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STIPULATION EXTENDING TIME 19-30088 (DM) 

25887521.2

Rebecca Weissman (No. 322402)

DECHERT LLP 

One Bush Street, Suite 1600 

San Francisco, California 94104 

Telephone: 415.262.4500 

Facsimile: 415.262.4555 

rebecca.weissman@dechert.com 

Allan S. Brilliant (pro hac vice) 

Shmuel Vasser (pro hac vice) 

Alaina R. Heine (pro hac vice) 

DECHERT LLP 

1095 Avenue of the Americas 

New York, New York 10036 

Telephone: 212.698.3500 

Facsimile: 415.698.3599 

allan.brilliant@dechert.com 

shmuel.vasser@dechert.com 

alaina.heine@dechert.com 

Attorneys for State Farm Mutual Automobile Insurance 

Company and its affiliates and subsidiaries

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION and PACIFIC 

GAS & ELECTRIC COMPANY, 

 Debtors. 

□ Affects PG&E Corporation 

□ Affects Pacific Gas and 

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 

Jointly Administered 

STIPULATION BETWEEN STATE FARM 

AND AD HOC COMMITTEE OF SENIOR 

UNSECURED NOTEHOLDERS EXTENDING 

TIME TO RESPOND TO 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 

[DOCKET NO. 2741] 

[No Hearing Requested] 

Case: 19-30088 Doc# 2972 Filed: 07/15/19 Entered: 07/15/19 09:25:54 Page 1 of

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STIPULATION EXTENDING TIME 19-30088 (DM) 

25887521.2

This stipulation and agreement for order (the “Stipulation”) is entered into 

by (i) State Farm Mutual Automobile Insurance Company and its affiliates and subsidiaries 

(collectively, “State Farm”), on the one hand; and (ii) the Ad Hoc Committee of Senior 

Unsecured Noteholders (the “Ad Hoc Committee” and together with State Farm, the “Parties”), 

on the other hand. 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 (the “Motion”) [Docket No. 2741], which 

is set for hearing before the Court at 9:30 a.m. (Pacific Time) on July 24, 2019. The notice of the 

Motion indicated that any response or opposition to the Motion is due by 4:00 p.m. (Pacific Time) 

on July 16, 2019. 

B. Counsel to State Farm has requested, and counsel to the Ad Hoc 

Committee has agreed, that the time for State Farm to respond to the 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: 

1. The time for State Farm to file and serve any response or opposition to the 

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

[Remainder of page left intentionally blank] 

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STIPULATION EXTENDING TIME 19-30088 (DM) 

Dated: July 15, 2019 Dated: July 15, 2019 

DECHERT LLP AKIN GUMP STRAUSS HAUER & 

FELD LLP 

/s/ Shmuel Vasser /s/ Ashley Crawford .

Allan S. Brilliant (pro hac vice) Ashley Crawford 

Shmuel Vasser (pro hac vice) 

Alaina R. Heine (pro hac vice) 

Rebecca Weissman (No. 322402) 

Attorneys for State Farm Mutual Automobile Attorneys for Ad Hoc Committee of Senior 

Insurance Company and its affiliates and Unsecured Noteholders 

subsidiaries

Case: 19-30088 Doc# 2972 Filed: 07/15/19 Entered: 07/15/19 09:25:54 Page 3 of

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