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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) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Theodore Tsekerides (pro hac vice) 

(theodore.tsekerides@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 

Attorneys for Debtors and Debtors in Possession 

 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: 650 636 9251 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 - and - 

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).

 Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

STATEMENT OF DEBTORS 

REGARDING STATUS OF 

RESOLUTION OF PHILIP 

VERWEY FARMS’ (“PVF”) 

MOTION FOR RELIEF FROM 

AUTOMATIC STAY TO EXERCISE 

SETOFF PURSUANT TO 11 U.S.C. 

§§ 362 AND 553 

[Relates to Dkt. No. 1141] 

Date: August 28, 2019 

Time: 9:30 a.m. 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Case: 19-30088 Doc# 3680 Filed: 08/23/19 Entered: 08/23/19 16:15:06 Page 1 of

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

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”), respectfully submit this statement 

regarding the efforts to resolve Philip Verwey Farms’ (“PVF”)1 Motion for Relief from Automatic 

Stay to Exercise Setoff Pursuant to 11 U.S.C. §§ 362 and 553 (the “Motion”) [Dkt. No. 1141]. 

At the Court’s direction, the parties have attempted to resolve the Motion by entering into 

a stipulation by which PG&E would commit to forbearance from its collection efforts against PVF 

(but not any of the related entities) until PVF’s claims are resolved through the claims allowance 

process. Counsel for the Debtors and PVF have corresponded and exchanged drafts of a proposed 

stipulation and order, but, due to various conflicting schedules, have not yet reached agreement on 

all terms. The Debtors are hopeful that agreement will be reached, but cannot assure that will 

occur before the continued hearing date. 

The Debtors propose that, if the parties are unable to conclude an agreement prior to the 

August 28 hearing, the hearing on the Motion be continued another two weeks (to September 10) 

so the parties may have more time to finalize their stipulation. The Debtors are currently 

forbearing from collection activity against PVF (or any of its related entities) on account of their 

prepetition obligations to PG&E, and will continue to forbear during the proposed continuance. 

 Respectfully submitted, 

Dated: August 23, 2019 

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVNUTTI LLP 

By: /s/ Peter J. Benvenutti 

 Peter J. Benvenutti 

Attorneys for Debtors and Debtors in Possession

1 The motion papers and relevant proofs of claim identify the moving party and creditor as Philip 

Verwey d/b/a Philip Verwey Farms – in other words, as an individual/sole proprietorship. 

Case: 19-30088 Doc# 3680 Filed: 08/23/19 Entered: 08/23/19 16:15:06 Page 2 of

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