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KELLER BENVENUTTI KIM LLP

Tobias S. Keller (#151445) 

(tkeller@kbkllp.com) 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized 

Debtors

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

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) 

ORDER APPROVING 

STIPULATION MODIFYING 

PLAN INJUNCTION (SONOMA 

COUNTY WATER AGENCY) 

 

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Signed and Filed: October 11, 2022

Entered on Docket 

October 11, 2022

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 13060 Filed: 10/11/22 Entered: 10/11/22 15:49:27 Page 1

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The Court having considered the Stipulation Modifying Plan Injunction (Mendocino County 

Inland Water and Power Commission), dated October 6, 2022 [Dkt. No. 13047] (the 

“Stipulation”),1 entered into by PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric 

Company (the “Utility”), as debtors and reorganized debtors (collectively, the “Debtors” and as 

reorganized pursuant to the Plan, the “Reorganized Debtors”) in the above-captioned cases (the 

“Chapter 11 Cases”), on the one hand, and Sonoma County Water Agency (“Sonoma Water”), 

on the other hand (collectively, the “Parties”); and pursuant to such Stipulation and agreement of 

the Parties, and good cause appearing, 

IT IS HEREBY ORDERED THAT: 

1. The Stipulation is approved. 

2. Upon the date of the entry of this Order, the Plan Injunction and any potentially 

applicable Plan provision is modified, to the extent necessary, to permit Sonoma Water to pursue 

the claims asserted or described in the Proofs of Claim (including the rights preserved and/or 

reserved in the Proofs of Claim) and any remedies associated therewith outside of these Chapter 

11 Cases as if the Chapter 11 Cases had not been commenced. 

3. Nothing in the Stipulation or this Order is intended, nor shall it be construed, to be a 

waiver or relinquishment by the Reorganized Debtors or Sonoma Water of any rights, claims, 

causes of action, rights of setoff, counter-claims, objections, arguments, or any legal or equitable 

defenses (including any rights, claims, causes of action, rights of setoff, counter-claims, 

objections, arguments, or any legal or equitable defenses that the Parties had immediately prior to 

the Petition Date), against or with respect to Sonoma Water’s claims or otherwise relating to or in 

connection with the Project or the Contract. 

4. The Reorganized Debtors or their agents are authorized to adjust the claims register 

to reflect the expungement of the Proofs of Claim. 

1

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to 

them in the Stipulation. 

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5. For the avoidance of doubt, nothing in the Stipulation or this Order shall affect or 

amend the MCIWPC Stipulation or MCIWPC Approval Order. 

6. The Stipulation shall be binding on the Parties and each of their successors in interest. 

7. The Stipulation shall constitute the entire agreement and understanding of the Parties 

relating to the subject matter thereof and supersedes all prior agreements and understandings relating 

to the subject matter hereof. 

8. This Court shall retain jurisdiction to resolve any disputes or controversies arising 

from this Order or the Stipulation. 

APPROVED AS TO FORM AND CONTENT: 

Dated: October 6, 2022 

COUNTY OF SONOMA

SONOMA COUNTY WATER AGENCY 

/s/ Adam Brand

Adam Brand

Chief Deputy County Counsel, 

County of Sonoma 

*** END OF ORDER *** 

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