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Gibson, Dunn & 

Crutcher LLP 

Jeffrey C. Krause (State Bar No. 94053) 

GIBSON, DUNN & CRUTCHER LLP 

333 South Grand Avenue 

Los Angeles, CA 90071-3197 

Telephone: 213.229.7000 

Facsimile: 213.229.7520 

Email: jkrause@gibsondunn.com 

Attorneys for Topaz Solar Farms LLC

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

-andPACIFIC 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).

 Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

JOINDER OF TOPAZ SOLAR FARMS LLC 

TO NEXTERA’S MOTION FOR LIMITED 

RELIEF FROM STAY TO PARTICIPATE 

IN APPELLATE PROCEEDINGS WITH 

RESPECT TO FERC ORDERS 

Hearing: 

Date: June 26, 2019 

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

Place: United States Bankruptcy Court 

Courtroom 17, 16th Floor 

San Francisco, CA 94102 

Objection Deadline: June 21, 2019 

 4:00 p.m. (PDT) 

Topaz Solar Farms LLC (“Topaz”), a party in interest in the above-captioned cases, hereby 

joins (the “Joinder”) in the Motion for Limited Relief from Stay to Participate in Appellate 

Proceedings with Respect to FERC Orders [Docket No. 2400] (the “Motion”) of NextEra Energy, 

Inc. and NextEra Energy Partners, L.P. (collectively, “NextEra”) (i) to permit Topaz to (a) seek leave 

from the applicable circuit court of appeals to intervene in any appeal of the FERC Orders (as defined 

in the Motion); (b) to the extent permitted by the applicable circuit court of appeals, participate in and 

Case: 19-30088 Doc# 2620 Filed: 06/19/19 Entered: 06/19/19 12:19:45 Page 1 of

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prosecute to conclusion any appeal of the FERC Orders; (c) seek or oppose any request for rehearing, 

rehearing en banc, petition for writ of certiorari; (d) participate in the briefing and argument relating 

to any and all the foregoing; and (e) participate in any proceedings on remand of the FERC Orders; 

and (ii) to generally allow all courts and administrative agencies with jurisdiction over the appeal or 

remand to enter final orders relating thereto.1 The catalyst for the Motion (and this Joinder) is the 

Debtors’ Motion of the Utility for Limited Relief From the Automatic Stay to Appeal Certain Matters 

Pending Before the Federal Energy Regulatory Commission [Docket No. 2359] (the “PG&E Stay 

Motion”), seeking relief from the stay to allow the Debtors to pursue appellate relief from the FERC 

Orders, without granting the other parties in interest parallel relief from the stay to respond to the 

Debtors’ requests for such relief. 

In support hereof, Topaz respectfully represents as follows: 

JOINDER 

By its Motion, NextEra seeks narrowly-tailored relief to permit it to participate in the 

Debtors’ anticipated appeal of the FERC Orders to the extent authorized by the applicable appellate 

court. For the same reasons as those set forth in the Motion, Topaz merits the same relief. As an 

intervenor in the FERC Proceedings, Topaz has a substantial interest in the subject matter of the 

FERC Proceedings and a direct stake in any appeal of the FERC Orders. It would be fundamentally 

unfair to allow the Debtors to appeal the FERC Orders without affording Topaz an opportunity to 

defend its interests in connection with any such appeal. 

CONCLUSION 

Accordingly, Topaz respectfully requests that any order modifying the automatic stay as 

requested in the Motion and PG&E’s Stay Motion also modify the automatic stay as to Topaz to 

permit Topaz to participate in any appeal from the FERC Orders.

NOTICE 

Notice of this Joinder will be provided to (i) the Office of the U.S. Trustee for Region 17 

(Attn: Anthony R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Debtors; (iii) counsel to 

 

1

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them 

in the Motion. 

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the Creditors Committee; (iv) counsel to the Tort Claimants Committee; (v) the Securities and 

Exchange Commission; (vi) the Internal Revenue Service; (vii) the Office of the California Attorney 

General; (viii) the California Public Utilities Commission; (ix) the Nuclear Regulatory Commission; 

(x) the Federal Energy Regulatory Commission; (xi) the Office of the United States Attorney for the 

Northern District of California; (xii) counsel for the agent under the Debtors’ debtor-in-possession 

financing facility; (xiii) counsel to the PPA Counterparties; and (xiv) those persons who have 

formally appeared in these chapter 11 cases and requested service pursuant to Bankruptcy Rule 2002. 

Topaz respectfully submits that no further notice is required. 

Dated: June 19, 2019 

/s/ Jeffrey C. Krause 

Jeffrey C. Krause 

GIBSON, DUNN & CRUTCHER LLP 

Attorneys for Topaz Solar Farms LLC

103357632.3 

Case: 19-30088 Doc# 2620 Filed: 06/19/19 Entered: 06/19/19 12:19:45 Page 3 of

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