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4816-4449-2951 

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) 

STIPULATION BETWEEN OFFICIAL 

COMMITTEE OF UNSECURED 

CREDITORS AND OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

EXTENDING TIME TO RESPOND TO 

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ENTRY OF AN ORDER APPROVING 

PROPOSED MODEL PROOF OF CLAIM 

FORM FOR FIRE CLAIMS AND 

RELATED PROCEDURES [DOCKET NO. 

1824] 

[No Hearing Requested] 

Case: 19-30088 Doc# 2190 Filed: 05/22/19 Entered: 05/22/19 15:45:01 Page 1 of

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This stipulation and agreement for order (the “Stipulation”) is entered into by the 

(i) Official Committee of Unsecured Creditors (the “UCC”) appointed in the jointly administered 

chapter 11 cases (the “Chapter 11 Cases”) of the above-captioned debtors in possession, on the 

one hand; and (ii) Official Committee of Tort Claimants appointed in the Chapter 11 Cases (the 

“TCC” and together with the UCC, the “Parties”), on the other hand. The Parties hereby stipulate 

and agree as follows: 

RECITALS 

A. On May 3, 2019, the TCC filed the Motion of the Official Committee of Tort 

Claimants Pursuant to 11 U.S.C. §§ 105(a) and 501 and Fed. R. Bankr. P. 3001(a) for Entry of an 

Order Approving Proposed Model Proof of Claim Form for Fire Claims and Related Procedures

[Docket No. 1824] (the “Motion”), which is set for hearing before the Court at 9:30 a.m. (Pacific 

Time) on June 11, 2019. Any response or opposition to the Motion is due by 4:00 p.m. (Pacific 

Time) on May 28, 2019. 

B. Counsel to the UCC has requested, and counsel to the TCC has agreed, that the time 

for the UCC to respond to the Motion be extended. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH 

THE UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT 

TO ORDER, THAT:

1. The time for the UCC to file and serve any response or opposition to the Motion is 

extended through 4:00 p.m. (Pacific Time) on May 31, 2019. 

[Signatures on next page]

Case: 19-30088 Doc# 2190 Filed: 05/22/19 Entered: 05/22/19 15:45:01 Page 2 of

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Dated: May 22, 2019 

MILBANK LLP 

/s/ Thomas R. Kreller

Thomas R. Kreller

Attorneys for Official Committee of 

Unsecured Creditors

Dated: May 22, 2019 

BAKER & HOSTETLER LLP 

/s/ Eric R. Goodman

Eric R. Goodman 

Attorneys for Official Committee of 

Tort Claimants

Case: 19-30088 Doc# 2190 Filed: 05/22/19 Entered: 05/22/19 15:45:01 Page 3 of

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