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44553.00001

Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice)

MILBANK LLP 

55 Hudson Yards 

New York, New York 10001-2163

Telephone: (212) 530-5000

Facsimile: (212) 530-5219

and 

Gregory A. Bray (SBN 115367)

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor

Los Angeles, CA 90067

Telephone: (424) 386-4000

Facsimile: (213) 629-5063

Counsel for the Official Committee

of Unsecured Creditors

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

 Debtors.

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

 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)

STIPULATION BETWEEN OFFICIAL 

COMMITTEE OF UNSECURED 

CREDITORS AND UNITED STATES 

TRUSTEE EXTENDING TIME TO 

RESPOND TO APPLICATION TO RETAIN 

AND EMPLOY AXIOM ADVISORS AS 

GOVERNMENT AFFAIRS CONSULTANT

TO THE COMMITTEE [DOCKET NO. 

1524]

[No Hearing Requested]

This stipulation and agreement for order (the “Stipulation”) is entered into by the (i) 

Official Committee of Unsecured Creditors (the “Committee”) appointed in the jointly 

Case: 19-30088 Doc# 1776 Filed: 05/01/19 Entered: 05/01/19 13:10:41 Page 1 of

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administered chapter 11 cases of the above-captioned debtors in possession, on the one hand; and 

(ii) the Office of the United States Trustee (the “U.S. Trustee” and together with the Committee, 

the “Parties”), on the other hand. The Parties hereby stipulate and agree as follows:

RECITALS

A. On April 17, 2019, the Committee filed the Application of the Official Committee 

of Unsecured Creditors for Authority to Retain and Employ Axiom Advisors as Government Affairs 

Consultant, Effective as of March 15, 2019 [Docket No. 1524] (the “Axiom Application”), which 

is set for hearing before the Court at 9:30 a.m. (Pacific Time) on May 9, 2019. Any response or 

opposition to the Axiom Application is due by 4:00 p.m. (Pacific Time) on May 1, 2019.

B. Counsel to the U.S. Trustee has requested, and counsel to the Committee has 

agreed, that the time for the U.S. Trustee to respond to the Axiom Application 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 the U.S. Trustee to file and serve any response or opposition to the 

Axiom Application is extended through 4:00 p.m. (Pacific Time) on May 3, 2019.

[Signatures on next page]

Case: 19-30088 Doc# 1776 Filed: 05/01/19 Entered: 05/01/19 13:10:41 Page 2 of

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Dated: May 1, 2019

MILBANK LLP

/s/ Thomas R. Kreller

Thomas R. Kreller

Attorneys for Official Committee of 

Unsecured Creditors

Dated: May 1, 2019

OFFICE OF THE UNITED STATES 

TRUSTEE

/s/ Marta E. Villacorta

Marta E. Villacorta

Trial Attorney 

Attorney for Andrew R. Vara, Acting 

United States Trustee for Region 31

 

1 Andrew R. Vara, Acting United States Trustee for Region 3, is acting in this appointment 

for Tracy Hope Davis, United States Trustee for Region 17, who is recused from the 

above-captioned cases.

Case: 19-30088 Doc# 1776 Filed: 05/01/19 Entered: 05/01/19 13:10:41 Page 3 of

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