Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

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WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice)

(stephen.karotkin@weil.com)

Ray C. Schrock, P.C. (pro hac vice)

(ray.schrock@weil.com)

Jessica Liou (pro hac vice)

(jessica.liou@weil.com) 

Theodore Tsekerides (pro hac vice)

(theodore.tsekerides@weil.com)

Matthew Goren (pro hac vice)

(matthew.goren@weil.com)

767 Fifth Avenue

New York, NY 10153-0119

Tel: 212 310 8000

Fax: 212 310 8007

KELLER & BENVENUTTI LLP

Tobias S. Keller (#151445)

(tkeller@kellerbenvenutti.com)

Peter J. Benvenutti (#60566)

(pbenvenutti@kellerbenvenutti.com)

Jane Kim (#298192)

(jkim@kellerbenvenutti.com)

650 California Street, Suite 1900

San Francisco, CA 94108

Tel: 415 496 6723

Fax: 650 636 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,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

THIRD SUPPLEMENTAL DECLARATION 

OF TOBIAS S. KELLER PURSUANT TO 

11 U.S.C. § 327(a) AND FED. R. BANKR. 

P. 2014(a) AND 2016 ON BEHALF OF

KELLER & BENVENUTTI LLP

Debtors.

 ̈ Affects PG&E Corporation 

 ̈ Affects Pacific Gas and Electric Company 

þ Affects both Debtors

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

Case: 19-30088 Doc# 4881 Filed: 11/27/19 Entered: 11/27/19 08:44:22 Page 1 of

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I, Tobias S. Keller, hereby declare pursuant 28 U.S.C. § 1746:

1. I am a partner of the firm of Keller & Benvenutti LLP (the “Firm”), a law firm with 

offices at 650 California Street, Suite 1900, San Francisco, California 94108.

2. I submit this Declaration as a supplement to my declaration dated March 13, 2019 

[Docket No. 870] (the “Original Declaration”) in support of the Application of Debtors Pursuant to 

11 U.S.C. §327(a) and Fed. R. Bankr. Proc. 2014(a) and 2016 for Authority to Retain and Employ 

Keller & Benvenutti LLP as Co-Counsel for the Debtors Nunc Pro Tunc to the Petition Date.

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3. On May 16, 2019, the Firm filed its first supplement to the Original Declaration 

[Docket No. 2042] in which it disclosed, among other things, a potential dispute as between the Fee 

Examiner’s proposed counsel and one of the Firm’s attorneys. On June 21, 2019, the Firm filed its 

second supplement to the Original Declaration [Docket No. 2715] further elaborating that potential 

dispute.

4. As anticipated in the Original Declaration, this declaration is submitted to supplement 

information disclosed in the Original Declaration; as additional information regarding parties in 

interest becomes available, further supplemental declarations will be submitted to the Court reflecting 

such amended, supplemented or otherwise modified information.

5. Since the filing of the Original Declaration, additional developments in the Chapter 11 

Cases require the supplemental disclosures set forth in the following paragraphs.

6. Disclosure Regarding Claims Representative for Unfiled Fire Claimants

a. On November 12, 2019, Michael G. Kasolas was appointed as the Claims 

Representative for Unfiled Fire Claimants by the Order Extending Bar Date for Fire Claimants and 

Appointing Claims Representative [Docket No. 4672].

b. One attorney of the Firm, Thomas Rupp, worked on representations of Mr. 

Kasolas in several engagements at his prior firm, usually in Mr. Kasolas’s capacity as a bankruptcy 

1 Capitalized terms used but not otherwise herein defined have the meanings ascribed to such terms in 

the Original Declaration.

Case: 19-30088 Doc# 4881 Filed: 11/27/19 Entered: 11/27/19 08:44:22 Page 2 of

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trustee or state court receiver. Mr. Rupp did not continue to represent Mr. Kasolas after leaving his 

prior firm.

7. Disclosure Regarding Previous Client

a. At his prior firm, Mr. Rupp also worked on a representation of a client2 with an 

indirect interest in real property that was destroyed in the October 2017 Sonoma County fires. Mr. 

Rupp did not represent this former client in asserting any claims against the Debtors, and he did not 

continue to represent this client after leaving his prior firm.

8. Disclosure Regarding Fee Examiner

a. Bruce A. Markell, the Fee Examiner in these Chapter 11 Cases, informed the 

Court on October 28, 2019 [Docket No. 4709] that he is a friend and former partner of the father of an 

attorney of the Firm, Dara Silveira.

I declare under penalty of perjury that, to the best of my knowledge and after reasonable 

inquiry, the foregoing is true and correct and that this declaration was executed at San Francisco, 

California, on November 27, 2019.

/s/ Tobias S. Keller

Tobias S. Keller

2 The name of the client was not disclosed in the Declaration of Scott H. Mr. McNutt in Support of 

Application for Order Authorizing Employment of Scott H. McNutt as Counsel to Fee Examiner

[Docket No. 2559] for attorney-client confidentiality reasons.

Case: 19-30088 Doc# 4881 Filed: 11/27/19 Entered: 11/27/19 08:44:22 Page 3 of

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