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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: (415) 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) 

CERTIFICATION OF TOBIAS S. KELLER IN 

SUPPORT OF SECOND INTERIM FEE 

APPLICATION OF KELLER & BENVENUTTI 

LLP FOR ALLOWANCE AND PAYMENT OF 

COMPENSATION AND REIMBURSEMENT OF 

EXPENSES (JUNE 1, 2019 THROUGH 

SEPTEMBER 30, 2019) 

Date: TBD 

Time: TBD 

Place: United States Bankruptcy Court 

Courtroom 17, 16th Floor 

San Francisco, CA 94102 

Judge: Hon. Dennis Montali

Objection Deadline: December 4, 2019 

 4:00 p.m. (Pacific Time) 

Case: 19-30088 Doc# 4715 Filed: 11/14/19 Entered: 11/14/19 08:32:29 Page 1 of

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I, Tobias S. Keller, hereby certify as follows: 

1. I am attorney licensed to practice law in the State of California. I am a partner in the 

law firm of Keller & Benvenutti LLP, co-counsel for the Debtors 1, and am authorized to make this 

Declaration in that capacity. Except as otherwise indicated, all statements in this Declaration are based 

on my personal knowledge, and, if called upon to do so, I could and would testify competently thereto. 

2. I make this Declaration in support of the Second Interim Fee Application of Keller & 

Benvenutti LLP for Allowance and Payment of Compensation and Reimbursement of Expenses (June 1, 

2019 Through September 30, 2019) (the “Interim Application”). I am an attorney designated by the 

Firm to sign the Interim Application on its behalf. 

3. Pursuant to the Northern District Guidelines, I certify that: 

a. I have read the Interim Application. 

b. To the best of my knowledge, information and belief formed after reasonable 

inquiry, the compensation and expense reimbursement sought in the Interim 

Application are in conformity with the Northern District Guidelines except as 

otherwise indicated in the Interim Application. 

c. The compensation requested in the Interim Application has been billed at rates 

and in accordance with practices no less favorable than those currently 

employed by the Firm and generally accepted by the Firm’s clients. 

4. There is no agreement or understanding between Keller & Benvenutti and any other 

person other than the partners of the Firm for the sharing of compensation to be received for services 

rendered in these cases. 

5. As required by the Northern District Guidelines, the Firm has sent billing statements to 

the Debtors on a monthly basis during these chapter 11 cases. I certify that the Debtors, counsel for 

the Creditors Committee and the TCC, and the U.S. Trustee are each being provided with a copy of the 

Interim Application in accordance with the Interim Compensation Order. 

6. Attached hereto as Exhibit A is a true and correct copy of a letter transmitting the 

1

 Capitalized terms not defined herein shall have the meaning ascribed to them in the Interim Application. 

Case: 19-30088 Doc# 4715 Filed: 11/14/19 Entered: 11/14/19 08:32:29 Page 2 of

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Interim Application to the Debtors and advising them of their rights to review and object to the 

compensation and expense reimbursement sought therein. To the best of my knowledge, information, 

and belief, this letter was transmitted to the Debtors by electronic mail on November 14, 2019. 

7. The Firm responds to the questions identified in the UST Guidelines as follows: 

 Question 1: Did Keller & Benvenutti agree to any variations from, or alternatives to, 

Keller & Benvenutti’s standard or customary billing rates, fees or terms for services pertaining to this 

engagement that were provided during the Interim Fee Period? If so, please explain. Answer: No. 

 Question 2: If the fees sought in the Interim Application as compared to the fees 

budgeted for the time period covered by the Interim Application are higher by 10% or more, did Keller 

& Benvenutti discuss the reasons for the variation with the client? Answer: The fees sought in the 

Interim Application do not exceed by 10% or more the aggregate fees budgeted for Keller & 

Benvenutti in the debtor in possession financing budget for the Interim Fee Period. 

 Question 3: Have any of the professionals included in the Interim Application varied 

their hourly rate based on geographic location of the Chapter 11 Cases? Answer: No. 

 Question 4: Does the Interim Application include time or fees related to reviewing or 

revising time records or preparing, reviewing or revising invoices? If so, please quantify by hours and 

fees. Answer: The Interim Application includes fees for reviewing and revising time records and 

preparing and reviewing invoices in connection with the preparation of the Firm’s monthly fee 

statements. The Firm used a billing code for such tasks that also includes matters relating to Keller & 

Benvenutti’s retention and the preparation of the monthly fee statements; the total hours expended 

during the Interim Fee Period was 80.1 hours, corresponding to $37,995.00 in fees. The time spent 

only on preparing invoices is approximately 12.6 hours, corresponding to $5,240.00 in fees. The Firm 

does not typically revise time records and invoices after they are prepared, and I expect that any time 

spend doing so would be de minimis. 

 Question 5: Does the Interim Application include time or fees for reviewing time 

records to redact any privileged or other confidential information? If so, please quantify hours and 

fees. Answer: No. 

Case: 19-30088 Doc# 4715 Filed: 11/14/19 Entered: 11/14/19 08:32:29 Page 3 of

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 Question 6: Does the Interim Application include any rate increases since Keller & 

Benvenutti’s retention in this case? If so, did the client review and approve those rate increases in 

advance? Did the client agree when retaining the law firm to accept all future rate increases? Answer: 

The Interim Application does not include any rate increases since the Firm’s retention. Keller & 

Benvenutti has advised the Debtors that the Firm may increase its hourly rates each year. 

I declare under penalty of perjury under the laws of the State of California that the foregoing is 

true and correct. Executed this 14th day of November, 2019, in San Francisco, California. 

/s/ Tobias S. Keller

Tobias S. Keller 

Case: 19-30088 Doc# 4715 Filed: 11/14/19 Entered: 11/14/19 08:32:29 Page 4 of

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