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BRAD BRIAN (State Bar No. 79001)

Brad.Brian@mto.com

THOMAS B. WALPER (State Bar No. 96667)

thomas.walper@mto.com

HENRY WEISSMANN (State Bar No. 132418)

henry.weissmann@mto.com

BRADLEY SCHNEIDER (State Bar No. 235296)

bradley.schneider@mto.com

MUNGER, TOLLES & OLSON LLP

350 South Grand Avenue

Fiftieth Floor

Los Angeles, California 90071

Telephone: (213) 683-9100

Facsimile: (213) 683-3702

Attorneys for Debtors 

and Debtors in Possession

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

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

DECLARATION OF HENRY 

WEISSMANN IN SUPPORT OF SECOND 

APPLICATION OF DEBTORS TO 

AMEND ORDER PURSUANT TO 11 

U.S.C. § 327(e) AND FED. R. BANKR. P. 

2014(a) AND 2016 FOR AUTHORITY TO 

RETAIN AND EMPLOY MUNGER, 

TOLLES & OLSON LLP AS COUNSEL 

FOR CERTAIN MATTERS

Case: 19-30088 Doc# 4527-3 Filed: 10/30/19 Entered: 10/30/19 17:53:12 Page 1

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Pursuant to 28 U.S.C. § 1746, I, Henry Weissmann, hereby declare as follows:

I am a partner at Munger, Tolles & Olson LLP (“MTO” or the “Firm”), located at 350 S. 

Grand Ave., 50th Floor, Los Angeles, California 90071, and have been duly admitted to practice 

law in the State of California and the United States District Courts in California. 

I submit this declaration (“Declaration”) in support of Debtors’ Second Application to 

Amend Order Pursuant to 11 U.S.C. § 327(e) and Fed. R. Bankr. P. 2014(a) and 2016 for 

Authority to Retain and Employ Munger, Tolles & Olson LLP as Counsel for Certain Matters (the 

“Second Application to Amend”), which is being filed contemporaneously herewith. This 

Declaration also supplements my prior declarations that were filed on April 1, 2019 [Dkt. No. 

1168], April 10, 2019 [Dkt No. 1301], June 14, 2019 [Dkt No. 2522], and September 18, 2019 

[Dkt. No. 3929-1] in support of the Debtors’ initial application to retain MTO [Dkt. No. 1167] and 

the first Application to amend the Retention Order [Dkt. No. 3929].1

The Second Application to Amend seeks to amend the Retention Order to further clarify 

and/or expand the scope of the Specific Matters in two respects. 

First, the Debtors have retained MTO to represent them in responding to a petition for 

modification of CPUC Decision 18-01-022, which concerns the Diablo Canyon Nuclear Power 

Plant (“DCNPP”). The petition for modification, filed by the Alliance for Nuclear Responsibility, 

asks the CPUC to evaluate the cost-effectiveness of DCNPP and to consider ordering PG&E to 

shut down the plant before the end of its license period. While the Retention Order already 

authorizes MTO to represent the Debtors in connection with CPUC matters, the Second 

Application to Amend seeks to confirm that the DCNPP Matter falls within the scope of the 

Specific Matters.

I believe that MTO is well qualified for this engagement. In addition to the qualifications 

set out in my prior declarations, MTO previously represented a different utility in connection with 

certain legal issues arising from the utility’s operation of a nuclear power plant in California. 

 

1 Capitalized terms used but not defined herein shall have the meaning given those terms in the 

Application or the first Application to Amend.

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MTO can draw upon this experience and other expertise in representing the Debtors in connection 

with the DCNPP Matter. 

Second, the Debtors seek authority to retain MTO as counsel in connection with any civil, 

administrative, or criminal investigations or proceedings arising out of the recent Kincade wildfire 

in Sonoma County, California. While the Retention Order and First Amended Retention Order 

already authorize MTO to represent the Debtors in criminal or civil matters arising out of the 

Northern California wildfires, the Debtors seek to clarify that MTO’s authorized engagement 

includes not only matters relating to prior wildfires but also matters arising from the Kincade 

wildfire. 

MTO’s qualifications for this engagement are the same as its qualifications for its existing 

representation of the Debtors in connection with the Northern California wildfires, as described in 

more detail in my declaration in support of the Retention Application and the First Application to 

Amend.

MTO will continue to undertake reasonable efforts to coordinate with other counsel to the 

Debtors, including Cravath, to avoid any unnecessary duplication of work by counsel with respect 

to this additional work as it has done with respect to the Specific Matters to date. 

Based on reasonable inquiry, and subject to the disclosures in my earlier declarations, 

MTO does not hold an interest that is adverse to the Debtors or their estates with respect to the 

forgoing matters.

Executed within the United States. 

DATED: October 30, 2019 By: /s/ Henry Weissmann

Henry Weissmann

MUNGER, TOLLES & OLSON LLP

350 South Grand Avenue, 50th Floor

Los Angeles, California, 90071

Telephone: (213) 683-9150

Facsimile: (213) 683-5150

Case: 19-30088 Doc# 4527-3 Filed: 10/30/19 Entered: 10/30/19 17:53:12 Page 3

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