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Bruce S. Bennett (SBN 105430) 

Joshua M. Mester (SBN 194783) 

James O. Johnston (SBN 167330) 

JONES DAY 

555 South Flower Street 

Fiftieth Floor 

Los Angeles, CA 90071.2300 

Telephone: +1.213.489.3939 

Facsimile: +1.213.243.2539 

E-mail: bbennett@jonesday.com 

 jmester@jonesday.com 

 jjohnston@jonesday.com 

Attorneys for PG&E Shareholders 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

- and - 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STIPULATION BETWEEN AD HOC 

COMMITTEE OF SENIOR 

UNSECURED NOTEHOLDERS AND 

CERTAIN PG&E SHAREHOLDERS 

EXTENDING TIME TO RESPOND TO 

MOTION OF THE AD HOC 

COMMITTEE OF SENIOR 

UNSECURED NOTEHOLDERS TO 

TERMINATE THE DEBTORS’ 

EXCLUSIVE PERIODS

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).

 

Re: Docket No. 2741 

[No Hearing Requested] 

Case: 19-30088 Doc# 3011 Filed: 07/16/19 Entered: 07/16/19 15:46:43 Page 1 of

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This stipulation (“Stipulation”) is entered into by the undersigned counsel acting on behalf 

of the Ad Hoc Committee of Senior Unsecured Noteholders of Pacific Gas and Electric Company 

(the “Ad Hoc Committee”) on the one hand, and certain owners of common stock of PG&E 

Corporation (the “PG&E Shareholders”) who desire to respond to the Motion to Terminate 

Exclusivity (as defined below),1 on the other hand. 

RECITALS AND STIPULATION 

A. On June 25, 2019, the Ad Hoc Committee filed its Motion of the Ad Hoc 

Committee of Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods 

Pursuant to Section 1121(d)(1) of the Bankruptcy Code [Dkt. No. 2741] (the “Motion to 

Terminate Exclusivity”). The Notice of Hearing on Motion of the Ad Hoc Committee of Senior 

Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods Pursuant to Section 

1121(d)(1) of the Bankruptcy Code [ECF 2744], set the hearing on the Motion to Terminate 

Exclusivity for July 23, 2019, at 9:30 a.m. (Pacific) and stated that any response or objection had 

to be filed by July 16, 2019, at 4:00 p.m. (Pacific). 

B. On July 2, 2019, the Court continued the hearing on the Motion to Terminate 

Exclusivity to July 24, 2019, at 9:30 a.m. (Pacific). 

C. Counsel for the Ad Hoc Committee and counsel for the PG&E Shareholders have 

agreed that the time for the PG&E Shareholders to respond to the Motion to Terminate 

Exclusivity should be extended. 

NOW THEREFORE, the parties stipulate and agree as follows: 

A. The time for the PG&E Shareholders to file and serve any response or opposition 

to the Motion to Terminate Exclusivity is extended through 4:00 p.m. (Pacific) on July 18, 2019. 

 

1

 The PG&E Shareholders are identified in the Verified Statement Of Jones Day Pursuant To 

Federal Rule Of Bankruptcy Procedure 2019 [ECF 2071]. 

Case: 19-30088 Doc# 3011 Filed: 07/16/19 Entered: 07/16/19 15:46:43 Page 2 of

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Dated: July 16, 2019 JONES DAY 

By: /s/ James O. Johnston 

James O. Johnston 

Attorneys for PG&E Shareholders 

 

Dated: July 16, 2019 AKIN GUMP STRAUSS HAUER & FELD 

LLP 

By: /s/ Ashley Vinson Crawford

Ashley Vinson Crawford 

Attorneys for the Ad Hoc Committee of Senior 

Unsecured Noteholders 

 

Case: 19-30088 Doc# 3011 Filed: 07/16/19 Entered: 07/16/19 15:46:43 Page 3 of

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