1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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 MARY GARDNER 

IN SUPPORT 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# 4311 Filed: 10/18/19 Entered: 10/18/19 16:03:40 Page 1 of

4
1

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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.

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

Bankr. Case No. 19-30088-DM

DECLARATION OF MARY 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, Mary Gardner, declare as follows: 

1. I am 67 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. I owned two rental properties on Ponderosa Way in Magalia, California. Both of my 

properties were destroyed by the Camp Fire that occurred on November 8, 2018. I 

Case: 19-30088 Doc# 4311 Filed: 10/18/19 Entered: 10/18/19 16:03:40 Page 2 of

4
2

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

owned these homes in Magalia for approximately 10 years before the fire.

3. I rented one of my homes to my son and his wife. They have three disabled children. 

The other home was rented to a good tenant. I was worried crazy about my son and 

daughter-in-law and their children. Their kids are disabled. One is in a wheelchair. I 

was helpless and I couldn’t get to them. It took them over five hours to get down the 

hill. We lost contact many times.

4. As a result of the fire, I lost my properties and income and my daughter, and her 

family, lost their home and belongings.

5. Shortly after the fire, PG&E had someone contact me about its “wood and debris removal 

program.” I told them that I did not authorize the company or any of its subcontractors to 

enter my property, and that I did not want any living trees removed from my property. I 

wanted to preserve what I could without having further fire danger.

6. To my astonishment and despite my specific instructions, PG&E and/or its subcontractor 

still entered my property, felled and removed my trees, and absolutely devastated my 

property. They took down a living cherry tree that was not near any power lines. Many of 

the other trees were healthy and not located near any utility lines or equipment. I cannot 

understand why PG&E did not work with me first, obtain my consent, and did this to my 

property after the damage already caused by the fire.

7. I do not know what PG&E and/or its subcontractors did with wood from the living trees 

after they were felled.

8. During the communications regarding my trees, neither PG&E nor its subcontractor

informed me of the pending bankruptcy case or that I was entitled to pursue 

compensation for my losses. I do not recall receiving any other notice in the mail about 

the bankruptcy or the claims process. If I did, I didn’t notice it and it could have easily 

gotten lost in junk mail or advertisements.

9. My losses were more than the payment I received from my insurance company. My 

son’s house had been totally remodeled and it was in good shape. It was a “total 

Case: 19-30088 Doc# 4311 Filed: 10/18/19 Entered: 10/18/19 16:03:40 Page 3 of

4
3 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

loss”. In my discussions with the insurers for my property, they did not tell me that I 

could try to recover from PG&E for the difference or that they were trying to fully 

recover against PG&E all payments made to me for losses I also sustained in the fire. 

10. The loss of the rental income did cause me difficulties. 

11. My daughter-in-law found attorneys on the internet. We also watch the news.

12. I submit this declaration because I believe people should be given better information 

about their rights than a form letter, if it was even sent to them. People need to know 

their rights before they have to decide whether they should make a claim.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 6th

day of October, 2019 in Chico, California.

 ____________________________ 

 Mary Gardner 

Case: 19-30088 Doc# 4311 Filed: 10/18/19 Entered: 10/18/19 16:03:40 Page 4 of

4