Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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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,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

EX PARTE APPLICATION FOR ORDER 

PURSUANT TO L.B.R. 9013-1(c) 

AUTHORIZING OVERSIZE BRIEFING FOR 

MEMORANDUM OF POINTS AND 

AUTHORITIES IN SUPPORT OF THE 

DEBTORS’ BAR DATE MOTION 

Related Document: Dkt. No. 1784 

[No hearing requested] 

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: 19-30088 Doc# 1818 Filed: 05/02/19 Entered: 05/02/19 18:06:06 Page 1 of

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PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the 

“Utility”), as debtors and debtors in possession (collectively, “PG&E” or the “Debtors”) in the 

above-captioned chapter 11 cases (the “Chapter 11 Cases”), hereby submit this Ex Parte

Application (the “Application”), pursuant to Rule 9013-1(c) of the Bankruptcy Local Rules for the 

United States District Court for the Northern District of California (the “Bankruptcy Local 

Rules”), for an order authorizing the Debtors to file an oversize memorandum of points and 

authorities in support of the Motion of Debtors Pursuant to 11 U.S.C. §§ 502(b)(9) and 105(a), 

Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 For Order (I) Establishing 

Deadline for Filing Proofs of Claim, (II) Establishing the Form and Manner of Notice Thereof, and 

(III) Approving Procedures for Providing Notice of Bar Date and Other Information to All 

Creditors and Potential Creditors (the “Bar Date Motion”)1 [Dkt. No. 1784], which the Debtors 

filed on May 1, 2019. 

In support of this Application, the Debtors submit the Declaration of Matthew P. 

Goren (the “Goren Declaration”), filed contemporaneously herewith. 

MEMORANDUM OF POINTS AND AUTHORITIES 

I. JURISDICTION 

The Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 

1334, the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General 

Order 24 (N.D. Cal.), and Bankruptcy Local Rule 5011-1(a). This is a core proceeding pursuant to 

28 U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

II. BACKGROUND 

On January 29, 2019 (the “Petition Date”), the Debtors commenced with the Court 

voluntary cases under chapter 11 of the Bankruptcy Code. The Debtors continue to operate their 

businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 

 

1

 Capitalized terms used but not defined herein have the meanings ascribed to them in the Bar Date 

Motion. 

Case: 19-30088 Doc# 1818 Filed: 05/02/19 Entered: 05/02/19 18:06:06 Page 2 of

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1108 of the Bankruptcy Code. The Debtors’ Chapter 11 Cases are being jointly administered for 

procedural purposes only pursuant to Bankruptcy Rule 1015(b). 

On February 12, 2019, the United States Trustee (the “U.S. Trustee”) appointed an 

Official Committee of Unsecured Creditors (the “Creditors Committee”). On February 15, 2019, 

the U.S. Trustee appointed an Official Committee of Tort Claimants (the “Tort Claimants 

Committee”). 

Additional information regarding the circumstances leading to the commencement 

of the Chapter 11 Cases and information regarding the Debtors’ businesses and capital structure is 

set forth in the Amended Declaration of Jason P. Wells in Support of the First Day Motions and 

Related Relief [Docket No. 263]. 

III. OVERSIZE BRIEFING FOR THE BAR DATE MOTION IS WARRANTED 

Bankruptcy Local Rule 9013-1(c) provides that, “Unless the Court expressly orders 

otherwise, the initial and response memoranda of points and authorities shall not exceed 25 pages of 

text, and reply memorandum shall not exceed 15 pages of text.” B.L.R. 9013-1(c). 

The Bar Date Motion seeks an order (i) establishing deadlines for filing proofs of claim 

(the “Bar Date”), (ii) establishing the form and manner of notice thereof, and (iii) approving the 

Debtors’ plan for providing notice of the Bar Date and other important deadlines and information to 

all creditors and potential creditors. Due to the unique nature of these Chapter 11 Cases, the Debtors 

are proposing special procedures to facilitate the submission and evaluation of Wildfire Claims, 

including, as discussed in the Bar Date Motion, a simpler Wildfire Claim Bar Date Notice and 

customized Proof of Claim Forms for both Wildfire Claimants and Wildfire Subrogation Claimants. 

The Debtors are also proposing special procedures for providing notice of the Bar Date to their 16 

million Customers, including a simpler Customer Bar Date Notice. In addition to serving the Bar Date 

Notices, as set forth in the Bar Date Motion, the Debtors intend to provide supplemental notice of the 

Bar Date to unknown creditors, including Unknown Wildfire Claimants, through a multi-faceted 

Supplemental Notice Plan that has been designed to reach its target audiences in a variety of different 

ways, including: (i) multiple newspaper publication notices, (ii) digital advertising, including social 

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media and other paid internet search listings, (iii) television and radio advertising, (iv) email notice, 

and (v) dedicated claim service centers. 

The Debtors submit that sufficient cause exists for the Court to allow oversize briefing 

for the Bar Date Motion. To adequately describe the Debtors’ unique circumstances, which necessitate 

and justify the Notice Procedures, and detail the special procedures of which the Debtors seek the 

Court’s approval pursuant to the Bar Date Motion, the Debtors believe it is appropriate to request 

authority for the MPA to exceed the 25 pages allowed under Bankruptcy Local Rule 9013-1(c). 

IV. NOTICE 

Notice of this Application will be provided to (i) the Office of the United States Trustee 

for Region 17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Creditors 

Committee; (iii) counsel to the Tort Claimants Committee; (iv) the Securities and Exchange 

Commission; (v) the Internal Revenue Service; (vi) the Office of the California Attorney General; (vii) 

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

Energy Regulatory Commission; (x) the Office of the United States Attorney for the Northern District 

of California; (xi) counsel for the agent under the Debtors’ debtor in possession financing facility; and 

(xii) those persons who have formally appeared in these Chapter 11 Cases and requested service 

pursuant to Bankruptcy Rule 2002. The Debtors respectfully submit that no further notice is required. 

No previous request for the relief sought herein has been made by the Debtors to this 

or any other court. 

WHEREFORE, the Debtors respectfully request entry of an order authorizing the 

Debtors to file a memorandum of points and authorities in support of the Bar Date Motion to exceed 

25 pages, but not to exceed 40 pages, and such other and further relief as the Court may deem just and 

appropriate. 

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Dated: May 2, 2019 WEIL, GOTSHAL & MANGES LLP 

 KELLER & BENVENUTTI LLP 

 By: /s/ Jane Kim 

 Jane Kim 

Attorneys for Debtors and Debtors in Possession 

Case: 19-30088 Doc# 1818 Filed: 05/02/19 Entered: 05/02/19 18:06:06 Page 5 of

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