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Sim

pson

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425 Lexington

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New

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017

Jonathan Sanders (No. #228785) 

SIMPSON THACHER & BARTLETT LLP 

2475 Hanover Street 

Palo Alto, CA 94304 

Telephone: (650) 251-5000 

Facsimile: (650) 252-5002 

Michael H. Torkin 

Nicholas Goldin 

Kathrine A. McLendon 

Jamie J. Fell 

SIMPSON THACHER & BARTLETT LLP 

425 Lexington Avenue 

New York, NY 10017 

Telephone: (212) 455-2000 

Facsimile: (212) 455-2502 

Counsel for the Board of Each of PG&E Corporation and 

Pacific Gas and Electric Company and for Certain 

Current and Former Independent Directors 

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). 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

CERTIFICATE OF NO OBJECTION 

REGARDING FOURTH MONTHLY FEE 

STATEMENT OF SIMPSON THACHER & 

BARTLETT LLP FOR ALLOWANCE AND 

PAYMENT OF COMPENSATION AND 

REIMBURSEMENT OF EXPENSES FOR 

THE PERIOD OF JULY 1, 2019 THROUGH 

JULY 31, 2019 

Re: Docket No. 4032 

Objection Deadline: October 21, 2019 

 4:00 pm (Pacific Time) 

Case: 19-30088 Doc# 4490 Filed: 10/28/19 Entered: 10/28/19 15:01:41 Page 1 of

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425 Lexington

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New

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017

On September 30, 2019, Simpson Thacher & Bartlett LLP (“Simpson Thacher”), 

counsel for (i) the Board of Directors (the “Board”) of each of PG&E Corporation and Pacific 

Gas and Electric Company (the “Debtors”), as the Board may be constituted from time to time, 

and for the members of the Board from time to time in their capacities as members of the Board, 

and (ii) certain current and former independent directors in their individual capacities who serve 

or served as independent directors prior to and/or as of the Petition Date (as defined below) (each 

an “Independent Director” and collectively, the “Independent Directors”), filed its Fourth 

Monthly Fee Statement of Simpson Thacher & Bartlett LLP for Allowance and Payment of 

Compensation and Reimbursement of Expenses for the Period July 1, 2019 through July 31, 

2019, pursuant to the Order Pursuant to 11 U.S.C. §§ 331 and 105(a) and Fed. R. Bankr. P. 

2016 for Authority to Establish Procedures for Interim Compensation and Reimbursement of 

Expenses of Professionals, dated February 27, 2019 [Docket No. 701] (the “Interim Procedures 

Order”). 

The Fourth Monthly Fee Statement was served as described in the Certificate of Service 

of Andrew G. Vignali [Docket No. 4090]. The deadline to file responses or oppositions to the 

Fourth Monthly Fee Statement was October 21, 2019 at 4:00 pm (PT). On October 21, an 

objection was filed by the Public Employees Retirement Association of New Mexico objecting 

to a portion of Simpson Thacher’s fees totaling $28,741 [Docket No. 4351] (the “PERA 

Objection”).1 No other oppositions or responses have been filed with the Court or received by 

Simpson Thacher. Pursuant to the Interim Compensation Order, the Debtors are authorized to 

pay Simpson Thacher eighty percent (80%) of the remaining fees that are not subject to an 

objection and one hundred percent (100%) of the expenses requested in the Fourth Monthly Fee 

Statement upon the filing of this certification without the need for a further order of the Court. A 

summary of the fees and expenses sought by Simpson Thacher is annexed hereto as Exhibit A. 

 

1

 Simpson Thacher does not agree with the assertions made in the PERA Objection and reserves all rights to dispute 

the PERA Objection, and any future objections made on similar grounds, either before or in connection with any 

hearing to consider the applicable interim fee applications. 

Case: 19-30088 Doc# 4490 Filed: 10/28/19 Entered: 10/28/19 15:01:41 Page 2 of

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The undersigned hereby declares, pursuant to 28 U.S.C. § 1746, under penalty of perjury, 

that: 

1. I am a counsel at the law firm Simpson Thacher & Bartlett LLP, counsel 

to the Board and the Independent Directors. 

2. I certify that I have reviewed or caused the review of the Court’s docket in 

these chapter 11 cases and that Simpson Thacher has not received any response or opposition to 

the Fourth Monthly Fee Statement other than the PERA Objection. 

3. This declaration was executed in Palo Alto, California. 

Dated: October 28, 2019 

 Palo Alto, California 

SIMPSON THACHER & BARTLETT LLP 

/s/ Jonathan Sanders 

Jonathan Sanders (No. 228785)

Counsel for the Board of Each of PG&E 

Corporation and Pacific Gas and Electric 

Company and for Certain Current and Former 

Independent Directors 

Case: 19-30088 Doc# 4490 Filed: 10/28/19 Entered: 10/28/19 15:01:41 Page 3 of

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