1 JOSHUA HILL JR. (SBN 250842) 

jhill@mofo.com 

2 CHRISTINE Y. WONG (SBN 284026) 

christinewong@mofo.com 

3 MORRISON & FOERSTER LLP 

425 Market Street 

4 San Francisco, CA 94105 

Tel: (415) 268-7000 

5 Fax: (415) 268-7522 

6 Proposed Special Regulatory Counsel to Debtors 

and Debtors in Possession 

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8 UNITED STATES BANKRUPTCY COURT 

9 NORTHERN DISTRICT OF CALIFORNIA 

10 SAN FRANCISCO DIVISION 

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In re 

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PG&E CORPORATION, 

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- and -

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PACIFIC GAS AND ELECTRIC 

16 COMPANY, 

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Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

ORDER GRANTING APPLICATION OF 

DEBTORS PURSUANT TO 11 U.S.C. § 

327(E) AND FED. R. BANKR. P. 2014(A) 

AND 2016 FOR AUTHORITY TO RETAIN 

AND EMPLOY MORRISON & 

FOERSTER LLP AS SPECIAL 

REGULATORY COUNSEL FOR THE 

DEBTORS EFFECTIVE AS OF THE 

PETITION DATE 

Date: June 11, 2019 

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

Place: United States Bankruptcy Court 

Courtroom 17, 16th Floor 

San Francisco, CA 94102 

Morrison & Foerster LLP

425 Market Street 

San Francisco, CA 94105 

Signed and Filed: June 11, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

June 12, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 2502 Filed: 06/11/19 Entered: 06/12/19 15:47:12 Page 1 of

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1 Upon the Application, dated March 22, 2019 (the “Application”),1

 of PG&E Corporation 

2 (“PG&E Corp.”) and Pacific Gas and Electric Company (the “Utility”), as debtors and debtors 

3 in possession (collectively, "PG&E" or the "Debtors") in the above-captioned chapter 11 cases 

4 (the “Chapter 11 Cases”), pursuant to section 327(e) of title 11 of the United States Code (the 

5 “Bankruptcy Code”) and Rules 2014(a) and 2016 of the Federal Rules of Bankruptcy Procedure 

6 (the “Bankruptcy Rules”), for authority to retain and employ Morrison & Foerster LLP 

7 (“Morrison & Foerster”) as special regulatory counsel for the Debtors, effective as of the Petition 

8 Date, all as more fully set forth in the Application; and this Court having jurisdiction to consider 

9 the Application and the relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334, and the 

10 Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24 and 

11 Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District Court for the

12 Northern District of California (the “Bankruptcy Local Rules”); and consideration of the 

13 Application and the requested relief being a core proceeding pursuant to 28 U.S.C. § 157(b); and 

14 venue being proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and due and 

15 proper notice of the Application having been provided to the parties listed therein, and it 

16 appearing that no other or further notice need be provided; and this Court having reviewed the 

17 Application, the Hill Declaration and the Loduca Declaration; and upon the record of the Hearing 

18 (if any was held) and all of the proceedings had before the Court; and this Court having found and 

19 determined that the relief sought in the Application is in the best interests of the Debtors, their 

20 estates, creditors, shareholders, and all parties in interest; and that the legal and factual bases set 

21 forth in the Application establish just cause for the relief granted herein; and after due 

22 deliberation and sufficient cause appearing therefor, 

23 IT IS HEREBY ORDERED THAT: 

24 1. The Application is GRANTED. 

25 2. The Debtors are authorized, pursuant to section 327(e) of the Bankruptcy Code 

26 and Bankruptcy Rules 2014(a) and 2016, to retain and employ Morrison & Foerster as special 

27 1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in 

28 the Application. 

Morrison & Foerster LLP

425 Market Street 

San Francisco, CA 94105 

Case: 19-30088 Doc# 2502 Filed: 06/11/19 Entered: 06/12/19 15:47:12 Page 2 of

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1 regulatory counsel in these Chapter 11 Cases, in accordance with Morrison & Foerster’s standard 

2 hourly rates and reimbursement of disbursements policies, all as contemplated by the Application, 

3 effective as of the Petition Date. 

4 3. Morrison & Foerster is authorized to render the following professional services: 

5 a. advising and representing the Debtors generally in connection with 

ongoing investigations conducted by the Safety and Enforcement 

6 Division of the CPUC (“SED”), including by performing legal and 

factual due diligence, analyzing documents, conducting interviews, 

7 and formulating responses to inquiries received from CPUC 

(including the following data requests issued by the SED: Camp Fire 

8 SED-001 through SED-006; North Bay Fire SED-006 and SED-007; 

and other miscellaneous data requests); 

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b. formulating strategy in advance of and preparing on behalf of the 

10 Debtors necessary motions, applications, objections, and other 

filings in any Orders Instituting Investigation commenced by the 

11 SED relating to alleged violations of state laws and regulations in 

connection with the 2017 and 2018 wildfires; 

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c. advising and representing the Debtors generally in connection with 

13 any Notices of Violation or Electric Safety Citations, pursuant to 

CPUC Resolution ALJ-274, commenced by the SED relating to 

14 alleged violations of state laws and regulations in connection with 

the 2017 and 2018 wildfires; 

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d. negotiating with the SED and other regulatory bodies, as 

16 appropriate; 

17 e. advising and representing the Utility regarding its rights and 

obligations under its Transportation Services Agreements with Ruby 

18 Pipeline, L.L.C.; and 

19 f. performing all other necessary legal services in connection with the 

foregoing; provided, however, that to the extent Morrison & Foerster 

20 determines that such services fall outside of the scope of services 

historically or generally performed by Morrison & Foerster as 

21 special regulatory counsel, Morrison & Foerster will file a 

supplemental declaration. 

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4. Morrison & Foerster shall be compensated in accordance with, and will file, 

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interim and final fee applications for allowance of its compensation and expenses and shall be 

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subject to sections 330 and 331 of the Bankruptcy Code, the Bankruptcy Rules, the Bankruptcy 

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Local Rules, the Fee Guidelines, and any further order of the Court. 

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5. Morrison & Foerster shall be reimbursed for reasonable and necessary expenses as 

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provided by the Fee Guidelines. 

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Morrison & Foerster LLP

425 Market Street 

San Francisco, CA 94105 

Case: 19-30088 Doc# 2502 Filed: 06/11/19 Entered: 06/12/19 15:47:12 Page 3 of

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1 6. Morrison & Foerster shall use its best efforts to avoid any duplication of services 

2 provided by any of the Debtors’ other retained professionals in these Chapter 11 Cases. 

3 7. Notice of the Application as provided therein shall be deemed good and sufficient 

4 notice thereof. 

5 8. Morrison & Foerster shall provide reasonable notice to the Debtors and the U.S. 

6 Trustee of any increase of Morrison & Foerster’s hourly rates. 

7 9. To the extent the Application is inconsistent with the terms of this Order, the terms 

8 of this Order shall govern. 

9 10. The Court shall retain jurisdiction to hear and determine all matters arising from or 

10 relating to the implementation, interpretation, or enforcement of this Order. 

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** END OF ORDER ** 

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Morrison & Foerster LLP

425 Market Street 

San Francisco, CA 94105 

Case: 19-30088 Doc# 2502 Filed: 06/11/19 Entered: 06/12/19 15:47:12 Page 4 of

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