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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 LYNDA 

BRADWAY 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# 4301 Filed: 10/18/19 Entered: 10/18/19 15:43:27 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 LYNDA BRADWAY

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, Lynda Bradway, 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. I used to reside on Washo Court in Magalia, California. On November 8, 2018, the

mobile home I rented was destroyed by the Camp Fire. I had lived in the home for

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four years. I did not have insurance. As a result of the fire, I lost my home, all my 

personal belongings, and my entire community. 

3. My sister was in the process of moving back in with me. She had just been hired for

a new job at Grocery Outlet in Paradise on Clark Road.

4. On the morning of the fire, my sister and I fled my home to a parking lot in Magalia.

We quickly became trapped and were escorted through the fire and down the hill by

the sheriffs and firefighters. My sister left her car behind and it was destroyed. If it

were not for these first responders directing us to safety, we would have died.

5. I was low on gas but kept driving. We decided to “go for it” since we had no choice.

As we drove down the hill, we were surrounded by flames on both sides of the car

and we nearly ran out of gas.

6. After the fire, I stayed at a shelter at a church in Oroville, California until I could find

housing. I was unable to locate housing anywhere in Northern California. My exhusband offered me temporary housing in San Diego. With no other options, I

relocated 600 miles away to San Diego and now live at his place. Since the fire, I can

only drive short distance, such as just down the street. My daughter will drive me if I

need to go far. It is very hard. I don’t have a job and my disability has run out. There

was not really any talk about PG&E or the fires in San Diego.

7. The Grocery Outlet in Paradise also burned down and my sister lost her job.

8. Since I was a renter, and not a homeowner, I was under the belief that I did not qualify to

bring a lawsuit or claim against PG&E for my losses. At the same time, I heard that

PG&E might file for bankruptcy, but I didn’t know they did. So, I believed that

money was not available to compensate fire victims anyway.

9. I did receive a notice, but I wasn’t sure what to do. I thought it might be scam. I do

not recall it coming with the normal PG&E envelope that PG&E customers get. The

questions were confusing; I didn’t understand what they meant. It is very difficult for

me to talk about the fire and for me to have to relive my experiences both during and

Case: 19-30088 Doc# 4301 Filed: 10/18/19 Entered: 10/18/19 15:43:27 Page 3 of

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after the fire. Even reading the questions caused me distress. 

10. A friend suggested that I reach out to a law firm and double-check whether I could

recover for my losses. After speaking with an attorney, I learned that PG&E had

money available to pay fire victims, that renters qualify in addition to homeowners,

and that I was eligible to recover for the loss of my property and other damages. I

would not have signed up as a claimant in this proceeding if my friend did not inform

me that I might have a claim, and if my lawyers did not help me understand my right

to participate.

11. I have two sisters who suffered losses in the Camp Fire, and I have since alerted

them to pursue their claims, as well. They didn’t know they could file claims until I

told them.

12. I feel there are many other people who are uninformed about their right to recover

damages in this bankruptcy case or even that there is a deadline.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 6th day 

of October, 2019 in San Diego, California.

 ____________________________ 

Lynda Bradway

Case: 19-30088 Doc# 4301 Filed: 10/18/19 Entered: 10/18/19 15:43:27 Page 4 of

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