ML022120109

Declaration of Martin Hunt in Support of Motion for Authority to Incur Information Technology Consulting Expenses

ML022120109
Person / Time
Site:	Diablo Canyon
Issue date:	07/23/2002
From:	Hunt M - No Known Affiliation, Howard, Rice, Nemerovski, Canady, Falk & Rabkin, Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
01-30923 DM, 94-0742640
Download: ML022120109 (3)

Text

1 JAMES L. LOPES (No. 63678)

JANET A. NEXON (No. 104747) 2 JULIE B. LANDAU (No. 162038)

HOWARD, RICE, NEMEROVSKI, CANADY, 3 FALK & RABKIN A Professional Corporation 4 Three Embarcadero Center, 7th Floor San Francisco, California 94111-4065 s-e:(4-'

5 Telephone: 415/434-1600 Facsimile: 415/217-5910 6

Attorneys for Debtor and Debtor in Possession 7 PACIFIC GAS AND ELECTRIC COMPANY 8

UNITED STATES BANKRUPTCY COURT 9

NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 Case No. 01-30923 DM In re 12 Chapter 11 Case PACIFIC GAS AND ELECTRIC HclVRD 13 COMPANY, a California corporation, Date: August 12, 2002 "CA RKIý 14 Time: 9:30 a.m.

Debtor. Place: 235 Pine Street, 22nd Floor San Francisco, California 15 Federal I.D. No. 94-0742640 16 17 18 DECLARATION OF MARTIN HUNT IN SUPPORT OF MOTION FOR AUTHORITY TO INCUR 19 INFORMATION TECHNOLOGY CONSULTING EXPENSES 20 21 22 23 24 25 26 27 28 DECLARATION OF MARTIN HUNT

1 I, Martin Hunt, declare:

2 1. I am employed by Pacific Gas and Electric Company ("PG&E"), the debtor 3 and debtor-in-possession in this Chapter 11 case. I am the Principal Project Manager for the 4 IT Equipment Project (as defmed below) in connection with the implementation of PG&E's 5 proposed Plan of Reorganization (as amended from time to time, the "Plan"). I have worked 6 for PG&E in various capacities for over 22 years. Before assuming my current position, I 7 held the position of Project Team Lead at PG&E's primary data center from March 2000 to 8 June 2001; from April 1996 to March 2000, I held the position of Senior Project Manager 9 for PG&E's Information Systems Technology Services Department, with responsibility for 10 managing large projects covering PG&E's entire service territory. In my current position as 11 Principal Project Manager, I have responsibility for the development of project cost, scope 12 and schedule and for the coordination of the IT Equipment Project with other PG&E teams RIaE 13 working on implementation of the Plan.

CA'N 14 2. This declaration is submitted in support of PG&E's Motion for Authority

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,*.,z., 15 to Incur Information Technology Consulting Expenses (the "Motion"). Defined terms used 16 herein shall have the meanings set forth in the Motion. I make this declaration based on 17 personal knowledge, except where otherwise indicated, and if called as a witness, could and 18 would testify competently to the matters set forth herein.

19 3. The New Entities will require various information technology computer 20 and network hardware, software and miscellaneous components (collectively, the "IT 21 Equipment") in order to support their business operations. PG&E seeks approval to utilize 22 an IT consultant to provide project management for the design, programming, configuration, 23 installation and testing of the IT Equipment (collectively, the "IT Equipment Project").

24 4. The IT Equipment Project requires an experienced project manager, with 25 both project management and IT experience, in order to manage cost, schedule and risks 26 related to this project.

27 5. PG&E has identified a consultant to be hired through Millennium 28 Consulting, a consulting firm specializing in IT projects, for the position of Senior Project DECLARATION OF MARTIN HUNT 1 Manager, to coordinate, supervise, track and report on the IT Equipment Project.

2 Specifically, the Senior Project Manager will (i) monitor all aspects of the IT Equipment 3 Project for adherence to cost, schedule and technical performance criteria; (ii) ensure 4 consistency in the reporting, work product and processes of the IT Equipment Project; and 5 (iii) facilitate and coordinate the IT Equipment Project to ensure that the project is successful 6 in meeting the New Entities' requirements.

7 6. The total estimated cost for the services of the Senior Project Manager 8 described above is $210,000. This cost is based on the estimated number of hours required 9 for the project, the applicable hourly rate and estimated reimbursable expenses.

10 7. PG&E's standard contractual provisions in place with Millennium 11 Consulting do not guarantee any future work or any minimum amount of revenue. PG&E 12 also maintains the right to terminate the work at any time without cause, in which case 13 PG&E is liable only for work performed to the date of termination plus costs reasonably RKI NA 14 incurred by the consultant in terminating any work in progress.

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,;;- ..- 15 I declare under penalty of perjury of the laws of the United States that the 16 foregoing is true and correct, and that-this declaration was executed at San Francisco, 17 California on July 23, 2002.

18 19 MARTIN HUNT 20 WD 072202/1-1419905/1011128/vl 21 22 23 24 25 26 27 28 DECLARATION OF MARTIN HUNT