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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO

Robert A. Julian (SBN 88469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Blvd., Suite 1400 

Los Angeles, CA 90025-0509 

Telephone: 310.820.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel to the Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

-andPACIFIC 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) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STATEMENT OF NON-OPPOSITION 

TO DEBTORS’ MUTUAL ASSISTANCE 

MOTION (Dkt. No. 2588) 

Hearing Date: July 9, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

Case: 19-30088 Doc# 2832 Filed: 07/02/19 Entered: 07/02/19 15:24:24 Page 1 of

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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW SAN FRANCISCO

 - 2 - 

On June 18, 2019, PG&E Corp. and Pacific Gas and Electric Company (collectively, the 

“Debtors” or “PG&E”) filed an Omnibus Motion Pursuant to 11 U.S.C. § 365(a), Fed. R. Bankr. 

P. 6006, and B.L.R. 6006-1 to Approve the Utility’s Assumption of Mutual Assistance Agreements 

(the “Mutual Assistance Motion”) (Dkt. No. 2588), which seeks authority to assume six 

agreements (the “Mutual Assistance Agreements”) that each provide a framework for the Debtors 

and other utilities or government agencies to voluntarily provide assistance to each other in 

emergency or disruptive situations. 

The Official Committee of Tort Claimants (the “TCC”) does not oppose the Mutual 

Assistance Motion, given the representations therein that assumption of the Mutual Assistance 

Agreements is necessary to avoid “difficulty in obtaining the critical and necessary assistance of 

other utilities during future outages and emergency situations” and that “the number of Assisting 

Parties which have responded to requests for mutual assistance following the commencement of 

the Chapter 11 Cases has been lower than the Utility would expect based on previous requests[.]” 

(Mutual Assistance Motion at pp. 11-12). Given the extreme importance of rapid response to fires, 

the Debtors should seek assurances from their counterparts that they will assist when requested. 

This is particularly true of the counterparts receiving cure payments, which exceed $28 million, but 

such amounts could pale in comparison to the costs of uncontained future wildfire liability. 

Dated: July 2, 2019 

BAKER & HOSTETLER LLP 

By: /s/ Lauren Attard 

Counsel to the Official Committee of Tort 

Claimants 

Case: 19-30088 Doc# 2832 Filed: 07/02/19 Entered: 07/02/19 15:24:24 Page 2 of

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