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Kevin J. Lamb, SBN 125710

E-Mail: klamb@lkfirm.com

Michael K. Slattery, SBN 107303

E-Mail: mslattery@lkfirm.com

Thomas G. Kelch, SBN 100709

E-Mail: tkelch@lkfirm.com

LAMB & KAWAKAMI LLP

333 South Grand Avenue, Suite 4200

Los Angeles, California 90071

Telephone: (213) 630-5500

Facsimile: (213) 630-5555

Attorneys for AD HOC CALIFORNIA

PUBLIC ENTITIES COMMITTEE

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors,

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

AMENDED VERIFIED 

STATEMENT OF THE AD HOC 

CALIFORNIA PUBLIC ENTITIES 

COMMITTEE PURSUANT TO 

BANKRUPTCY RULE 2019 ☐ Affects PG&E Corporation

☐ Affects Pacific Gas and Electric 

Company

☒ Affects Both

*All papers shall be filed in the Lead 

Case, 19-30088 (DM)

Case: 19-30088 Doc# 4570 Filed: 11/04/19 Entered: 11/04/19 16:24:48 Page 1 of

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Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”) the Ad Hoc California Public Entities Committee (the “Ad 

Hoc Committee”), composed of the California counties listed in Exhibit 1, and 

having claims as public entities against PG&E Corporation and Pacific Gas and 

Electric Company (the “Debtors”) more fully described in Exhibit 1, by and 

through its undersigned counsel, hereby submits this amended verified statement 

(“Amended Verified Statement”), and in support thereof, states as follows:

1. In January, 2019, the California County Counsel Association, which 

monitors developments in the law and new cases which affect the interests of 

California counties, formed the Ad Hoc Committee. On March 22, 2019, the Ad 

Hoc Committee engaged Lamb & Kawakami LLP (“L&K”) to represent it in 

connection with these chapter 11 cases. Individual members of the Ad Hoc 

Committee joined the committee and engaged L&K on various dates due, in part, 

to the fact that public entities require approval of boards or other governmental 

bodies to retain counsel. This Amended Verified Statement is filed because 

additional entities have become members of the Ad Hoc Committee.

2. As of the date of this Amended Verified Statement, L&K represents 

only the Ad Hoc Committee and certain individual municipal entities. L&K does 

not represent or purport to represent any other entities in connection with the 

Debtors’ chapter 11 cases and does not undertake to represent the interest of, and 

are not fiduciaries to any other entities other than those identified above. Each 

member of the Ad Hoc Committee is aware of and has consented to the L&K 

group representation. Members of the AD Hoc Committee do not represent or 

purport to represent any other entities in connection with the Debtors’ chapter 11 

cases, but are public entities that provide services to the public within their 

jurisdictions.

3. The members of the Ad Hoc Committee have claims of various types 

arising from their relationship with the Debtors as public entities. Pursuant to 

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Bankruptcy Rule 2019, a list of names, addresses and the disclosable economic 

interests of members in relation to the Debtors as of October 30, 2019, is attached 

as Exhibit 1. The Ad Hoc Committee members hold numerous and varied types of 

economic interests in relation to the Debtors including claims of the kinds more 

fully described in Exhibit 1.

4. The information set forth in Exhibit 1, which has been reviewed and 

approved by the Ad Hoc Committee, is intended only to comply with Bankruptcy 

Rule 2019 and is not intended for any other purpose. L&K does not make any 

representation regarding the validity, amount, allowance, or priority of such 

economic interests and reserves all rights with respect thereto. 

5. There is no written instrument which authorizes the Ad Hoc 

Committee to act. The Ad Hoc Committee has acted and will continue to act with 

the consent of its members.

6. Nothing contained in the Amended Verified Statement or Exhibit 1

should be construed as a limitation on, or waiver of, any rights of any member of 

the Ad Hoc Committee to assert, file and/or amend their claims in accordance with 

applicable law and any orders entered in these chapter 11 cases.

7. The Ad Hoc Committee does not, by filing this Amended Verified 

Statement nor any subsequent appearance, pleading, claim or suit, submit to the 

jurisdiction of the Bankruptcy Court or intend that this Amended Verified 

Statement constitute a waiver of any of its rights: (i) to have final orders in core 

and non-core matters entered only after de novo review by a District Judge; (ii) to 

have any final order entered by, or other exercise of the judicial power of the 

United States performed by, an Article III court; (iii) to trial by jury in any 

proceeding so triable in these cases, or any controversy or proceeding related to 

these cases; (iv) to have the reference withdrawn by the District Court in any 

matter subject to mandatory or discretionary withdrawal; (v) to any objection to the 

jurisdiction of the Bankruptcy Court; or (vi) to assert any other rights, claims, 

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actions, defenses, setoffs or recoupments to which the Ad Hoc Committee is or 

may be entitled, in law or in equity, all of which rights, claims, actions, defenses, 

setoffs and recoupments the Ad Hoc Committee expressly reserves.

8. L&K reserves the right to amend and/or supplement this Amended 

Verified Statement in accordance with the requirements of Bankruptcy Rule 2019.

DATED: November 4, 2019 Respectfully submitted,

LAMB & KAWAKAMI LLP

MICHAEL K. SLATTERY

THOMAS G. KELCH

By: /s/ Michael K. Slattery

Michael K. Slattery

Attorneys for the Ad Hoc California 

Public Entities Committee

Case: 19-30088 Doc# 4570 Filed: 11/04/19 Entered: 11/04/19 16:24:48 Page 4 of

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EXHIBIT 1

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Names and Addresses of Committee Members

Member Name Address Disclosable Economic 

Interest

County of San Luis Obispo 1055 Monterey Street 

Ste. D320 

San Luis Obispo, CA 93408 

General Claimsi

County of Sonoma 575 Administration Drive 

Room 105-A 

Santa Rosa, CA 95403

General Claims

Wildfire Claimsii

County of Marin 3501 Civic Center Drive 

Ste. 275

San Rafael, CA 94903

General Claims

County of Calaveras 891 Mountain Ranch Road

San Andreas, CA 95249

General Claims

County of Monterey 168 West Alisal Street, 3rd fl. 

Salinas, CA 93901

General Claims

County of San Benito Office of the County Counsel, 

481 4th St. Fl. 2 

Hollister, CA 95023-3840 

General Claims

County of San Joaquin 44 North San Joaquin Street

Sixth Floor, Suite 679

Stockton, CA 95202

General Claims

County of Tulare 2900 W. Burrel Avenue 

Visalia, CA 93291

General Claims

County of Fresno 2220 Tulare St, Fifth Floor 

Fresno, CA 93721

General Claims

County of Mariposa 5100 Bullion Street, 2nd fl. 

Mariposa, CA 95338

General Claims

County of Tuolumne 2 S. Green Street 

Sonora, CA 95370

General Claims

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Member Name Address Disclosable Economic 

Interest

County of Yolo 625 Court St., Ste. 201 

Woodland, CA 95695

General Claims

County of Alameda 1221 Oak Street, Suite 450 

Oakland, CA 94612

General Claims

County of Madera 200 West 4th St

Madera, CA 93637

General Claims

County of El Dorado 330 Fair Lane 

Placerville, CA 95667

General Claims

County of Stanislaus 1010 10th St., #6400

Modesto, CA 95354

General Claims

County of El Dorado 330 Fair Lane

Placerville, CA 95667

General Claims

County of Santa Cruz 701 Ocean Street, Room 505

Santa Cruz, CA 95060

General Claims

i

The economic interests of members of the Committee include several types of existing and potential claims against 

PG&E described below. These claims vary from member to member of the Committee. The types of claims the 

members generally hold or may hold include (these claims are referred to as “General Claims”):

a. Claims for real property taxes, franchise fees, and utility users’ taxes collected by PG&E;

b. Claims for damage to public property from PG&E’s operations;

c. Claims for failure to restore public property after excavation of public property to service PG&E’s 

underground facilities;

d. Claims for performance of obligations to move utility lines underground pursuant to Public Utilities 

Commission Rule 20 A;

e. Claims arising from breach of contract between PG&E and a particular member;

f. Claims for failure to perform obligations under state or federal law, including obligations to make monetary 

payments; 

g. Breach of obligations to provide electric power and natural gas to public facilities operated by the 

members;

h. Claims resulting from power outages, including outages resulting from de-energization decisions made by 

the Debtors;

i. Claims for reductions in the tax base of members resulting from wildfires caused by the Debtors;

j. Claims for indemnity for any obligations paid by members as a result of any failure of performance, default 

or other harm caused by PG&E.

In addition to General Claims, members hold or may hold claims of the following kinds (these claims are referred to 

as “Wildfire Claims”):

a. Damage to public services and infrastructure including public buildings, revenue generating public assets 

and services, roads, bridges, sidewalks, culverts, drains, storm and water systems (both damage to and 

contamination of such systems), traffic lights, stop signs, public landscaping, art, lost capacities in 

reservoirs, water storage and landfills;

b. Increased costs from workers’ compensation claims and overtime, and from increased use of and need for 

law enforcement, emergency response personnel, and other public safety services;

c. Other damages that have or may in the future result from wildfires caused by the debtors;

 

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d. Claims for indemnity for any payments made by members as a result of any damage caused by wild fires.

ii See definition in Endnote i above.

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