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Anne Costin (SBN 260126) 

COSTIN LAW INC.

315 Montgomery Street, 10th Floor 

San Francisco, CA 94104 

Tel: (415) 977-0400 

Email: anne@costinlawfirm.com 

Attorney for Creditor TODD HEARN 

 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re 

PG&E CORPORATION 

& 

PACIFIC GAS & ELECTRIC COMPANY, 

 Debtors 

TODD HEARN 

 Creditor and Moving Party 

v. 

PACIFIC GAS & ELECTRIC COMPANY 

 Debtor & Responding Party 

 Bankruptcy Case No. 19-30088 

Chapter 11 

DECLARATION OF 

TODD HEARN 

SUBMITTED WITH 

SUPPLEMENTAL BRIEF 

IN SUPPORT OF 

MOTION FOR RELIEF 

FROM AUTOMATIC STAY 

Dept: Courtroom 17, 16th Floor 

 450 Golden Gate Avenue 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 5239-2 Filed: 12/31/19 Entered: 12/31/19 12:35:35 Page 1

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DECLARATION OF TODD HEARN

I, Todd Hearn, do hereby declare and state as follows: 

1. I am an adult above the age of eighteen years of age. I have personal knowledge of the 

facts contained herein and if called as a witness I could and would testify competently thereto. 

2. I worked as a lineman for PG&E for over 20 years. 

3. On January 22, 2019 PG&E terminated my employment. 

4. In August of 2019 I received the attached letter (“Exhibit A”) informing me that I am 

ineligible for rehire with PG&E, and ineligible to work on PG&E projects or for any PG&E 

contractor or subcontractor working on PG&E projects. 

5. PG&E’s lawyer Stacy Campos stated in the Declaration she provided to the Court that I 

could just obtain employment with another utility or with a municipality. As a career lineman I am 

familiar with the utilities and municipalities in the Northern California area. There are not any other 

utilities within several hours of my home in Napa, and as such I can’t work as a lineman for a utility 

unless I commuted to Bakersfield, Nevada, or up north past Mt. Shasta. 

6. There are municipalities in Sacramento, Santa Clara, and Ukiah, but these are also far 

from (at least an hour away from) my home in Napa. Because of my family responsibilities (I have 

two minor children who live at home with me) it would be extremely difficult for me to commute 

several hours each day. Despite this I have applied for work with these municipalities, but have not 

received any job offer. 

7. When PG&E fired me in January, I stopped receiving income and lost my health 

benefits for me and for my family. I have exhausted all of my savings, and have been forced to 

withdraw money early from my 401K in order to cover my mortgage payments. I have sold my 

truck and a family car to try to keep up with my financial obligations, but am severely behind on the 

payments for my children’s school, and am becoming increasingly concerned about how we will 

make ends meet. 

Case: 19-30088 Doc# 5239-2 Filed: 12/31/19 Entered: 12/31/19 12:35:35 Page 2

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8. I understand that the legal process of pursuing a whistleblower retaliation Court case 

may take a long time, but every month counts for me and for my family, and so I therefore request 

that the Court allow me to move forward and start 

 I declare under penalty of perjury under the laws of the State of California that the foregoing 

is true and correct. This declaration was executed on December 30, 2019. 

 ___//s// Todd Hearn_____________________ 

 Todd Hearn 

Case: 19-30088 Doc# 5239-2 Filed: 12/31/19 Entered: 12/31/19 12:35:35 Page 3

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EXHIBIT A 

EXHIBIT A 

Case: 19-30088 Doc# 5239-2 Filed: 12/31/19 Entered: 12/31/19 12:35:35 Page 4

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-- Ineligible (no change) for Rehire Letter –

Pacific Gas and Electric Company 

Human Resources 

08/02/2019

Todd N. Hearn

Personnel Number: #75822

LAN ID: TNH3

Napa, CA 94559 

Phone:

Email:

Dear Mr. Todd N. Hearn,

This message is to confirm that your employment status with Pacific Gas and Electric Company 

(PG&E) has been recently reviewed. At this time, we have decided that your status will remain 

as “Ineligible” for rehire with PG&E including as a hiring hall employee, or as an agency worker, 

contractor or subcontractor working on PG&E projects. 

If you have any additional questions, please contact us directly via email at 

HREmploymentEligibilityReviewCommittee@pge.com. 

Sincerely, 

Employment Eligibility Review Committee

Case: 19-30088 Doc# 5239-2 Filed: 12/31/19 Entered: 12/31/19 12:35:35 Page 5

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