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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: (212) 310-8000 

Fax: (212) 310-8007

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (650) 636-9251 

Attorneys for Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

- and - 

PACIFIC 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 W. SLACK IN 

SUPPORT OF DEBTORS’ OBJECTION TO CLASS 

REPRESENTATIVE’S MOTION TO EXTEND 

APPLICATION OF FEDERAL RULE OF CIVIL 

PROCEDURE 23 TO CLASS PROOF OF CLAIM 

Date: November 19, 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# 4686 Filed: 11/12/19 Entered: 11/12/19 15:50:31 Page 1 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

I, Richard W. Slack, hereby declare as follows: 

1. I am a partner at the law firm Weil, Gotshal & Manges LLP, 767 Fifth Avenue, New 

York, New York 10153, counsel for the Debtors in the above-captioned action. I am admitted to this 

Court pro hac vice and respectfully submit this declaration in support of the Debtors’ Objection to Class 

Representative’s Motion to Extend Application of Federal Rule of Civil Procedure 23 to Class Proof of 

Claim. 

2. The matters set forth below are of my own personal knowledge or upon information and 

belief based upon materials, books, and records made available to me. If called upon to testify I could 

and would competently testify to those facts. 

3. Attached as Exhibit A is a true and correct copy of the July 18, 2019 Notice of 

Bankruptcy Filing and Imposition of Automatic Stay from PG&E to Dave Alonzo’s attorney, John 

Lattin, which includes the corresponding proof of service. 

4. Attached as Exhibit B is a true and correct copy of Dave Alonzo’s March Wage 

Statement, dated March 22, 2019, obtained from Debtors’ records. 

5. Attached as Exhibit C is a true and correct copy of Dave Alonzo’s Payroll Check Request, 

dated March 26, 2019, obtained from Debtors’ records. 

6. Attached as Exhibit D is a true and correct copy of Dave Alonzo’s Vacation Payoff at 

Term Statement, dated March 29, 2019, obtained from Debtors’ records. 

7. Attached as Exhibit E is a true and correct copy of the UPS Shipping Confirmation, dated 

March 29, 2019, that confirms the delivery of Dave Alonzo’s final check to Steve Watson, obtained 

from Debtors’ records. 

8. Attached as Exhibit F is a true and correct copy of the PG&E “Short-Term Incentive Plan 

Administration Standard” policy, dated May 2019, obtained from Debtors’ records. 

9. Attached as Exhibit G is a true and correct copy of Dave Alonzo’s February Wage 

Statement, dated February 22, 2019, obtained from Debtors’ records. 

10. Attached as Exhibit H is a true and correct copy of Dave Alonzo’s Short-Term Incentive 

Plan Payment, dated May 15, 2019, obtained from Debtors’ records. 

Case: 19-30088 Doc# 4686 Filed: 11/12/19 Entered: 11/12/19 15:50:31 Page 2 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

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

Executed: November 12, 2019 

 New York, New York 

/s/ Richard W. Slack___________ 

Richard W. Slack 

Case: 19-30088 Doc# 4686 Filed: 11/12/19 Entered: 11/12/19 15:50:31 Page 3 of

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