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28 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 TRUSTEE 

EXTENDING TIME TO RESPOND TO 

WILDFIRE ASSISTANCE PROGRAM 

MOTION 

[Related to Dkt. No. 1777] 

[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# 2036 Filed: 05/16/19 Entered: 05/16/19 09:08:43 Page 1 of

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28 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”) and the Office of the United States Trustee 

(the “U.S. Trustee”). The Debtors and the U.S. Trustee 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 1, 2019, the Debtors filed the Motion Pursuant to 11 U.S.C. §§ 105(a)

and 363(b) and Fed. Bankr. P. 2002 and 6004(h) for an Order (a) Authorizing Debtors to 

Establish and Fund Program to Assist Wildfire Claimants with Alternative Living Expenses and 

Other Urgent Needs and (b) Granting Related Relief [Dkt No. 1777] (the “Wildfire Assistance 

Program Motion”), which is set for a hearing before the Court at 9:30 a.m. on May 22, 2019. 

Any response or opposition to the Wildfire Assistance Program Motion was due by 4:00 p.m. 

(Pacific Time) May 15, 2019 (“Response Deadline”). 

B. On May 15, 2019, prior to the Response Deadline, Counsel for the U.S. Trustee 

requested, and counsel for the Debtors agreed, that the time for the U.S. Trustee to respond to the 

Wildfire Assistance Program Motion be further 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 U.S. Trustee to file and serve any response or opposition 

to the Wildfire Assistance Program Motion is extended through 12:00 p.m. (Pacific Time) on 

May 17, 2019. 

[Signatures on next page] 

Case: 19-30088 Doc# 2036 Filed: 05/16/19 Entered: 05/16/19 09:08:43 Page 2 of

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

Dated: May 16, 2019 Dated: May 16, 2019

KELLER & BENVENUTTI LLP OFFICE OF THE UNITED STATES 

TRUSTEE 

/s/ Thomas B. Rupp /s/ Marta E. Villacorta

Thomas B. Rupp

Attorneys for Debtors 

and Debtors in Possession

Marta E. Villacorta

Trial Attorney 

Attorney for Andrew R. Vara, 

Acting United States Trustee for Region 31

 

1 Andrew R. Vara, Acting United States Trustee for Region 3, is acting in this appointment for Tracy Hope Davis, 

United States Trustee for Region 17, who is recused from the above-captioned cases.

Case: 19-30088 Doc# 2036 Filed: 05/16/19 Entered: 05/16/19 09:08:43 Page 3 of

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