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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 STEVEN THOMAS 

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# 4315 Filed: 10/18/19 Entered: 10/18/19 16:15:54 Page 1 of

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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

Attorney for Declarant

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

 -andPACIFIC GAS AND ELECTRIC 

COMPANY,

 Debtors.

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Bankr. Case No. 19-30088-DM

DECLARATION OF STEVEN THOMAS

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, Steven Thomas, declare as follows: 

1. I am 56 years old. I have personal knowledge of the facts contained in this 

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

2. I owned my home on O’Donnell Lane in Glen Ellen, California. My property had 

two homes – the main house and a rental. Both houses were completely destroyed by 

Case: 19-30088 Doc# 4315 Filed: 10/18/19 Entered: 10/18/19 16:15:54 Page 2 of

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the Nuns Fire that occurred on October 8, 2017. 

3. On the night of the fire, I went to bed at 11:00pm. At around 1:30am, my tenant from 

the rental unit came pounding on my bedroom window saying we had to evacuate. 

My spouse and I left without taking anything – no passports, no belongings. We 

drove to the Safeway parking lot in Sonoma. We saw fire 360 degrees all around us. 

At 6:00am, we drove back home. When we got there, we could only stand and watch 

as both houses on our property were totally engulfed in flames. It was surreal. 

4. As a result of the fire, I lost two homes, my cat, and a lifetime of possessions. I also 

lost a good tenant and the income from my rental property. My lot sits along Sonoma 

Creek. The trees are still dying off two years later.

5. I have spent the past two years trying to recover from this disaster. I have logged 

countless hours dealing with my insurance company, mortgage lender, and building 

contractor. Given the shortfall in my insurance coverage, I can only afford to rebuild 

one of the homes that I lost in the fire. Many of my neighbors are in the same 

situation. They are tired of fighting all these battles and I’m afraid they are going to 

give up.

6. After the fires, I saw advertisements about all the safety measures PG&E was taking 

to protect us from another disaster, but I never saw any communications from PG&E 

about how their equipment started the fires in the first place.

7. I did not know I could recover damages from PG&E, especially after the company 

filed for bankruptcy. I recall receiving a claim form in the mail, but I did not 

understand the significance and probably thought it was junk mail. 

8. Fortunately, I learned about the claims process and my rights in the bankruptcy from 

a Q&A that one of my neighbors wrote. It cleared up a lot of misconceptions I had 

about the case. If I had not received her email, I would not have understood my rights 

as a creditor, that PG&E has money available to pay claims, that I would not be 

taking money away from other fire survivors or rate payers if I pursued my claim, 

Case: 19-30088 Doc# 4315 Filed: 10/18/19 Entered: 10/18/19 16:15:54 Page 3 of

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and that I needed to act before the October 21st deadline. 

9. My insurance company required that I sign a letter acknowledging its “subrogation 

rights” in my policy. I did not know exactly what this meant, but thought I had to 

sign. My insurer never explained that it was making a claim against PG&E for my 

losses. 

10. A few weeks ago, I read that PG&E has agreed to pay the insurance companies $11 

billion in reimbursement. I was shocked. If PG&E has tens of billions of dollars, it 

should go to all these fire victims who are in desperate need of help to put their lives 

back together. 

11. My neighbors and I are not litigious. We do not want to be victims. We do not want 

to be defined by the fire. We want to put this experience behind us. But we should 

not have to sit on the sidelines while investors step in ahead of us and profit. 

12. I am providing this declaration because I only recently obtained the facts and 

information necessary to understand my rights in this bankruptcy. The other 

members of my community should be afforded the same opportunity. 

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

10th day of October, 2019 in Glen Ellen, California.

 ____________________________ 

 Steven Thomas 

Case: 19-30088 Doc# 4315 Filed: 10/18/19 Entered: 10/18/19 16:15:54 Page 4 of

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