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

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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) 

767 Fifth Avenue 

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: 650 636 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 - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

EX PARTE APPLICATION FOR ORDER 

PURSUANT TO L.B.R. 9013-1(c) 

AUTHORIZING OVERSIZE BRIEFING FOR 

DEBTORS’ OMNIBUS (I) REPLY IN 

SUPPORT OF THE DEBTORS’ BAR DATE 

MOTION, AND (II) OBJECTION TO THE 

TCC’S BAR DATE MOTION 

Related Document: Dkt. No. 2636 

[No hearing requested] 

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# 2638 Filed: 06/19/19 Entered: 06/19/19 14:12:44 Page 1 of

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PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the 

“Utility”), as debtors and debtors in possession (collectively, “PG&E” or the “Debtors”) in the 

above-captioned chapter 11 cases (the “Chapter 11 Cases”), hereby submit this Ex Parte

Application (the “Application”), pursuant to Rule 9013-1(c) of the Bankruptcy Local Rules for the 

United States District Court for the Northern District of California (the “Bankruptcy Local 

Rules”), for an order authorizing the Debtors to file an oversize Omnibus (I) Reply in Support of 

the Debtors’ Bar Date Motion, and (II) Objection to the TCC’s Bar Date Motion [Dkt. No. 2636] 

(the “Omnibus Bar Date Reply and Objection”)1, which the Debtors filed on the date hereof. 

MEMORANDUM OF POINTS AND AUTHORITIES 

I. JURISDICTION 

The Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 

1334, the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General 

Order 24 (N.D. Cal.), and Bankruptcy Local Rule 5011-1(a). This is a core proceeding pursuant to 

28 U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

II. BACKGROUND 

On January 29, 2019 (the “Petition Date”), the Debtors commenced with the Court 

voluntary cases under chapter 11 of the Bankruptcy Code. The Debtors continue to operate their 

businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 

1108 of the Bankruptcy Code. The Debtors’ Chapter 11 Cases are being jointly administered for 

procedural purposes only pursuant to Bankruptcy Rule 1015(b). 

On February 12, 2019, the United States Trustee (the “U.S. Trustee”) appointed an 

Official Committee of Unsecured Creditors (the “Creditors Committee”). On February 15, 2019, 

the U.S. Trustee appointed an Official Committee of Tort Claimants (the “Tort Claimants 

Committee”). 

 

1

 Capitalized terms used but not defined herein have the meanings ascribed to them in the Omnibus 

Bar Date Reply and Objection. 

Case: 19-30088 Doc# 2638 Filed: 06/19/19 Entered: 06/19/19 14:12:44 Page 2 of

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Additional information regarding the circumstances leading to the commencement 

of the Chapter 11 Cases and information regarding the Debtors’ businesses and capital structure is 

set forth in the Amended Declaration of Jason P. Wells in Support of the First Day Motions and 

Related Relief [Docket No. 263]. 

On May 1, 2019, the Debtors filed the Motion of Debtors Pursuant to 11 U.S.C. §§ 

502(b)(9) and 105(a), Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 for 

Order (i) Establishing Deadline for Filing Proofs of Claim, (ii) Establishing the Form and Manner 

of Notice Thereof, and (iii) Approving Procedures for Providing Notice of Bar Date and Other 

Information to all Creditors and Potential Creditors [Docket No. 1784] (the “Bar Date Motion”). 

At least fifteen objections, joinders to objections, and other responses were filed with 

respect to the Bar Date Motion (collectively, the “Objections”). 

On May 31, 2019, the Tort Claimants Committee filed the Motion of the Official 

Committee of Tort Claimants Pursuant to 11 U.S.C. §§ 105(a), 501 and Fed. R. Bankr. P. 3001(a), 

3003(c), 5005 and 9007 for Entry of an Order (i) Establishing a Bar Date for Filing Fire Claims, 

(ii) Approving the Form and Procedures for Notice of the Bar Date for Fire Claims, and (iii) 

Approving Supplemental Procedure for Notice of the Bar Date to Fire Claimants [Docket No. 

2297] (together with the supporting memorandum of law and declarations, the “TCC Bar Date 

Motion”). Objections and responses with respect to the TCC Bar Date Motion are due June 19, 

2019 at 4:00 p.m. (Pacific Time). 

III. OVERSIZE BRIEFING FOR THE OMNIBUS BAR DATE REPLY AND 

OBJECTION IS WARRANTED 

Bankruptcy Local Rule 9013-1(c) provides that, “Unless the Court expressly orders 

otherwise, the initial and response memoranda of points and authorities shall not exceed 25 pages of 

text, and reply memorandum shall not exceed 15 pages of text.” B.L.R. 9013-1(c). 

The Bar Date Motion seeks an order (i) establishing deadlines for filing proofs of claim 

(the “Bar Date”), (ii) establishing the form and manner of notice thereof, and (iii) approving the 

Debtors’ plan for providing notice of the Bar Date and other important deadlines and information to 

all creditors and potential creditors. 

Case: 19-30088 Doc# 2638 Filed: 06/19/19 Entered: 06/19/19 14:12:44 Page 3 of

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The TCC Bar Date Motion proposes a different Bar Date and a claims noticing and 

proof of claim process that is vastly different from the procedures proposed by the Debtors in their 

Bar Date Motion. 

The Debtors submit that sufficient cause exists for the Court to allow oversize briefing 

for the Omnibus Bar Date Reply and Objection. Because many of the Objections raise similar issues 

with respect to the Bar Date Motion, including the Debtors’ proposed Bar Date and their proposed 

notice procedures and proof of claim process, responding to the Objections by an omnibus reply is 

efficient. The Debtors’ objections to the TCC Bar Date Motion – namely, to the extended Bar Date 

proposed by the Tort Claimants Committee and their alternative notice plan – also overlap with the 

arguments raised by the Debtors’ reply to the Objections, and, thus, addressing the TCC Bar Date 

Motion in the same filing as the Debtors’ reply to the Objections is an efficient use of the Debtors’ 

resources and the Court’s time. In order to respond sufficiently to fifteen Objections and the TCC Bar 

Date Motion in a single document, the Debtors submit that they require more than the 15 pages 

otherwise permitted under the Local Rules. 

Accordingly, the Debtors believe it is appropriate to request authority for the Omnibus 

Bar Date Reply and Objection to exceed the 15 pages allowed under Bankruptcy Local Rule 9013-1(c). 

IV. NOTICE 

Notice of this Application will be provided to (i) the Office of the United States Trustee 

for Region 17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Creditors 

Committee; (iii) counsel to the Tort Claimants Committee; (iv) the Securities and Exchange 

Commission; (v) the Internal Revenue Service; (vi) the Office of the California Attorney General; (vii) 

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

Energy Regulatory Commission; (x) the Office of the United States Attorney for the Northern District 

of California; (xi) counsel for the agent under the Debtors’ debtor in possession financing facility; and 

(xii) those persons who have formally appeared in these Chapter 11 Cases and requested service 

pursuant to Bankruptcy Rule 2002. The Debtors respectfully submit that no further notice is required. 

No previous request for the relief sought herein has been made by the Debtors to this 

or any other court. 

Case: 19-30088 Doc# 2638 Filed: 06/19/19 Entered: 06/19/19 14:12:44 Page 4 of

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WHEREFORE, the Debtors respectfully request entry of an order authorizing the 

Debtors to file the Omnibus Bar Date Reply and Objection to exceed 15 pages, but not to exceed 30 

pages (exclusive of any schedules or exhibits thereto and/or any declarations filed in connection 

therewith), and such other and further relief as the Court may deem just and appropriate. 

Dated: June 19, 2019 WEIL, GOTSHAL & MANGES LLP 

 KELLER & BENVENUTTI LLP 

 By: /s/ Jane Kim 

 Jane Kim 

Attorneys for Debtors and Debtors in Possession 

Case: 19-30088 Doc# 2638 Filed: 06/19/19 Entered: 06/19/19 14:12:44 Page 5 of

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