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Adam C. Harris (pro hac vice pending) 

James T. Bentley (pro hac vice pending) 

Kelly (Bucky) Knight (pro hac vice pending) 

SCHULTE ROTH & ZABEL LLP 

919 Third Avenue 

New York, New York 10022 

Telephone: (212) 756-2000 

Facsimile: (212) 593-5955 

Email: adam.harris@srz.com 

Email: james.bentley@srz.com 

Email: kelly.knight@srz.com 

David M. Guess (SBN 238241) 

BIENERT | KATZMAN PC 

903 Calle Amanecer, Suite 350 

San Clemente, California 92673 

Telephone: (949) 369-3700 

Facsimile: (949) 369-3701 

Email: dguess@bienertkatzman.com 

Counsel to certain Utility Bondholders 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

-andPACIFIC 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) 

VERIFIED STATEMENT OF SCHULTE ROTH & 

ZABEL LLP AND BIENERT KATZMAN PC 

PURSUANT TO FEDERAL RULE OF 

BANKRUPTCY PROCEDURE 2019

Case: 19-30088 Doc# 4396 Filed: 10/22/19 Entered: 10/22/19 17:30:13 Page 1 of

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Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), 

Schulte Roth & Zabel LLP (“Schulte Roth”) and Bienert Katzman PC (“Bienert Katzman”) submit this 

verified statement (this “Statement”) with respect to certain beneficial holders or investment advisers or 

managers for certain beneficial holders of unsecured notes (the “Utility Bonds”) issued by Pacific Gas and 

Electric Company (the “Utility”), each as identified on Exhibit A hereto (each, a “Utility Bondholder”), 

and in support hereof states as follows: 

In October 2019, the Utility Bondholders retained Schulte Roth and Bienert Katzman to advise 

them, solely in their capacity as Utility Bondholders, in connection with the chapter 11 cases of the Utility 

and PG&E Corporation (“PG&E” and, together with the Utility, the “Debtors”). The Utility Bondholders 

hold, or manage or advise funds and/or accounts that hold, disclosable economic interests in relation to the 

Debtors. Attached hereto as Exhibit A is a list of the names, addresses, nature, and amount of all 

disclosable economic interests of each Utility Bondholder in relation to the Debtors as of October 16, 2019. 

The information set forth in Exhibit A is based on information provided to Schulte Roth and Bienert 

Katzman by each applicable Utility Bondholder. Schulte Roth and Bienert Katzman submit this Statement 

in an abundance of caution and without conceding that the provisions of Bankruptcy Rule 2019 apply to 

their representation of the Utility Bondholders. 

As of the date of this Statement, Schulte Roth and Bienert Katzman represent only the Utility 

Bondholders, solely in their capacity as Utility Bondholders, in connection with the Debtors’ restructuring. 

The Utility Bondholders determined to jointly retain Schulte Roth and Bienert Katzman, to protect their 

legal rights in connection with the Joint Chapter 11 Plan of Reorganization of Official Committee of Tort 

Claimants and Ad Hoc Committee of Senior Unsecured Noteholders, dated October 17, 2019 (as the same 

may be amended, modified or supplemented from time to time; the “TCC/Ad Hoc Committee Plan”), 

including (without limitation) (a) the right of all holders of Utility Bonds (who are not members of the Ad 

Hoc Committee) to be treated equally and fairly, and to not be discriminated against, in relation to the 

holders of Utility Bonds that are members of the Ad Hoc Committee, and (b) the right to ensure that any 

debt and/or equity financings contemplated by the TCC/Ad Hoc Committee Plan are subjected to a market 

test so as to permit the Debtors to obtain the most favorable terms available. 

Case: 19-30088 Doc# 4396 Filed: 10/22/19 Entered: 10/22/19 17:30:13 Page 2 of

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Schulte Roth and Bienert Katzman do not represent or purport to represent any other person or 

entities with respect to these chapter 11 cases. Schulte Roth and Bienert Katzman do not represent the 

Utility Bondholders as a “committee” (as such term is used in the Bankruptcy Code and Bankruptcy Rules) 

and do not undertake to represent the interests of, and are not a fiduciary for, any other creditor, party in 

interest, or other entity. In addition, as of the date of this Statement, no Utility Bondholder represents or 

purports to represent any other entity in connection with these chapter 11 cases. Moreover, no Utility 

Bondholder has or is a party to any agreement to act as a group or in concert with respect to its interests in 

the Debtors and each Utility Bondholder has the unrestricted right to act as it chooses in respect of such 

interests without respect to the actions or interests of any other party. 

Upon information and belief formed after due inquiry, Schulte Roth and Bienert Katzman do not 

hold any disclosable economic interest (as that term is defined in Bankruptcy Rule 2019(a)(1)) in relation 

to the Debtors. 

The undersigned verify that the foregoing is true and correct to the best of their knowledge, as of 

the date of this Statement. 

Nothing contained in this Statement is intended or shall be construed to constitute: (a) a waiver or 

release of the rights of any Utility Bondholder to have any final order entered by, or other exercise of the 

judicial power of the United States performed by, an Article III court; (b) a waiver or release of the rights 

of any Utility Bondholder to have any and all final orders in any and all non-core matters entered only after 

de novo review by a United States District Judge; (c) consent to the jurisdiction of the Court over any 

matter; (d) an election of remedy; (e) a waiver or release of any rights any Utility Bondholder may have to 

a jury trial; (f) a waiver or release of the right to move to withdraw the reference with respect to any matter 

or proceeding that may be commenced in the chapter 11 cases against or otherwise involving any Utility 

Bondholder; (g) a waiver or release of any other rights, claims, actions, defenses, setoffs or recoupments 

to which any Utility Bondholder is or may be entitled, in law or in equity, under any agreement or 

otherwise, with all such rights, claims, actions, defenses, setoffs or recoupments being expressly reserved; 

or (h) an admission or acknowledgement that Bankruptcy Rule 2019 applies to Schulte Roth’s or Bienert 

Katzman’s representation of the Utility Bondholders. 

Case: 19-30088 Doc# 4396 Filed: 10/22/19 Entered: 10/22/19 17:30:13 Page 3 of

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Schulte Roth and Bienert Katzman reserve the right to amend or supplement this Statement in 

accordance with the requirements of Bankruptcy Rule 2019 with any additional information that may 

become available. 

Dated: October 22, 2019 BIENERT | KATZMAN PC 

By: 

 David M. Guess (SBN 238241)

SCHULTE ROTH & ZABEL LLP 

By: 

 Adam C. Harris (pro hac vice pending) 

James T. Bentley (pro hac vice pending) 

Kelly (Bucky) Knight (pro hac vice pending)

Counsel to certain Utility Bondholders 

s/ David M. Guess

s/ Adam C. Harris

Case: 19-30088 Doc# 4396 Filed: 10/22/19 Entered: 10/22/19 17:30:13 Page 4 of

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Exhibit A 

Name and Address Disclosable Economic Interests 

Anchorage Capital Group, L.L.C., 

on behalf of certain funds and 

accounts 

610 Broadway, 6th Floor New 

York, NY 10012 

Utility Bonds: $157,000,000

DIP Loan Obligations: $22,500,0001

PG&E Common Shares: 24,905,000

Centerbridge Partners, L.P., on 

behalf of certain funds and 

accounts 

375 Park Avenue, 11th Floor 

New York, NY 10152 

Utility Bonds: $338,618,000

Utility Revolver: $4,935,725

Subrogation Claims: $189,875,301

PG&E Common Shares: 8,826,985

Utility Preferred Shares: 80,884

Silver Point Capital, L.P., on 

behalf of certain funds and 

accounts 

Two Greenwich Plaza 

Greenwich, CT 06830 

Utility Debt: $134,646,158.802

Subrogation Claims: $74,934,854.02

Trade Vendor Claims: $11,166,029.27

PG&E Common Shares: 17,887,000

SteelMill Master Fund LP 

c/o PointState Capital LP 

40 West 57th Street, 25th Floor 

New York, NY 10019 

Utility Bonds: $209,046,000

PG&E Common Shares: 6,251,765

1

 DIP Loan Obligations include undrawn commitments, if any. 

2

 Utility Debt includes both Utility bank debt and Utility Bonds. 

Case: 19-30088 Doc# 4396 Filed: 10/22/19 Entered: 10/22/19 17:30:13 Page 5 of

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