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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: 310.820.8859

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 DAVID J. RICHARDSON IN 

SUPPORT OF OPPOSITION OF OFFICIAL 

COMMITTEE OF TORT CLAIMANTS TO 

DEBTORS’ MOTION PURSUANT TO 11 U.S.C. §§ 

363(b) AND 105(a) AND FED. R. BANKR. P. 6004 

AND 9019 FOR ENTRY OF AN ORDER (I) 

AUTHORIZING THE DEBTORS TO ENTER 

INTO RESTRUCTURING SUPPORT 

AGREEMENT WITH THE CONSENTING 

SUBROGATION CLAIMHOLDERS, (II) 

APPROVING THE TERMS OF SETTLEMENT 

WITH SUCH CONSENTING SUBROGATION 

CLAIMHOLDERS, INCLUDING THE ALLOWED 

SUBROGATION CLAIM AMOUNT, AND (III) 

GRANTING RELATED RELIEF [DKT NO. 3992]

Date: October 23, 2019

Time: 10:00 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Case: 19-30088 Doc# 4235 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 1 of

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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DECLARATION OF DAVID J. RICHARDSON

I, David J. Richardson, pursuant to 28 U.S.C. § 1746, declare the following under penalty 

of perjury:

1. I am Counsel at Baker & Hostetler LLP (“Baker & Hostetler”), which has an 

office at 1160 Battery Street, San Francisco, California 94111 and is an independent, privatelyheld, legal firm. I am authorized to make this declaration (this “Declaration”) on behalf of Baker 

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

set forth herein.

2. Baker & Hostetler was engaged as counsel to the Official Committee of Tort 

Claimants (the “TCC”) effective as of February 2019. I am a member of the team of Baker & 

Hostetler professionals on this engagement. I submit this Declaration in support of the 

Opposition of Official Committee of Tort Claimants to Debtors’ Motion Pursuant to 11 U.S.C. 

§§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9019 for Entry of an Order (i) Authorizing 

the Debtors to Enter into Restructuring Support Agreement with the Consenting Subrogation 

Claimholders, (ii) Approving the Terms of Settlement with such Consenting Subrogation 

Claimholders, Including the Allowed Subrogation Claim Amount, and (iii) Granting Related 

Relief [Dkt No. 3992] (the “Opposition”).1

3. Except where specifically noted, all statements in this Declaration are based upon 

(a) my personal knowledge developed during the course of my engagement with the TCC, (b) my 

discussions with advisors of other parties in interest in these chapter 11 cases and other members 

of our team at Baker & Hostetler and (c) my review of relevant documents and/or my 

professional opinion based upon my experience. If called to testify, I could and would testify to 

each of the facts set forth herein based on such personal knowledge, discussions, review of 

documents and/or professional opinion. 

4. Attached hereto as Exhibit A is a true and correct copy of relevant pages of the 

Transcript of Proceedings of Proceedings before the Hon. James Donato, Judge, United States 

 1 Capitalized terms not otherwise defined herein have the meanings given to them in the Opposition. 

Case: 19-30088 Doc# 4235 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 2 of

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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

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District Court for the Northern District of California, held in Case No. 19-05257 JD on 

September 10, 2019.

5. Attached hereto as Exhibit B is a true and correct copy of the Notice of Motion 

and Motion by Pacific Gas and Electric Company for Order (A) Approving Settlement and 

Support Agreement by and among Plan Proponents and Senior Debtholders, (B) Authorizing 

Payment of Pre- and Post-Petition Interest to Holders of Undisputed Claims in Certain Classes, 

(C) Authorizing Payment of Fees and Expenses of Indenture Trustees and Paying Agents and (D) 

Authorizing Debtor to Enter into Similar Settlement; Supporting Memorandum of Points and 

Authorities, filed on March 5, 2002 [Dkt. No. 5013] in Case No. 01-30923 DM, in the United 

States Bankruptcy Court for the Northern District of California, San Francisco Division, which I 

obtained from this Court’s ECF filing system.

6. On October 15, 2019, I represented the TCC in the 30(b)(6) deposition of Baupost, 

LLC, for whom Joshua Greenhill testified on as the 30(b)(6) witness on certain topics. The rough 

transcript of the deposition of Mr. Greenhill was distributed to counsel on October 16, 2019. 

Although the transcript was initially marked “Highly Confidential,” I confirmed by email with 

counsel for Baupost on October 16, 2019, that they do not designate pages 23-26 as protected, 

and do not object to their filing with this Declaration. A true and correct copy of pages 23-26 of 

the Greenhill deposition transcript are attached hereto as Exhibit C. 

7. On October 11, 2019, I represented the TCC in the 30(b)(6) deposition of the 

Debtors, at which Jason Wells, CFO of PG&E was presented as the witness. The relevant pages 

of the final transcript of the Debtors’ 30(b)(6) are attached hereto as Exhibit D. The entire 

transcript for the Wells deposition was originally marked “Confidential-Professional Eyes Only” 

while the parties addressed the proper scope of any such designation. The Debtors have provided 

the TCC with a list of those pages that they deem to be “Confidential-Professional Eyes Only,” 

and have undertaken to reach out to the reporter to have the designation on the transcript revised 

to reflect those entries. In the meantime, Debtors’ counsel has agreed in writing that the TCC 

may remove this designation from the pages attached hereto, as they do not fall within the scope 

of the designated pages.

Case: 19-30088 Doc# 4235 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 3 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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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: Los Angeles

October 16, 2019 /s/ David J. Richardson

David J. Richardson

Case: 19-30088 Doc# 4235 Filed: 10/16/19 Entered: 10/16/19 15:39:12 Page 4 of

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