1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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 EXTENDING TIME FOR 

COMMUNITY CHOICE 

AGGREGATORS TO RESPOND TO BAR 

DATE MOTION 

Re: Dkt. No. 1784 

[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# 2237 Filed: 05/28/19 Entered: 05/28/19 13:26:00 Page 1 of

3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 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 G. Larry Engel, Esq. 

(“Engel”), for this purpose only for the benefit of or on behalf of (1) Sonoma Clean Power 

Authority (“SCPA”), (2) Clean Power SF (a division of the City and County of San Francisco), 

City of San Jose, East Bay Community Energy Authority, Marin Clean Energy, Monterey Bay 

Community Power, Peninsula Clean Energy, Pioneer Community Energy, Redwood Coast 

Energy Authority, Silicon Valley Clean Energy Authority, Valley Clean Energy Alliance, the 

Northern California Power Agency, the Transmission Agency of Northern California (the 

“Additional CCA Parties”), and (3) the SCPA and other CCA program operating agencies or 

member agencies who elect to file joinders with or in addition to Additional CCA Parties named 

in Exhibit A hereto (collectively, the “Participating Governmental Units”), on the other hand. 

The Debtors and Engel 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 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 [Dkt. No. 1784] (the “Bar Date 

Motion”), which is set for a hearing before the Court at 9:30 a.m. on June 11, 2019. Any 

response or opposition to the Bar Date Motion is due by 4:00 p.m. (Pacific Time) on May 28, 

2019. 

B. SCPA has prepared objections to the Bar Date Motion in which some or all of the 

Additional CCA Parties may join or support by signing or filing separate responses of moderate 

or less length, and Participating Governmental Units may join by signing or filing separate 1-2 

page joinder responses supporting the SCPA objections or such related Additional CCA Parties’ 

filings. Engel, on behalf of or for the benefit of SCPA, the Additional CCA Parties, and other 

Case: 19-30088 Doc# 2237 Filed: 05/28/19 Entered: 05/28/19 13:26:00 Page 2 of

3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

Participating Governmental Units, has requested, and counsel for the Debtors has agreed, that the 

time for the SCPA to file any objections to the Bar Date Motion and the time for the Additional 

CCA Parties and the other Participating Governmental Units to file any such described joinders 

or supporting responses to the any objection filed by SCPA (or their Additional CCA Parties’ 

supporting filings) 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 (i) SCPA to file and serve any response or opposition to the Bar Date 

Motion, and (2) the Additional CCA Parties and other Participating Governmental Units to file 

such joinders and responses in support of, or to sign on to, any response or opposition to the Bar 

Date Motion filed by SCPA is extended through 4:00 p.m. (Pacific Time) on May 31, 2019. 

Dated: May 28, 2019 Dated: May 28, 2019

KELLER & BENVENUTTI LLP G. LARRY ENGEL, ESQ. 

/s/ Jane Kim /s/ G. Larry Engel

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

G. Larry Engel

 

Counsel for Sonoma Clean Power 

Authority 

Case: 19-30088 Doc# 2237 Filed: 05/28/19 Entered: 05/28/19 13:26:00 Page 3 of

3