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44553.00001

Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice)

MILBANK LLP 

55 Hudson Yards 

New York, New York 10001-2163

Telephone: (212) 530-5000

Facsimile: (212) 530-5219

and 

Gregory A. Bray (SBN 115367)

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor

Los Angeles, CA 90067

Telephone: (424) 386-4000

Facsimile: (213) 629-5063

Counsel for the Official Committee

of Unsecured Creditors

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 THOMAS R. 

KRELLER IN SUPPORT OF THE 

STATEMENT OF THE OFFICIAL 

COMMITTEE OF UNSECURED 

CREDITORS IN SUPPORT OF DEBTORS’ 

MOTION FOR THE ESTABLISHMENT 

OF WILDFIRE CLAIMS ESTIMATION 

PROCEDURES

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# 3434 Filed: 08/07/19 Entered: 08/07/19 16:06:20 Page 1 of

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2

I, THOMAS R. KRELLER, being duly sworn, state the following under the penalty of 

perjury:

1. I am an attorney admitted to practice in the State of California and I am a partner 

in the Financial Restructuring Group of the firm Milbank LLP (“Milbank”), counsel to the 

Official Committee of Unsecured Creditors of the above-captioned debtors and debtors in 

possession (the “Official Committee”). Milbank maintains an office at, among other places, 

2029 Century Park East, 33rd Floor, Los Angeles, California, 90067-3019. There are no 

disciplinary proceedings pending against me.

2. I am duly authorized to make this declaration on behalf of Milbank in support of

the Official Committee’s statement (the “Statement”) in support of the Debtors’ Motion 

Pursuant to 11 U.S.C. §§ 105(a) and 502(c) for the Establishment of Wildfire Claims Estimation 

Procedures, dated July 18, 2019.

3. For the Court’s reference in its consideration of the Statement, attached hereto as 

Exhibit A is a true and correct copy of the Master Complaint – Individual Plaintiffs, California 

North Bay Fire Cases, JCCP No. 4955 (Cal. Super. Ct. March 12, 2018).

4. Attached hereto as Exhibit B is a true and correct copy of the Master Complaint –

Subrogation Plaintiffs, California North Bay Fire Cases, JCCP No. 4955 (Cal. Super. Ct. March 

12, 2018).

5. Attached hereto as Exhibit C is a true and correct copy of the Public Entity 

Master Complaint, California North Bay Fire Cases, JCCP No. 4955 (Cal. Super. Ct. March 12, 

2018).

I declare under penalty of perjury that the foregoing is true and correct to the best of my 

knowledge and belief. 

Executed on August 7, 2019, Los Angeles, CA

/s/ Thomas R. Kreller 

Thomas R. Kreller

Case: 19-30088 Doc# 3434 Filed: 08/07/19 Entered: 08/07/19 16:06:20 Page 2 of

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