ARENT FOX LLP 

ATTORNEYS AT LAW

LOS ANGELES

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Andrew I. Silfen (pro hac vice) 

Beth M. Brownstein (pro hac vice) 

Jordana L. Renert (pro hac vice) 

ARENT FOX LLP 

1301 Avenue of the Americas, 42nd Floor 

New York, New York 10019 

Telephone: (212) 484-3900 

Facsimile: (212) 484-3990 

Email: andrew.silfen@arentfox.com 

 beth.brownstein@arentfox.com 

 jordana.renert@arentfox.com 

Aram Ordubegian (SBN 185142) 

ARENT FOX LLP 

55 Second Street, 21st Floor 

San Francisco, CA 94105 

Telephone: (415) 757-5500 

Facsimile: (415) 757-5501 

Email: aram.ordubegian@arentfox.com 

Counsel for BOKF, NA, solely in its capacity as 

Indenture Trustee

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 - and – 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

STIPULATION BETWEEN AD HOC 

COMMITTEE OF SENIOR UNSECURED 

NOTEHOLDERS AND BOKF, N.A. 

EXTENDING TIME TO RESPOND TO THE 

MOTION OF THE AD HOC COMMITTEE 

OF SENIOR UNSECURED NOTEHOLDERS 

TO TERMINATE THE DEBTORS’ 

EXCLUSIVE PERIODS PURSUANT TO 

SECTION 1121(d)(1) OF THE BANKRUPTCY 

CODE 

Re: Dkt. No. 2741 

[No Hearing Requested] 

 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). 

This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by, on the one hand, the Ad Hoc Committee of Senior Unsecured Noteholders of 

Case: 19-30088 Doc# 2963 Filed: 07/12/19 Entered: 07/12/19 17:41:33 Page 1 of

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ARENT FOX LLP 

ATTORNEYS AT LAW

LOS ANGELES

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Pacific Gas and Electric Company (the “Ad Hoc Committee”) and, on the other hand, BOKF, 

NA (“BOKF”), in its capacity as successor indenture trustee (the “Unsecured Notes Trustee”) 

under the Indentures dated as of (i) March 11, 2004 (as supplemented, amended and restated), 

(ii) November 29, 2017 and (iii) August 6, 2018 pursuant to which Pacific Gas and Electric 

Company (the “Utility” and, together with PG&E Corporation, the “Debtors”) issued the senior 

notes (collectively, the “Senior Notes”). The Ad Hoc Committee and BOKF 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 June 25, 2019, the Ad Hoc Committee filed the Motion of the Ad Hoc 

Committee of Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods 

Pursuant to Section 1121(d)(1) of the Bankruptcy Code [Dkt. No. 2741] (the “Motion to 

Terminate Exclusivity”), which is set for a hearing before the Court at 9:30 a.m. on July 24, 

2019. The Notice of Hearing on Motion of the Ad Hoc Committee of Senior Unsecured 

Noteholders to Terminate the Debtors’ Exclusive Periods Pursuant to Section 1121(d)(1) of the 

Bankruptcy Code [Dkt. No. 2744] (the “Notice”) states that any response or objection is to be 

filed “so as to be received by no later than 4:00 p.m. (Pacific Time) on July 16, 2019.” 

B. Counsel for the Ad Hoc Committee and counsel for BOKF have agreed that the 

time for BOKF to respond to the Motion to Terminate Exclusivity should 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: 

1. The time for BOKF to file and serve any response or opposition to the Motion to 

Terminate Exclusivity is extended through 4:00 p.m. (Pacific Time) on July 18, 2019. 

Case: 19-30088 Doc# 2963 Filed: 07/12/19 Entered: 07/12/19 17:41:33 Page 2 of

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ARENT FOX LLP 

ATTORNEYS AT LAW

LOS ANGELES

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Dated: July 12, 2019 

AKIN GUMP STRAUSS HAUER & 

FELD LLP 

/s/ Ashley Vinson Crawford

Ashley Vinson Crawford 

Attorneys for the Ad Hoc Committee of 

Senior Unsecured Noteholders

Dated: July 12, 2019 

ARENT FOX LLP 

/s/ Aram Ordubegian

Aram Ordubegian (SBN 185142) 

Andrew I. Silfen (pro hac vice) 

 Beth M. Brownstein (pro hac vice) 

 Jordana L. Renert (pro hac vice) 

Counsel for BOKF, NA, solely in its capacity 

as Indenture Trustee 

Case: 19-30088 Doc# 2963 Filed: 07/12/19 Entered: 07/12/19 17:41:33 Page 3 of

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