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THOMAS F. KOEGEL (SBN 125852)

tkoegel@crowell.com

CROWELL & MORING LLP

3 Embarcadero Center, 26th Floor

San Francisco, CA 94111

Telephone: 415.986.2800

Facsimile: 415.986.2827

Attorneys for Creditors and Parties-in-Interest

Vantage and KES

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

PG&E CORPORATION

And

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case

Case No. No. 3:19-bk-30088-DM

Chapter 11

(Lead Case)

(Jointly Administered)

JOINDER OF VANTAGE WIND ENERGY 

LLC AND KES KINGSBURG, L.P., TO 

NEXTERA ENERGY’S LIMITED 

OPPOSITION TO 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: July 19, 2019*

4:00 p.m. (Pacific Time)

 Affects PG&E Corporation

 Affects Pacific Gas and Electric

Company

 Affects both Debtors

* All papers shall be filed in the Lead Case 

No. 3:19-bk-30088-DM

 *

As stated by the Debtor. The basis for the asserted deadline is not clear. Paragraph 27 of the Second 

Amended Order Implementing Certain Notice and Case Management Procedures [Docket No. 1996].sets a deadline 

of five days prior to the preliminary hearing for the Debtors and the Committees to respond to motions for relief from 

stay. It is not apparent that timing applies to other parties. But if it does, pursuant to the counting rules of FRBP 

9006(a), five days prior to the hearing would be Friday, July 21.

Case: 19-30088 Doc# 2692 Filed: 06/20/19 Entered: 06/20/19 17:01:02 Page 1 of

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-2- JOINDER TO LIMITED OPPOSITION;

CASE NO. NO. 3:19-BK-30088-DM

; CASE NO. NO. 3:19-BK-30088-DM

Vantage Wind Energy LLC and KES Ki Second Amended Order Implementing Certain 

Notice and Case Management Proedures [Docket No. 1996].ngsburg, L.P. (“Vantage and KES”) 

hereby join in the limited opposition of NextEra Energy, Inc. and NextEra Energy Partners, L.P. 

[Docket No. 2616] to the 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]. For the reasons stated by NextEra as to its own cause, Vantage and KES as intervenors in 

the proceedings that led to the FERC Orders should be granted reciprocal relief to that sought by

PG&E so that Vantage and KES may participate in any appeals of such Orders.

NOTICE

Vantage and KES respectfully submit that all required notice will be given by the 

Notification of Electronic Filing by ECF, as permitted by Paragraph 11 of the Second Amended 

Order Implementing Certain Notice and Case Management Procedures [Docket No. 1996].

Respectfully submitted, 

DATED: June 20, 2019 CROWELL & MORING LLP

By: /s/

Thomas F. Koegel

Attorneys for Creditors and Parties-in-Interest

Vantage Wind Energy LLC and KES Kingsburg, 

L.P.

Case: 19-30088 Doc# 2692 Filed: 06/20/19 Entered: 06/20/19 17:01:02 Page 2 of

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