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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) 

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 TURNER CONSTRUCTION 

COMPANY EXTENDING TIME TO 

RESPOND TO BAR DATE MOTION 

Re: Dkt. No. 1784 

[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# 2251 Filed: 05/28/19 Entered: 05/28/19 16:20:31 Page 1 of

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 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 Turner Construction 

Company (“Turner”), on the other hand. The Debtors and Turner 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. Counsel for Turner has requested, and counsel for the Debtors has agreed, that the 

time for Turner to respond to the Bar Date Motion be extended. 

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 Turner 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. 

[Signatures on next page] 

Case: 19-30088 Doc# 2251 Filed: 05/28/19 Entered: 05/28/19 16:20:31 Page 2 of

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

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

KELLER & BENVENUTTI LLP SEYFARTH SHAW LLP 

/s/ Jane Kim /s/ M. Ryan Pinkston

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

M. Ryan Pinkston

Attorneys for Turner Construction 

Company 

Case: 19-30088 Doc# 2251 Filed: 05/28/19 Entered: 05/28/19 16:20:31 Page 3 of

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