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28 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) 

STIPULATION BETWEEN DEBTORS 

AND OFFICIAL COMMITTEE OF TORT 

CLAIMANTS EXTENDING TIME TO 

RESPOND TO BAR DATE MOTION AND 

MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

FOR ENTRY OF AN ORDER 

APPROVING PROPOSED MODEL 

PROOF OF CLAIM FORM FOR FIRE 

CLAIMS AND RELATED PROCEDURES 

Re: Dkt. Nos. 1784, 1824 

[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# 2234 Filed: 05/28/19 Entered: 05/28/19 11:28:49 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 “TCC”), on the other. The Debtors and the TCC 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 May 1, 2019, the Debtors filed the Motion of Debtors Pursuant to 11 U.S.C. 

§§ 502(b)(9) and 105(a), Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 

for Order (I) Establishing Deadline for Filing Proofs of Claim, (II) Establishing the Form and 

Manner of Notice Thereof, and (III) Approving Procedures for Providing Notice of Bar Date and 

Other Information to All Creditors and Potential Creditors [Dkt. No. 1784] (the “Bar Date 

Motion”), which is set for a hearing before the Court at 9:30 a.m. on June 11, 2019. Any 

response or opposition to the Bar Date Motion is due by 4:00 p.m. (Pacific Time) on May 28, 

2019. 

B. On May 3, 2019, the TCC filed the Motion of the Official Committee of Tort 

Claimants Pursuant to 11 U.S.C. §§ 105(a) and 501 and Fed. R. Bankr. P. 3001(a) for Entry of 

an Order Approving Proposed Model Proof of Claim Form for Fire Claims and Related 

Procedures [Dkt. No. 1824] (the “TCC Claim Form Motion”), which is set for a hearing before 

the Court at 9:30 a.m. on June 11, 2019. Any response or opposition to the TCC Claim Form 

Motion is due by 4:00 p.m. (Pacific Time) on May 28, 2019.

C. Counsel for the Debtors and counsel for the TCC have agreed that the time for the 

TCC to respond to the Bar Date Motion and the time for the Debtors to respond to the TCC 

Claim Form Motion be 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:

Case: 19-30088 Doc# 2234 Filed: 05/28/19 Entered: 05/28/19 11:28:49 Page 2 of

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

1. The time for the TCC to file and serve any response or opposition to the Bar Date 

Motion is extended through 4:00 p.m. (Pacific Time) on May 31, 2019. 

2. The time for the Debtors file and serve any response or opposition to the TCC Claim 

Form Motion is extended through 4:00 p.m. (Pacific Time) on May 31, 2019. 

Dated: May 28, 2019 Dated: May 28, 2019

KELLER & BENVENUTTI LLP BAKER & HOSTETLER LLP 

/s/ Jane Kim /s/ Eric R. Goldman

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

Eric R. Goldman

 

Attorneys for Official Committee of Tort 

Claimants

Case: 19-30088 Doc# 2234 Filed: 05/28/19 Entered: 05/28/19 11:28:49 Page 3 of

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