1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

New York, NY 10153-0119 

Tel: (212) 310-8000 

Fax: (212) 310-8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 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 - 

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

STIPULATION BETWEEN DEBTORS 

AND AD HOC GROUP OF 

SUBROGATION CLAIM HOLDERS 

EXTENDING TIME TO RESPOND TO 

DEBTORS’ BAR DATE MOTION AND 

MOTION OF THE AD HOC GROUP OF 

SUBROGATION CLAIM HOLDERS FOR 

ENTRY OF AN ORDER APPROVING 

PROPOSED MODEL OMNIBUS 

INSURANCE SUBROGATION PROOF 

OF CLAIM FORM FOR SUBROGATION 

CLAIMS AND RELATED PROCEDURES 

Re: Dkt. Nos. 1784, 2044 

[No Hearing Requested]

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: 19-30088 Doc# 2235 Filed: 05/28/19 Entered: 05/28/19 11:33:31 Page 1 of

3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

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

This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), on the one hand, and the Ad Hoc Group of 

Subrogation Claim Holders (the “Ad Hoc Subrogation Group”), on the other hand. The 

Debtors and the Ad Hoc Subrogation Group are referred to in this Stipulation and Agreement for 

Order collectively as the “Parties,” and each as a “Party.” The Parties hereby stipulate and 

agree as follows: 

RECITALS 

A. On May 1, 2019, the Debtors filed the Motion of Debtors Pursuant to 11 U.S.C. 

§§ 502(b)(9) and 105(a), Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 

for Order (I) Establishing Deadline for Filing Proofs of Claim, (II) Establishing the Form and 

Manner of Notice Thereof, and (III) Approving Procedures for Providing Notice of Bar Date and 

Other Information to All Creditors and Potential Creditors [Dkt. No. 1784] (the “Bar Date 

Motion”), which is set for a hearing before the Court at 9:30 a.m. on June 11, 2019. Any 

response or opposition to the Bar Date Motion is due by 4:00 p.m. (Pacific Time) on May 28, 

2019. 

B. On May 16, 2019, the Ad Hoc Subrogation Group filed the Motion of the Ad Hoc 

Group of Subrogation Claim Holders Pursuant to 11 U.S.C. § 105(a), 107(b) and 501 and Fed. 

R. Bankr. P. 3001(a) and 9018 for Entry of an Order Approving Proposed Model Omnibus 

Insurance Subrogation Proof of Claim Form for Subrogation Claims and Related Procedures

[Dkt. No. 2044] (the “Subrogation Claim Form Motion”), which is set for a hearing before the 

Court at 9:30 a.m. on June 11, 2019. Any response or opposition to the Subrogation Claim Form 

Motion is due by 4:00 p.m. (Pacific Time) on May 28, 2019.

C. Counsel for the Debtors and counsel for the Ad Hoc Subrogation Group have 

agreed that the time for the Ad Hoc Subrogation Group to respond to the Bar Date Motion and 

the time for the Debtors to respond to the Subrogation Claim Form Motion be extended. 

Case: 19-30088 Doc# 2235 Filed: 05/28/19 Entered: 05/28/19 11:33:31 Page 2 of

3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

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

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, 

THAT:

1. The time for the Ad Hoc Subrogation Group to file and serve any response or 

opposition to the Bar Date Motion is extended through 4:00 p.m. (Pacific Time) on May 31, 2019. 

2. The time for the Debtors file and serve any response or opposition to the 

Subrogation Claim Form Motion is extended through 4:00 p.m. (Pacific Time) on May 31, 2019. 

Dated: May 28, 2019 Dated: May 28, 2019

KELLER & BENVENUTTI LLP DIEMER & WEI LLP 

/s/ Jane Kim /s/ Alexander Lewicki

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

Alexander Lewicki

 

Attorneys for Ad Hoc Group of Subrogation 

Claim Holders

Case: 19-30088 Doc# 2235 Filed: 05/28/19 Entered: 05/28/19 11:33:31 Page 3 of

3