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STUTZMAN BROMBERG ESSERMAN

& PLIFKA, P.C.

2323 BRYAN STREET, SUITE 2200

DALLAS, TX 75201-2689

TELEPHONE: 214-969-4900

Sander L. Esserman (Admitted Pro Hac Vice)

Cliff I. Taylor (Admitted Pro Hac Vice)

STUTZMAN, BROMBERG, ESSERMAN & PLIFKA, P.C.

2323 Bryan Street, Suite 2200

Dallas, TX 75201-2689

Telephone: 214-969-4900

Email: esserman@sbep-law.com

Scott Summy

John Fiske (CSBN 249256)

BARON & BUDD, P.C.

3102 Oak Lawn Avenue #1100

Dallas, TX 75219

Telephone: 214-521-3605

Email: ssummy@baronbudd.com

Christopher H. Hart (CSBN 184117)

Kimberly S. Fineman (CSBN 184433)

NUTI HART LLP

411 30TH Street, Suite 408 

Oakland, CA 94609-3311

Telephone: 510-506-7152

Email: kfineman@nutihart.com

Attorneys for Public Entities Impacted by the Wildfires

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

In re

PG&E CORPORATION,

and

PACIFIC 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. 

Case No. 19-30088-DM

Chapter 11

Lead Case, Jointly Administered

WITHDRAWAL OF LIMITED OBJECTION 

OF PUBLIC ENTITIES IMPACTED BY 

THE WILDFIRES TO TCC’S BAR DATE 

MOTION AND STATEMENT WITH 

RESPECT TO THE RESPECTIVE BAR 

DATES FOR WILDFIRE CLAIMS

PROPOSED BY EACH OF THE DEBTORS 

AND THE OFFICIAL COMMITTEE OF 

TORT CLAIMANTS IN THEIR 

RESPECTIVE PLEADINGS TO THIS 

COURT

Date: June 26, 2019

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

Place: 450 Golden Gate Avenue, Ctrm 17 

 San Francisco, CA 94102

Judge: Hon. Dennis Montali

Case: 19-30088 Doc# 2706 Filed: 06/21/19 Entered: 06/21/19 13:43:19 Page 1 of

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STUTZMAN BROMBERG ESSERMAN

& PLIFKA, P.C.

2323 BRYAN STREET, SUITE 2200

DALLAS, TX 75201-2689

TELEPHONE: 214-969-4900

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The Public Entities Impacted by the Wildfires (the “Public Entities”)1hereby 

WITHDRAW their Limited Objection of Public Entities Impacted by the Wildfire to 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. 2654] (the “PE Limited Objection to TCC’s Bar Date Motion”) and 

provide the following statement with respect to the respective bar dates for Wildfire Claims 

proposed by each of the Debtors and the Official Committee of Tort Claimants (the “TCC”) in 

these bankruptcy cases:

WITHDRAWAL OF LIMITED OBJECTION AND STATEMENT 

WITH RESPECT TO PROPOSED BAR DATES

On June 19, 2019, the Public Entities filed the PE Limited Objection to TCC’s Bar Date 

Motion wherein the Public Entities expressed their concern that the January 31, 2020 bar date 

proposed by the TCC could possibly delay resolution of the Public Entities’ Wildfire Claims. 

After reviewing subsequent pleadings filed by interested parties in these bankruptcy cases, and 

after further consideration of, and deference to, the facts and circumstances of each of the other 

interested parties who will be affected by any bar date ordered by this Court, the Public Entities 

hereby WITHDRAW the PE Limited Objection to TCC’s Bar Date Motion. The Public Entities 

do not oppose either the January 31, 2020 bar date proposed by the TCC or the October 21, 2019

bar date proposed by the Debtors. However, the Public Entities urge this Court to enter an order 

 

1 The Public Entities consist of the following California public entities: (a) Calaveras County Water 

District, (b) Napa County, (c) City of Napa, (d) Mendocino County, (e) Lake County, (f) City of 

Clearlake, (g) Nevada County, (h) Yuba County, (i) City of Santa Rosa, (j) Sonoma County, (k) Sonoma 

County Agricultural Preservation and Open Space District, (l) Sonoma County Community Development 

Commission, (m) Sonoma County Water Agency, (n) Sonoma County Sanitation District, (o) Town of 

Paradise, and (p) Butte County.

Case: 19-30088 Doc# 2706 Filed: 06/21/19 Entered: 06/21/19 13:43:19 Page 2 of

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STUTZMAN BROMBERG ESSERMAN

& PLIFKA, P.C.

2323 BRYAN STREET, SUITE 2200

DALLAS, TX 75201-2689

TELEPHONE: 214-969-4900

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establishing a bar date that encourages prompt confirmation of a plan of reorganization in these 

bankruptcy cases.

Dated: June 21, 2019 STUTZMAN, BROMBERG, ESSERMAN & 

PLIFKA, P.C.

By: /s/ Sander L. Esserman

Sander L. Esserman

Attorneys for Public Entities Impacted by the Wildfires

Dated: June 21, 2019 BARON & BUDD, P.C.

By: /s/ Scott Summy

Scott Summy

Attorneys for Public Entities Impacted by the Wildfires

Dated: June 21, 2019 NUTI HART LLP

By: /s/ Kimberly S. Fineman

Kimberly S. Fineman

Attorneys for Public Entities Impacted by the Wildfires

Case: 19-30088 Doc# 2706 Filed: 06/21/19 Entered: 06/21/19 13:43:19 Page 3 of

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