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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)

REDACTED DECLARATION OF JAMES 

DRINKHALL

Date: November 13, 2019

Time: 10:00 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Case: 19-30088 Doc# 4319 Filed: 10/18/19 Entered: 10/18/19 16:54:07 Page 1 of

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REDACTED DECLARATION OF JAMES DRINKHALL

I, James Drinkhall, pursuant to 28 U.S.C. § 1746, declare the following under penalty of 

perjury:

1. I am an investigator for Baker & Hostetler, LLP, in connection with the abovecaptioned Pacific Gas & Electric chapter 11 cases (the “Cases”), under the direction of Robert 

Julian (“Julian”), counsel for the Official Committee of Tort Claimants (the “TCC”) in the Cases.

2. I submit this Declaration in support of the TCC’s motion for entry of an order 

extending the bar date.

3. Except where specifically noted, all statements in this Declaration are based upon 

(a) my personal knowledge developed during the course of my engagement with the TCC, (b) my 

discussions with advisors of other parties in interest in these chapter 11 cases, and (c) my review 

of relevant documents and/or my professional opinion based upon my experience. If called to 

testify, I could and would testify to each of the facts set forth herein based on such personal 

knowledge, discussions, review of documents and/or professional opinion. 

4. On Saturday, October 12, 2019, Julian and I visited the FEMA temporary housing 

facility established for survivors of the Camp Fire, in Gridley, California. It is a large and grim 

facility with mobile units arranged in rows like boxcars, and no vegetation or gardens of any kind. 

Our purpose in the visit was to speak with fire victims who have found refuge in the camp, learn 

whether or not they had filed claims in the Cases, and if not, the reasons for that. We spoke 

randomly to five residents who were survivors of the Camp Fire, all five of whom had been 

renters with no insurance to help them find replacement housing or possessions. 

5. Two of the residents informed me in our discussions that they had hired lawyers 

who had filed claims on their behalf in the Cases. The other three residents informed me that they 

had not filed claims in the Cases. I believe that detail about these interviews would help to 

explain some of the reasons why many fire victims have not filed claims, by allowing them to 

describe the trauma that they have experienced, and how it affects their daily lives. None of the 

residents we spoke to stated that they had received information about the Cases or the claims 

process, and had simply decided not to file a claim. In each case, their explanations demonstrated 

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SAN FRANCISCO

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a lack of knowledge, misunderstandings, or, overwhelmingly, an inability to deal with issues 

related to the fires because of the ongoing and debilitating trauma.

6. [Jane Doe 1]: [Jane Doe 1] is a resident of the FEMA camp who has not filed a 

claim in the PG&E Cases. She would only speak with me by telephone, even though I was only 

two mobile home units away at the time, as she informed me that she “could not spend five 

minutes meeting with you” because “I have to take care of my cat.” She said she had not been 

contacted by anyone about the Cases, or the possibility of filing a proof of claim in the Cases, and 

had no knowledge of her right to do so until told during our phone conversation. Once informed 

of her right to file a claim, she stated that “I intend to; PGE owes us that,” but it is my impression 

from our conversation that she may be unable or incapable of doing so prior to the bar date. 

During our conversation, [Jane Doe 1] jumped back and forth among several subjects, all 

revolving around the anxiety she felt about escaping the Camp Fire as it swept into Paradise in 

November 2017. Compiled from portions of her conversation on various subjects and incidents, 

she related to me that “I have been diagnosed with PTSD . . . I lost everything I owned . . . I can’t 

look at a candle flame without thinking of fire. I almost burned to death. Those flames were five 

feet away from me and I was trapped in my apartment for an hour trying to get out. I was saved 

only because of neighbors (she later said it was her roommate) . . . my anxiety is mostly caused 

by the fire, not having to live in these FEMA units . . . during that fire, I saw people trapped in 

cars . . . I ran up and down the street trying to get help . . . there were people burned to death on 

Edgewood (Lane, the street where her apartment building was located).” One of [Jane Doe 1]’s 

neighbors described her to me as suffering from “severe PTSD.” The impression I had from my 

conversation with [Jane Doe 1] is that she will be unable to file a proof of claim in the Cases 

without assistance, and that she may be unable to locate that assistance on her own.

7. [Jane Doe 2]: Another non-filer that I spoke to was [Jane Doe 2], who is 89 years 

old. She was unaware that she could file a claim against PG&E in the Cases, and added that 

“even if I did know, I don’t know if I could because I have severe health issues and the trauma of 

that day blocks my mind and I don’t want to think anything about that day.”

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8. I learned from our conversation that [Jane Doe 2] requires constant use of an 

oxygen mask and oxygen tank. Though her raspy voice faltered slightly when she talked 

continuously for a few minutes at a time, she said she would detail the reasons that “myself, and I 

think a lot of people from Paradise who went through that day. . . cannot cope with daily life 

now.” She described for me some of her physical ailments, but seemed to consider such ailments 

a far lesser concern than “that day and how it triggers anxiety” and “exacerbates the pain in my 

stomach and, oh my god, the nightmares!” She informed me that her declining health now 

includes COPD, acute and chronic pancreatitis “and other ailments” she did not bother to name. 

“What affects me most is how I remember, or something triggers my memory. It is so surreal.” 

9. [Jane Doe 2] described the events of the Camp Fire, stating that “I was in the 

Feather River Hospital in Paradise when the fire hit. It was chaos, such chaos, they were trying to 

get everyone out at once. With my oxygen problems, I couldn’t do anything for myself, it was so 

hard to breathe in all that plus the smoke, I had to keep catching my breath. So helpless.” 

10. After taking drags from her oxygen, she continued: “Right outside, they put me in 

a car with a 19-year-old driver who was crying . . . there were walls of red flame on both sides of 

the street . . . wind so strong and hot, it was blowing hard, sideways with embers shooting 

everywhere, wood, branches and metal through the air, propane cans exploding, screaming, 

sparks falling on and around the cars . . we got to the K-Mart parking lot and hundreds of cars 

were there . . . then on the highway, three lanes of cars abreast, dead stopped, our car window was 

hot to touch, I happened to turn around and a car behind us just exploded, then some people 

jumped out of cars and started running. I thought it was over for me . . . but somehow firetrucks 

were hosing the road down. It took us four hours to get out.” [Jane Doe 2] seemed exhausted 

after that recitation, and it was obviously very difficult for her to discuss that day. “I relive that in 

nightmares,” [Jane Doe 2] said.

11. One of the reasons that [Jane Doe 2] gave for having not retained a lawyer to file a 

claim on her behalf was her stated belief that she would have to pay cash to obtain their services, 

and that she lives on an SSI income of $900/month. She lacked the money to replace an oxygen 

concentrator that had been destroyed in the fires, but had been able to obtain a donated 

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replacement from a local charity. She seemed surprised to learn that it was possible to retain an 

attorney on contingency. [Jane Doe 2] expressed to me that she wondered how she could take the 

time to file a claim in the Cases because now it was a struggle to deal with simple, daily life, but 

she stated that she would file a claim if she had help doing so. She said she had a quiet life in 

Paradise, a comfortable apartment. “Before all this (the fire), you’re in that pace of life. In a 

flash, it’s gone. I’m here in this place (FEMA housing), a sterile internment camp. They won’t 

even let us plant anything.” Now, she said, “I’m just about totally disabled. It’s hard to think 

about much . . . I don’t feel like this is a home. Where am I going now?” The impression I had 

from my conversation with [Jane Doe 2] is that she will be unable to file a proof of claim in the 

Cases without assistance, and that she may be unable to locate that assistance on her own.

12. A third former Paradise resident that I spoke with at the FEMA Camp is [Jane Doe 

3]. [Jane Doe 3] had not filed a claim, and explained that she had not done so because of the 

trauma from the fire and because the recent family tragedy of the death of her son has diverted 

her attention. As we spoke, she stated that she now intended to hire a lawyer and file a claim in 

the Case. However, whether or not she succeeds in doing so, it was my impression that she 

definitely would not have filed a claim had we not visited with her and explained her rights to her.

13. [Jane Doe 3] related that she was not in Paradise the morning of the fire. “I was 

outside Oroville then because my van broke down (about 15 miles south of Paradise) with my 

son. It was so dark with smoke. We could look toward Paradise and I could see fire moving east 

toward where Paradise was. It was going so fast, I just watched it, trying to understand. I never 

saw fire move so fast. Why?” Her residence was “completely destroyed,” she said, along with 

all contents. 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct.

Dated: Sonoma

October 17, 2019

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