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DIEMER & WEI, LLP

Kathryn S. Diemer (#133977)

100 West San Fernando Street, Suite 555

San Jose, CA 95113

Telephone: 408-971-6270 

Facsimile: 408-971-6271

Email: kdiemer@diemerwei.com 

WILLKIE FARR & GALLAGHER LLP

Matthew A. Feldman (pro hac vice)

Joseph G. Minias (pro hac vice)

Benjamin P. McCallen (pro hac vice)

Daniel I. Forman (pro hac vice)

787 Seventh Avenue

New York, NY 10019-6099

Telephone: (212) 728-8000

Facsimile: (212) 728-8111

Email: mfeldman@willkie.com

jminias@willkie.com

bmccallen@willkie.com

dforman@willkie.com

Counsel for Ad Hoc Group of Subrogation Claim Holders

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 AD HOC 

COMMITTEE OF SENIOR UNSECURED 

NOTEHOLDERS AND AD HOC GROUP OF 

SUBROGATION CLAIM HOLDERS 

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

Re: Dkt. No. 2741

[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# 2932 Filed: 07/11/19 Entered: 07/11/19 15:00:44 Page 1 of

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

entered into by the Ad Hoc Committee of Senior Unsecured Noteholders of Pacific Gas and 

Electric Company (the “Ad Hoc Committee”), on the one hand, and the Ad Hoc Group of 

Subrogation Claim Holders (the “Ad Hoc Subrogation Group”), on the other hand. The Ad 

Hoc Committee and the Ad Hoc Subrogation Group 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 the Ad Hoc Subrogation 

Group have agreed that the time for the Ad Hoc Subrogation Group 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 the Ad Hoc Subrogation Group 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# 2932 Filed: 07/11/19 Entered: 07/11/19 15:00:44 Page 2 of

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Dated: July 11, 2019 Dated: July 11, 2019

AKIN GUMP STRAUSS HAUER & 

FELD LLP

DIEMER & WEI LLP

/s/ Ashley Vinson Crawford /s/ Kathryn S. Diemer

Ashley Vinson Crawford

Attorneys for the Ad Hoc Committee of 

Senior Unsecured Noteholders

Kathryn S. Diemer

Attorneys for Ad Hoc Group of Subrogation 

Claim Holders

Case: 19-30088 Doc# 2932 Filed: 07/11/19 Entered: 07/11/19 15:00:44 Page 3 of

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