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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)

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: (415) 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 -

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

STIPULATION BETWEEN DEBTORS 

AND UNITED STATES OF AMERICA

EXTENDING TIME TO RESPOND TO 

LEASE ASSUMPTION MOTION 

Re: Dkt. No. 3726

[No Hearing Requested]

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

 ̈ Affects PG&E Corporation

 ̈ Affects Pacific Gas and Electric Company

þ Affects both Debtors

* All papers shall be filed in the lead case, 

No. 19-30088 (DM)

Case: 19-30088 Doc# 3830 Filed: 09/06/19 Entered: 09/06/19 12:21:02 Page 1 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

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

entered into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), on the one hand, and the United States of 

America (the “United States”), on the other hand. The Debtors and the United States 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 August 27, 2019, the Debtors filed the Fifth Omnibus Motion of the Debtors 

Pursuant to 11 U.S.C. § 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 for an Order 

Approving Assumption of Certain Real Property Leases [Dkt. No. 3726] (the “Lease 

Assumption Motion”), which is set for a hearing before the Court at 9:30 a.m. on September 24, 

2019. Any response or opposition to the Lease Assumption Motion is due by 4:00 p.m. (Pacific 

Time) on September 10, 2019.

B. Counsel for the United States has requested, and counsel for the Debtors has 

agreed, that the time for the United States to respond to the Lease Assumption Motion be 

extended. 

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 United States to file and serve any response or opposition to the 

Lease Assumption Motion is extended through 4:00 p.m. (Pacific Time) on September 13, 2019.

[Signatures on next page]

Case: 19-30088 Doc# 3830 Filed: 09/06/19 Entered: 09/06/19 12:21:02 Page 2 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Dated: September 6, 2019 Dated: September 6, 2019

KELLER & BENVENUTTI LLP UNITED STATES DEPARTMENT OF 

JUSTICE, CIVIL DIVISION

/s/ Dara L. Silveira /s/ Danielle A. Pham

Dara L. Silveira

Attorneys for Debtors 

and Debtors in Possession

Danielle A. Pham

Attorneys for United States 

Case: 19-30088 Doc# 3830 Filed: 09/06/19 Entered: 09/06/19 12:21:02 Page 3 of

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