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

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

Pursuant to 28 U.S.C. § 1746, I, James Mesterharm, state under penalty of perjury, that:

1. I am a Managing Director of AlixPartners, LLP (“AlixPartners”), which has a place of 

business at 909 Third Avenue, Floor 30, New York, New York 10022.

2. I am duly authorized to execute this fourth supplemental declaration on behalf of AP 

Services, LLC (“APS”), an affiliate of AlixPartners LLP.

3. Except as otherwise noted, I have personal knowledge of the matters set forth herein and, 

if called as a witness, would testify competently thereto.

4. I am filing this fourth supplemental declaration to supplement the disclosures that were 

included in my original declaration dated March 13, 2019 [ECF No. 867], my supplemental declaration 

dated April 11, 2019 [ECF No. 1342], my second supplemental declaration dated May 1, 2019 [ECF No. 

1773], and my third supplemental declaration dated November 13, 2019 [ECF No. 4718]. 

5. Unless otherwise noted, references to AP below collectively refer to AP Holdings, LLP, 

APS, and each of their respective subsidiaries. APS wishes to disclose the following:

In re: 

PG&E CORPORATION,

 - and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

FOURTH SUPPLEMENTAL DECLARATION OF 

JAMES MESTERHARM OF AP SERVICES, LLC 

Related Doc: Dkt. Nos. 867, 868, 1299, 1342, 1773, 

4718

Case: 19-30088 Doc# 5251 Filed: 01/02/20 Entered: 01/02/20 18:38:00 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

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

• Albertsons Companies, Inc., notice of appearance party in this bankruptcy matter, and affiliates 

(Albertsons) are adverse parties, affiliates, litigation parties and related parties to current and 

former AP clients in matters unrelated to the Debtors.

• Gibson Dunn & Crutcher (“Gibson Dunn”), an ad hoc committee of holders of trade claims in 

this bankruptcy matter, is opposing counsel, professional and vendor to current and former AP 

clients in matters unrelated to the Debtors. Gibson Dunn is a current and former AP client in 

matters unrelated to the Debtors. Gibson Dunn is a former employer of current AP employees. 

Gibson Dunn provides legal services to AP.

• Hyundai Corporation USA, a notice of appearance party in this bankruptcy matter, and affiliates 

(“Hyundai”) are adverse parties, adverse litigation parties, litigation parties, creditors, 

bondholders, insurance providers, director-affiliated companies, contract parties, vendors, 

customers, and related parties to current and former AP clients in matters unrelated to the 

Debtors. Hyundai is a former employer of a current AP employee.

• Riverstone, a subrogation claimant in this bankruptcy matter, is a contract party, creditor, 

shareholder, investor, lender, adverse litigation party and parent company to current and former 

AP clients in matters unrelated to the Debtors. Riverstone is a current AP client in matters 

unrelated to the Debtors.

• RSUI Group, a subrogation claimant in this bankruptcy matter, and affiliates, are bondholders, 

litigation parties, insurance providers, lenders, and adverse litigation parties to current and former 

AP clients in matters unrelated to the Debtors.

• Safeway Inc., a notice of appearance party in this bankruptcy matter, and affiliates are related 

parties, adverse litigation parties and parties to current and former AP clients in matters unrelated 

to the Debtors.

• Silver Rock Financial LP, a 2019 statement party in this bankruptcy matter, is a bondholder and 

related party to current and former AP clients in matters unrelated to the Debtors.

• Standard Fire Insurance Company, a subrogation claimant in this bankruptcy matter, is a limited 

partner to a current AP client in matters unrelated to the Debtors.

• Strategic Value Partners, a subrogation claimant in this bankruptcy matter, and affiliates (“SVP”) 

are litigation parties, bondholders, creditors, lenders, and noteholders to current and former AP 

clients in matters unrelated to the Debtors. SVP is a current and former AP client in matters 

unrelated to the Debtors.

APS does not believe that the fourth supplemental disclosures above impact its disinterestedness. 

I continue to reserve the right to supplement APS’ disclosures in the event that APS discovers any 

additional connections that require disclosure. If any new material relevant facts or relationships are 

Case: 19-30088 Doc# 5251 Filed: 01/02/20 Entered: 01/02/20 18:38:00 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

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

discovered or arise, APS will promptly file a supplemental declaration pursuant to Bankruptcy Rule 

2014(a).

I declare under penalty of perjury pursuant to 28 U.S.C. §1746 that the foregoing is true and 

correct.

Dated: January 2, 2020 AP Services, LLC

James Mesterharm

Authorized Representative

Case: 19-30088 Doc# 5251 Filed: 01/02/20 Entered: 01/02/20 18:38:00 Page 3 of

3