1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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) 

767 Fifth Avenue

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: 650 636 9251

Attorneys for Debtors and Debtors in Possession

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice)

(pzumbro@cravath.com)

Kevin J. Orsini (pro hac vice)

(korsini@cravath.com)

Omid H. Nasab (pro hac vice)

(onasab@cravath.com)

825 Eighth Avenue

New York, NY 10019

Tel: 212 474 1000

Fax: 212 474 3700

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

 - and -

PACIFIC GAS AND ELECTRIC

COMPANY,

Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

EX PARTE APPLICATION FOR ORDER 

PURSUANT TO L.B.R. 9013-1(c) 

AUTHORIZING OVERSIZE BRIEFING FOR

DEBTORS’ OMNIBUS REPLY IN FURTHER

SUPPORT OF THE DEBTORS’ MOTION 

PURSUANT TO 11 U.S.C. §§ 105(a) AND 502(c) 

FOR THE ESTABLISHMENT OF WILDFIRE 

CLAIMS ESTIMATION PROCEDURES

Related Document: Dkt. No. 3091

[No hearing requested]

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# 3496 Filed: 08/09/19 Entered: 08/09/19 16:24:16 Page 1 of

4
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the 

“Utility”), as debtors and debtors in possession (collectively, “PG&E” or the “Debtors”) in the 

above-captioned chapter 11 cases (the “Chapter 11 Cases”), hereby submit this Ex Parte

Application (the “Application”), pursuant to Rule 9013-1(c) of the Bankruptcy Local Rules for the 

United States District Court for the Northern District of California (the “Bankruptcy Local 

Rules”), for an order authorizing the Debtors to file an oversize Omnibus Reply in Further Support 

of the Debtors’ Motion Pursuant to 11 U.S.C. §§ 105(a) and 502(c) for the Establishment of 

Wildfire Claims Estimation Procedures (the “Estimation Motion Omnibus Reply”)1, which the 

Debtors filed on the date hereof.

MEMORANDUM OF POINTS AND AUTHORITIES

I. JURISDICTION

The Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 

1334, the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General 

Order 24 (N.D. Cal.), and Bankruptcy Local Rule 5011-1(a). This is a core proceeding pursuant to 

28 U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409.

II. BACKGROUND

On January 29, 2019 (the “Petition Date”), the Debtors commenced with the Court 

voluntary cases under chapter 11 of the Bankruptcy Code. The Debtors continue to operate their 

businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 

1108 of the Bankruptcy Code. The Debtors’ Chapter 11 Cases are being jointly administered for 

procedural purposes only pursuant to Bankruptcy Rule 1015(b). 

On February 12, 2019, the United States Trustee (the “U.S. Trustee”) appointed an 

Official Committee of Unsecured Creditors (the “Creditors Committee”). On February 15, 2019, 

the U.S. Trustee appointed an Official Committee of Tort Claimants (the “Tort Claimants 

Committee”).

1 Capitalized terms used but not defined herein have the meanings ascribed to them in the Estimation 

Motion Omnibus Reply.

Case: 19-30088 Doc# 3496 Filed: 08/09/19 Entered: 08/09/19 16:24:16 Page 2 of

4
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Additional information regarding the circumstances leading to the commencement 

of the Chapter 11 Cases and information regarding the Debtors’ businesses and capital structure is 

set forth in the Amended Declaration of Jason P. Wells in Support of the First Day Motions and 

Related Relief [Docket No. 263].

On July 18, 2019, the Debtors filed the Debtors’ Motion Pursuant to 11 U.S.C. §§ 

105(a) and 502(c) for the Establishment of Wildfire Claims Estimation Procedures [Docket No. 

3091] (the “Estimation Motion”). At least twelve objections, joinders to objections, and other 

responses were filed with respect to the Estimation Motion (collectively, the “Objections”). At 

the hearing in these Chapter 11 Cases on July 24, 2019, the Court also directed the Debtors to 

address several additional questions for supplemental briefing in their Reply. On July 24, 2019, 

the Court set August 11, 2019 as the deadline for the Debtors to file a reply to the Objections and 

in further support of the Estimation Motion. [Transcript of July 24, 2019 Hearing at 31:20-21].

III. OVERSIZE BRIEFING FOR THE ESTIMATION MOTION OMNIBUS REPLY 

IS WARRANTED

Bankruptcy Local Rule 9013-1(c) provides that, “Unless the Court expressly orders 

otherwise, the initial and response memoranda of points and authorities shall not exceed 25 pages of 

text, and reply memorandum shall not exceed 15 pages of text.” B.L.R. 9013-1(c). 

The Debtors submit that sufficient cause exists for the Court to allow oversize briefing 

for the Estimation Motion Omnibus Reply. The Estimation Motion Omnibus Reply will respond to 

the twelve Objections filed. Among those Objections is the opposition filed by the Tort Claimants 

Committee [Docket No. 3431] (the “TCC Objection”), with respect to which the Tort Claimants 

Committee filed an ex parte application requesting an order authorizing oversize briefing [Docket No. 

3443]. The TCC Objection alone is thirty-two pages long and includes multiple appendices, two 

supporting declarations, and numerous exhibits. Additionally, the Estimation Motion Omnibus Reply 

addresses each of the topics the Court identified for supplemental briefing at the July 24, 2019 hearing. 

Because many of the Objections raise similar issues with respect to the Estimation

Motion, responding to the Objections by an omnibus reply is efficient. In order to respond sufficiently 

to twelve Objections, including the TCC Objection, and the questions posed by the Court in a single 

Case: 19-30088 Doc# 3496 Filed: 08/09/19 Entered: 08/09/19 16:24:16 Page 3 of

4
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

document, the Debtors submit that they require more than the 15 pages otherwise permitted under the 

Local Rules.

Accordingly, the Debtors believe it is appropriate to request authority for the 

Estimation Motion Omnibus Reply to exceed the 15 pages allowed under Bankruptcy Local Rule

9013-1(c).

IV. NOTICE

Notice of this Application will be provided to (i) the Office of the United States Trustee 

for Region 17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Creditors 

Committee; (iii) counsel to the Tort Claimants Committee; (iv) the Securities and Exchange 

Commission; (v) the Internal Revenue Service; (vi) the Office of the California Attorney General; (vii) 

the California Public Utilities Commission; (viii) the Nuclear Regulatory Commission; (ix) the Federal 

Energy Regulatory Commission; (x) the Office of the United States Attorney for the Northern District 

of California; (xi) counsel for the agent under the Debtors’ debtor in possession financing facility; and 

(xii) those persons who have formally appeared in these Chapter 11 Cases and requested service 

pursuant to Bankruptcy Rule 2002. The Debtors respectfully submit that no further notice is required.

No previous request for the relief sought herein has been made by the Debtors to this 

or any other court.

WHEREFORE, the Debtors respectfully request entry of an order authorizing the 

Debtors to file the Estimation Motion Omnibus Reply to exceed 15 pages, but not to exceed 25 pages

(exclusive of any schedules or exhibits thereto and/or any declarations filed in connection therewith), 

and such other and further relief as the Court may deem just and appropriate.

Dated: August 9, 2019 WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP

By: /s/ Jane Kim 

Jane Kim

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 3496 Filed: 08/09/19 Entered: 08/09/19 16:24:16 Page 4 of

4