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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)

767 Fifth Avenue

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: 650 636 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 -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered) 

DECLARATION OF JOHN BOKEN IN 

SUPPORT OF DEBTORS’ MOTION 

PURSUANT TO FED R. BANKR. P. 9006(b) AND 

9027 ENLARGING THE TIME WITHIN WHICH 

TO FILE NOTICES OF REMOVAL OF 

RELATED PROCEEDINGS

Date: May 22, 2019

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

☐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# 1739 Filed: 04/26/19 Entered: 04/26/19 18:26:37 Page 1 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

I, John Boken, pursuant to section 1746 of title 28 of the United States Code, hereby declare 

under penalty of perjury that the following is true and correct to the best of my knowledge, 

information, and belief:

1. I am a Managing Director in the Turnaround and Restructuring Services practice of 

AlixPartners, LLP, which is an affiliate of both AlixPartners, LLC and AP Services, LLC, (“APS”), 

which provides interim management services to Pacific Gas and Electric Corporation and Pacific Gas 

and Electric Company, as debtors and debtors-in-possession (collectively, “PG&E” or the “Debtors” 

and together with their non-Debtor subsidiaries, the “Company”) in the above-captioned Chapter 11 

Cases (the “Chapter 11 Cases”). I currently serve as the Deputy Chief Restructuring Officer (“Deputy 

CRO”) for the Debtors as authorized by this Court by Order dated April 9, 2019 [Docket No. 1299].1

2. Except as otherwise indicated herein, the facts set forth in this Declaration are based 

upon my personal knowledge, my review of relevant documents, and information provided to me by 

the Debtors’ other employees or the Debtors’ legal, restructuring, and financial advisors. If called 

upon to testify, I would testify competently to the facts set forth in this Declaration. I am authorized to 

submit this Declaration on behalf of the Debtors.

3. This Declaration is submitted in further support of the Debtors’ Motion Pursuant to 

Federal Rules of Bankruptcy Procedure 9006(b) and 9027 Enlarging the Time Within Which to File 

Notices of Removal of Related Proceedings filed contemporaneously herewith.

Litigation to Which the Debtors are a Party

4. As part of my role as Deputy CRO, I am aware that the Debtors are party to numerous

civil actions and proceedings. Given the sheer number of pending actions, the Debtors require 

additional time to consider whether to file notices of removal of the Civil Actions because the Debtors’ 

key personnel must assess these numerous lawsuits while concurrently attending to the day-to-day 

demands of these complex Chapter 11 Cases.

Enlarging the Time to Seek Removal

5. I understand that under Federal Rule of Bankruptcy Procedure 9027, for cases 

 1 My education, background, and professional experience is described in the Declaration of John Boken

in Further Support of First Day Motions and Related Relief [Docket No. 653] at 2–3.

Case: 19-30088 Doc# 1739 Filed: 04/26/19 Entered: 04/26/19 18:26:37 Page 2 of

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767 Fifth Avenue

New York, NY 10153-0119

commenced before January 29, 2019 (the “Petition Date”), the Debtors have 90 days from the Petition 

Date to remove claims or causes of action from state to federal court. I further understand that the 

deadline for such removal is April 29, 2019.

6. In addition to managing and operating a large and complex business enterprise, the 

Debtors must address and resolve in the chapter 11 plan process, the potentially thousands of wildfire 

claims that have already been asserted and will be asserted against them over the next several months. 

During the initial stages of these Chapter 11 Cases, the Debtors’ resources have been devoted to 

successfully assuring a smooth transition into chapter 11 and minimizing the business disruptions 

normally attendant thereto, maintaining relationships with the Debtors’ business partners, and 

establishing a collaborative working relationship with the U.S. Trustee, the Committees, as well as the 

Debtors’ other key economic stakeholders, including the ad hoc committee of senior unsecured 

noteholders, the ad hoc group of institutional bondholders, and the ad hoc group of subrogation claim 

holders. 

7. The Debtors’ primary focus has been on stabilizing their business by securing Court 

approval of $5.5 billion debtor-in-possession financing and obtaining certain relief with respect to their 

cash management system, employee compensation and benefit programs, customer and public purpose 

programs, insurance and surety bond programs, utility providers, taxes, certain safety and reliability 

suppliers, and lienholders, among others. 

8. In addition, in the less than three months following the Petition Date, the Debtors have 

filed a number of additional motions and applications seeking operational and other relief, addressed 

numerous requests to lift the automatic stay, filed their Schedules of Assets and Liabilities and 

Statements of Financial Affairs, and provided responses to numerous requests for diligence, including 

holding multiple meetings and calls with the Committees and their advisors, as well as other key 

economic stakeholders. During this same period, the Debtors and their professionals have met with the 

advisors to the Governor to address their inquiries and to provide information relevant to the ongoing 

work of the Governor’s Task Force and have met with the advisors for each of the Committees, the 

CPUC, the Ad Hoc Equity Holder Committee, and of the Ad Hoc Bondholders Committee to make 

Case: 19-30088 Doc# 1739 Filed: 04/26/19 Entered: 04/26/19 18:26:37 Page 3 of

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formal presentations as to the Debtors’ extensive business and operations. The Debtors are also in the 

midst of prosecuting two adversary proceedings: the first, to protect the Debtors’ rights under sections 

362 and 365 of the Bankruptcy Code, and the second, to preserve estate assets by enjoining actions 

against non-debtor co-defendants to whom the Debtors owe indemnification obligations. All of these 

tasks have taken significant time but were necessary to the effective administration of these Chapter 11 

Cases. As a result, the Debtors have not yet had the opportunity to fully examine all of the Civil 

Actions to determine the feasibility or benefit of removing each case. 

9. The Debtors are continuing to review their records to determine whether it would 

benefit their estates to remove any of the Civil Actions. To date, however, the Debtors have not made 

a determination as to which, if any, of the Civil Actions they may seek to remove. Therefore, I believe 

that it is prudent to seek an extension of the time prescribed under Bankruptcy Rule 9027(a), until 

October 28, 2019, to protect the Debtors’ right to remove those Civil Actions if they deem it to be 

appropriate. Extending the deadline to remove the Civil Actions will help to ensure that the Debtors 

do not forfeit valuable rights under 28 U.S.C. § 1452. 

Case: 19-30088 Doc# 1739 Filed: 04/26/19 Entered: 04/26/19 18:26:37 Page 4 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury, that the foregoing is true

and correct to the best of my knowledge, information, and belief.

Dated: April 26, 2019

John Boken

Case: 19-30088 Doc# 1739 Filed: 04/26/19 Entered: 04/26/19 18:26:37 Page 5 of

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