above-captioned bankruptcy case (“Motion”). The facts set forth below are true 

and within the scope of my personal knowledge, and if called upon to do so I could and would 

testify competently to these facts.

4. On January 29, 2019, Debtors filed voluntary petitions commencing their 

bankruptcy cases. 

5. On October 16, 2019, the Firm filed Proof of Claim No. 30183 on behalf of 

Sherry Mitcham (“Claim”), seeking damages from the North Bay Fire. Since the filing of the 

Claim, an irreconcilable difference has developed between Creditor and the Firm. As a result, the 

Firm notified Creditor that it must withdraw as counsel. 

6. To the extent that Creditor requests that the Firm turn over any files or 

information that he is entitled to, the Firm will cooperate and transmit such files.

7. The Firm will cause the Motion to be served on all of the addresses provided to 

the Firm by Creditor, including the following: 

2810 Porter Creek Road 

Santa Rosa, CA 95404 

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

Executed on October 13, 2022. 

Robert Bryson 

1 The Firm retained Grimshaw Law Group, P.C. (“GLG”) to, among other things, assist it in filing 

this motion. GLG has no contractual or attorney/client relationship with Creditor. 

Case: 19-30088 Doc# 13074 Filed: 10/13/22 Entered: 10/13/22 17:36:31 Page 2

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