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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 RYAN MOONEY 

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# 4313 Filed: 10/18/19 Entered: 10/18/19 16:09:38 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 

Attorneys for Declarant

UNITED STATES BANKRUPTCY 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 RYAN MOONEY 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, Ryan Mooney, declare as follows: 

1. I am over 18 years of age. 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. My wife and I owned our home on Drendel Circle in Paradise, California. We

purchased and moved into the home three months before the Camp Fire destroyed

Case: 19-30088 Doc# 4313 Filed: 10/18/19 Entered: 10/18/19 16:09:38 Page 2 of

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our neighborhood and our entire city. Our aunt and uncle lived a few blocks away, 

and they also lost their home.

3. On the morning of November 8th, we awoke to the smell of smoke. We saw a wall of

flames coming over the canyon. My wife and I evacuated immediately and barely

escaped. We rushed to my parents’ house across town to help them evacuate, as well.

All of us are still grappling with the trauma to this day. We are constantly planning

fire escape routes and putting together emergency kits. When there is smoke outside,

we get nervous. It is difficult for us to talk about the fire.

4. After the fire, my wife and I moved from room to room in a hotel for six weeks before

finding an apartment to rent in Chico, California for six months. We now live in a

house in Chico away from our property in Paradise.

5. My wife Beth was a high school teacher at a local charter school in Paradise before

the fire. The school burned down, temporarily reopened in Chico, then permanently

closed due to lack of enrollment. Beth lost her job.

6. Our home and all our belongings were totally destroyed in the fire. Our 1.3 acres of

land are charred along with a dozen dead, mature trees that cannot be replaced. The

once scenic view from our property now looks out across the scorched canyon and

hilltops.

7. We haven’t rebuilt, but we would like to do so. We don’t have the money, and we

don’t know what to do because the community is gone, the areas around are destitute,

and the property values have dropped. I would like for my community to be rebuilt

but that hasn’t even started.

8. Our house was insured and I’ve had at least 20 phone calls with our agents. They

never disclosed that my insurer was seeking reimbursement from PG&E in the

bankruptcy for payments it made to us or that we had the right to pursue our own

claim against PG&E for our losses and emotional distress. Our insurance claim is

still open. I recently learned that the insurance companies in this bankruptcy

Case: 19-30088 Doc# 4313 Filed: 10/18/19 Entered: 10/18/19 16:09:38 Page 3 of

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settled for around $10 billion and that was insulting and frustrating to me because 

my insurer is taking so long to settle our insurance claim. 

9. I also did not know we could recover money from PG&E for our losses. I do not

recall receiving any notice through the mail or a phone call from PG&E regarding

our rights in the bankruptcy. I became aware that there is money available in this

case through Facebook. I saw attorney commercials on television, but they didn’t

mean anything to me. Had I not luckily learned about this through Facebook, I never

would have filed a claim.

10. I now have an attorney. I now intend to pursue a claim to cover all our damages.

11. I submit this declaration because I believe there are countless people who like me

don’t know that they should be filing claims in this bankruptcy or what they will lose

if they don’t. I feel horrible for these people, and I ask the court to do something to

let them participate too.

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

6th day of October, 2019 in Chico, California.

 ____________________________ 

Ryan Mooney 

Case: 19-30088 Doc# 4313 Filed: 10/18/19 Entered: 10/18/19 16:09:38 Page 4 of

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