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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) 

Theodore Tsekerides (pro hac vice) 

(theodore.tsekerides@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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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 DEBTOR 

PACIFIC GAS AND ELECTRIC 

COMPANY AND MOVANTS MARINA 

AND MIKHAIL GELMAN FOR LIMITED 

RELIEF FROM THE AUTOMATIC STAY

[Relates to Dkt. Nos. 1310, 3617] 

[Resolving Motion Set for Hearing 

September 25, 2019 at 9:30 am] 

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# 3939 Filed: 09/19/19 Entered: 09/19/19 13:28:53 Page 1 of

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

This stipulation (the “Stipulation”) is entered into by and between Pacific Gas and Electric 

Company (the “Utility” or the “Debtor”), as debtor and debtor in possession, and movants Marina 

and Mikhail Gelman (the “Gelmans”). The Debtor and the Gelmans are referred to in this 

Stipulation collectively as the “Parties,” and each as a “Party.” The Parties hereby stipulate and 

agree as follows: 

RECITALS 

A. On April 10, 2019, the Gelmans filed the Motion for Relief from the Automatic Stay 

and Abstention Pursuant to 28 U.S.C. 1334(c)(1) [Dkt. 1310] (the “Initial Relief from Stay 

Motion”), superseding a similar motion filed on April 3, 2019 [Dkt. 1201]. 

B. The Court held a preliminary hearing on the Initial Relief from Stay Motion on May 

9, 2019, and on May 13, 2019, issued its Memorandum Decision [Dkt. No. 1982] continuing the 

preliminary hearing to September 10, 2019 (subsequently continued by agreement of the Parties 

to September 25). 

C. On August 20, 2019, the Gelmans filed the Supplement to Their Motion for Relief 

from the Automatic Stay and Abstention Pursuant to 28 U.S.C. 1334(c)(1); Objection to the 

Bankruptcy Court Adjudicating Movants’ Personal Injury Claims [Dkt. 3617] (the “Supplemental 

Relief from Stay Motion,” and, together with the Initial Relief from Stay Motion, the “Relief 

from Stay Motion”). 

D. The Gelmans seek relief from the automatic stay to prosecute their personal injury 

claims against the Utility in Marina and Mikhail Gelman v. Pacific Gas and Electric Company, 

City and County of San Francisco, and Blue Plantain, LLC, Case No. CGC-17-556763 (the “State

Court Action”) pending in the Superior Court of California, County of San Francisco (the 

“Superior Court”). 

E. The State Court Action arises out of an injury suffered by Ms. Gelman when she 

allegedly tripped on a Utility vault located in a public sidewalk in San Francisco in front of a 

restaurant owned by Blue Plantain, LLC. 

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F. The Gelmans filed the State Court Action on January 31, 2017. The Utility served 

its answer on October 10, 2017. 

G. The State Court Action initially was set for jury trial on August 27, 2018, and was 

reset first to April 22, 2019 and again to December 16, 2019 (the “Trial”). 

H. The Debtor and its parent, PG&E Corporation (collectively the “Debtors”), filed 

these Chapter 11 Cases on January 29, 2019 (the “Petition Date”). 

I. The Utility filed the Notice of Bankruptcy Filing and Imposition of Automatic Stay 

in the State Court Action on February 4, 2019. The automatic stay applicable to the State Court 

Action has remained in effect as to the Debtors since the Petition Date. 

NOW, THEREFORE, 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. This Stipulation shall be effective upon entry of an order by this Court 

approving it, and resolves the Relief from Stay Motion. 

2. The automatic stay shall initially and immediately be modified solely as 

follows: 

a. To permit the Parties to participate in a mediation to attempt to 

resolve the claims against the Utility and its co-defendants alleged 

in the State Court Action (the “Mediation”). The Parties shall use 

their best efforts to schedule the Mediation within sixty days of the 

filing of this Stipulation. The automatic stay shall remain in place 

for all other purposes during this time. 

b. To permit counsel for the Gelmans to obtain and file (and, so 

desired, obtain approval of the Superior Court to) a stipulation in the 

State Court Action among all the parties to that action (including the 

Debtor) confirming the parties’ agreement to the proposed schedule 

laid out herein. 

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