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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 for 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

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

□ 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)

DECLARATION OF LAUREN T. 

ATTARD IN SUPPORT OF RESPONSE 

OF OFFICIAL COMMITTEE OF TORT 

CLAIMANTS TO DEBTORS’ 

RESTATED RESTRUCTURING 

SUPPORT AND SETTLEMENT 

AGREEMENT WITH THE 

CONSENTING SUBROGATION 

CLAIMHOLDERS [DKT NO. 4554-1]

Case: 19-30088 Doc# 4630 Filed: 11/08/19 Entered: 11/08/19 15:41:24 Page 1 of

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BAKER 

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ATTORNEYS AT LAW

SAN FRANCISCO

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LAUREN T. ATTARD, under penalty of perjury, declares:

1. I am an associate at Baker & Hostetler LLP, counsel to the Official Committee of 

Tort Claimants (the “TCC”) of PG&E Corporation and Pacific Gas and Electric Company (the 

“Debtors”) in these chapter 11 cases.

2. I submit this Declaration in support of the TCC’s response to the Debtors’ restated 

Restructuring Support and Settlement Agreement with the Consenting Subrogation Claim Holders.

3. Attached hereto as EXHIBIT A is a true and correct copy of a report issued by the 

California Department of Insurance, “North Bay Insured Losses from the October 2017 Wildfires,” 

dated May 18, 2018, which this firm obtained from the California Department of Insurance website, 

www.insurance.ca.gov, but no longer appears to be available on the website. This report states that 

the direct incurred losses for the 2017 North Bay Wildfires is $9,731,079,051. 

4. Attached hereto as EXHIBIT B is a true and correct copy of the report issued by 

the California Department of Insurance, “North Bay Insured Losses from the October 2018 

Wildfires,” dated April 30, 2019, available at http://www.insurance.ca.gov/0400-news/0100-

pressreleases/2019/upload/nr041-19InsuredLosses2018Wildfires050819.pdf. The report states 

that the Direct Incurred Losses for the 2018 Camp Fire (Butte) is $8,473,363,059. This figure 

combined with the 2017 North Bay Wildfires above yields approximately $18.2 billion.

5. Attached hereto as EXHIBIT C is the Motion of the Ad Hoc Group of Subrogation 

Claim Holders to Terminate the Debtors’ Exclusive Periods Pursuant to Section 1121(d)(1) of the 

Bankruptcy Code, dated July 23, 2019 (Dkt. No. 3147). 

6. Attached hereto as EXHIBIT D is the Debtors’ Designation of Claims Filed by the 

United States of America, the State of California and Adventist Health System as Unliquidated and 

Subject to Estimation Under Section 502(c) of the Bankruptcy Code, dated November 1, 2019 (Dkt. 

No. 4553). The claims listed in this designation add up to approximately $8.6 billion.

7. Attached hereto as EXHIBIT E is a true and correct copy of a portion of the 

transcript from the Estimation Status Conference on October 28, 2019 in the District Court.

8. Attached hereto as EXHIBIT F is a true and correct copy of a portion of PG&E’s 

Form 10-Q for the period ended September 30, 2019. 

Case: 19-30088 Doc# 4630 Filed: 11/08/19 Entered: 11/08/19 15:41:24 Page 2 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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9. Attached hereto as EXHIBIT G is a true and correct copy of a portion PG&E’s 

Form 8-K , dated June 18, 2019.

Pursuant to 28 U.S.C. §1746, I declare under penalty of perjury under the laws of the United States 

of America that the foregoing is true and correct to the best of my knowledge and belief. 

Dated: Los Angeles, CA

November 8, 2019 /s/ Lauren T. Attard

Lauren T. Attard

Case: 19-30088 Doc# 4630 Filed: 11/08/19 Entered: 11/08/19 15:41:24 Page 3 of

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