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AKIN GUMP STRAUSS HAUER & FELD LLP

Michael S. Stamer (pro hac vice)

Ira S. Dizengoff (pro hac vice)

David H. Botter (pro hac vice)

Abid Qureshi (pro hac vice)

One Bryant Park

New York, New York 10036

Telephone: (212) 872-1000

Facsimile: (212) 872-1002

Email: mstamer@akingump.com

idizengoff@akingump.com

dbotter@akingump.com

aqureshi@akingump.com

AKIN GUMP STRAUSS HAUER & FELD LLP

Ashley Vinson Crawford (SBN 257246)

580 California Street

Suite 1500

San Francisco, CA 94104

Telephone: (415) 765-9500

Facsimile: (415) 765-9501

Email: avcrawford@akingump.com

Counsel to the Ad Hoc Committee of Senior Unsecured 

Noteholders of Pacific Gas and Electric Company 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

STATEMENT OF THE AD HOC 

COMMITTEE OF SENIOR UNSECURED 

NOTEHOLDERS TO CORRECTED 

MOTION OF DEBTORS PURSUANT TO 11 

U.S.C. § 1121(d) TO EXTEND EXCLUSIVE 

PERIODS [DOCKET NO. 1797]

Hearing

Date: May 22, 2019

Time: 9:30 a.m. (Pacific Time)

Place: Courtroom 17

450 Golden Gate Ave, 16th Floor

San Francisco, CA 9410

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# 2008 Filed: 05/15/19 Entered: 05/15/19 14:47:54 Page 1 of

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The Ad Hoc Committee of Senior Unsecured Noteholders of Pacific Gas and Electric Company

(the “Ad Hoc Committee”) in the above-captioned chapter 11 cases of Pacific Gas and Electric 

Company (the “Utility”) and PG&E Corporation (“PG&E” and, together with the Utility, the 

“Debtors”), by its undersigned counsel, Akin Gump Strauss Hauer & Feld LLP, hereby files this 

statement (the “Statement”) with respect to the Corrected Motion of Debtors Pursuant to 11 U.S.C. §

1121(d) to Extend Exclusive Periods [Docket. No. 1797] (the “Exclusivity Motion”).1In support 

hereof, the Ad Hoc Committee respectfully represents as follows:

STATEMENT

1. By the Exclusivity Motion, the Debtors request a six month extension of their exclusive 

plan filing and solicitation periods (collectively, the “Exclusive Periods”) to November 29, 2019 and 

January 28, 2020, respectively. While the Ad Hoc Committee does not at this time object to the relief 

requested in the Exclusivity Motion and is hopeful that the Debtors will propose a confirmable plan of 

reorganization in the near future, the Ad Hoc Committee nevertheless files this Statement to register its 

concerns regarding the length of the extension sought and to reserve its right to seek to shorten or 

terminate the Debtors’ Exclusive Periods at a later date, if necessary.

2. The Ad Hoc Committee is aware of the many legal and operational issues the Debtors 

must contend with during these chapter 11 cases. However, to date, the Debtors have not, as far as the 

Ad Hoc Committee is aware, engaged in any substantive plan-related discussions with any of their 

primary stakeholders, including the Ad Hoc Committee, which holds a majority of the Utility’s 

approximately $20.5 billion in funded debt. The Ad Hoc Committee is concerned that the process to 

replace the Debtors’ board of directors initiated and pursued by the Debtors’ major shareholders 

hampered the progress of these chapter 11 cases.

3. It is the Ad Hoc Committee’s firm belief that the Debtors and all key parties in interest 

should focus their efforts on building consensus with respect to a confirmable chapter 11 plan and exiting

from bankruptcy as soon as possible. The granting of a lengthy extension should not deter parties in 

interest from working quickly to reach a global resolution with respect to plan issues, wildfire mitigation 

1 Capitalized terms used, but not defined, herein shall have the meanings ascribed to them in the Exclusivity Motion.

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