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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 SETH GOLDMAN IN 

SUPPORT OF THE SECOND INTERIM 

FEE APPLICATION OF MUNGER, 

TOLLES & OLSON LLP FOR 

COMPENSATION FOR SERVICES AND 

REIMBURSEMENT OF EXPENSES AS 

ATTORNEYS TO THE DEBTORS AND 

DEBTORS IN POSSESSION FOR 

CERTAIN MATTERS FROM JUNE 1, 

2019 THROUGH SEPTEMBER 30, 2019 

Hearing to be set 

Case: 19-30088 Doc# 4758-10 Filed: 11/15/19 Entered: 11/15/19 10:11:43 Page 1

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Pursuant to 28 U.S.C. § 1746, I, Seth Goldman, 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. There are no 

disciplinary proceedings pending against me. 

I have read the Second Interim Fee Application of Munger, Tolles & Olson LLP, for 

Compensation for Services and Reimbursement of Expenses as Attorneys to the Debtors and 

Debtors in Possession for Certain Matters from June 1, 2019 through September 30, 2019 (the 

“Fee Application”). Capitalized terms used herein shall have the meaning ascribed to those terms 

in the Fee Application unless otherwise defined herein. 

To the best of my knowledge, information and belief, the statements contained in the Fee 

Application are true and correct. In connection therewith, I hereby certify that: 

a) to the best of my knowledge, information, and belief, formed after reasonable 

inquiry, the fees and disbursements sought in the Fee Application are permissible under the 

relevant rules, court orders, the Fee Guidelines, and the relevant Bankruptcy Code provisions, 

except as specifically set forth herein; 

b) except to the extent disclosed in the Fee Application, the fees and disbursements 

sought in the Fee Application are billed at rates customarily employed by MTO and generally 

accepted by MTO’s clients. In addition, none of the professionals seeking compensation varied 

their hourly rate based on the geographic location of the Debtors’ cases; 

c) in providing a reimbursable expense, MTO does not make a profit on that expense, 

whether the service is performed by MTO in-house or through a third party; 

d) in accordance with Rule 2016(a) of the Federal Rules of Bankruptcy Procedure and 

section 504 of the Bankruptcy Code, no agreement or understanding exists between MTO and any 

other person for the sharing of compensation to be received in connection with the above cases 

except as authorized pursuant to the Bankruptcy Code, Bankruptcy Rules, and Local Rules; 

e) all services for which compensation is sought were professional services on behalf 

of the Debtors and not on behalf of any other person; 

Case: 19-30088 Doc# 4758-10 Filed: 11/15/19 Entered: 11/15/19 10:11:43 Page 2

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f) MTO is seeking compensation with respect to the approximately 78.1 hours and 

$44,347.50 in fees spent reviewing or revising time records and preparing, reviewing, and revising 

invoices for privileged or confidential information during the Second Interim Fee Period; and 

g) MTO has included non-working travel time, whether by airplane or other means of 

transportation, in the Fee Application. The time originally recorded by each timekeeper has been 

reduced by 50% to effect a 50% discount for non-working travel time. The Specific Matters on 

which MTO is advising the Debtors require frequent travel from Los Angeles to northern 

California, and other locations, for board meetings, court hearings, meetings related to legislative 

and regulatory matters, and investigation of the 2017 and 2018 wildfires, including document and 

data collection, and witness interviews. 

The Debtors have actively worked with MTO to prepare budgets and forecasts of the work 

performed by MTO, have authorized the matter categories used by MTO, and have monitored and 

reviewed the compensation and reimbursement sought by MTO. 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true 

and correct. 

DATED: November 15, 2019 By: /s/ Seth Goldman 

 Seth Goldman (State Bar No. 223428) 

MUNGER, TOLLES & OLSON LLP 

350 South Grand Avenue, 50th Floor 

Los Angeles, California, 90071 

Telephone: (213) 683-9100 

Facsimile: (213) 687-3702 

Case: 19-30088 Doc# 4758-10 Filed: 11/15/19 Entered: 11/15/19 10:11:43 Page 3

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