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DIEMER & WEI, LLP 

Kathryn S. Diemer (#133977) 

100 West San Fernando Street, Suite 555 

San Jose, CA 95113 

Telephone: (408) 971-6270 

Facsimile: (408) 971-6271 

Email: kdiemer@diemerwei.com 

WILLKIE FARR & GALLAGHER LLP 

Matthew A. Feldman (pro hac vice) 

Joseph G. Minias (pro hac vice) 

Benjamin P. McCallen (pro hac vice) 

787 Seventh Avenue 

New York, NY 10019-6099 

Telephone: (212) 728-8000 

Facsimile: (212) 728-8111 

Email: mfeldman@willkie.com 

 jminias@willkie.com 

 bmccallen@willkie.com 

Counsel for Ad Hoc Group of Subrogation Claim Holders

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 

Chapter 11 

(Lead Case)

(Jointly Administered) 

NOTICE OF HEARING ON THE MOTION OF 

THE AD HOC GROUP OF SUBROGATION 

CLAIM HOLDERS FOR RELIEF FROM THE 

AUTOMATIC STAY 

Date: July 24, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: July 19, 2019 at 4:00 p.m. 

Case: 19-30088 Doc# 2865 Filed: 07/03/19 Entered: 07/03/19 18:51:04 Page 1 of

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PLEASE TAKE NOTICE that on July 24, 2019, at 9:30 a.m. (Pacific Time) at the United 

States Bankruptcy Court for the Northern District of California, located at 450 Golden Gate Avenue, 

16th Floor, San Francisco, California in Courtroom 17 before the Honorable Dennis Montali, the Ad 

Hoc Group of Subrogation Claim Holders (“Ad Hoc Subrogation Group”) will bring on for a 

hearing its Motion for Relief from the Automatic Stay under Bankruptcy Code section 362(d) in 

order to pursue claims of the Ad Hoc Subrogation Group’s members against PG&E Corporation and 

Pacific Gas and Electric Company (hereinafter “PG&E” or the “Debtors”) regarding the issue of the 

Debtors’ liability for the Tubbs Fire in the California Superior Court, where the claims are currently 

pending in a Coordination Proceeding, Case No. 4955 (the “Motion”). 

The Motion is based on this Notice of Hearing, the Motion, the Memorandum of Points and 

Authorities in Support of the Ad Hoc Group of Subrogation Claim Holders’ Motion for Relief from 

the Automatic Stay and points and authorities therein, the Declaration of Benjamin P. McCallen and 

supporting exhibits, and such other and further evidence and matters that this Court may consider at 

the hearing of the Motion. 

PLEASE TAKE FURTHER NOTICE that any oppositions or responses to the Motion must 

be in writing, filed with the Bankruptcy Court, and served on the counsel for the Ad Hoc Subrogation 

Group at the above-referenced addresses so as to be received by no later than 4:00 p.m. (Pacific 

Time) on July 19, 2019. Any oppositions or responses must be filed and served on all “Standard 

Parties” as defined in, and in accordance with, the Second Amended Order Implementing Certain 

Notice and Case Management Procedures entered on May 14, 2019 (ECF No. 1996) (“Case 

Management Order”). 

PLEASE TAKE FURTHER NOTICE that as provided in Local Rule 4001-1(a), the Debtors 

are advised to appear personally or by counsel at the hearing, and that failure to do so may result in 

Case: 19-30088 Doc# 2865 Filed: 07/03/19 Entered: 07/03/19 18:51:04 Page 2 of

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this Court granting the relief requested without further hearing, including granting relief from the 

automatic stay to allow the Ad Hoc Subrogation Group to pursue claims of the Ad Hoc Subrogation 

Group’s members against the Debtors regarding the issue of the Debtors’ liability for the Tubbs Fire 

in the California Superior Court, where the claims are currently pending in a Coordination 

Proceeding, Case No. 4955. 

Dated: July 3, 2019 

WILLKIE FARR & GALLAGHER LLP 

/s/ Benjamin P. McCallen 

Matthew A. Feldman (pro hac vice) 

Joseph G. Minias (pro hac vice) 

Benjamin P. McCallen (pro hac vice) 

787 Seventh Avenue 

New York, NY 10019-6099 

Telephone: (212) 728-8000 

Facsimile: (212) 728-8111 

Email: mfeldman@willkie.com 

 jminias@willkie.com

bmccallen@willkie.com 

Counsel to the Ad Hoc Group of Subrogation Claim Holders 

Case: 19-30088 Doc# 2865 Filed: 07/03/19 Entered: 07/03/19 18:51:04 Page 3 of

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