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 

44553.00001

Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice) 

MILBANK LLP 

55 Hudson Yards 

New York, New York 10001-2163 

Telephone: (212) 530-5000 

Facsimile: (212) 530-5219 

and 

Gregory A. Bray (SBN 115367) 

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor 

Los Angeles, CA 90067 

Telephone: (424) 386-4000 

Facsimile: (213) 629-5063 

Counsel for the Official Committee 

of Unsecured Creditors

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

 -andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered)

 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) 

DECLARATION OF GREGORY A. BRAY 

IN SUPPORT OF MOTION OF THE 

OFFICIAL COMMITTEE OF 

UNSECURED CREDITORS FOR AN 

ORDER AUTHORIZING THE FILING OF 

AN OBJECTION UNDER SEAL 

[No Hearing Requested] 

Case: 19-30088 Doc# 2833 Filed: 07/02/19 Entered: 07/02/19 15:36:26 Page 1 of

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 

2 

 I, Gregory A. Bray, 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: 

1. I am an attorney admitted to practice in the State of California and I am a partner 

in the Financial Restructuring Group of the firm Milbank LLP (“Milbank”), counsel to the Official 

Committee of Unsecured Creditors (the “Creditors’ Committee”) of the above-captioned debtors 

and debtors in possession (collectively, the “Debtors”). Milbank maintains an office at, among 

other places, 2029 Century Park East, 33rd Floor, Los Angeles, California, 90067-3019. There are 

no disciplinary proceedings pending against me. 

2. I am duly authorized to make this declaration on behalf of Milbank in support of 

the Motion of the Official Committee of Unsecured Creditors for an Order Authorizing the Filing 

of an Objection Under Seal, filed concurrently herewith (the “Motion to Redact”). The facts set 

forth in this declaration are based upon my personal knowledge, my review of relevant documents, 

or information provided to me by other advisors to the Creditors’ Committee, including other 

attorneys at Milbank. If called upon to testify, I would testify competently to the facts set forth in 

this Declaration. 

3. As stated, this declaration is submitted in support of the Motion to Redact, which 

seeks authority to file under seal portions of the Creditors’ Committee’s objection (the 

“Objection”) to the Debtors’ Motion Pursuant to 11 U.S.C. §§ 363 and 105(a) and Fed. R. Bankr. 

P. 6004 Authorizing Debtors to Purchase Directors and Officers Insurance (the “D&O Motion”) 

[Docket No. 2471], which objection is filed contemporaneously herewith. 

4. In particular, the Creditors’ Committee received materials from the Debtors as part 

of Creditors’ Committee’s diligence of the D&O Motion, which materials the Debtors designated 

as “confidential” or “highly confidential” pursuant to the Order Governing Discovery by and 

Case: 19-30088 Doc# 2833 Filed: 07/02/19 Entered: 07/02/19 15:36:26 Page 2 of

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 

3 

Among Debtors, Official Committee of Unsecured Creditors, and Official Committee of Tort 

Claimants entered by the Court on July 1, 2019 (“Protective Order”) [Docket No. 2807]. The 

Protective Order governs the production, review, disclosure, and handling of any information 

exchanged by and among the Official Committee of Tort Claimants (the “TCC”), the Creditors’ 

Committee, and the Debtors in these chapter 11 cases. 

5. The Creditors’ Committee notified the Debtors that the Objection would reference 

certain of the materials that the Debtors had designated as “confidential” and/or “highly 

confidential” under the Protective Order (the “Designated Materials”) and asked whether the 

Debtors would require that the Creditors’ Committee file the Designated Materials under seal. 

Counsel for the Debtors answered in the affirmative, thereby necessitating the filing of the Motion 

to Redact and this Declaration. 

 I declare under penalty of perjury that the foregoing is true and correct to the best of my 

knowledge and belief. 

Executed on July 2, 2019, Los Angeles, CA 

/s/ Gregory A. Bray 

Gregory A. Bray

Case: 19-30088 Doc# 2833 Filed: 07/02/19 Entered: 07/02/19 15:36:26 Page 3 of

3