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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

New York, NY 10153-0119 

Tel: (212) 310-8000 

Fax: (212) 310-8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 636-9251 

Attorneys for Debtors and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

STIPULATION BETWEEN DEBTORS 

AND AD HOC GROUP OF 

INTERCONNECTION CUSTOMERS TO 

CONTINUE HEARING ON MOTION TO 

COMPEL PAYMENT OF PASSTHROUGH AMOUNTS WITHHELD BY 

PACIFIC GAS AND ELECTRIC 

COMPANY 

Re: Dkt. Nos. 4400 

[No Hearing Requested]

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: 19-30088 Doc# 4621 Filed: 11/08/19 Entered: 11/08/19 12:37:39 Page 1 of

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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), on the one hand, and the Ad Hoc Group of 

Interconnection Customers (the “Ad Hoc Group of Interconnection Customers”), on the other. 

The Debtors and the Ad Hoc Group of Interconnection Customers are referred to in this 

Stipulation and Agreement for Order collectively as the “Parties,” and each as a “Party.” The 

Parties hereby stipulate and agree as follows: 

RECITALS 

A. On October 22, 2019, the Ad Hoc Group of Interconnection Customers filed the 

Motion and Memorandum of the Ad Hoc Group of Interconnection Customers to Compel 

Payment of Pass-Through Amounts Withheld by Pacific Gas and Electric Company [Dkt. 

No. 4400] (the “Motion”) which is currently set for a hearing at 10:00 a.m. on November 13, 

2019 (the “Hearing”). Any response or opposition to the Motion by the Debtors or either 

official committee appointed in this case is due by 4:00 p.m. (Pacific Time) on November 8, 

2019. 

B. The Parties have engaged in productive discussions regarding the Motion, and are 

working toward a consensual resolution of the Motion. 

C. The Parties’ respective counsel have agreed that the Hearing be continued to the 

omnibus hearing scheduled for 10:00 a.m. on November 19, 2019, so that the Parties may 

continue their settlement discussions and propose a stipulated order on the Motion. 

NOW, THEREFORE, IT HEREBY IS STIPULATED AND AGREED BY AND 

BETWEEN THE PARTIES, THROUGH THE UNDERSIGNED, AND THE PARTIES 

JOINTLY REQUEST THE COURT TO ORDER, THAT:

1. The Hearing on the Motion is continued to 10:00 a.m. (Pacific Time) on 

November 19, 2019. 

2. The time for the Debtors and the official appointed committees to respond 

to the Motion shall be extended to 4:00 p.m. (Pacific Time) on November 14, 2019. 

Case: 19-30088 Doc# 4621 Filed: 11/08/19 Entered: 11/08/19 12:37:39 Page 2 of

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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Dated: November 8, 2019 Dated: November 8, 2019

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

STOEL RIVES LLP 

/s/ Thomas B. Rupp /s/ Andrew Morton

Thomas B. Rupp

Attorneys for Debtors 

and Debtors in Possession

Andrew Morton

Attorneys for Ad Hoc Group of 

Interconnection Customers

Case: 19-30088 Doc# 4621 Filed: 11/08/19 Entered: 11/08/19 12:37:39 Page 3 of

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