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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000 

SAN FRANCISCO, CA 

94111 

UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 -andPACIFIC GAS & 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 No.: 19-30088-DM 

Chapter 11 

JOINDER OF THE CITY AND 

COUNTY OF SAN FRANCISCO TO 

OBJECTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

TO CORRECTED MOTION OF 

DEBTORS PURSUANT TO 11 USC § 

1121(d) TO EXTEND EXCLUSIVITY 

PERIODS 

DATE: May 22, 2019 

TIME: 9:30 am 

PLACE: Courtroom 17 

450 Golden Gate Avenue, 16th Fl.

San Francisco, California 

JUDGE: Hon. Dennis Montali 

RELATED DOCKET NOS: 1797, 2017 

 The City and County of San Francisco (“San Francisco”) in the above-captioned chapter 11 

cases of Pacific Gas and Electric Company (the “Utility”) and PG&E Corporation (“PG&E” and, 

EDWARD J. TREDINNICK (#84033) 

GREENE RADOVSKY MALONEY 

 SHARE & HENNIGH LLP

Four Embarcadero Center, Suite 4000 

San Francisco, California 94111-4106 

Telephone: (415) 981-1400 

Facsimile: (415) 777-4961 

E-mail: etredinnick@greeneradovsky.com 

Attorneys for Creditor, 

City and County of San Francisco 

Case: 19-30088 Doc# 2118 Filed: 05/20/19 Entered: 05/20/19 16:13:41 Page 1 of

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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000 

SAN FRANCISCO, CA 

94111 

together with the Utility, the “Debtors”), hereby joins, as further described herein, in the Objection of 

the Official Committee of Tort Claimants to Corrected Motion of Debtors Pursuant to 11 U.S.C. § 

1121(d) to Extend the Exclusivity Periods [Docket # 2017]. (the “Tort Committee Objection”). 

 San Francisco generally concurs with the Tort Committee Objection filed herein and believes 

that any extension granted by the court should be brief to move this case forward. In support hereof, 

San Francisco respectfully represents as follows: 

JOINDER 

San Francisco’s interest in the Motion is both as a creditor and on behalf of the Utility’s 

ratepayers in San Francisco. 

San Francisco joins the Tort Committee Objection and believes that an extension of six (6) 

months to the exclusivity periods as requested by the Debtors is excessive. 

San Francisco shares concerns stated by the Tort Committee, including those about the 

Debtors’ financial condition, reliance on changes to wildfire liability laws as a key component of 

reorganization, and seeming inability to affect meaningful change to its corporate culture. 

San Francisco contends that, if the court is inclined to give the Debtors an extension, the time 

period should be for a much shorter period and be geared toward making substantial progress and a 

reasonable checkpoint for the Court and creditors to evaluate the Debtors progress. Other 

constituents have suggested extension ranging from 75 days (Governor Newsom) to four (4) months 

(Unsecured Creditors Committee). San Francisco thinks either would be appropriate at this early 

stage to keep the Debtor moving rapidly toward a workable plan for all interested parties. 

CONCLUSION 

For the reasons stated herein, San Francisco joins in the Tort Committee Objection and 

requests that the Court to limit the extension as the Court deems appropriate. 

 Respectfully submitted, 

Dated: May 20, 2019 GREENE RADOVSKY MALONEY 

SHARE & HENNIGH LLP 

By: _____/s/ Edward Tredinnick_________________ 

 Edward J. Tredinnick 

 Attorneys for Creditor, 

 City and County of San Francisco 

Case: 19-30088 Doc# 2118 Filed: 05/20/19 Entered: 05/20/19 16:13:41 Page 2 of

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