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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

Sander L. Esserman (Admitted Pro Hac Vice)

Cliff I. Taylor (Admitted Pro Hac Vice)

STUTZMAN, BROMBERG, ESSERMAN & PLIFKA, P.C. 

2323 Bryan Street, Suite 2200 

Dallas, TX 75201-2689 

Telephone: 214-969-4900 

Email: esserman@sbep-law.com

Scott Summy 

John Fiske (CSBN 249256) 

BARON & BUDD, P.C. 

3102 Oak Lawn Avenue #1100 

Dallas, TX 75219 

Telephone: 214-521-3605 

Email: ssummy@baronbudd.com 

Christopher H. Hart (CSBN 184117) 

Kimberly S. Fineman (CSBN 184433) 

NUTI HART LLP 

411 30TH Street, Suite 408 

Oakland, CA 94609-3311 

Telephone: 510-506-7152 

Email: kfineman@nutihart.com 

Attorneys for the Association of California Water Agencies 

Joint Powers Insurance Authority 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

In re 

PG&E CORPORATION, 

and 

PACIFIC 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. 

 Case No. 19-30088-DM 

Chapter 11 

Lead Case, Jointly Administered 

DECLARATION OF JENNIFER 

NOGOSEK IN SUPPORT OF MOTION 

PURSUANT TO FED. R. BANKR. P. 

9006(b)(1) TO ENLARGE THE TIME 

FOR ACWA/JPIA TO FILE PROOF OF 

CLAIM 

Date: February 26, 2020 

Time: 10:00 a.m. 

Place: 450 Golden Gate Avenue, Ctrm 17 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

Objection Deadline: February 19, 2020 

 4:00 p.m. (Pacific Time)

Case: 19-30088 Doc# 5216 Filed: 12/27/19 Entered: 12/27/19 14:40:26 Page 1 of

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STUTZMAN BROMBERG ESSERMAN

& PLIF

KA, P.C. 

2323 BRYAN STREET, SUITE 2200 

DALLAS, TX 75201-2689 

TELEPHONE: 214-969-4900 

2 

I, Jennifer Nogosek, hereby declare as follows: 

1. I am over eighteen years of age, of sound mind, and fully-competent to make 

this declaration. All statements in this declaration are based on my own personal knowledge 

and observation and from my review of the court and business records in this case, or upon 

information and belief as indicated. If called to testify on this matter, I can and would 

competently testify to the matters set forth in this Declaration. 

2. Since September 2015, I have been employed by the Association of California 

Water Agencies Joint Powers Insurance Authority (“ACWA/JPIA”) as a Liability and 

Property Claims Manager and working out of ACWA/JPIA’s offices in Roseville, California 

near Sacramento. 

3. ACWA/JPIA is a risk-sharing pool owned and governed by its member agencies 

that formed in 1979 to provide risk-sharing pools. ACWA/JPIA maintains a property program 

that is designed specifically for public water agencies. Like its members, ACWA/JPIA is a 

special district subject to the California Government Code. 

4. ACWA/JIPA provides pooled, reinsurance, and excess coverage protection to 

members against liability for bodily injury, property damage, errors and omissions, 

employment practices, fiduciary responsibilities products, and pollution. Infrastructure losses 

are among the most frequent and costly casualty-related losses to ACWA/JPIA’s member 

agencies, each of which is a California water utility. 

5. One of ACWA/JPIA’s members is the Paradise Irrigation District—water utility 

to the Town of Paradise devastated by a deadly and extremely destructive wildfire, the Camp 

Fire, in November 2018. As a result of the Camp Fire, the Paradise Irrigation District 

sustained sizeable losses, mostly from loss of and damage to infrastructure. 

6. As a risk-sharing cooperative, ACWA/JPIA effectively insured fire-related 

claims of its member, the Paradise Irrigation District, arising from the Camp Fire to the extent 

of ACWA/JPIA’s $350,000 retention. Various excess carriers are responsible for the loss to the 

extent it exceeds $350,000. 

Case: 19-30088 Doc# 5216 Filed: 12/27/19 Entered: 12/27/19 14:40:26 Page 2 of

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