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Gibson, Dunn & 

Crutcher LLP

DAVID M. FELDMAN (pro hac vice)

 dfeldman@gibsondunn.com

MATTHEW K. KELSEY (pro hac vice)

 mkelsey@gibsondunn.com

GIBSON, DUNN & CRUTCHER LLP

200 Park Avenue

New York, NY 10166-0193

Telephone: 212.351.4000

Facsimile: 212.351.4035

MICHAEL S. NEUMEISTER, SBN 274220

 mneumeister@gibsondunn.com

MICHELLE CHOI, SBN 313557

 mchoi@gibsondunn.com

GIBSON, DUNN & CRUTCHER LLP

333 South Grand Avenue

Los Angeles, CA 90071-3197

Telephone: 213.229.7000

Facsimile: 213.229.7520

Attorneys for the Ad Hoc Committee of

Holders of Trade Claims

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 AD HOC 

COMMITTEE OF HOLDERS OF TRADE 

CLAIMS PURSUANT TO BANKRUPTCY 

RULE 2019

Case: 19-30088 Doc# 4214 Filed: 10/16/19 Entered: 10/16/19 08:27:13 Page 1 of

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Gibson, Dunn & 

Crutcher LLP

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

Rules”), certain holders of trade claims (the “Ad Hoc Trade Committee”) against debtor Pacific Gas & 

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

their undersigned counsel, submit this verified statement (the “2019 Statement”), and in support 

thereof, state as follows:

1. On or around October 4, 2019, the Ad Hoc Trade Committee engaged Gibson, 

Dunn & Crutcher LLP (“Counsel”) to represent it in connection with the Debtors’ restructuring.

2. The claims held by the members of the Ad Hoc Trade Committee include, but 

are not limited to, trade and contract claims against Utility (the “Trade Claims”). Certain members of 

the Ad Hoc Trade Committee hold claims and/or interests of the Debtors that do not constitute Trade 

Claims, and which are not being represented by the Ad Hoc Trade Committee. In accordance with 

Bankruptcy Rule 2019, the address and the “nature and amount of all disclosable economic interests” 

for each member are set forth on Exhibit A attached hereto. The information set forth on Exhibit A is 

based upon information the members provided to Counsel and is subject to change.

3. Nothing in this 2019 Statement, including Exhibit A hereto, should be construed 

as a limitation upon, or waiver of, any holder’s right to assert, file and/or amend its claims in accordance 

with applicable law and any orders entered in these cases.

4. The undersigned verify that the foregoing is true and correct to the best of their 

knowledge.

5. Counsel reserves the right to amend or supplement this 2019 Statement. Counsel 

is in discussion with other holders of large Trade Claims and will supplement this filing as additional 

holders join the Ad Hoc Trade Committee.

6. The information contained herein is intended only to comply with Bankruptcy 

Rule 2019 and is not intended for any other use or purpose.

///

///

///

///

Case: 19-30088 Doc# 4214 Filed: 10/16/19 Entered: 10/16/19 08:27:13 Page 2 of

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Gibson, Dunn & 

Crutcher LLP

Dated: October 16, 2019 GIBSON, DUNN & CRUTCHER LLP

By: /s/ Michael S. Neumeister

David M. Feldman (pro hac vice)

Matthew K. Kelsey (pro hac vice)

Matthew D. McGill (pro hac vice)

Michael S. Neumeister (SBN 274220)

Michelle Choi (SBN 313557)

Attorneys for the Ad Hoc Committee of

Holders of Trade Claims

Case: 19-30088 Doc# 4214 Filed: 10/16/19 Entered: 10/16/19 08:27:13 Page 3 of

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Exhibit A

Name

Nature and Amount1 of Disclosable Economic Interests

Trade Claims Other

Whitebox Advisors LLC

3033 Excelsior Blvd.

Minneapolis, MN 55416

$73,180,443.00 Mechanics’ Lien Claims: $11,265,560.00

Senior Notes:

2 $2,500,000.00

DIP Obligations:3 $1,500,000.00

Olympus Peak Asset Management

745 Fifth Avenue, Suite 1604

New York, NY 10151

$74,345,080.00 Utility L/C Reimbursement:

4 $25,000,000.00

Marble Ridge Capital

1250 Broadway, Suite 2601

New York, NY 10001

$51,803,006.00 Holdco Revolver Loans:

5 $21,600,000.00

Utility L/C Reimbursement: $20,000,000.00

 

1 Amounts listed on this Exhibit A are calculated as of October 16, 2019 (unless otherwise noted) and do not include any claims for, without limitation, fees, expenses, 

accrued and unpaid interest, premiums, make-wholes or indemnification that may be owing under any applicable contract or agreement. The information on Exhibit 

A will be supplemented as appropriate in the event the information disclosed herein changes.

2 As defined in the Amended Declaration of Jason P. Wells in Support of First Day Motions and Related Relief [Dkt. No. 263].

3 As defined in the Final Order Pursuant to 11 U.S.C. §§ 105, 362, 363, 364, 503, and 507 and Fed. R. Bankr. P. 2002, 4001, 6004, and 9014 (I) Authorizing Debtors 

to Obtain Senior Secured Superpriority, Postpetition Financing, (II) Granting Liens and Superpriority Claims, (III) Modifying the Automatic Stay, and (IV) Granting 

Related Relief [Dkt. No. 1091].

4

“Utility L/C Reimbursement” means unsecured claims arising out of reimbursement agreements entered into by Utility in connection with the issuance of certain 

letters of credit.

5

“Holdco Revolver Loans” means loans under that certain Second Amended and Restated Credit Agreement, dated as of April 27, 2015, by and between PG&E 

Corporation and Bank of America, N.A., as administrative agent.

Case: 19-30088 Doc# 4214 Filed: 10/16/19 Entered: 10/16/19 08:27:13 Page 4 of

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Name

Nature and Amount1 of Disclosable Economic Interests

Trade Claims Other

Citigroup Financial Products, Inc. 

Citigroup Global Markets Inc.

(“Citigroup”)6

390 Greenwich St., 6th Floor

New York, New York 10013

$38,000,000.00 Mechanics’ Lien Claims: $16,000,000.00

Utility Revolver Loans:7 $49,281,015.00

Senior Notes: $23,360,000.00

Holdco Revolver Loans: $10,000,000.00

Wildfire Subrogation Claims:8 $30,804,004.00

 

6 These holdings apply only to Citigroup’s distressed debt trading desk.

7

“Utility Revolver Loans” means loans under that certain Second Amended and Restated Credit Agreement, dated as of April 27, 2015, by and between Utility and 

Citibank, N.A., as administrative agent.

8

“Wildfire Subrogation Claims” means insurance subrogation claims against the Debtors relating to certain California wildfires.

Case: 19-30088 Doc# 4214 Filed: 10/16/19 Entered: 10/16/19 08:27:13 Page 5 of

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