ML030230649

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Declaration of Clara Yang Strand; in Support of Fifth Interim Application of FTI Consulting Inc. for Allowance & Payment of Compensation & Reimbursement of Expenses (August 1, 2002 Through November 30, 2002)
ML030230649
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 01/13/2003
From: Strand C
Bank of America, NA, FTI Consulting
To:
Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
SF 01-30923 DM
Download: ML030230649 (5)


Text

Thomas E. Lumsden FTI Consulting Inc.

199 Fremont Street San Francisco, CA 94105 Telephone:

(415) 498-5000 Facsimile:

(415) 498-6699 Accountants and Financial Advisors for Official Committee of Unsecured Creditors 1

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION In re PACIFIC GAS AND ELECTRIC COMPANY, A California corporation, "Debtor.

Case No. SF 01-30923 DM Chapter 11 DECLARATION OF CLARA YANG STRAND; IN SUPPORT OF THE FIFTH INTERIM APPLICATION OF FTI CONSULTING INC. FOR ALLOWANCE AND PAYMENT OF COMPENSATION AND REIMBURSEMENT OF EXPENSES (AUGUST 1, 2002 THROUGH NOVEMBER 30, 2002)

Hearing:

Date: February 28, 2003 Time: 11:00 PM Place: 235 Pine Street, 2 2nd Floor San Francisco, CA JAN 1j4 2003 UNTTED SrAT* ARp~

JA 1,4~teve ýoUt

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I DECLARATION OF CLARA YANG STRAND 2

I, Clara Yang Strand, declare:

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1.

am employed by Bank of America, N.A., one of the members of the Official Committee of 4

Unsecured Creditors ("Committee") in the Pacific Gas and Electric Company ("PG&E") chapter 11 5

bankruptcy case. I am one of the Co-Chairs of the Committee. Except as otherwise stated, I have 6

personal knowledge of the facts set forth below, and if called upon, I could and would testify 7

competently with regard thereto. I make this declaration in support of the Fifth Interim Application 8

of FTI Consulting Inc. ("FTI") for Allowance and Payment of Compensation and Reimbursement 9

of Expenses (August 1, 2002 Through November 30, 2002) (the "Application").

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2.

I have reviewed the Application and FTI's invoices for August 1, 2002 through November 12 30,2002.

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3.

I believe that the fees and costs requested by FTi for the August 1, 2002 through November 15 30, 2002 period are appropriate and reasonable. Based on my experience with FTI in this case, 16 their work has been done in a professional and efficient manner and has added significant value to 17 the estate for the benefit of creditors. FTI has worked effectively with the Debtor in the review and 18 analysis of the Debtor's financial projections to support its Plan of Reorganization, including 19 analysis of filed claims against the Debtor, and with the CPUC in the development of an alternative 20 plan structure. Accordingly, I believe that FTI's request for fees and reimbursement of expenses 21 should be approved.

22 I declare under penalty of perjury under the laws of the United States of America that the foregoing 23 is true and correct.

24 Executed this day of January 2003 at Los Angeles California.

25 26 Clara Yang Strand 27 28 I

I

PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO I am employed in the County of San Francisco, State of California. I am over the age of.

18 and not a party to the within action; my business address is 199 Fremont Street, 8th Floor, San Francisco, California.

On January 14, 2003, I served on the parties listed on the attached Service List, the foregoing document(s) described as:

DECLARATION OF CLARA YANG STRAND; IN SUPPORT OF THE FIFTH INTERIM APPLICATION OF FTI CONSULTING INC. FOR ALLOWANCE AND PAYMENT OF, COMPENSATION AND REIMBURSEMTN OF EXPENSES (AUGUST 1, 2002 THROUGH NOVEMBER 30,2002):

X by placing the _ original X a true copy thereof enclosed in sealed envelopes addressed as stated on the attached service list:

(BY UPS OVERNIGHT DELIVERY)

X Following ordinary business practices at the San Francisco office of FTI Consulting, Inc., I placed the sealed envelope(s) for collection and mailing with UPS on that same day. I am readily familiar with the firm's practice for collection and processing of correspondence for mailing.

Under that practice, such correspondence would be deposited with UPS on that same day, with postage thereon fully prepaid at San Francisco, California, in the ordinary course of business.

(FEDERAL)

I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.

Executed on January 14, 2003 San Francisco, California.

Catherine Dolan Type or Print Name Signature 01/14/03 12:39 PM

Proof of Service by UPS Next Day Air James L. Lopes, Esq.

Howard, Rice, Nemerovski, Canady, Falk & Rabkin Three Embarcadero Center, 7h Floor San Francisco, CA 94111-4065

[Counsel to Debtor]

Robert Jay Moore Paul S. Aronzon Milbank, Tweed, Hadley & McCloy LLP 601 South Figueroa Street Los Angeles, CA 90017

[Counsel for Official Committee of Unsecured Creditors]

Office of the U.S. Trustee Attn: Stephen Johnson 250 Montgomery Street, Suite 1000 San Francisco, CA 94104-3401

PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO I am employed in the County of San Francisco, State of California. I am over the age of 18 and not a party to the within action; my business address is 199 Fremont Street, 8t" Floor, San Francisco, California.

On January 14, 2003, I served on the parties listed on the attached Service List, the foregoing document(s) without exhibits described as:

DECLARATION OF CLARA YANG STRAND; IN SUPPORT OF THE FIFTH INTERIM APPLICATION OF FTI CONSULTING INC. FOR ALLOWANCE AND PAYMENT OF COMPENSATION AND REIMBURSEMTN OF EXPENSES (AUGUST 1, 2002 THROUGH NOVEMBER 30,2002):

X by placing the _ original X. a true copy thereof enclosed in sealed envelopes addreskea as" stated on the attached service list:

(BY MAIL)

X Following ordinary business practices at the San Francisco office of PricewaterhouseCoopers LLP, I placed the sealed envelope(s) for collection and mailing with the United States Postal Service on that same day. I am readily familiar with the firm's practice for collection and processing of correspondence for mailing. Under that practice, such correspondence would be deposited with the United States Postal Service on that same day, with postage thereon fully prepaid at San Francisco, California, in the ordinary course of business.

(FEDERAL)

I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.

Executed on January 14, 2003 San Francisco, Califorriia.

Catherine Dolan 9Sgau Type or Print NameSintr 01/14103 12 41 PM