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JENNER & BLOCK LLP 

Randall E. Mehrberg 

353 N. Clark Street 

Chicago, IL 60654 

Tel: 312 840 7505 

rmehrberg@jenner.com 

Special Corporate Defense & Energy Counsel 

for Debtors and Debtors in Possession 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

- and -

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

 Affects PG&E Corporation 

 Affects Pacific Gas & Electric Company 

 X Affects both Debtors 

* All papers shall be filed in the Lead Case,

No. 19-30088 (DM).

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

FIRST INTERIM APPLICATION 

OF JENNER & BLOCK LLP AS 

SPECIAL CORPORATE DEFENSE AND 

ENERGY COUNSEL TO THE DEBTORS 

FOR COMPENSATION FOR SERVICES 

RENDERED AND REIMBURSEMENT 

OF EXPENSES INCURRED FOR THE 

PERIOD FROM JANUARY 29, 2019 

THROUGH MAY 31, 2019 

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General Information 

Name of Applicant: Jenner & Block LLP 

Authorized to Provide Professional Services to: Special corporate defense and energy 

counsel to the above-captioned Debtors 

and Debtors in Possession 

Petition Date: January 29, 2019 

Retention Date: April 25, 2019, nunc pro tunc to January 

29, 2019 

Prior Applications: None 

Summary of Fees and Expenses Sought for the First Interim Application Period 

Time Period Covered By This Application: January 29, 2019 through May 31, 2019 

(the “First Interim Application Period”) 

Amount of Compensation Sought to Be Allowed 

as Actual, Reasonable, and Necessary for the 

First Interim Application Period: 

$3,484,976.50 

Amount of Expense Reimbursement Sought to 

Be Allowed as Actual, Reasonable, and 

Necessary for the First Interim Application 

Period: 

$21,436.56 

Total Compensation and Expense 

Reimbursement Sought to Be Allowed for the 

First Interim Application Period: 

$3,506,413.06 

Fees (80%) and Expenses (100%) Previously 

Paid for the First Interim Application Period: 

N/A 

Holdback Amount (20% of Fees): N/A 

Summary of Rates and Other Related Information for the First Interim Application Period

Blended Rate in This Application for All 

Attorneys: $594.29 

Blended Rate in This Application for All 

Timekeepers: $580.33 

Number of Timekeepers Included in This 

Application: 

49 (41 attorneys; 8 paraprofessionals and 

other non-legal staff) 

Number of Attorneys in this Application Not 

Included in Staffing Plan: 

None. 

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Difference Between Fees Budgeted and 

Compensation Sought for This Period: 

Fees were less than budgeted amount. 

Are any rates higher than those approved or 

disclosed at retention? 

No. 

This is a(n): x Interim Final Application 

SUMMARY OF PRIOR MONTHLY FEE STATEMENTS 

Date 

Filed 

Period 

Covered 

Total Compensation and 

Expenses Incurred for 

Period Covered 

Total Amount Previously 

Requested with Prior 

Monthly Fee Statement 

Total Amount Paid 

To Date1

Holdback Fees 

Requested 

Fees Expenses Fees (80%) Expenses 

(100%) 

Fees 

(80%) 

Expenses 

(100%) Fees (20%) 

8/8/19 

1/29/19 -

5/31/19 

$3,484,976.50 $21,436.56 $2,787,981.20 $21,436.56 $0.00 $0.00 $696,995.30 

Total $3,484,976.50 $21,436.56 $2,787,981.20 $21,436.56 $0.00 $0.00 $696,995.30 

1

 The objection deadline with respect to Jenner’s First Monthly Fee Statement is August 29, 2019. If the 

deadline passes without objection, the Debtors will remit $2,787,981.20 in compensation for fees and 

$21,436.56 in reimbursement of expenses. 

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Under sections 330 and 331 of title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. (the 

“Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy 

Rules”), and the Order Pursuant to 11 U.S.C. §§ 130 and 105(a) and Fed. R. Bankr. P. 2016 for Authority 

to Establish Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Dkt. 

701] (the “Compensation Procedures Order”), Jenner & Block LLP (the “Applicant” or “Jenner &

Block”) submits this First Interim Fee Application of Jenner & Block LLP as Special Corporate Defense 

Counsel to the Debtors for Compensation for Services Rendered and Reimbursement of Expenses Incurred 

for the Period January 29, 2019 Through May 31, 2019 (the “First Interim Fee Application”), seeking 

interim allowance and payment of compensation for services rendered and reimbursement of actual and 

necessary expenses incurred by Jenner & Block for the period January 29, 2019 through May 31, 2019 

(the “First Interim Application Period”). In support of this First Interim Fee Application, Jenner & 

Block submits the Certification of Randall M. Mehrberg attached hereto as Exhibit A, and respectfully 

states as follows: 

JURISDICTION, VENUE AND STATUTORY PREDICATES 

1. This Court has jurisdiction over this matter under 28 U.S.C. §§ 157 and 1334. This is core

proceeding under 28 U.S.C. § 157(b). Venue of this proceeding is proper in this district under 28 U.S.C. 

§§ 1408 and 1409.

2. The statutory predicates for the relief sought in this First Interim Fee Application are

sections 330 and 331 of the Bankruptcy Code and Bankruptcy Rule 2016. This First Interim Fee 

Application has been prepared in accordance with the Guidelines for Compensation and Expense 

Reimbursement of Professionals and Trustees in the United States Bankruptcy Court for the Northern 

District of California (updated February 19, 2014) (the “Local Guidelines”) and the Guidelines for 

Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under United States 

Code by Attorneys in Larger Chapter 11 Cases, adopted by the Executive Office for the United States 

Trustee (the “UST Guidelines”, and together with the Local Guidelines, the “Guidelines”). Attached 

hereto is a certification regarding compliance with the Guidelines. 

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BACKGROUND 

3. On January 29, 2019 (the “Petition Date”), each of the Debtors filed a voluntary petition

for relief 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. No trustee or examiner has been appointed in either of the Chapter 11 Cases. The Debtors’ Chapter 

11 Cases are being jointly administered for procedural purposes only pursuant to Bankruptcy Rule 

1015(b). 

4. 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” and, together with 

the Creditors Committee, the “Committees”). 

5. 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 [Dkt. 

263] (the “Wells Declaration”).

6. On April 25, 2019, the Court approved the Debtors’ employment of Jenner & Block as

special corporate defense and energy counsel nunc pro tunc to January 29, 2019 (the “Retention Order”). 

[Dkt. 1679.] A copy of the Retention Order is attached hereto as Exhibit B. The Retention Order authorized 

Jenner & Block to render the following services to the Debtors during the pendency of these Chapter 11 

Cases: 

(a) draft motions and briefs, appear at hearings, and otherwise represent

[Pacific Gas & Electric Company] in connection with the probation and the

monitorship resulting from the criminal investigation and convictions

relating to the natural gas explosion that occurred in the City of San Bruno,

California, on September 9, 2010 (the “Criminal Case”);

(b) advise the Debtors in complying with the probationary measures imposed

in the Criminal Case;

(c) advise the Debtors in connection with various regulatory and enforcement

matters involving the Federal Energy Regulatory Commission, Department

of the Interior, Federal Communications Commission, and other federal

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agencies, and/or California state agencies, including the California Public

Utilities Commission; 

(d) conduct internal investigations and advise the Debtors with respect to

remediation of same, including in defending the Debtors in any regulatory

actions taken against the Debtors;

(e) assist, as requested, with matters relating to the aforementioned services as

they may impact the Chapter 11 Cases; and

(f) perform all other necessary legal services required by the Debtors during

the pendency of their Chapter 11 Cases.

7. An overview of the current status of these Chapter 11 Cases is set forth in the First Interim

Fee Application of Weil, Gotshal & Manges LLP for Allowance and Payment of Compensation and 

Reimbursement of Expenses for the Period January 29, 2019 Through and Including April 30, 2019 [Dkt. 

2988]. 

SUMMARY OF SERVICES RENDERED AND DISBURSEMENTS INCURRED 

8. This is Jenner & Block’s first interim fee application in this case.

9. Jenner & Block attaches the following in support of its First Interim Fee Application:

 Exhibit C is a summary of the compensation Jenner & Block seeks for the

First Interim Application Period, by matter number.

 Exhibit D is a list of the attorneys and paraprofessionals who have worked

on this case during the First Interim Application Period, the aggregate time

invested by each individual, the applicable hourly billing rate, and the

amount of fees attributable to each individual, as well as the hours and time

spent by position (e.g., partner, associate, paralegal).

 Exhibit E contains a list of time entries reflecting the time recorded during

the First Interim Application Period, organized in project billing categories

by Jenner & Block.

 Exhibit F is a summary of reimbursement Jenner & Block seeks, by

expense type, for all expenses incurred during the First Interim Application

Period.

 Exhibit G contains a list of expenses incurred during the First Interim

Application Period.

 Exhibit H contains a comparison of the fees requested for services rendered

during the First Interim Application Period against the fees budgeted for

the First Interim Application Period.

 Exhibit I contains a comparison of Jenner & Block professionals who

rendered services during the First Interim Application Period against the

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staffing plan approved by the Debtors for the First Interim Application 

Period. 

 Exhibit J contains a comparison of the blended hourly rates for amounts

requested in the First Interim Fee Application against the blended hourly

rates for amounts billed by all nonbankruptcy lawyers at Jenner & Block

in 2018.

Narrative Summary of Services Rendered by Project Category 

10. The following is a brief description of the principal activities of Jenner & Block’s

professionals during the First Interim Application Period for each project category, consistent with the 

requirements of section C(8)(c) of the U.S. Trustee Guidelines and section I.3 of the Local Guidelines. 

For each project category, the narrative summary provides a description of the services rendered in that 

category, their necessity and benefit to the estate, and the current status, as applicable: 

Criminal Investigation (10006), North Bay Fires – Monitorship (10090) 

These matter numbers encompass services rendered in connection with PG&E’s sentencing and 

term of probation, which includes a monitorship. During the First Interim Application Period, Jenner & 

Block professionals spent a total of 501.2 hours on these categories having a lodestar value of $384,188.10. 

The services in this category include, among other things: drafting sections of responses to multiple orders 

from Judge Alsup of the Northern District of California and coordinating with co-counsel regarding 

sections of responses drafted by co-counsel; preparing for and participating in probation hearings; working 

on an audit response letter; conducting legal research related to various probation and monitorship issues; 

preparing for a sentencing hearing on a probation violation; and counseling the company in relation to 

ongoing issues that impact the terms of probation, including ongoing investigations into various wildfires. 

These categories also includes various telephone calls, email correspondence, and other administrative 

services provided in connection with the foregoing matters. The services in these categories were 

necessary to assist PG&E in complying with PG&E’s terms of probation. The status of these matters is 

ongoing. 

DOI Investigation (10014) 

This matter number encompasses services rendered in connection with a suspension and 

debarment investigation conducted by the U.S. Department of the Interior (“DOI”). During the First 

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Interim Application Period, Jenner & Block professionals spent a total of 4.0 hours on this category having 

a lodestar value of $2,941.60. The services in this category include various communications among Jenner 

& Block attorneys and PG&E representatives relating to the DOI investigation. The services in this 

category were necessary to assist PG&E in complying with its obligations under federal law. The status 

of this matter is ongoing. 

Federal Contracts Advice and Counsel (10065) 

This matter number encompasses services rendered in connection with administration and 

compliance with federal contracts and grants. During the First Interim Application Period, Jenner & Block 

professionals spent a total of 15.0 hours on this category having a lodestar value of $11,415.00. The 

services in this category include, among other things, advising on contract negotiations and required 

representations and certifications. This category also includes various telephone calls, email 

correspondence, and other administrative services provided in connection with the foregoing matters. The 

services in this category were necessary to continue proper administration and compliance with federal 

contracts and grants. The status of this matter is ongoing. 

FCC Regulatory Advice and Counsel (10081) 

This matter number encompasses services rendered in connection with the notification to the Federal 

Communications Commission (“FCC”) of PG&E’s bankruptcy status in connection with its control of 

various FCC wireless radio service spectrum licenses. During the First Interim Application Period, Jenner 

& Block professionals spent a total of 51.70 hours on this category having a lodestar value of $32,675.60. 

The services in this category include, among other things: investigating facts and conducting legal research 

related to notification requirements, conferring and coordinating with PG&E and its bankruptcy counsel 

regarding FCC issues, preparing the necessary notification materials for filing with the FCC, and 

interaction with the FCC to ensure PG&E’s actions were in accordance with the FCC’s rules. This category 

also includes various telephone calls, email correspondence, and other administrative services provided 

in connection with the foregoing matters. The services in this category were necessary to ensure that 

PG&E remains in compliance with its obligations as an FCC licensee. The status of this matter is ongoing.

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Locate & Mark (10111) 

This matter number encompasses services rendered in connection with the California Public 

Utilities Commission’s (“CPUC”) December 14, 2018 Order Instituting Investigation and Order to Show 

Cause (OII), to assess the Debtors' practices and procedures related to the locating and marking (“L&M”) 

of their underground facilities. During the First Interim Application Period, Jenner & Block professionals 

spent a total of 5,025.30 hours on this category having a lodestar value of $2,783,361.00. The services in 

this category include, among other things: investigation, document reviews and interviews regarding 

PG&E’s practices with respect to the locating and marking of both gas and electric facilities; the 

preparation of a report, filed in the OII, regarding L&M practices during the 2012-2017 period at issue in 

the OII; research and analysis of legal theories relevant to the OII; counseling regarding the factual, legal, 

and strategic issues in the OII; support and involvement in discovery; support in preparation for prehearing 

conferences; preparation for settlement discussions; and preparation for evidentiary hearings now 

scheduled for October 2019. This category also includes various telephone calls, email correspondence, 

and other administrative services provided in connection with the foregoing matters. The services in this 

category were necessary to address PG&E’s potential financial, legal and regulatory exposure in a 

proceeding in which the CPUC seeks a variety of penalties and fines, including monetary and nonmonetary relief. The status of this matter is ongoing. 

Triennial MBR Filing (10138) 

This matter number encompasses services rendered in connection with the company’s 

authorization from the Federal Energy Regulatory Commission to make energy sales at market-based rates 

and the scope of federal jurisdiction over PG&E’s purchases and sales of energy resource adequacy 

products. During the First Interim Application Period, Jenner & Block professionals spent a total of 2.2 

hours on this category having a lodestar value of $1,628.00. The services in this category include, among 

other things, legal research on resource adequacy in California and the scope of state/federal jurisdiction. 

This category also includes various telephone calls, email correspondence, and other administrative 

services provided in connection with the foregoing matters. The services in this category were necessary 

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to ensure that the company was in compliance with its regulatory obligations under state and federal law. 

The status of this matter is ongoing. 

FPA Advice & Counsel (10146) 

This matter number encompasses services rendered in connection with advising PG&E with 

respect to its obligations under the Federal Power Act. During the First Interim Application Period, Jenner 

& Block professionals spent a total of 42.4 hours on this category having a lodestar value of $28,622.40. 

The services in this category include, among other things: conducting legal research regarding PG&E’s 

disclosure obligations, investigating factual matters relating to FPA issues, and preparing memoranda 

analyzing relevant legal and factual issues. This category also includes various telephone calls, email 

correspondence, and other administrative services provided in connection with the foregoing matters. The 

services in this category were necessary to ensure that PG&E complied with its obligations under federal 

law. The status of this matter is ongoing. 

Bankruptcy Employment (10252) 

This matter number encompasses services rendered in connection with Jenner & Block’s retention 

and compensation in these chapter 11 cases. During the First Interim Application Period, Jenner & Block 

professionals spent a total of 141.80 hours on this category having a lodestar value of $88,654.60. The 

services in this category include, among other things, preparing Jenner & Block’s retention application 

and related materials, conducting legal research related to Jenner & Block’s retention, communicating 

with the U.S. Trustee regarding Jenner & Block’s retention, preparing monthly fee statements, preparing 

supplemental disinterestedness disclosures, and coordinating with Weil, Gothsal & Manges LLP regarding 

retention and compensation-related matters. This category also includes various telephone calls, email 

correspondence, and other administrative services provided in connection with the foregoing matters. The 

services in this category were necessary to obtain the Court’s approval of Jenner’s retention as special 

corporate defense counsel and to allow Jenner to be compensated for its services. The status of this matter 

is ongoing. 

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Bankruptcy Administration (10261) 

This matter number encompasses services rendered in connection with monitoring substantive 

proceedings in these chapter 11 cases to the extent such proceedings may impact the special matters as to 

which PG&E retained Jenner & Block. During the First Interim Application Period, Jenner & Block 

professionals spent a total of 17.4 hours on this category having a lodestar value of $11,802.40. The 

services in this category include, among other things: reviewing bankruptcy docket activity and preparing 

summaries of noteworthy filings. This category also includes various telephone calls, email 

correspondence, and other administrative services provided in connection with the foregoing matters. The 

services in this category were necessary to keep Jenner & Block’s nonbankruptcy attorneys apprised of 

the status of the Debtors’ chapter 11 cases and of any filings that might affect the matters on which they 

are working. The status of this matter is ongoing. 

Regulatory Matter (10295) 

This matter number encompasses services rendered in connection with responding to multiple 

government inquiries, including an SEC investigation being conducted by the SEC’s San Francisco 

Regional Office related to PG&E Corporation’s and the Utility’s public disclosures and accounting for 

losses associated with the 2017 and 2018 Northern California wildfires and the 2015 Butte fire. During 

the First Interim Application Period, Jenner & Block professionals spent a total of 186.1 hours on this 

category having a lodestar value of $127,458.50. The services in this category include, among other things: 

investigating facts in response to government inquiries; reviewing and analyzing document requests; 

reviewing documents and conducting privilege review in response to government document requests; 

producing documents in response to inquiries, and preparing for and participating in certain witness 

interviews and meetings with the government. This category also includes various telephone calls, email 

correspondence, and other administrative services provided in connection with the foregoing matters. The 

services in this category were necessary to respond to government inquiries. The status of this matter is 

ongoing. 

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FERC Interlock Advice (10309) 

This matter number encompasses services rendered in connection with advising PG&E on their 

regulatory obligations relating to prospective new members of its board of directors. During the First 

Interim Application Period, Jenner & Block professionals spent a total of 16.9 hours on this category 

having a lodestar value of $11,050.90. The services in this category include, among other things, 

conducting legal research relating to possible regulatory approvals needed from the Federal Energy 

Regulatory Commission relating to potential members for the board of directors and providing feedback 

to the Debtors on decisions about potential board members. This category also includes various telephone 

calls, email correspondence, and other administrative services provided in connection with the foregoing 

matters. The services in this category were necessary to ensure that the company and its board members 

complied with their obligations under federal law. The status of this matter is ongoing. 

11. There is currently $710,732.74 remaining of the retainer the Debtors provided to Jenner &

Block prior to the commencement of these Chapter 11 Cases. Jenner & Block intends to apply this amount 

towards the fees and expenses allowed by the Court for services rendered during the First Interim 

Application Period. 

EVALUATING JENNER & BLOCK’S SERVICES 

12. Section 331 of the Bankruptcy Code provides for interim compensation of professionals

and incorporates the substantive standards of Section 330 of the Bankruptcy Code to govern the 

Bankruptcy Court’s award of such compensation. Section 330 provides that a court may award a 

professional employed under Section 327 of the Bankruptcy Code “reasonable compensation for actual, 

necessary services rendered ... and reimbursement for actual, necessary expenses.” Section 330 also sets 

forth the criteria for the award of such compensation and reimbursement. 

13. In determining the amount of reasonable compensation to be awarded, the court should

consider the nature, extent, and the value of such services, taking into account all relevant factors, 

including: 

a. the time spent on such services;

b. the rates charged for such services;

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c. whether the services were necessary to the administration of, or beneficial at the

time at which the service was rendered toward the completion of, a case under this

title;

d. whether the services were performed within a reasonable amount of time

commensurate with the complexity, importance, and nature of the problem, issue,

or task addressed; and

e. whether the compensation is reasonable based on the customary compensation

charged by comparably skilled practitioners in cases other than cases under this

title.

14. Jenner & Block respectfully submits that its request for interim allowance of compensation

is reasonable and appropriate. The services rendered by Jenner & Block were appropriate in light of 

Jenner & Block’s role as the Debtors’ special corporate defense counsel in this case. 

DISBURSEMENTS 

15. Jenner & Block maintains records of all actual and necessary out-of-pocket expenses

incurred in connection with the rendition of professional services. A schedule setting forth the categories 

of expenses and amounts for which reimbursement is requested for the First Interim Application Period is 

annexed hereto as Exhibit F. A list of Jenner & Block’s expenses for the First Interim Application Period 

is attached hereto as Exhibit G. 

16. By this Application, Jenner & Block respectfully requests allowance of such

reimbursement in full. 

THE APPLICANT’S STATEMENT PURSUANT 

TO APPENDIX B OF THE UST GUIDELINES 

17. The following statement is provided pursuant to ¶ C.5 of the UST Guidelines.

a. Question: Did you agree to any variations from, or alternatives to, your

standard or customary billing rates, fees or terms of services pertaining to this

engagement that were provided during the application period? If so, please

explain.

Answer: Yes, Jenner & Block provided the discounts described in its 

retention application [Dkt. 911]. Jenner & Block will calculate and apply 

the volume discounts triggered by Jenner & Block’s collection in 2019 of 

$2.5 million and $5 million, respectively, once the allowed amount of fees 

is known. Jenner & Block will then credit the applicable discount from the 

portion of its fees held back prior to allowance. 

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b. Question: If the fees sought in this fee application as compared to the fees

budgeted for the time period covered by this fee application are higher by 10%

or more, did you discuss the reasons for the variation with the client?

Answer: As indicated in Exhibit H, the compensation requested in this First 

Interim Fee Application is less than the amount budgeted for the First 

Interim Application Period. 

c. Question: Have any of the professionals included in this fee application varied

their hourly rate based on the geographic location of the bankruptcy case?

Answer: No. 

d. Question: Does the fee application include time or fees related to reviewing or

revising time records or preparing, reviewing, or revising invoices? (This is

limited to work involved in preparing and editing billing records that would not

be compensable outside of bankruptcy and does not include reasonable fees for

preparing a fee application.) If so, please quantify by hours and fees.

Answer: No. 

e. Question: Does this fee application include time or fees for reviewing time

records to redact any privileged or other confidential information? If so, please

quantify by hours and fees.

Answer: The First Interim Application includes 5.6 hours for such services, 

having a lodestar value of $4,595.70. 

f. Question: If the fee application includes any rate increases since retention: (i)

did your client review and approve those rate increases in advance? (ii) Did

your client agree when retaining the law firm to accept all future rate increases?

If not, did you inform your client that they need not agree to modified rates or

terms in order to have you continue the representation, consistent with ABA

Formal Ethics Opinion 11-458?

Answer: The First Interim Fee Application does not include any rate 

increases since Jenner & Block’s retention. 

Case: 19-30088 Doc# 3465 Filed: 08/08/19 Entered: 08/08/19 12:10:33 Page 14

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CONCLUSION

18. Jenner & Block believes that the services rendered during the First Interim Application

Period were reasonable and necessary within the meaning of Section 330 of the Bankruptcy Code and that 

the expenses were actual and necessary to the performance of the Jenner & Block’s services. 

WHEREFORE, Jenner & Block respectfully requests that this Court enter an order substantially 

in the form of Exhibit K (a) approving an interim allowance of legal fees in the amount of $3,484,976.50 

plus reimbursement of actual and necessary out-of-pocket expenses in the amount of $21,436.56 for all 

services rendered and expenses incurred during the First Interim Application Period; and (b) granting such 

other and further relief as may be just and proper. 

Dated: August 8, 2019 Respectfully submitted, 

Chicago, Illinois 

JENNER & BLOCK LLP 

By: ________________________ 

Randall E. Mehrberg 

353 N. Clark Street 

Chicago, IL 60654 

Tel: 312 840 7505 

rmehrberg@jenner.com 

Special Corporate Defense & Energy 

Counsel for Debtors and Debtors in 

Possession 

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