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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 BROOKE 

GARDNER 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# 4310 Filed: 10/18/19 Entered: 10/18/19 16:00:36 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 BROOKE

GARDNER 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, Brooke Gardner, 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. Before the Camp Fire, I rented a home on Purdue Court in Magalia, California. I had

lived in Magalia my whole life until the fire, nearly 30 years.

Case: 19-30088 Doc# 4310 Filed: 10/18/19 Entered: 10/18/19 16:00:36 Page 2 of

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3. The morning of the fire, my husband and I were working from home. I saw smoke 

and billows outside. There were high winds. We started to pack essentials, and I

called my sister and told her to get out. My husband went to check on an elderly 

neighbor. He saw the smoke closing in on our home, and we fled with our two 

young children (3-year-old son and 10-month-old daughter).

4. We tried to go to south to Paradise. We didn’t realize the fire was there. The roads 

were blocked so we turned around to go north. We were low on gas and it took us an 

hour to refuel. Cars were running into each other, and the gas station was chaos. The 

fire was a 1⁄4 mile away. While we were waiting for gas, we saw the smoke coming 

towards us. We thought we would have to ditch the car and make a run for it with 

our children. 

5. We decided to take a small dirt road that I knew about. We slowly inched our way to 

Chico. From the time we left until the time we got to Chico, it took 6 hours for us to 

get to safety. We barely escaped. I thought I was going to lose my children and my 

life. My family and I are still dealing with the emotional trauma, not to mention the 

financial difficulties.

6. The home and all our possessions were completely destroyed, except for the few 

items we kept in storage. Immediately before the fire, we had begun the process of 

remodeling the home at our own expense. We had just canceled our renter’s 

insurance because we were preparing to purchase the home. We then decided not to 

for reasons unrelated to the fire. But when the fire struck, we were still renters, and 

we have no insurance coverage to pay for our losses.

7. Following the fire, we were unable to afford housing anywhere in California. We 

were forced to relocate over 500 miles away in late November and now live in 

Caldwell, Idaho. It was very hard to move away from all our good friends and family

and the community I lived in for my entire life. 

8. I was also forced to resign from my job. Currently, I’m out of work.

Case: 19-30088 Doc# 4310 Filed: 10/18/19 Entered: 10/18/19 16:00:36 Page 3 of

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9. I do not recall ever receiving notice from PG&E about the bankruptcy or the claims

process. I had no idea that I was even entitled to file a claim. I thought bankruptcy

meant the case was over.

10. A close friend of mine called to tell me that I was eligible to file a claim. If it wasn’t

for her, I would not have learned of my rights. She encouraged me to file. I learned

that renters are eligible, and there is money available to compensate my family and

the other fire survivors for our losses. I didn’t learn any of this from PG&E. I

certainly never received any communication from PG&E telling me that there is

money available to pay for my losses in the bankruptcy.

11. I am afraid there are many people in my position who do not know they can recover

their losses by filing a claim. I am also afraid that they do not know about the

deadline coming up.

12. I’m afraid many people in my position will not get the information in time.

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

6th day of October, 2019 in Caldwell, Idaho.

 ____________________________ 

Brooke Gardner 

Case: 19-30088 Doc# 4310 Filed: 10/18/19 Entered: 10/18/19 16:00:36 Page 4 of

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