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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 AMONG DEBTORS, 

CREDITORS COMMITTEE, AND MNOC 

AERS LLC EXTENDING TIME TO 

RESPOND TO MOTION AND 

MEMORANDUM OF POINTS AND 

AUTHORITIES OF MNOC AERS LLC 

FOR ENTRY OF AN ORDER 

CONFIRMING SAFE HARBOR 

PROTECTION UNDER 1 U.S.C. §§ 

362(B)(6) AND 556 

Re: Dkt. No. 1599 

[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# 1855 Filed: 05/06/19 Entered: 05/06/19 12:47:42 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 (a) PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), (b) the Official Committee of Unsecured 

Creditors (the “Creditors Committee”), and (c) mNoc AERS LLC (“mNOC”). The Debtors, 

the Creditors Committee, and mNoc 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 April 22, 2019, mNoc filed the Motion and Memorandum of Points and 

Authorities of mNoc AERS LLC for Entry of an Order Confirming Safe Harbor Protection Under 

1 U.S.C. §§ 362(b)(6) and 556 (redacted version [Dkt. No. 1599] (the “mNoc Safe Harbor 

Motion”), which is set for a hearing before the Court at 9:30 a.m. on May 21, 2019. Any 

response or opposition to the mNoc Safe Harbor Motion is due by 4:00 p.m. (Pacific Time) on 

May 7, 2019. 

B. Counsel for the Debtors and the Creditors Committee have requested, and counsel 

for mNoc has agreed, that the time for the Debtors and the Creditors Committee to respond to the 

mNoc Safe Harbor 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 AMONG THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, 

THAT:

1. The time for the Debtors and the Creditors Committee to file and serve any 

response or opposition to the mNoc Safe Harbor Motion is extended through 4:00 p.m. (Pacific 

Time) on May 14, 2019. 

[Signatures on next page] 

Case: 19-30088 Doc# 1855 Filed: 05/06/19 Entered: 05/06/19 12:47:42 Page 2 of

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

Dated: May 6, 2019 Dated: May 6, 2019

KELLER & BENVENUTTI LLP ORRICK, HERRINGTON & 

SUTCLIFFE LLP 

/s/ Jane Kim /s/ Thomas C. Mitchell

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

Thomas C. Mitchell

Attorneys for mNoc AERS LLC

Dated: May 6, 2019

MILBANK LLP 

/s/ Thomas R. Kreller

Thomas R. Kreller

Attorneys for Official Committee of 

Unsecured Creditors

Case: 19-30088 Doc# 1855 Filed: 05/06/19 Entered: 05/06/19 12:47:42 Page 3 of

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