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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 .corn 

Email: cdurnas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.442.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

11 Counsel for Official 

Committee of Tort Claimants 

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UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

-andPACIFIC GAS AND ELECTRIC 

19 COMPANY, 

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Debtors. 

o Affects PG&E Corporation 

o 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 ROGER K. 

PITMAN, M.D. 

- 1 - Case: 19-30088 Doc# 4298 Filed: 10/18/19 Entered: 10/18/19 15:32:18 Page 1 of

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I, Roger K. Pitman, M.D., declare and state as follows: 

1. I am a psychiatrist with over 50 years of experience practicing medicine. I have 

spent my career diagnosing, treating, and researching Post Traumatic Stress Disorder ("PTSD") 

and other stress- and trauma-related mental disorders. I am the Director of the PTSD Research 

Laboratory at the Massachusetts General Hospital, which performs psychobiological research 

into the assessment, pathophysiology, prevention, and treatment of PTSD. I am also a Professor 

of Psychiatry at the Harvard Medical School, where I supervise medical students, psychiatric 

residents, psychology trainees, and junior faculty. I am certified by the American Board of 

Psychiatry and Neurology in the Specialty of Psychiatry and the Subspecialty of Forensic 

Psychiatry. My qualifications and background are explained further in my prior declaration 

submitted to the Court on August 7, 2019 ("August 7 Declaration"). 

2. As summarized in the August 7 Declaration, I have reviewed accounts of the fires 

and wildfires that destroyed areas of Northern California which are at issue in this matter, 

specifically, the fire referred to as the "Camp Fire" in November 2018 and the fires referred to as 

the "North Bay Fires" in 2017 ( collectively referred to as the "Fires"). I have reviewed 

coverage of the Fires from major newspapers and media outlets, I have reviewed narratives 

describing events that occurred during the Fires, and I have also watched videos of claimants 

escaping. I understand that many of these claimants physically encountered the Fires, had 

seconds to flee impending flames, were stuck in traffic with family members (some of whom 

were children or elderly) while they attempted to flee, and watched loved ones and others suffer 

or die from the Fires. 

3. Through these accounts and others, I understand that many claimants experienced 

and/or witnessed a significant level of traumatic exposure, in which they either suffered or feared 

suffering burns on their body and/or believed they or family members would die or suffer serious 

physical injury as a result of the Fires. Specific examples of these accounts are summarized in 

my August 7 Declaration. 

4. Based on my understanding of the conditions to which many of the claimants 

were exposed, it is my opinion, as explained in my August 7 Declaration, that a substantial 

Case: 19-30088 Doc# 4298 Filed: 10/18/19 Entered: 10/18/19 15:32:18 Page 2 of -2- 5
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portion of the claimants already have developed, or will develop, PTSD. Claimants who do not 

meet the full diagnostic criteria for PTSD, may have already developed, or will develop, (a) 

"partial PTSD," "subsyndromal PTSD," or "subthreshold PTSD"; and/or (b) a DSM-5 

Adjustment Disorder or other mental disorder, such as Major Depressive Disorder ("MOD"), or 

Anxiety Disorder. Persons in any of these latter groups often suffer from clinically significant 

distress and/or functional impairment and may also show some of the same physical 

manifestations as PTSD, which are described in more detail in my August 7 Declaration. 

5. Counsel for the Official Committee of Tort Claimants ("TCC") have now asked 

me to consider whether the occurrence of PTSD and/or other trauma- and stress-related mental 

disorders among claimants could interfere with their ability to submit their proof of claim 

("POC") by the current October 21, 2019 deadline. 

6. I have reviewed a copy of the POC. It is my professional opinion that PTSD 

and/or other trauma- and stress-related mental disorders, which cause clinically significant 

distress and/or functional impairment, would interfere with many claimants' ability to review, 

complete, and submit the POC by the October 21 deadline. Extending this deadline would 

provide additional time for claimants to become educated regarding the nature of the mental 

disorders they may be suffering from. Extending the deadline would also allow more time for 

claimants to seek professional diagnostic opinions and treatment. This would put them in a 

19 position to complete their POCs more accurately. 

20 7. PTSD is an underrecognized condition. Many victims of psychological trauma 

21 who would qualify for this diagnosis do not step forward for recognition, diagnosis, and 

22 treatment, for at least two reasons. 

23 8. First, a feature of PTSD is "Avoidance of ... reminders ... that arouse distressing 

24 memories, thoughts, or feelings about ... the traumatic event." 1,

271 Because it is painful to 

25 remember, many PTSD sufferers will go out of their way not to think about it. They may not 

26 discuss it with others. They may switch the channel when they start to see or read news about it. 

27 Because of this avoidance, many victims of the fires may not even have become aware of the 

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Case: 19-30088 Doc# 4298 Filed: 10/18/19 Entered: 10/18/19 15:32:18 Page 3 of

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opportunity to file a claim. Alternately, the prospect of having to do so, and set down in writing 

what happened to them, may be so anxiety-provoking that they can't get themselves do it alone. 

9. Second, some victims do not make the connection between the emotional 

problems they are experiencing and the traumatic event.2 Some do not understand that their 

problems constitute symptoms and signs of a mental disorder. Some believe that PTSD only 

happens in combat veterans, so it can't apply to them. Some fear the humiliation and 

stigmatization that may result from being labelled mentally ill. Some are simply in denial. 

10. It is also officially recognized that "there may be a delay of months, or even 

years, before the criteria for the [PTSD] diagnosis are met."1,P276 This has led to the inclusion of 

the subtype, "With delayed expression" in the DSM-5 PTSD criteria. 1,P 274 

11. In light of the above, it is not surprising that psychiatric epidemiologic surveys 

have found that the majority of persons with PTSD in the community go untreated and 

unidentified by any service or professional organization. Racial and ethnic minorities are less 

likely to be identified than whites. 3 Even among persons with PTSD in the past 12 months, only 

about half seek help.4 These data underscore the need for outreach efforts. 

12. The POC requires claimants to provide information about their experiences with 

the Fires, including remembering their evacuation, describing the harms to themselves and their 

family members, and itemizing the damages they are claiming for each of the types of harms 

sustained by themselves and family members. The POC also requests that claimants gather and 

provide documentation regarding their harms, damages, and claims. As explained above, the 

avoidance reminder feature of PTSD could make many claimants avoid recounting their 

experiences, as is necessary to complete the POC. Also, claimants who have not been diagnosed 

or whose expression has not yet been manifested, such as victims of the Camp fire less than a 

24 year ago, may not yet recognize their impairment. 

25 13. In light of the above factors that militate against PTSD patients coming forward 

26 for diagnosis and treatment, PTSD and other trauma- and stress-related mental disorders among 

27 many claimants may be expected to interfere with their ability to complete the POC by the 

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October 21 deadline. Time beyond the deadline is necessary for further diagnosing and treating 

these disorders and educating claimants. 

I declare under the pl.!nal ty of perjury under the laws of the United Stat es that the ·~ 

foregoing is true ,md correct and that this declaration wa:S executed qn the 11 day of October in 

Charlestovm Massachusetts, 

:,~ ~ P~+~ 

Rog~r K. Pitman, M.D. 

References 

l. American Psychiatric Association. Diagnoslic and Statistical ,\,/anual of Mental Disorders. 

Washington, D.C., 2013. 

2. Grinage BD. Diagnosis and management of posHraumatic stress disorder. Amerian Family 

Physician 2003;68:2401 ~2408. 

3. Roberts AL, Gilman SE, Breslau J, Breslau N, Koenen KC. Race/ethnic differences in 

exposure to traumatic events, development of post-traumatic stress disorder, and treatmentseeking for post-traumatic stress disorder in the United States. Psycholpgical Medicine 

2011;41:71-83. 

4. Koenen KC, Ratanatharathorn A, Ng L, ct al. Posttraumatic stress disorder in the World 

Mental Health Surveys. Psychological Medicine 2017;47:2260-2274. 

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