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AKIN GUMP STRAUSS HAUER & FELD LLP

Michael S. Stamer (pro hac vice)

Ira S. Dizengoff (pro hac vice)

David H. Botter (pro hac vice)

Abid Qureshi (pro hac vice)

One Bryant Park

New York, New York 10036

Telephone: (212) 872-1000

Facsimile: (212) 872-1002

Email: mstamer@akingump.com

idizengoff@akingump.com

dbotter@akingump.com

aqureshi@akingump.com

AKIN GUMP STRAUSS HAUER & FELD LLP

Ashley Vinson Crawford (SBN 257246)

580 California Street

Suite 1500

San Francisco, CA 94104

Telephone: (415) 765-9500

Facsimile: (415) 765-9501

Email: avcrawford@akingump.com

Counsel to the Ad Hoc Committee of Senior Unsecured 

Noteholders of Pacific Gas and Electric Company 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

EX PARTE APPLICATION FOR ORDER 

PURSUANT TO L.B.R. 9013-1(c) 

AUTHORIZING OVERSIZE BRIEFING 

FOR REPLY IN SUPPORT OF 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

Related Document: Dkt. 2741

[No hearing requested]

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# 3139 Filed: 07/22/19 Entered: 07/22/19 18:12:18 Page 1 of

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The Ad Hoc Committee of Senior Unsecured Noteholders of Pacific Gas and Electric Company 

(the “Ad Hoc Committee”)1 in the above-captioned chapter 11 cases of Pacific Gas and Electric 

Company (the “Utility”) and PG&E Corporation (“PG&E” and, together with the Utility, the “Debtors”), 

by its undersigned counsel, Akin Gump Strauss Hauer & Feld LLP, hereby submits this Ex Parte

Application (the “Application”), pursuant to Rule 9013-1(c) of the Bankruptcy Local Rules for the 

United States District Court for the Northern District of California (the “Bankruptcy Local Rules”), for 

an order authorizing the Ad Hoc Committee to file an oversize Reply in Support of Motion of the Ad Hoc 

Committee of Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods Pursuant to 

Section 1121(d) of the Bankruptcy Code (the “Reply”), which the Ad Hoc Committee will file on July 

23, 2019.

MEMORANDUM OF POINTS AND AUTHORITIES

I. JURISDICTION AND VENUE

1. The Court has jurisdiction to consider this matter pursuant to 28 U.S. C. §§ 157 and 1334, 

the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24 (N.D. 

Cal.), and Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District Court for the 

Northern District of California (the “Bankruptcy Local Rules”). 

2. This is a core proceeding pursuant to 28 U.S.C. §157(b). 

3. Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409.

II. BACKGROUND

4. 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 the Bankruptcy Code [Docket No. 2741] (the “Termination Motion”).

5. At least sixteen objections, joinders to objections, and other responses were filed with 

respect to the Motion (the “Responses”).

1 The Ad Hoc Committee filed an amended verified statement pursuant to Rule 2019 of the Federal Rules of 

Bankruptcy Procedure on July 18, 2019 [Docket No. 3083].

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6. The Ad Hoc Committee now seeks to file the Reply, which will address all the Responses 

filed to date. 

III. OVERSIZE BRIEFING FOR THE REPLY IS WARRANTED

7. Bankruptcy Local Rule 9013-1(c) provides that, “Unless the court expressly orders 

otherwise, the initial and response memoranda of points and authorities shall not exceed 25 pages of 

text, and reply memorandum shall not exceed 15 pages of text.” B.L.R. 9013-1(c).

8. The Ad Hoc Committee submits that sufficient cause exists for the Court to allow oversize 

briefing for the Reply. Because many of the Responses raise similar issues with respect to the Motion, 

addressing the Responses by an omnibus reply is efficient. However, given the number and substance 

of the Responses, the 15-page limit would not permit the Ad Hoc Committee to adequately address all 

of the arguments made by the sixteen respondents. Specifically, through the Reply, the Ad Hoc 

Committee will be responding to a 20-page objection filed by the Debtors, a 14-page objection filed by 

the Official Committee of Tort Claimants, a 13-page objection filed by the Shareholder Group, and a

13-page objection filed by the Ad Hoc Group of Subrogation Claim Holders.

9. The Ad Hoc Committee has tried to limit the length of the Reply, however, in order to 

adequately address all of the points raised in the various Responses in a single document, the Ad Hoc 

Committee hereby requests up to 25 pages for the Reply.

NOTICE

10. Notice of this Motion will be provided to (i) counsel to the Debtors; (ii) the Office of the 

U.S. Trustee for Region 17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (iii) counsel to the 

Creditors Committee; (iv) counsel to the Tort Claimants Committee; (v) the Securities and Exchange 

Commission; (vi) the Internal Revenue Service; (vii) the Office of the California Attorney General; (viii) 

the California Public Utilities Commission; (ix) the Nuclear Regulatory Commission; (x) the Federal 

Regulatory Commission; (xi) the Office of the United States Attorney for the Northern District of 

California; (xii) counsel for the agent under the Debtors’ debtor in possession financing facility; and 

(xiii) those persons who have formally appeared in these chapter 11 cases and requested service pursuant 

to Bankruptcy Rule 2002. The Ad Hoc Committee respectfully submits that no further notice is required.

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WHEREFORE, the Ad Hoc Committee respectfully requests entry of an order authorizing the 

Ad Hoc Committee to file the Reply in excess of 15 pages, but not to exceed 25 pages (exclusive of any 

schedules or exhibits thereto and/or any declarations filed in connection therewith), and such other and 

further relief as the Court may deem just and appropriate.

Dated: July 22, 2019 AKIN GUMP STRAUSS HAUER & FELD LLP

By: /s/ Ashley Vinson Crawford

Ashley Vinson Crawford (SBN 257246)

Michael S. Stamer (pro hac vice)

Ira S. Dizengoff (pro hac vice)

David H. Botter (pro hac vice)

Abid Qureshi (pro hac vice)

Counsel to the Ad Hoc Committee of Senior Unsecured 

Noteholders of Pacific Gas and Electric Company 

Case: 19-30088 Doc# 3139 Filed: 07/22/19 Entered: 07/22/19 18:12:18 Page 4 of

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Exhibit A

Proposed Order

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AKIN GUMP STRAUSS HAUER & FELD LLP

Michael S. Stamer (pro hac vice)

Ira S. Dizengoff (pro hac vice)

David H. Botter (pro hac vice)

Abid Qureshi (pro hac vice)

One Bryant Park

New York, New York 10036

Telephone: (212) 872-1000

Facsimile: (212) 872-1002

Email: mstamer@akingump.com

idizengoff@akingump.com

dbotter@akingump.com

aqureshi@akingump.com

Ashley Vinson Crawford (SBN 257246)

580 California Street

Suite 1500

San Francisco, CA 94104

Telephone: (415) 765-9500

Facsimile: (415) 765-9501

Email: avcrawford@akingump.com

Counsel to the Ad Hoc Committee of Senior Unsecured 

Noteholders of Pacific Gas and Electric Company 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

[PROPOSED] ORDER AUTHORIZING 

OVERSIZE BRIEFING FOR REPLY IN 

SUPPORT OF 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

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).

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The Court, having reviewed the Ex Parte Application for Order Pursuant to L.B.R. 9013-1(c) 

Authorizing Oversize Briefing for Reply in Support of 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 (the “Application”) filed on July 22, 2019, and after due deliberation and sufficient 

cause appearing therefor, 

IT IS HEREBY ORDERED THAT:

1. The Application is granted, as provided herein.

2. The Ad Hoc Committee is authorized to file and serve a reply memorandum of points and 

authorities in support of 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, in 

excess of 15 pages, but not to exceed 25 pages (exclusive of any schedules or exhibits thereto and/or any 

declarations filed in connection therewith).

** END OF ORDER **

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