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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)

SECOND STIPULATION BETWEEN 

DEBTORS AND OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

EXTENDING TIME FOR DEBTORS TO 

RESPOND TO MOTION OF OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ORDER DIRECTING DEBTORS TO 

SUPPLEMENT SCHEDULES

Re: Docket No. 2964

[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# 3622 Filed: 08/20/19 Entered: 08/20/19 15:55:44 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 Official Committee 

of Tort Claimants (the “Tort Claimants Committee”), on the other. The Debtors and the Tort 

Claimants Committee 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 July 12, 2019, the Tort Claimants Committee filed the Motion of the Official 

Committee of Tort Claimants for Order Directing Debtors to Supplement Schedules [Docket No. 

2964] (the “TCC Schedules Motion”) which is set for a hearing before the Court at 9:30 a.m. on

August 28, 2019. Pursuant to a Stipulation dated July 25, 2019 [Docket No. 3204], which the 

Court granted by Order dated July 26, 2019 [Docket No. 3223], the time for the Debtors to file 

and serve any response or opposition to the TCC Schedules Motion was extended through 4:00 

p.m. (Pacific Time) on August 7, 2019.

B. Counsel for the Debtors has requested, and counsel for the Tort Claimants 

Committee has agreed, that the time for the Debtors to respond to the TCC Schedules 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 Debtors to file and serve any response or opposition to the 

TCC Schedules Motion is extended through 4:00 p.m. (Pacific Time) on August 23, 2019.

[Signatures on next page]

Case: 19-30088 Doc# 3622 Filed: 08/20/19 Entered: 08/20/19 15:55:44 Page 2 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Dated: August 20, 2019 Dated: August 20, 2019

KELLER & BENVENUTTI LLP BAKER & HOSTETLER LLP

/s/ Jane Kim /s/ Lars Fuller

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

Lars Fuller

Attorneys for Official Committee of Tort 

Claimants

Case: 19-30088 Doc# 3622 Filed: 08/20/19 Entered: 08/20/19 15:55:44 Page 3 of

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