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

BAKER 

&

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 90025-0509

Telephone: 310.820.8800

Facsimile: 310.820.8859

Email: esagerman@bakerlaw.com

Email: lattard@bakerlaw.com

Counsel to the 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)

STIPULATION BETWEEN AD HOC

COMMITTEE OF SENIOR UNSECURED

NOTEHOLDERS AND THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS

EXTENDING TIME TO RESPOND TO 

THE 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 [Dkt. No. 

2741]

Date: July 24, 2019

Time: 9:30 a.m. (Pacific Time)

Place: United States Bankruptcy Court

Courtroom 17, 16 Floor

San Francisco, CA 94102

Case: 19-30088 Doc# 2975 Filed: 07/15/19 Entered: 07/15/19 12:34:04 Page 1 of

2
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

BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

- 1 -

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

entered into by, on the one hand, the Ad Hoc Committee of Senior Unsecured Noteholders of 

Pacific Gas and Electric Company (the “Ad Hoc Committee”) and, on the other hand, the Official 

Committee of Tort Claimants (“TCC”) in the chapter 11 cases of PG&E Corporation and Pacific 

Gas and Electric Company (the “Debtors” or “PG&E”). The Ad Hoc Committee and the TCC are 

referred to in this Stipulation and Agreement for Order collectively as the “Parties.” The Parties 

hereby stipulate and agree as follows:

RECITALS

On June 25, 2019, the Ad Hoc Committee filed the Motion of the Ad Hoc Committee of 

Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods Pursuant to Section 

1121(d)(1) of title 11 of the Bankruptcy Code [Dkt. No. 2741] (“Motion”). The Motion is set for 

a hearing before the Court at 9:30 a.m. on July 24, 2019, and the objection deadline is 4:00 p.m. on 

July 17, 2019. 

Counsel for the Ad Hoc Committee and the TCC have agreed that the time for the TCC to 

respond to the Motion should 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 TCC to file and serve any response or opposition to the Motion to 

Terminate Exclusivity is extended through 4:00 p.m. (Pacific Time) on July 18, 2019.

Dated: July 15, 2019 Dated: July 15, 2019

AKIN GUMP STRAUSS HAUER &

FELD LLP

BAKER & HOSTETLER LLP

By: /s/ Ashley Vinson Crawford By: /s/ Cecily A. Dumas 

 Ashley Vinson Crawford Cecily A. Dumas

Counsel for the Ad Hoc Committee of 

Senior Unsecured Noteholders

Counsel for Official Committee of Tort 

Claimants

Case: 19-30088 Doc# 2975 Filed: 07/15/19 Entered: 07/15/19 12:34:04 Page 2 of

2