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28 JOINDER TO NEXTERA ENERGY’S LIMITED

OPPOSITION TO MOTION OF THE UTILITY

FOR LIMITED RELIEF FROM THE AUTOMATIC

STAY

CASE NO: 19-30088 (DM)

Amy S. Park (SBN 208204)

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP

525 University Avenue

Palo Alto, California 94301

Telephone: (650) 470-4500

Facsimile: (650) 470-4570

amy.park@skadden.com

J. Eric Ivester (admitted pro hac vice)

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP

Four Times Square

New York, New York 10036-6522

Telephone: (212) 735-3000

Facsimile: (212) 735-2000

eric.ivester@skadden.com

Attorneys for 

MOJAVE SOLAR, 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 (DM)

Chapter 11

(Lead Case) 

(Jointly Administered)

JOINDER TO NEXTERA ENERGY’S 

LIMITED OPPOSITION TO MOTION 

OF THE UTILITY FOR LIMITED 

RELIEF FROM THE AUTOMATIC 

STAY TO APPEAL CERTAIN 

MATTERS PENDING BEFORE THE 

FEDERAL ENERGY REGULATORY 

COMMISSION

Date: June 26, 2019

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

Place: United Stated Bankruptcy Court

 Courtroom 17, 16th Floor

 San Francisco, CA 94102

Objection Deadline: June 19, 2019

 4:00 p.m. (PST)

Case: 19-30088 Doc# 2628 Filed: 06/19/19 Entered: 06/19/19 13:42:03 Page 1 of

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28 1

JOINDER TO NEXTERA ENERGY’S LIMITED

OPPOSITION TO MOTION OF THE UTILITY

FOR LIMITED RELIEF FROM THE AUTOMATIC

STAY

CASE NO: 19-30088 (DM)

Mojave Solar LLC ( “Mojave”) hereby joins (this “Joinder”) in the limited opposition of 

NextEra Energy, Inc. and NextEra Energy Partners, L.P. (collectively, “NextEra”) [Docket No 

2616] (the “NextEra Stay Objection”) to the Motion of the Utility for Limited Relief from the 

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

Commission [[Docket No. 2359] (the “Utility Stay Motion”).1

For the reasons set forth in the NextEra Stay Objection as well as NextEra’s Motion for 

Limited Relief from Stay to Participate in Appellate Proceedings with Respect to FERC Orders

[Docket No. 2400] (the “NextEra Stay Motion”),

2 Mojave respectfully requests that the Court 

deny the prospective relief requested in the Debtor Stay Motion unless it also enters an order 

granting the NextEra Stay Motion (or incorporates the relief requested therein into its order on the 

Utility Stay Motion).

NOTICE

Notice of this Joinder will be provided to (i) the Office of the U.S. Trustee for Region 17 

(Attn: Anthony R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Debtors; (iii) counsel 

to the Creditors Committee; (iv) counsel to the Tort Claimants Committee; (v) the Securities and 

Exchange Commission; (vi) the Internal Revenue Service; (vii) the Office of the California 

Attorney General; (viii) the California Public Utilities Commission; (ix) the Nuclear Regulatory 

Commission; (x) the Federal Energy Regulatory Commission; (xi) the Office of the United States 

Attorney for the Northern District of California; (xii) counsel for the agent under the Debtors’ 

debtor-in-possession financing facility; (xiii) counsel to the PPA Counterparties; and (xiv) those 

persons who have formally appeared in these chapter 11 cases and requested service pursuant to 

Bankruptcy Rule 2002.

Mojave respectfully submits that no further notice is required.

 

1 Capitalized terms used but not otherwise defined herein shall have the meaning ascribed to 

them in the Debtor Stay Motion.

2 Mojave also joined the NextEra Stay Motion at Docket No. 2452 and hereby incorporates 

by reference all arguments made therein. 

Case: 19-30088 Doc# 2628 Filed: 06/19/19 Entered: 06/19/19 13:42:03 Page 2 of

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28 2

JOINDER TO NEXTERA ENERGY’S LIMITED

OPPOSITION TO MOTION OF THE UTILITY

FOR LIMITED RELIEF FROM THE AUTOMATIC

STAY

CASE NO: 19-30088 (DM)

DATED: June 19, 2019

SKADDEN, ARPS, SLATE, MEAGHER & FLOM, LLP

By: /s/ Amy S. Park 

Amy S. Park

Attorneys for 

MOJAVE SOLAR LLC

Case: 19-30088 Doc# 2628 Filed: 06/19/19 Entered: 06/19/19 13:42:03 Page 3 of

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