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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) 

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 CALIFORNIA DEPARTMENT OF 

FORESTRY AND FIRE PROTECTION 

EXTENDING TIME TO RESPOND TO 

LEASE ASSUMPTION MOTION 

Re: Dkt. No. 3726 

[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# 3840 Filed: 09/09/19 Entered: 09/09/19 13:17:19 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 California 

Department of Forestry and Fire Protection (“CAL FIRE”), on the other hand. The Debtors and 

CAL FIRE 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 August 27, 2019, the Debtors filed the Fifth Omnibus Motion of the Debtors 

Pursuant to 11 U.S.C. § 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 for an Order 

Approving Assumption of Certain Real Property Leases [Dkt. No. 3726] (the “Lease 

Assumption Motion”), which is set for a hearing before the Court at 9:30 a.m. on September 24, 

2019. Any response or opposition to the Lease Assumption Motion is due by 4:00 p.m. (Pacific 

Time) on September 10, 2019. 

B. Counsel for CAL FIRE has requested, and counsel for the Debtors has agreed, 

that the time for CAL FIRE to respond to the Lease Assumption Motion 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 CAL FIRE to file and serve any response or opposition to the Lease 

Assumption Motion is extended through 4:00 p.m. (Pacific Time) on September 13, 2019. 

[Signatures on next page] 

Case: 19-30088 Doc# 3840 Filed: 09/09/19 Entered: 09/09/19 13:17:19 Page 2 of

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

Dated: September 9, 2019 Dated: September 9, 2019

KELLER & BENVENUTTI LLP XAVIER BECERRA 

Attorney General of California 

MARGARITA PADILLA 

Supervising Deputy Attorney General 

 

/s/ Thomas B. Rupp /s/ Paul J. Pascuzzi

Thomas B. Rupp

Attorneys for Debtors 

and Debtors in Possession

STEVEN H. FELDERSTEIN

PAUL J. PASCUZZI 

FELDERSTEIN FITZGERALD 

WILLOUGHBY PASCUZZI & RIOS 

LLP 

Attorneys for California Department of 

Forestry and Fire Protection 

Case: 19-30088 Doc# 3840 Filed: 09/09/19 Entered: 09/09/19 13:17:19 Page 3 of

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