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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

New York, NY 10153-0119 

Tel: (212) 310-8000 

Fax: (212) 310-8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 636-9251 

Attorneys for Debtors and Debtors in Possession 

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 DEBTORS 

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 

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# 2948 Filed: 07/12/19 Entered: 07/12/19 10:46:48 Page 1 of

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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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

entered into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), on the one hand, and the Ad Hoc Committee 

of Senior Unsecured Noteholders (the “Noteholders Committee”), on the other. The Debtors 

and the Noteholders Committee 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 July 11, 2019, the Noteholders Committee filed the Motion of Ad Hoc 

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

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

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

2019. Any response or opposition to the Noteholders Motion to Terminate Exclusivity is due by 

4:00 p.m. (Pacific Time) on July 17, 2019. 

B. Counsel for the Debtors has requested, and counsel for the Noteholders 

Committee has agreed, that the time for the Debtors to respond to the Noteholders Motion to 

Terminate Exclusivity 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 Debtors to file and serve any response or opposition to the 

Noteholders Motion to Terminate Exclusivity is extended through 4:00 p.m. (Pacific Time) on 

July 18, 2019. 

[Signatures on next page] 

Case: 19-30088 Doc# 2948 Filed: 07/12/19 Entered: 07/12/19 10:46:48 Page 2 of

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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Dated: July 12, 2019 Dated: July 12, 2019

KELLER & BENVENUTTI LLP AKIN GUMP STRAUSS HAUER & 

FELD LLP 

/s/ Jane Kim /s/ Ashley Vinson Crawford

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

Ashley Vinson Crawford

Attorneys for Ad Hoc Committee of Senior 

Unsecured Noteholders

Case: 19-30088 Doc# 2948 Filed: 07/12/19 Entered: 07/12/19 10:46:48 Page 3 of

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