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WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Theodore E. Tsekerides (pro hac vice) 

(theodore.tsekerides@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

Attorneys for Debtors and Debtors in Possession

KELLER & BENVENUTTI LLP

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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 

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) 

DEBTORS’ OBJECTION TO THE EX 

PARTE MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

PURSUANT TO B.L.R. 9006-1 

REQUESTING ORDER SHORTENING 

TIME FOR HEARING ON MOTION FOR 

ENTRY OF AN ORDER 

DETERMININING PROCEDURES FOR 

PRESERVING JURY TRIAL RIGHTS

Related to Dkt. Nos. 3479 and 3481 

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# 3497 Filed: 08/11/19 Entered: 08/11/19 14:52:51 Page 1 of

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

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

as debtors and debtors in possession (collectively, the “Debtors”) in the above-captioned chapter 11 

cases (the “Chapter 11 Cases”), hereby submit this objection to the Ex Parte Motion of the Official 

Committee of Tort Claimants (the “TCC”) Pursuant to B.L.R. 9006-1 Requesting Order Shortening 

Time for Hearing on Motion for Entry of an Order Determining Procedures For Preserving Jury 

Trial Rights, Dkt. No. 3481 (the “Motion to Shorten”). 

On August 8, 2019, the TCC filed a Motion for Entry of an Order Determining Procedures 

for Preserving Jury Trial Rights, Dkt. No. 3479 (the “Jury Trial Motion”). On that same date, the 

TCC filed its Motion to Shorten, seeking to have its Jury Trial Motion heard on August 14, 2019, 

i.e., on six days’ notice. As the Court knows, there are already substantial issues set to be heard on 

August 14; issues that require the Debtors’—as well as the Court’s—immediate attention. The TCC 

sets forth only one justification for its requested highly expedited timeframe: if the Court requires 

the TCC to adhere to Bankruptcy Local Rule 9014-1(c)(2) and set their Jury Trial motion for hearing 

on September 10, 2019, their motion will be heard “only 41 days prior to the [October 21, 2019] bar 

date in these cases.” See Motion to Shorten at 3-4 (emphasis added). Simply stated, there is no 

reason to grant the Motion to Shorten. 

As an initial matter, a September 10, 2019 hearing will provide more than sufficient time for 

filing proofs of claim by any claimants who are “wait[ing] until confirmation of preservation of their 

jury trial rights to file their claims.” Motion to Shorten at 3. Also, missing from the Motion to 

Shorten is any explanation as to why, if the relief the TCC seeks in their Jury Trial Motion is truly so 

urgent, the TCC did not seek such relief earlier, having been aware of the Debtors’ motion to 

establish a bar date since it was filed on May 1, 2019. See Dkt. No. 1784. 

In addition, the parties may very well be able to resolve the issues presented in the Jury Trial 

Motion without the Court’s involvement, if provided the time contemplated by the Court’s Local 

Rules. For example, one such issue can be resolved now: the Debtors do not contend—and never 

contended—that the submission of claims data and information to the BrownGreer database waives 

Case: 19-30088 Doc# 3497 Filed: 08/11/19 Entered: 08/11/19 14:52:51 Page 2 of

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any jury trial rights that may exist with respect to wrongful death or personal injury claims.1 And 

while the Debtors similarly may not take issue with certain other aspects of the relief sought by the 

TCC, they need sufficient time to thoughtfully consider whether such relief is appropriate and 

whether and how any related issues should be addressed and the Debtors’ rights preserved in any 

order to be issued. 

For the reasons stated herein, the Court should deny the Motion to Shorten and set the 

hearing on the Jury Trial Motion for September 10, 2019, pursuant to Bankruptcy Local 

Rule 9014-1(c)(2). 

 Dated: August 11, 2019 

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

By: /s/ Theodore E. Tsekerides 

 Theodore E. Tsekerides 

Attorneys for Debtors and Debtors in Possession

1

 The TCC provides no authority even suggesting that claimants would in any way risk waiver of 

their jury trial rights by simply providing information to interested parties in these Chapter 11 

Cases, and this purported concern should not delay the Debtors’ access to the BrownGreer 

database that is long overdue. 

Case: 19-30088 Doc# 3497 Filed: 08/11/19 Entered: 08/11/19 14:52:51 Page 3 of

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