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KELLER BENVENUTTI KIM LLP

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Thomas B. Rupp (#278041) 

(trupp@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized 

Debtors

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

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 No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STIPULATION BY AND BETWEEN 

REORGANIZED DEBTORS AND 

CITY AND COUNTY OF SAN 

FRANCISCO REGARDING CLAIM 

NO. 108511 

 

Case: 19-30088 Doc# 13660 Filed: 04/07/23 Entered: 04/07/23 15:08:27 Page 1

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PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the 

“Utility”), as debtors and reorganized debtors (collectively, the “Debtors” and as reorganized 

pursuant to the Plan,1 the “Reorganized Debtors”) in the above-captioned cases (the “Chapter 

11 Cases”) and the City and County of San Francisco (“CCSF,” and together with the 

Reorganized Debtors, the “Parties”), by and through their respective counsel, hereby submit this 

stipulation (the “Stipulation”) regarding Claim No. 108511 filed by CCSF. The Parties hereby 

stipulate and agree as follows: 

RECITALS 

A. On January 29, 2019 (the “Petition Date”), PG&E Corporation (“PG&E Corp.”)

and Pacific Gas and Electric Company (the “Utility”), as debtors and debtors in possession 

(collectively, the “Debtors” or, as reorganized pursuant to the Plan (as defined below), the 

“Reorganized Debtors”) in the below captioned chapter 11 cases (the “Chapter 11 Cases”), each 

commenced with the United States Bankruptcy Court for the Northern District of California (the 

“Bankruptcy Court”) a voluntary case for relief under chapter 11 of title 11 of the United States 

Code (the “Bankruptcy Code”), which Chapter 11 Cases have been consolidated for procedural 

purposes only under the lead case styled: PG&E Corporation and Pacific Gas and Electric 

Company, Case No. 19-30088. 

B. On June 20, 2020, the Bankruptcy Court entered an Order [Docket No. 8053] (the 

“Confirmation Order”) confirming the Debtors’ and Shareholder Proponents’ Joint Chapter 11 

Plan of Reorganization Dated June 19, 2020 [Docket No. 8048] (as may be further modified, 

supplemented, or amended from time to time, and together with all schedules and exhibits thereto, 

the “Plan”).2 The Plan became effective on July 1, 2020. 

1

 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in 

the Debtors’ and Shareholder Proponents’ Joint Chapter 11 Plan of Reorganization Dated June 

19, 2020 (as may be further modified, amended or supplemented from time to time, and together 

with any exhibits or schedules thereto, the “Plan”). 

2

 Capitalized terms used but not herein defined have the meanings ascribed to them in the Plan. 

Case: 19-30088 Doc# 13660 Filed: 04/07/23 Entered: 04/07/23 15:08:27 Page 2

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C. On October 18, 2019, Claimant timely filed proof of claim number 64163 in the 

Chapter 11 Cases against the Debtors; 

D. On June 3, 2022, Claimant timely filed proof of claim number 108511 (the “Proof of 

Claim),” which amended and superseded claim number 64163. A copy of the Proof of Claim is 

attached hereto as Exhibit A. The Subclaims of the Proof of Claim are identified on Exhibit B 

attached hereto. 

E. Pursuant to section 7.2 of the Plan, the Reorganized Debtors are authorized to, among 

other things, compromise, settle, otherwise resolve, or withdraw any objections to Disputed Claims 

(as defined in the Plan) and to compromise, settle, or otherwise resolve any Disputed Claims without 

approval of the Bankruptcy Court; and 

F. The Parties wish to document the resolution of the claims that are asserted by the 

Claimant in the Proof of Claim. 

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 BANKRUPTCY COURT 

TO ORDER, THAT: 

1. The Proof of Claim is deemed withdrawn by Claimant with prejudice; provided, 

however, that: 

a. Claimant is entitled to pursue Subclaim No. 108511-2—which pertains to ongoing 

project work related to the Cross Bore Agreement dated October 14, 2014, and the 

subsequent Amendments thereto—as if the Chapter 11 Cases had not been 

commenced. 

b. Nothing herein shall affect or alter the terms of the Parties’ December 30, 2020, 

settlement of the Gas House Cove matter described in Subclaim 108511-3. 

c. Claimant is entitled to pursue the following Subclaims, which are the subject of 

FERC proceedings for which the automatic stay was modified pursuant to the Order 

Modifying the Automatic Stay for the City and County of San Francisco Regarding 

FERC Proceedings [Docket No. 2027], as if the Chapter 11 Cases had not been 

commenced: 

i. Subclaim No. 108511-8, pertaining to FERC Case No. EL19-38; 

ii. Subclaim No. 108511-9, pertaining to FERC Case No. EL15-3-00, and 

related consolidated disputes on servicing regarding the Wholesale 

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Distribution Tariff (FERC Case Nos. ER15-702, ER15-703, ER15-

704, ER15-705, and ER15-735); and 

iii. Subclaim No. 108511-10, pertaining to FERC Case Nos. ER17-910, 

ER17-1509, ER17-2181, and ER18-1102. 

d. Claimant is entitled to pursue the following Subclaims, which are for potential 

recovery pursuant to FERC Tariff Rate Proceedings, as defined by the Plan, as if the 

Chapter 11 Cases had not been commenced: 

i. Subclaim No. 108511-11, pertaining to FERC Case No. ER19-13; 

ii. Subclaim No. 108511-12, pertaining to FERC Case No. ER17-2154; 

and 

iii. Subclaim No. 108511-13, pertaining to FERC Case No. ER16-2320. 

2. This Stipulation shall be binding on the Parties and each of their successors in 

interest. 

3. This Stipulation shall constitute the entire agreement and understanding of the Parties 

relating to the subject matter hereof and supersedes all prior agreements and understandings relating 

to the subject matter hereof. 

4. This Stipulation may be executed in counterparts, each of which shall be deemed an 

original but all of which together shall constitute one and the same agreement. 

5. The Bankruptcy Court shall retain jurisdiction to resolve any disputes or 

controversies arising from this Stipulation or any Order approving the terms of this Stipulation 

6. Claimant acknowledges and agrees that the Reorganized Debtors or their agents are 

authorized to adjust the official claims register to reflect the withdrawal of the Proof of Claim 

pursuant to this Stipulation. 

Dated: April 7, 2023 Dated: April 7, 2023

KELLER BENVENUTTI KIM LLP FOX ROTHSCHILD LLP 

/s/ David A. Taylor /s/ Edward J. Tredinnick

David A. Taylor

Attorneys for Debtors 

and Reorganized Debtors 

Edward J. Tredinnick

Attorneys for the City and County of San 

Francisco 

Case: 19-30088 Doc# 13660 Filed: 04/07/23 Entered: 04/07/23 15:08:27 Page 4

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