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Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice)

MILBANK LLP 

55 Hudson Yards

New York, New York 10001-2163

Telephone: (212) 530-5000

Facsimile: (212) 530-5219

and 

Gregory A. Bray (SBN 115367)

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor

Los Angeles, CA 90067

Telephone: (424) 386-4000

Facsimile: (213) 629-5063

Counsel for the Official Committee

of Unsecured Creditors

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION

- and -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

LIMITED OBJECTION OF THE OFFICIAL 

COMMITTEE OF UNSECURED 

CREDITORS TO DEBTORS’ CORRECTED

MOTION PURSUANT TO 11 U.S.C. 

§ 1121(d) TO EXTEND EXCLUSIVE 

PERIODS

Date: May 22, 2019

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

450 Golden Gate Avenue

San Francisco, CA 94102

Re: Docket No. 1797 

 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# 2009 Filed: 05/15/19 Entered: 05/15/19 15:01:56 Page 1 of

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44553.00001

The Official Committee of Unsecured Creditors (the “Committee”) respectfully submits 

this limited objection (the “Limited Objection”) to the Corrected Motion of Debtors’ Pursuant to 

11 U.S.C. § 1121(d) to Extend Exclusive Periods (the “Motion”) [Docket No. 1797], filed on May 

1, 2019. The Committee reserves all rights to be heard before the Court in connection with the 

Motion.

On January 29, 2019, the Debtors filed petitions for relief under chapter 11 of the 

Bankruptcy Code.

On February 12, 2019, the U.S. Trustee appointed and formed the Committee. As the 

statutorily appointed fiduciary, the Committee is duty-bound to safeguard the interests of a broad 

constituency of unsecured creditors holding more than $22 billion in claims in a wide variety of 

capacities. These individuals and companies play a critical role in supporting PG&E’s operations 

and their support is essential to preserving the operations of the restructured company.

Pursuant to the Motion, the Debtors seek an order extending for approximately six (6) 

months the periods during which they have the exclusive right to: (i) file a chapter 11 plan (the 

“Exclusive Filing Period”), through and including November 29, 2019, and (ii) solicit votes 

thereon, through and including January 28, 2020 (the “Exclusive Solicitation Period” and, together 

with the Exclusive Filing Period, the “Exclusive Periods”). 

This is a large, complex case and some extension of exclusivity is warranted. The 

Committee believes, however, that a four (4) month extension: (i) of the Exclusive Filing Period, 

through September 29, 2019, rather than through November 29, 2019; and (ii) of the Exclusive 

Solicitation Period, through November 29, 2019, rather than through January 28, 2020, is more 

appropriate. The Court and the parties in interest should be in a position by the beginning of the 

fall to assess the Debtors’ progress and the prospects for emergence from bankruptcy protection, 

such that September 29 is an appropriate checkpoint. Exclusivity is a significant right afforded by 

Case: 19-30088 Doc# 2009 Filed: 05/15/19 Entered: 05/15/19 15:01:56 Page 2 of

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44553.00001

Congress to debtors in possession, and the Court and the Debtors’ creditors should be assured it is 

being utilized properly by the Debtors to advance a restructuring at the swiftest pace that is 

reasonable under the circumstances and is generally supported by creditors.

WHEREFORE, for the reasons set forth in this Limited Objection, the Committee 

respectfully requests that this Court enter an order: (i) denying the Motion unless the extension of

the Exclusive Periods is reduced from six (6) months to four (4) months; and (ii) granting such 

other relief as is in the best interests of the Debtors’ estates. 

Dated: May 15, 2019

MILBANK LLP

/s/Gregory A. Bray .

DENNIS F. DUNNE

SAMUEL A. KHALIL

GREGORY A. BRAY

THOMAS R. KRELLER

Counsel for the Official Committee of 

Unsecured Creditors

Case: 19-30088 Doc# 2009 Filed: 05/15/19 Entered: 05/15/19 15:01:56 Page 3 of

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