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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)

Daniel I. Forman (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

dforman@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 -

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

STIPULATION BETWEEN BARBARA 

ZELMER AND ROBERT ZELMER AND AD 

HOC GROUP OF SUBROGATION CLAIM 

HOLDERS EXTENDING TIME TO 

RESPOND TO BARBRA ZELMER AND 

ROBERT ZELMER’S MOTION FOR RELIEF 

FROM THE AUTOMATIC STAY

Re: Dkt. No. 2183

[No Hearing Requested]

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: 19-30088 Doc# 2375 Filed: 06/04/19 Entered: 06/04/19 12:17:14 Page 1 of

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This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by Barbara Zelmer and Robert Zelmer (collectively, the “Zelmers”), on the one 

hand, and the Ad Hoc Group of Subrogation Claim Holders (the “Ad Hoc Subrogation 

Group”), on the other hand. The Debtors and the Ad Hoc Subrogation Group are referred to in 

this Stipulation and Agreement for Order collectively as the “Parties,” and each as a “Party.” 

The Parties hereby stipulate and agree as follows: 

RECITALS

A. On May 22, 2019, the Zelmers filed their motion for relief from the automatic 

stay [Dkt. No. 2183] (the “Lift Stay Motion”), which is set for a hearing before the Court at 

9:30 a.m. on June 25, 2019. The notice of hearing for relief from stay [Dkt. No. 2185] (the 

“Notice”) states that any response or objection is to be “filed or received no later than (14) days 

after services of the Motion at 4:00 p.m.” 

B. Paragraph 27 of the Second Amended Order Implementing Certain Notice and 

Case Management Procedures [Dkt. No. 1996] provides, “Unless otherwise ordered by the 

Court, the objection deadline for Debtors and the two official creditors’ committees with respect 

to [any motion to lift the automatic stay] shall be 4:00 p.m. five (5) days prior to the scheduled 

hearing.”

C. Counsel for the Zelmers and counsel for the Ad Hoc Subrogation Group have 

agreed that the time for the Ad Hoc Subrogation Group to respond to the Lift Stay Motion should 

be extended to match the deadline provided to the Debtors and official creditors’ committees. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, 

THAT:

1. The time for the Ad Hoc Subrogation Group to file and serve any response or 

opposition to the Lift Stay Motion is extended through 4:00 p.m. (Pacific Time) on June 20, 2019.

Case: 19-30088 Doc# 2375 Filed: 06/04/19 Entered: 06/04/19 12:17:14 Page 2 of

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Dated: June 4, 2019 Dated: June 4, 2019

Manuel Corrales, Jr. DIEMER & WEI LLP

/s/ Manuel Corrales, Jr. /s/ Kathryn S. Diemer

Manuel Corrales, Jr.

Attorneys for the Zelmers

Kathryn S. Diemer

Attorneys for Ad Hoc Group of Subrogation 

Claim Holders

Case: 19-30088 Doc# 2375 Filed: 06/04/19 Entered: 06/04/19 12:17:14 Page 3 of

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