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AKIN GUMP STRAUSS HAUER & FELD LLP

Michael S. Stamer (pro hac vice)

Ira S. Dizengoff (pro hac vice)

David H. Botter (pro hac vice)

Abid Qureshi (pro hac vice)

One Bryant Park

New York, New York 10036

Telephone: (212) 872-1000

Facsimile: (212) 872-1002

Email: mstamer@akingump.com

idizengoff@akingump.com

dbotter@akingump.com

 aqureshi@akingump.com

AKIN GUMP STRAUSS HAUER & FELD LLP

Ashley Vinson Crawford (SBN 257246)

580 California Street

Suite 1500

San Francisco, CA 94104

Telephone: (415) 765-9500

Facsimile: (415) 765-9501

Email: avcrawford@akingump.com

Counsel to the Ad Hoc Committee of Senior Unsecured

Noteholders of Pacific Gas and Electric Company 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

JOINDER OF THE AD HOC COMMITTEE 

OF SENIOR UNSECURED 

NOTEHOLDERS TO OBJECTION OF THE 

OFFICIAL COMMITTEE OF UNSECURED 

CREDITORS TO DEBTORS’ WILDFIRE 

ASSISTANCE MOTION

Hearing

Date: May 22, 2019

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

Place: Courtroom 17

 450 Golden Gate Ave, 16th Floor

 San Francisco, CA 94102

Re: Docket Nos. 1777, 2041

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# 2058 Filed: 05/16/19 Entered: 05/16/19 16:48:51 Page 1 of

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The Ad Hoc Committee of Senior Unsecured Noteholders of Pacific Gas and Electric Company 

(the “Ad Hoc Committee”) in the above-captioned chapter 11 cases of Pacific Gas and Electric Company 

(the “Utility”) and PG&E Corporation (“PG&E” and, together with the Utility, the “Debtors”), by its 

undersigned counsel, Akin Gump Strauss Hauer & Feld LLP, hereby joins (the “Joinder”) the Corrected 

Objection of the Official Committee of Unsecured Creditors to Motion of Debtors Pursuant to 11 U.S.C. 

§ 105(a) and 363(b) and Fed. R. Bankr. P. 2002 and 6004(h) for an Order (A) Authorizing Debtors to 

Establish and Fund Program to Assist Wildfire Claimants with Alternative Living Expenses and Other 

Urgent Needs (B) Granting Related Relief [Docket. No. 2041] (the “UCC Objection”). 1 In support of 

the Joinder, the Ad Hoc Committee respectfully states the following:

JOINDER

1. The Ad Hoc Committee joins the Official Committee of Unsecured Creditors (the 

“UCC”) in expressing its sympathy for the tragedy that the victims of the wildfires of 2017 and 2018

have had to endure. The Ad Hoc Committee, however, joins in the UCC Objection and agrees with the 

UCC that the Program is flawed and, therefore, can only be approved if modified in accordance with the 

UCC Objection to the Motion Pursuant to 11 U.S.C. §§ 105(a) and 363(b) and Fed. R. Bankr. P. 2002 

and 6004(h) for an Order (a) Authorizing Debtors to Establish and Fund Program to Assist Wildfire

Claimants with Alternative Living Expenses and Other Urgent Needs and (b) Granting Related Relief 

(“Wildfire Assistance Program Motion”) [Docket. No. 1777] (the “Motion”). In particular, the Ad Hoc 

Committee believes that the UCC’s concern that the Court “should remain mindful that it stands atop a 

slippery slope that very well may lead to additional ‘creeping confirmation’ requests,” UCC Objection 

¶ 8, is particularly apt in light of the fact that several requests have already been made to either increase

the amount of the Fund or make additional payments to different groups of plaintiffs. 

2. Specifically, shortly before the filing of the UCC Objection, the Official Committee of 

Tort Claimants filed the Official Committee of Tort Claimants’ Limited Joinder, Objection and Counter 

Motion to Debtors’ Wildfire Assistance Program Motion (Dkt. No. 1777) [Docket No. 2013], requesting 

that the Fund be increased to at least $250 million, with the option for the Administrator to seek 

1 Capitalized terms used, but not defined, herein shall have the meanings ascribed to them in the UCC Objection.

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additional amounts.2In addition, a group of wildfire claimants represented by the Singleton Law Firm 

(the “SLF Claimants”), filed the Objection by the Singleton Law Firm Fire Victim Claimants to PG&E’s 

Exclusivity Motion (Doc. 1795)[Docket No. 2019], requesting that the Court order the Debtors to resume 

a prepetition mediation system to begin immediately settling claims relating to the 2015 Butte Fire. The 

SLF Claimants estimate that remaining damages arising from that fire are between $100 million and 

$150 million. 

3. The Ad Hoc Committee is prepared to sit down with all the major parties in interest prior 

to the hearing to discuss the implementation of a program to aid wildfire victims, with appropriate 

safeguards, as the UCC has suggested. Ultimately, as previously stated in the Statement of the Ad Hoc 

Committee of Senior Unsecured Noteholders to Corrected Motion of Debtors Pursuant to 11 U.S.C. § 

1121(d) to Extend Exclusive Periods [Docket No. 2008], and echoed by the sentiments expressed by 

Governor Newsom in the Limited Objection of Governor Gavin Newsom to Corrected Motion of Debtors 

Pursuant to 11 U.S.C. § 1121 (d) to Extend Exclusive Periods [Docket No. 2006], the Ad Hoc Committee 

believes that it is in the best interests of all stakeholders for all of the key parties in interest to turn their 

full attention to negotiating a confirmable plan of reorganization so that all creditors, including all 

wildfire victims with claims against the Debtors, can have their claims satisfied as quickly as possible.

RESERVATION OF RIGHTS

4. The Ad Hoc Committee reserves the right to raise further and other objections to the 

Motion at the hearing as may be necessary or appropriate.

[Remainder of page left intentionally blank]

2 The Ad Hoc Committee reserves its right to object to the Official Committee of Tort Claimant’s CounterMotion within 

the time period provided under the Second Amended Order Implementing Certain Notice and Case Management 

Procedures[Docket No. 1996] and the applicable local rules.

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WHEREFORE, for the foregoing reasons, the Ad Hoc Committee respectfully requests that the 

Court (i) sustain the UCC Objection and only grant the Motion to the extent modified as proposed by 

the UCC, and (ii) grant such other and further relief as is just, equitable and proper. 

Dated: May 16, 2019 AKIN GUMP STRAUSS HAUER & FELD LLP

By:

David H. Botter (pro hac vice) 

Michael S. Stamer (pro hac vice) 

Ira S. Dizengoff (pro hac vice) 

Abid Qureshi (pro hac vice) 

Ashley Vinson Crawford (SBN 257246) 

Counsel to the Ad Hoc Committee of Senior Unsecured 

Noteholders of Pacific Gas and Electric Company 

Case: 19-30088 Doc# 2058 Filed: 05/16/19 Entered: 05/16/19 16:48:51 Page 4 of

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