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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) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 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 - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF THEODORE E. 

TSEKERIDES IN SUPPORT OF THE 

MOTION OF THE UTILITY FOR 

LIMITED RELIEF FROM THE 

AUTOMATIC STAY TO APPEAL 

CERTAIN MATTERS PENDING BEFORE 

THE FEDERAL ENERGY REGULATORY 

COMMISSION 

Date: June 26, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: June 19, 2019 

 4:00 p.m. (Pacific Time) 

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# 2361 Filed: 06/03/19 Entered: 06/03/19 17:47:43 Page 1 of

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

Pursuant to 28 U.S.C. § 1746, I, Theodore E. Tsekerides, hereby declare under the penalty of 

perjury that the following is true and correct to the best of my knowledge, information, and belief: 

I am a partner at Weil, Gotshal & Manges LLP, counsel to PG&E Corporation and Pacific Gas 

and Electric Company (the “Utility”) (collectively, “PG&E” or the “Debtors”) in the above-captioned 

chapter 11 cases (“Chapter 11 Cases”).1 I respectfully submit this Declaration in support of the 

Motion of the Utility for Limited Relief from the Automatic Stay to Appeal Certain Matters Pending 

Before the Federal Energy Regulatory Commission, filed on the date hereof. 

As this Court is aware, on January 25 and 28, 2019, the Federal Energy Regulatory 

Commission (“FERC”) entered two substantively similar orders finding that FERC had “concurrent” 

jurisdiction over the Utility’s rejection decisions in bankruptcy pursuant to section 365 of the 

Bankruptcy Code. True and correct copies of these orders are attached to this Declaration. See 

NextEra Energy, Inc. v. Pac. Gas & Elec. Co., 166 FERC ¶ 61,049 (Jan. 25, 2019) (the “NextEra 

Order”) (attached as Exhibit 1); Exelon Corp. v. Pac. Gas & Elec. Co., 166 FERC ¶ 61,053 (Jan. 28, 

2019) (the “Exelon Order”) (attached as Exhibit 2). 

In order to preserve its rights, on February 25, 2019, during the pendency of the Debtors’ 

Chapter 11 Cases, the Utility filed two Requests for Rehearing of the NextEra and Exelon Orders at 

FERC. True and correct copies of these Requests for Rehearing are attached to this Declaration. See 

Request for Rehearing, NextEra Energy, Inc. v. Pac. Gas & Elec. Co., No. EL19-35-001 (FERC Feb. 

25, 2019) (attached as Exhibit 3); Request for Rehearing, Exelon Corp. v. Pac. Gas & Elec. Co., No. 

EL19-36-001 (FERC Feb. 25, 2019) (attached as Exhibit 4). 

On March 26, 2019, FERC entered two orders finding that the Utility had timely requested 

rehearing. True and correct copies of these orders are attached to this Declaration. See Order Granting 

Rehearing for Further Consideration, NextEra v. Pac. Gas & Elec. Co., No. EL19-35-001 (FERC 

Mar. 26, 2019) (attached as Exhibit 5); Order Granting Rehearing for Further Consideration, Exelon 

Corp. v. Pac. Gas & Elec. Co., No. EL19-36-001 (FERC Mar. 26, 2019) (attached as Exhibit 6). 

 Most recently, FERC entered a single, consolidated order denying the Utility’s Requests for 

 

1

 Capitalized terms used in this Declaration that are not otherwise defined have the meanings given 

to them in the Utility’s Motion. 

Case: 19-30088 Doc# 2361 Filed: 06/03/19 Entered: 06/03/19 17:47:43 Page 2 of

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

Rehearing. A true and correct copy of this order is attached to this Declaration. See Order Denying 

Rehearing, NextEra Energy, Inc. v. Pac. Gas & Elec. Co., Nos. EL19-35-001, EL 19-36-001 (FERC 

May 1, 2019) (attached as Exhibit 7) (together with the other aforementioned FERC orders, the 

“FERC Orders”). Because FERC denied the Utility’s Requests for Rehearing, the Utility now files 

this Motion as a prophylactic measure to protect its rights to appeal to conclusion the FERC Orders. 

Date: June 3, 2019 WEIL, GOTSHAL & MANGES LLP

 KELLER & BENVENUTTI LLP

 

/s Theodore E. Tsekerides

 Theodore E. Tsekerides 

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 2361 Filed: 06/03/19 Entered: 06/03/19 17:47:43 Page 3 of

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