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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) 

Theodore E. Tsekerides (pro hac vice) 

(theodore.tsekerides@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 DEBTORS’ 

MOTION PURSUANT TO FED. R. BANKR. 

P. 4001(d) TO APPROVE STIPULATION 

WITH CALIFORNIA PUBLIC UTILITIES 

COMMISSION IN RESPECT OF CERTAIN 

PROCEEDINGS 

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# 2415 Filed: 06/05/19 Entered: 06/05/19 17:44:42 Page 1 of

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

I, Theodore E. Tsekerides, pursuant to section 1746 of title 28 of the United States Code, 

hereby declare under penalty of perjury that the following is true and correct to the best of my 

knowledge, information, and belief: 

1. I am a partner with Weil, Gotshal & Manges LLP, bankruptcy counsel to Pacific Gas 

and Electric Company (the “Utility”) and its parent, PG&E Corporation, both Debtors and Debtors in 

Possession in the above-captioned chapter 11 reorganization cases. I file this declaration in support of 

Debtors’ Motion (the “Motion”) to approve the Stipulation with the California Public Utilities 

Commission in respect of certain proceedings (the “Stipulation”). The matters stated herein are based 

upon my personal knowledge (including from a review of publicly filed documents), and if called as a 

witness I can and would testify to them on that basis. 

2. In carrying out its statutory duties, the California Public Utilities Commission (the 

“Commission”) regularly oversees proceedings initiated by third parties (such parties, “Commission 

Complainants” and proceedings initiated by such parties, “Commission Proceedings”). From time to 

time, Commission Complainants lack the means to engage counsel to bring proceedings in these 

Chapter 11 Cases for relief from the Automatic Stay, including certain Commission Complainants that 

are low-income customers eligible for PG&E’s low-income rate or assistance programs. Commission 

Complainants sometimes initiate proceedings before the Commission to enforce public policy and 

safety, utility tariffs, administrative orders and regulations, including proceedings concerning matters 

arising before the Petition Date to compel the Utility to relocate overhead power lines, to restore utility 

services, effectuate Commission rules and regulations and utility tariffs or to issue reimbursements for 

certain remedial actions taken by ratepayers. 

3. The Parties have determined that the commencement or continuation of certain 

Commission Proceedings, up to and including the determination of, but not the collection of, any 

money judgments in such proceedings, is in their best interests notwithstanding the Chapter 11 Cases. 

4. Specifically, with respect to Commission Proceedings filed prior to entry of an order 

approving the Stipulation, the Parties have agreed that the Automatic Stay should be modified to allow 

the commencement or continuation of the relevant Commission Proceedings set forth on Exhibit A 

attached to the Stipulation, including the determination of, but not the collection of, any money 

Case: 19-30088 Doc# 2415 Filed: 06/05/19 Entered: 06/05/19 17:44:42 Page 2 of

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

judgments in such proceedings. With respect to Commission Proceedings by Commission 

Complainants of the type identified above that are accepted for filing by the Commission after the 

entry of an order approving the Stipulation, the Parties have agreed that, upon the expiration of the 

applicable Notice Period (as defined in the Stipulation) without objection by the Debtors, the 

Automatic Stay should be modified to allow the commencement or continuation of the relevant 

Commission Proceeding, including the determination of, but not the collection of, any money 

judgments in such proceedings. If the Debtors timely object to the commencement or continuation of 

such Commission Proceeding (by filing an objection in such Commission Proceeding within the 

applicable Notice Period), the Commission shall suspend such Commission Proceeding and the 

Debtors, the Commission, and the Commission Complainant, if applicable, shall meet and confer in a 

good faith effort to resolve whether such Commission Proceeding may continue before the 

Commission. If the parties are unable to reach agreement, then the stipulated modification of the 

Automatic Stay shall be inapplicable to such Commission Proceeding, and the Automatic Stay shall 

remain in place as to such Commission Proceeding. 

5. The Parties have further agreed that the Automatic Stay should continue to apply to the 

allowance of claims, and to the enforcement of any money judgments awarded in any Commission 

Proceedings that are or become the subject of the Stipulation. Moreover, the Parties have agreed that 

nothing in the Stipulation should be deemed to modify or alter the requirements or obligations of any 

Commission Complainant to timely file a proof of claim in these Chapter 11 Cases in accordance with 

any order of the Court governing the filing of claims. 

6. Allowing the Commission to adjudicate the Commission Proceedings will not prejudice 

the Debtors’ estates or other creditors, and will instead promote efficiency by saving the Debtors the 

effort and expense of relitigating the claims of the Commission Complainants—involving highly 

specialized regulatory issues—from scratch in the Bankruptcy Court through a contested claims 

process. The Commission Proceedings involve the normal regulatory functions of the Commission. 

For that reason, permitting the Commission to decide Commission Proceedings as provided in the 

Stipulation will promote efficiency and economy and will not impose a material burden on the 

Debtors’ reorganization efforts. For these reasons, the Stipulation provides material benefits to the 

Case: 19-30088 Doc# 2415 Filed: 06/05/19 Entered: 06/05/19 17:44:42 Page 3 of

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Debtors and their estates at little cost, has been authorized by the Debtors in the exercise of their 

business judgment, and is in the best interest of the Debtors and their estates. 

7. Furthermore, without approval of the Stipulation, the Debtors (and the Court) could be 

faced with seriatim motions for relief from the automatic stay by the Commission or the Commission 

Complainants. Since the Commission Proceedings are alike in their procedure and subject matter, it is 

in the best interests of all parties that the Court approve an umbrella procedure for relief from stay, 

rather than having to determine whether each Commission Proceeding merits such relief. 

8. Notably, the Stipulation would in practice be discretionary. Except for the Commission 

Proceedings listed on Exhibit A, the Stipulation provides the Debtors with unilateral objection rights 

through which the Debtors can prevent the application of the Stipulation, and in turn the modification 

of the Automatic Stay pursuant to the Stipulation, as to any Commission Proceeding for which they 

believe the Automatic Stay should remain in place. If the Debtors do not agree to stay relief with 

respect to a particular Commission Proceeding, such proceeding will remain subject to the automatic 

stay—with the Commission Complainant’s recourse being to bring a new motion for stay relief in this 

Court. Under the Stipulation, questions of stay relief in matters where the Debtors believe stay relief 

should not be granted (because, for example, the burden on the estates would be undue or the matter 

raises issues that implicate significant bankruptcy policies or protections) would still be subject to this 

Court’s discretion. The Stipulation would provide the Debtors with this flexibility while sparing both 

the Court and the Parties the burden of repetitive formal requests for relief from stay or to approve 

agreements between the Parties for relief from stay. 

Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the foregoing is true 

and correct, and that this declaration is executed on June 5, 2019. 

 

 /s/ Theodore E. Tsekerides_______________

Theodore E. Tsekerides 

Case: 19-30088 Doc# 2415 Filed: 06/05/19 Entered: 06/05/19 17:44:42 Page 4 of

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