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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

New York, NY 10153-0119 

Tel: (212) 310-8000 

Fax: (212) 310-8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 636-9251 

Attorneys for Debtors and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STIPULATION BETWEEN DEBTORS 

AND CALIFORNIA STATE AGENCIES 

EXTENDING TIME TO RESPOND TO 

APPLICATION OF DELOITTE & 

TOUCHE LLP 

Re: Dkt. No. 2197 

[No Hearing Requested] 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

 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) 

 

Case: 19-30088 Doc# 2395 Filed: 06/05/19 Entered: 06/05/19 11:57:51 Page 1 of

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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), on the one hand, and California Department 

of Toxic Substances Control, California Department of Water Resources acting by and though 

the California Energy Resources Scheduling Division and on behalf of the State Water Project, 

State Water Resources Control Board, Regional Water Quality Control Boards, State Energy 

Resources Conservation and Development Commission, California Department of Forestry and 

Fire Protection (CAL FIRE), California Coastal Commission, California Air Resources Board, 

Department of Parks and Recreation, San Francisco Bay Conservation and Development 

Commission, Department of Housing and Community Development, Central Valley Flood 

Protection Board, High Speed Rail Authority and California Department of Fish and Wildlife 

(collectively, the “California State Agencies”), on the other hand. The Debtors and the 

California State Agencies are referred to in this Stipulation and Agreement for Order collectively 

as the “Parties,” and each as a “Party.” The Parties hereby stipulate and agree as follows: 

RECITALS 

A. On May 22, 2019, the Debtors filed the Application Pursuant to 11 U.S.C. §§ 327 

and 328 for an Order Authorizing Employment and Retention of Deloitte & Touche LLP as 

Independent Auditor and Advisor to the Debtors Nunc Pro Tunc to the Petition Date [Dkt. 

No. 2197] (the “Application”), which is set for a hearing before the Court at 9:30 a.m. on 

June 12, 2019. Any response or opposition to the Application is due by 4:00 p.m. (Pacific Time) 

on June 5, 2019. 

B. Counsel for the California State Agencies has requested, and counsel for the 

Debtors has agreed, that the time for the California State Agencies to respond to the Application 

be extended. 

Case: 19-30088 Doc# 2395 Filed: 06/05/19 Entered: 06/05/19 11:57:51 Page 2 of

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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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 California State Agencies to file and serve any response or 

opposition to the Application is extended through 4:00 p.m. (Pacific Time) on June 7, 2019. 

[Signatures on next page] 

Case: 19-30088 Doc# 2395 Filed: 06/05/19 Entered: 06/05/19 11:57:51 Page 3 of

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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Dated: June 5, 2019

KELLER & BENVENUTTI LLP 

/s/ Thomas B. Rupp

Thomas B. Rupp

Attorneys for Debtors 

and Debtors in Possession

XAVIER BECERRA 

Attorney General of California

DANETTE VALDEZ 

Supervising Deputy Attorney General 

FELDERSTEIN FITZGERALD 

WILLOUGHBY & PASCUZZI LLP 

/s/ Paul J. Pascuzzi

Paul J. Pascuzzi

FELDERSTEIN FITZGERALD 

WILLOUGHBY & PASCUZZI LLP 

 

Attorneys for California Department of 

Toxic Substances Control, California 

Department of Water Resources acting by 

and though the California Energy 

Resources Scheduling Division and on 

behalf of the State Water Project, State 

Water Resources Control Board, Regional 

Water Quality Control Boards, State 

Energy Resources Conservation and 

Development Commission, California 

Department of Forestry and Fire 

Protection (CAL FIRE), California Coastal 

Commission, California Air Resources 

Board, Department of Parks and 

Recreation, San Francisco Bay 

Conservation and Development 

Commission, Department of Housing and 

Community Development, Central Valley 

Flood Protection Board, High Speed Rail 

Authority, and California Department of 

Fish and Wildlife 

Case: 19-30088 Doc# 2395 Filed: 06/05/19 Entered: 06/05/19 11:57:51 Page 4 of

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