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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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) 

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) 

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) 

DECLARATION OF ELIZABETH COLLIER 

IN SUPPORT OF MOTION TO REDACT 

DOCUMENTS FILED IN SUPPORT OF 

SUPPLEMENTAL APPLICATION 

PURSUANT TO 11 U.S.C. §§ 327(a) AND 

328(a) AND FED. R. BANKR. P. 2014(a) AND 

2016 FOR AUTHORITY TO RETAIN AND 

EMPLOY PRICEWATERHOUSECOOPERS 

LLP AS MANAGEMENT, TAX, AND 

ADVISORY CONSULTANTS TO THE 

DEBTORS NUNC PRO TUNC TO PETITION 

DATE 

[No Hearing Requested] 

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: 19-30088 Doc# 4604 Filed: 11/07/19 Entered: 11/07/19 19:41:59 Page 1 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

I, Elizabeth Collier, pursuant to section 1746 of title 28 of the United States Code, hereby declare 

under penalty of perjury that the following is true and correct to the best of my knowledge, information, 

and belief: 

I am employed as Managing Counsel, Litigation in the legal department of Pacific Gas and 

Electric Company (the “Utility”), a wholly-owned subsidiary of PG&E Corporation (“PG&E Corp.” 

and together with Utility, the “Debtors”). I joined the Utility in 2001 and have held various positions 

of increasing responsibility working on litigation, regulatory, and commercial matters, since that time. 

I obtained my Juris Doctorate from University of California, Hastings College of the Law in 1990 and 

was admitted to the State Bar of California that same year. 

I am generally knowledgeable and familiar with the Debtors’ day-to-day operations, including 

the Debtors’ professional engagements with PricewaterhouseCoopers LLP (“PwC”). The facts set forth 

in this Declaration are based upon my personal knowledge, my review of relevant documents, and 

information provided to me by the Debtors’ other employees or the Debtors’ legal, restructuring, and 

financial advisors. If called upon to testify, I would testify to the facts set forth in this Declaration. 

This Declaration is submitted in support of the Motion to Redact Documents Filed in Support of 

Supplemental Application Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Fed. R. Bankr. P. 2014(a) 

and 2016 for Authority to Retain and Employ PricewaterhouseCoopers LLP as Management, Tax, and 

Advisory Consultants to the Debtors Nunc Pro Tunc to Petition Date (the “Redaction Motion”) filed 

concurrently herewith, which seeks authority to redact certain confidential information subject to 

attorney–client privilege and the attorney work product doctrine that is the subject of the Supplemental 

Application Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Fed. R. Bankr. P. 2014(a) and 2016 for 

Authority to Retain and Employ PricewaterhouseCoopers LLP as Management, Tax, and Advisory 

Consultants to the Debtors Nunc Pro Tunc to Petition Date (the “Supplemental Application”), filed 

concurrently herewith.1

PwC performed a number of engagements for the Debtors prior to the Petition Date and PwC has 

developed institutional knowledge about the Debtors’ businesses, operations, accounting systems, and 

1

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

in the Supplemental Application. 

Case: 19-30088 Doc# 4604 Filed: 11/07/19 Entered: 11/07/19 19:41:59 Page 2 of

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

other material information. PwC is party to a number of contracts with the Debtors; however the Debtors 

are only seeking to redact information from ten of such contracts. Redacted copies of the Supplemental 

MSA Contracts are annexed to the Bowman Declaration. I prepared the redactions to the Supplemental 

MSA Contracts. 

In addition to the relevant terms governing PwC’s work and other critical services that have been, 

and will continue to be, performed by PwC for the benefit of the Debtors (which are described in detail 

in the Supplemental Application), certain Supplemental MSA Contracts describe work to be performed 

at the direction of counsel and information subject to the attorney–client privilege and the attorney work 

product doctrine. The Debtors have narrowly tailored their request to redact by limiting the redactions 

to information subject to the attorney–client privilege and the attorney work product doctrine, rather than 

all commercially sensitive information. Therefore, the Debtors seek to file certain Supplemental MSA 

Contracts with the limited redactions described above. 

Case: 19-30088 Doc# 4604 Filed: 11/07/19 Entered: 11/07/19 19:41:59 Page 3 of

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Pursuant to 28 U.S.C. § 1746, I declare under the penalty of pe1jury, that the foregoing is true 

2 and correct. 

3 Dated: November b_

--, 2019 

4 

Respectfully submitted, 

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Case: 19-30088 Doc# 4604 Filed: 11/07/19 Entered: 11/07/19 19:41:59 Page 4 of

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