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28 JOINDER OF ADDITIONAL PPA

COUNTERPARTIES IN NEXTERA’S MOTION

FOR LIMITED RELIEF FROM STAY TO 

PARTICIPATE IN APPELLATE PROCEEDINGS WITH 

RESPECT TO FERC ORDERS

CASE NO: 19-30088 (DM)

Amy S. Park (SBN 208204)

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 

525 University Avenue 

Palo Alto, California 94301 

Telephone: (650) 470-4500 

Facsimile: (650) 470-4570 

amy.park@skadden.com 

J. Eric Ivester (admitted pro hac vice) 

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 

Four Times Square 

New York, New York 10036-6522 

Telephone: (212) 735-3000 

Facsimile: (212) 735-2000 

eric.ivester@skadden.com 

Attorneys for 

FIRST SOLAR, INC., 

WILLOW SPRINGS SOLAR 3 LLC, 

AND MOJAVE SOLAR, LLC 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

 -andPACIFIC 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). 

Bankruptcy Case

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

JOINDER TO NEXTERA’S MOTION 

FOR LIMITED RELIEF FROM STAY 

TO PARTICIPATE IN APPELLATE 

PROCEEDINGS WITH RESPECT TO 

FERC ORDERS 

Date: June 26, 2019 

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

Place: United Stated Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: June 21, 2019 

4:00 p.m. (PST)

Case: 19-30088 Doc# 2452 Filed: 06/07/19 Entered: 06/07/19 13:31:53 Page 1 of

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1

JOINDER OF ADDITIONAL PPA

COUNTERPARTIES IN NEXTERA’S MOTION

FOR LIMITED RELIEF FROM STAY TO 

PARTICIPATE IN APPELLATE PROCEEDINGS WITH 

RESPECT TO FERC ORDERS

CASE NO: 19-30088 (DM)

 First Solar, Inc., Mojave Solar LLC, and Willow Springs Solar 3, LLC (collectively, the 

“Additional PPA Counterparties”) hereby join (the “Joinder”) in the motion [ of NextEra 

Energy, Inc. and NextEra Energy Partners, L.P. (collectively, “NextEra”) and the Memorandum of 

Points and Authorities [Docket No. 2400] filed in support thereof (collectively, the “NextEra Lift 

Stay Motion”), to lift the automatic stay (to the extent necessary) in the Bankruptcy Court for the 

Northern District of California (the “Bankruptcy Court”). 

Each of the Additional PPA Counterparties have been granted leave to intervene in the 

Adversary Proceeding1 and for the reasons set forth in the NextEra Lift Stay Motion, the 

Additional PPA Counterparties respectfully request that the Court enter an order (i) lifting the 

automatic stay to the extent necessary to permit the Additional PPA Counterparties to (a) seek 

leave from the applicable circuit court of appeals to intervene in any appeal of the FERC Orders (as 

defined in the NextEra Lift Stay Motion); (b) to the extent permitted by the applicable circuit court 

of appeals, participate in and prosecute to conclusion any appeal of the FERC Orders; (c) seek or 

oppose any request for rehearing, rehearing en banc, petition for writ of certiorari; (d) participate in 

the briefing and argument relating to any and all the foregoing; and (e) participate in any 

proceedings on remand of the FERC Orders; (ii) lifting the automatic stay to the extent necessary 

to generally allow all courts and administrative agencies with jurisdiction over the appeal or 

remand to enter final orders relating thereto; and (iii) granting such other and further relief as is just 

and proper. 

1

See In re PG&E Corp. et al., PG&E Corp. et al. v. Fed. Energy Reg. Comm., Adv. No. 19-03003 (DM) (Bankr. N.D. 

Cal.), Adv. Docket Nos. 89 and 90. 

Case: 19-30088 Doc# 2452 Filed: 06/07/19 Entered: 06/07/19 13:31:53 Page 2 of

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JOINDER OF ADDITIONAL PPA

COUNTERPARTIES IN NEXTERA’S MOTION

FOR LIMITED RELIEF FROM STAY TO 

PARTICIPATE IN APPELLATE PROCEEDINGS WITH 

RESPECT TO FERC ORDERS

CASE NO: 19-30088 (DM)

NOTICE 

Notice of this Joinder will be provided to (i) the Office of the U.S. Trustee for Region 17 

(Attn: Anthony R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Debtors; (iii) counsel 

to the Creditors Committee; (iv) counsel to the Tort Claimants Committee; (v) the Securities and 

Exchange Commission; (vi) the Internal Revenue Service; (vii) the Office of the California 

Attorney General; (viii) the California Public Utilities Commission; (ix) the Nuclear Regulatory 

Commission; (x) the Federal Energy Regulatory Commission; (xi) the Office of the United States 

Attorney for the Northern District of California; (xii) counsel for the agent under the Debtors’ 

debtor-in-possession financing facility; (xiii) counsel to the PPA Counterparties; and (xiv) those 

persons who have formally appeared in these chapter 11 cases and requested service pursuant to 

Bankruptcy Rule 2002. 

The Additional PPA Counterparties respectfully submit that no further notice is required. 

DATED: June 7, 2019 

SKADDEN, ARPS, SLATE, MEAGHER & FLOM, LLP

By: /s/ Amy S. Park

Amy S. Park 

Attorneys for 

FIRST SOLAR, INC. 

WILLOW SPRINGS SOLAR 3, LLC AND 

MOJAVE SOLAR LLC

Case: 19-30088 Doc# 2452 Filed: 06/07/19 Entered: 06/07/19 13:31:53 Page 3 of

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