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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) 

JOINDER OF THE AD HOC COMMITTEE 

OF SENIOR UNSECURED 

NOTEHOLDERS TO OBJECTION OF THE 

OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS’ TO THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS’ 

BAR DATE MOTION 

Hearing 

Date: June 26, 2019 

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

Place: Courtroom 17 

 450 Golden Gate Ave, 16th Floor 

 San Francisco, CA 94102 

Re: Docket Nos. 2297, 2650 

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).

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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 joins (the “Joinder”) the Objection 

of the Official Committee of Unsecured Creditors to the Official Committee of Tort Claimant’s Bar Date 

Motion [Docket. No. 2650] (the “UCC Objection”).1 In support of the Joinder, the Ad Hoc Committee 

respectfully states the following: 

JOINDER 

1. Pursuant to the Motion of the Official Committee of Tort Claimants Pursuant to 11 U.S.C. 

§§ 105(a), 501, and Fed. R. Bankr. P. 3001(a), 3003(c), 5005 and 9007 for Entry of an Order (I) 

Establishing a Bar Date for Filing Fire Claims, (II) Approving the Form and Procedures for Notice of 

the Bar Date for Fire Claims, and (III) Approving Supplemental Procedures for Notice of the Bar Date 

to Fire Claimants [Docket No. 2297] (the “TCC Bar Date Motion”), the Official Committee of Tort 

Claimants seeks a bar date for fire victims of January 31, 2020, a date more than seven months from now 

and a full year from the date these cases were commenced. While the Ad Hoc Committee is aware of 

the difficulties the tort claimants may face in filing proofs of claim, the Ad Hoc Committee shares the 

concerns of the Official Committee of Unsecured Creditors (the “UCC”) regarding the attempts of the 

Official Committee of Tort Claimants (the “TCC”) to cause a significant delay in the administration of 

these cases. Indeed, if the news reports are accurate, Governor Newsom’s contemplated legislation to 

create a fund to pay future wildfire claims requires PG&E to have emerged from these proceedings by 

June 30, 2020 in order to participate in the fund.2 As a result, the Ad Hoc Committee joins in the UCC 

Objection and agrees with the UCC, and indeed, prior statements made by the TCC,3 that it is in the best 

interest of all parties, including the tort claimants, that this case move forward as quickly as possible so 

that all creditors, including the wildfire victims, can be paid and reorganized PG&E and its constituents 

1

 Capitalized terms used, but not defined, herein shall have the meanings ascribed to them in the UCC Objection. 

2 See Mark Chediak, If PG&E Wants Newsom’s Wildfire Aid, Here’s What It Has to Do, Bloomberg (June 21, 2019) 

https://www.bloomberg.com/news/articles/2019-06-21/if-pg-e-wants-newsom-s-wildfire-aid-here-s-what-it-has-to-do. 

3

See UCC Objection at 2. 

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can benefit from any legislation that is subsequently enacted. 

2. The Ad Hoc Committee strongly believes that the extension proposed by the TCC in the 

TCC Bar Date Motion is not in the best interest of any party in these cases, including the TCC’s 

constituents. The Ad Hoc Committee has maintained throughout the pendency of these chapter 11 cases 

that all key stakeholders should focus their efforts on building consensus with respect to a confirmable 

chapter 11 plan and the Debtors’ exiting from bankruptcy as soon as possible. The establishment of a 

bar date in the near term is essential to these efforts as it will provide the key stakeholders with critical 

information regarding the nature and scope of claims in these chapter 11 cases. Granting the relief 

requested in the TCC Bar Date Motion and setting the bar date on January 31, 2020 could delay 

unnecessarily the conclusion of the Debtor’s bankruptcy, thereby delaying creditor recoveries. 

3. Additionally, Ad Hoc Committee echoes the UCC’s request that the TCC share the claims 

information in the BrownGreer database with all major parties in interest, particularly in light of the 

Debtors’ acceptance of the TCC’s proposed proof of claim form for fire victims, a form which calls for 

little information. Denying other stakeholders relevant information about the universe of claims and 

forcing them to devote attention to a discovery process in order to get such information can only serve 

to hinder and delay the claims reconciliation process and arriving at a successful conclusion to these 

cases. 

4. Despite the TCC’s prior assertions that they seek an expeditious emergence from 

bankruptcy and payment of creditor claims, granting the relief requested in the TCC Bar Date Motion 

would accomplish neither. The best course of action here is for all parties in interest to work together in 

good faith (i) to gather and share all necessary wildfire claims information as quickly as possible and (ii) 

to try to reach a resolution on any open issue that could delay confirmation of a chapter 11 plan and the 

Debtors’ emergence from chapter 11. 

RESERVATION OF RIGHTS 

5. The Ad Hoc Committee reserves the right to raise further and other objections to the 

Motion at the hearing as may be necessary or appropriate. 

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