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BAKER 

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HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

Robert A. Julian (SBN 88469) 

Cecily A. Dumas (SBN 111449) 

BAKER & HOSTETLER LLP 

1160 Battery Street, Suite 100 

San Francisco, CA 94111 

Telephone: 628.208.6434 

Facsimile: 310.820.8859 

Email: rjulian@bakerlaw.com 

Email: cdumas@bakerlaw.com 

Eric E. Sagerman (SBN 155496) 

Lauren T. Attard (SBN 320898) 

BAKER & HOSTETLER LLP 

11601 Wilshire Boulevard 

Suite 1400 

Los Angeles, CA 90025 

Telephone: 310.820.8800 

Facsimile: 310.820.8859 

Email: esagerman@bakerlaw.com 

Email: lattard@bakerlaw.com 

Counsel for Official Committee of Tort Claimants 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

-andPACIFIC 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) 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

EX PARTE MOTION OF THE 

OFFICIAL COMMITTEE OF TORT 

CLAIMANTS PURSUANT TO B.L.R. 

9006-1 REQUESTING ORDER 

SHORTENING TIME FOR HEARING 

ON MOTION FOR ENTRY OF AN 

ORDER DETERMINING 

PROCEDURES FOR PRESERVING 

JURY TRIAL RIGHTS 

 [No hearing requested]

Case: 19-30088 Doc# 3481 Filed: 08/08/19 Entered: 08/08/19 18:25:15 Page 1 of

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The Official Committee of Tort Claimants (hereafter, the “TCC”) in the above-captioned 

chapter 11 cases (the “Chapter 11 Cases”) of PG&E Corporation and Pacific Gas and Electric 

Company (collectively, the “Debtors” or “PG&E”), hereby submits this Motion (the “Motion to 

Shorten”), pursuant to Rule 9006-1 of the Bankruptcy Local Rules for the United States 

Bankruptcy Court for the Northern District of California (the “Bankruptcy Local Rules”), for 

entry of an order shortening time for a hearing on the TCC’s motion for entry of an order 

determining procedures for jury trial rights (the “TCC Motion”). In support of this Application, 

the TCC submits the Declaration of Joseph M. Esmont (the “Esmont Declaration”) filed 

contemporaneously herewith. A proposed form of order granting the relief requested herein is 

annexed hereto as Exhibit A (the “Proposed Order”). 

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. BASIS FOR RELIEF SOUGHT 

Pursuant to Bankruptcy Local Rule 9014-1(c)(2), a hearing on the TCC Motion requires at 

least twenty-one (21) days’ notice of an opportunity for a hearing. Bankruptcy Local 

Rule 9006-1(a) provides that, except as set forth therein, “approval of the Court is required to 

enlarge or to shorten time to perform any act or file any paper pursuant to the Federal Rules of Civil 

Procedures, the Bankruptcy Rules, or these Bankruptcy Local Rules.” B.L.R. 9006-1(a). 

The Court’s approval is warranted here. The bar date for filing claims is just over two 

months away, on October 21, 2019. Multiple thousands of personal injury victims will file claims 

in these Chapter 11 Cases. Many may wait until confirmation of preservation of their jury trial 

rights to file their claims. 

Case: 19-30088 Doc# 3481 Filed: 08/08/19 Entered: 08/08/19 18:25:15 Page 2 of

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Using the Court’s 21 day notice period, the next available PG&E omnibus hearing date is 

September 10, 2019. That hearing is only 41 days prior to the claims bar date in these cases. The 

order would facilitate the filing of claims as quickly as possible and well in advance of the bar date. 

To this end, the TCC requests that notice be shortened to permit the TCC Motion to be 

heard as soon as possible. The TCC’s proposal is for the Motion to be heard on August 14, 2019. 

If that date is not available, the TCC requests that the Court hear the Motion as soon as practical 

after that date, up to and including August 27, 2019. In any event, the TCC requests that the Court 

set an appropriate objection deadline. 

As stated in the Esmont Declaration, as of the filing of this Motion to Shorten, the Debtors 

did not respond to this request. 

III. NOTICE 

Notice of this Motion to Shorten will be provided to (i) the Debtors, c/o PG&E Corporation 

and Pacific Gas and Electric Company, PO Box 770000, 77 Beale Street, San Francisco, CA 94105 

(Attn: Janet Loduca, Esq.); (ii) Weil, Gotshal & Manges LLP, 767 Fifth Avenue, New York, New 

York 10153 (Attn: Stephen Karotkin, Esq., Jessica Liou, Esq., and Matthew Goren, Esq.), proposed 

attorneys for the Debtors; (iii) Keller & Benvenutti LLP, 650 California Street, Suite 1900, San 

Francisco, CA 94108 (Attn: Tobias Keller, Esq. and Jane Kim, Esq.), proposed attorneys for the 

Debtors; (iv) Stroock & Stroock & Lavan LLP, 180 Maiden Lane, New York, NY 10038-4982 

(Attn: Kristopher M. Hansen, Esq., Erez E. Gilad, Esq., and Matthew G. Garofalo, Esq.) and 2029 

Century Park East, Los Angeles, CA 90067-3086 (Attn: Frank A. Merola, Esq.), as counsel for the 

administrative agent under the Debtors’ debtor-in-possession financing facility; (v) Davis Polk & 

Wardwell LLP, 450 Lexington Avenue, New York, NY 10017 (Attn: Eli J. Vonnegut, Esq., David 

Schiff, Esq., and Timothy Graulich, Esq.), as counsel for the collateral agent under the Debtors’ 

debtor-in-possession financing facility; (vi) Paul, Weiss, Rifkind, Wharton & Garrison LLP, 1285 

Avenue of the Americas, New York, NY 10019-6064 (Attn: Alan W. Kornberg, Esq., Brian S. 

Hermann, Esq., Walter R. Rieman, Esq., Sean A. Mitchell, Esq., and Neal P. Donnelly, Esq.), as 

counsel to the California Public Utilities Commission; (vii) the Office of the United States Trustee 

for Region 17, 450 Golden Gate Avenue, 5th Floor, Suite #05-0153, San Francisco, CA 94102 

Case: 19-30088 Doc# 3481 Filed: 08/08/19 Entered: 08/08/19 18:25:15 Page 3 of

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(Attn: James L. Snyder, Esq. and Timothy Laffredi, Esq.); (viii) U.S. Nuclear Regulatory 

Commission, Washington, DC 20555-0001 (Attn: General Counsel); (ix) U.S. Department of 

Justice, 1100 L Street, NW, Room 7106, Washington DC 20005 (Attn: Danielle A. Pham, Esq.,) 

as counsel for United States on behalf of the Federal Energy Regulatory Commission; (x) Milbank 

LLP, 55 Hudson Yards, New York, NY 10001-2163 (Attn: Dennis F. Dunne, Esq. and Sam A. 

Khalil, Esq.) and 2029 Century Park East, 33rd Floor, Los Angeles, CA 90067 (Attn: Paul S. 

Aronzon, Esq., Gregory A. Bray, Esq., and Thomas R. Kreller, Esq.), as counsel for the Official 

Committee of Unsecured Creditors; and (xi) those persons who have formally appeared in these 

Chapter 11 Cases and requested service pursuant to Bankruptcy Rule 2002. The TCC respectfully 

submits that no further notice is required. 

No previous request for the relief sought herein has been made by the TCC to this or any 

other court. 

WHEREFORE, the TCC respectfully requests entry of an order granting the Motion to 

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

Dated: August 8, 2019 

BAKER & HOSTETLER LLP 

By: /s/ Lauren T. Attard Lauren T. Attard 

Counsel for The Official Committee of Tort 

Claimants 

Case: 19-30088 Doc# 3481 Filed: 08/08/19 Entered: 08/08/19 18:25:15 Page 4 of

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