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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) 

Theodore Tsekerides (pro hac vice) 

(theodore.tsekerides@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) 

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: (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 DAN CLARKE TO CONTINUE 

HEARING ON MOTION FOR RELIEF 

FROM AUTOMATIC STAY 

Re: Dkt. Nos. 2823 

[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# 3050 Filed: 07/18/19 Entered: 07/18/19 10:25:05 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 Dan Clarke (“Clarke”), 

on the other. The Debtors and Clarke 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 June 19, 2019, Clarke filed the Motion for Relief from the Automatic Stay

[Dkt. No. 2823] (the “Motion”) which is currently set for a hearing at 9:30 a.m. on July 24, 2019 

(the “Hearing”). Any response or opposition to the Motion by the Debtors or either official 

committee appointed in this case is due by 4:00 p.m. (Pacific Time) on July 19, 2019. 

B. The Parties have agreed, subject to formal documentation, to a resolution of the 

Motion by allowing Clarke limited relief from the automatic stay. 

C. The Parties’ respective counsel have agreed that the Hearing be continued to the 

omnibus hearing scheduled for 9:30 a.m. on July 31, 2019, so that the Parties may prepare a 

formal stipulation and proposed order granting Clarke limited relief from the automatic stay. 

NOW, THEREFORE, 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 Hearing on the Motion is continued to 9:30 a.m. (Pacific Time) on 

July 31, 2019. 

2. The time for the Debtors and the official appointed committees to respond 

to the Motion shall be extended to 4:00 p.m. (Pacific Time) on July 26, 2019. 

[Signatures on next page] 

Case: 19-30088 Doc# 3050 Filed: 07/18/19 Entered: 07/18/19 10:25:05 Page 2 of

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

Dated: July 18, 2019 Dated: July 18, 2019

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

BELVEDERE LEGAL PC 

/s/ Peter J. Benvenutti /s/ Matthew D. Metzger

Peter J. Benvenutti

Attorneys for Debtors 

and Debtors in Possession

Matthew D. Metzger

Attorneys for Dan Clarke

Case: 19-30088 Doc# 3050 Filed: 07/18/19 Entered: 07/18/19 10:25:05 Page 3 of

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