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MORGAN, LEWIS &

BOCKIUS LLP 

ATTORNEYS AT LAW

COSTA MESA

MORGAN LEWIS & BOCKIUS LLP

Richard W. Esterkin, SBN 70769 

richard.esterkin@morganlewis.com

300 S Grand Ave Fl 22 

Los Angeles CA 90071-3132 

Tel: (213) 612-2500 

Fax: (213) 612-2501 

Attorneys for Exelon Corporation 

and AV Solar Ranch I, LLC 

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 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

EXELON CORPORATION AND AV 

SOLAR RANCH 1, LLC, JOINDER IN 

MOTION FOR LIMITED RELIEF FROM 

STAY TO PARTICIPATE IN 

APPELLATE PROCEEDINGS WITH 

RESPECT TO FERC ORDERS 

(DKT. NO. 2400) 

Date: June 26, 2019 

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

Dept.: United States Bankruptcy Court 

Courtroom 17, 16th Floor 

San Francisco, CA 94102 

Deadline for Objections: June 21, 2019 

4:00 p.m. (PDT)

Exelon Corporation (“Exelon”) and AV Solar Ranch 1, LLC (“AVSR-1” and, together 

with Exelon, the “Exelon Parties”), hereby join in the Motion for Limited Relief from Stay to 

Participate in Appellate Proceedings With Respect to FERC Orders (Dkt. No. 2400) (the 

Case: 19-30088 Doc# 2406 Filed: 06/05/19 Entered: 06/05/19 15:27:01 Page 1 of

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MORGAN, LEWIS &

BOCKIUS LLP 

ATTORNEYS AT LAW

COSTA MESA

“NextEra Motion”) and request that any order modifying the automatic stay to permit Pacific 

Gas and Electric Company (“PG&E”) to appeal from the FERC Orders (defined below) also 

provide that the automatic stay be modified as to the Exelon Parties to the extent requested in the 

NextEra Motion, and in support thereof, state as follows: 

1. AVSR-1 is an indirect wholly owned subsidiary of Exelon. 

2. On January 22, 2019, Exelon filed a petition before the Federal Energy Regulatory 

Commission (“FERC”) commencing the matter of Exelon Corp. v. Pacific Gas & Elec. Co., No. 

El19-36-001 (the “Exelon FERC Proceeding”). On January 28, 2019, FERC issued its Order on 

Petition for Declaratory Order and Complaint in the Exelon FERC Proceeding (the “Exelon 

FERC Order”). 

3. On February 25, 2019, PG&E filed a petition seeking rehearing of the Exelon 

FERC Order. On May 1, 2019, FERC issued its Order Denying Rehearing in the Exelon FERC 

Proceeding (the “Order Denying Rehearing”). In addition to denying PG&E’s petition for 

rehearing in the Exelon FERC Proceeding, the Order Denying Rehearing denied PG&E’s petition 

for rehearing in a FERC proceeding initiated by NextEra Energy, Inc. and NextEra Energy 

Partners, L.P. (the “NextEra FERC Proceeding”). 

4. On June 3, 2019, PG&E filed its Motion of the Utility for Limited Relief from the 

Automatic Stay to Appeal Certain Matters Pending Before the Federal Energy Regulatory 

Commission in this bankruptcy case (Dkt. No. 2359) (the “PG&E Motion”). The PG&E Motion 

seeks an order modifying the automatic stay in this case: 

To permit the Utility, should it elect to do so, to file notices of appeal 

to the Court of Appeals from our relating to certain orders issued by 

the Federal Regulatory Commission (“FERC”) in proceedings 

before FERC, all as more specifically identified and defined in the 

following Memorandum of Points and Authorities (the “FERC 

Orders”), and to prosecute such appeals to conclusion. 

PG&E Motion at 2:9-13. As defined in the PG&E Motion, the “FERC Orders” include the 

Exelon FERC Order and the Order Denying Rehearing. 

5. On June 5, 2029, NextEra Energy, Inc. and NextEra Energy Partners, L.P. filed the 

NextEra Motion, which seeks an order permitting NextEra to participate in any appeal that PG&E 

Case: 19-30088 Doc# 2406 Filed: 06/05/19 Entered: 06/05/19 15:27:01 Page 2 of

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MORGAN, LEWIS &

BOCKIUS LLP 

ATTORNEYS AT LAW

COSTA MESA

may file in relation to the FERC Orders as defined in the PG&E Motion. For the reasons set forth 

in the NextEra Motion, cause exists to modify the automatic stay to permit Exelon and AVSR-1 

to participate in PG&E’s contemplated appellate proceedings that, if filed, would seek review of 

orders obtained in the Exelon FERC Proceeding. Accordingly, Exelon and AVSR-1 respectfully 

request that any order modifying the automatic stay as requested in the PG&E Motion and the 

NextEra Motion also modify the automatic stay as to Exelon and AVSR-1 to permit Exelon and 

AVSR-1 to participate in any appeal from the Exelon FERC Order or the Order Denying 

Rehearing. 

Dated: June 5, 2019

MORGAN, LEWIS & BOCKIUS LLP 

By: /s/ Richard W. Esterkin 

Richard W. Esterkin 

Attorney for Exelon Corporation and 

AV Solar Ranch I, LLC 

Case: 19-30088 Doc# 2406 Filed: 06/05/19 Entered: 06/05/19 15:27:01 Page 3 of

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