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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 BETWEEN DEBTORS 

AND OFFICIAL COMMITTEE OF TORT 

CLAIMANTS EXTENDING TIME TO 

RESPOND TO KPMG APPLICATION 

AND MORRISON & FOERSTER 

APPLICATION 

 

Re: Dkt. Nos. 2171, 2193 

[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# 2379 Filed: 06/04/19 Entered: 06/04/19 13:33:17 Page 1 of

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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 the Official Committee 

of Tort Claimants (the “TCC”), on the other. The Debtors and the TCC 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 21, 2019, the Debtors filed the Application of Debtors Pursuant to 11 

U.S.C. §§ 327(a) and 328(a) and Fed. R. Bankr. P. 2014(a) and 2016 for Authority to Retain and 

Employ KPMG LLP as Information Technology, Risk, and Legal Support Consultants to the 

Debtors Nunc Pro Tunc to Petition Date [Dkt. No. 2171] (the “KPMG Application”), which is 

set for a hearing before the Court at 9:30 a.m. on June 11, 2019. Any response or opposition to 

the KPMG Application is due by 4:00 p.m. (Pacific Time) on June 4, 2019. 

B. On May 22, 2019, the Debtors filed the Application of Debtors Pursuant to 11 

U.S.C. § 327(e) and Fed. R. Bankr. P. 2014(a) and 2016 For Authority to Retain and Employ 

Morrison & Foerster LLP as Special Regulatory Counsel for the Debtors Effective as of the 

Petition Date [Dkt. No. 2193] (the “Morrison & Foerster Application”), which is set for a 

hearing before the Court at 9:30 a.m. on June 12, 2019. Any response or opposition to the 

Morrison & Foerster Application is due by 4:00 p.m. (Pacific Time) on June 5, 2019.

C. Counsel for the Debtors and counsel for the TCC have agreed that the time for the 

TCC to respond to the KPMG Application and the Morrison & Foerster Application 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: 

/// 

///

Case: 19-30088 Doc# 2379 Filed: 06/04/19 Entered: 06/04/19 13:33:17 Page 2 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

///

1. The time for the TCC to file and serve any response or opposition to the KPMG 

Application and the Morrison & Foerster Application is extended through 4:00 p.m. (Pacific Time) 

on June 7, 2019. 

Dated: June 4, 2019 Dated: June 4, 2019

WEIL GOTSHAL & MANGES 

KELLER & BENVENUTTI LLP 

BAKER & HOSTETLER LLP 

/s/ Tobias S. Keller /s/ Jorian L. Rose

Tobias S. Keller

Attorneys for Debtors 

and Debtors in Possession

Jorian L. Rose

 

Attorneys for Official Committee of Tort 

Claimants

Case: 19-30088 Doc# 2379 Filed: 06/04/19 Entered: 06/04/19 13:33:17 Page 3 of

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