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BAKER 

&

HOSTETLER LLP

ATTORNEYS AT LAW

SAN FRANCISCO

BAKER & HOSTETLER LLP

Robert A. Julian (SBN 88469)

Cecily A. Dumas (SBN 111449)

1160 Battery Street, Suite 100

San Francisco, CA 94111

Telephone: (628) 208-6434

Facsimile: (310) 820-8859

Email: rjulian@bakerlaw.com

 cdumas@bakerlaw.com

Eric E. Sagerman (SBN 155496)

Lauren T. Attard (SBN 320898)

11601 Wilshire Boulevard

Suite 1400

Los Angeles, CA 90025

Telephone: (310) 820-8800

Facsimile: (310) 820-8859

Email: esagerman@bakerlaw.com

lattard@bakerlaw.com

 

Counsel to the Official Committee of Tort 

Claimants

AKIN GUMP STRAUSS HAUER & FELD LLP

Michael S. Stamer (pro hac vice)

Ira S. Dizengoff (pro hac vice)

David H. Botter (pro hac vice)

Abid Qureshi (pro hac vice)

One Bryant Park

New York, New York 10036

Telephone: (212) 872-1000

Facsimile: (212) 872-1002

Email: mstamer@akingump.com

idizengoff@akingump.com

dbotter@akingump.com

 aqureshi@akingump.com

Ashley Vinson Crawford (SBN 257246)

580 California Street

Suite 1500

San Francisco, CA 94104

Telephone: (415) 765-9500

Facsimile: (415) 765-9501

Email: avcrawford@akingump.com

Counsel to the Ad Hoc Committee of Senior

Unsecured Noteholders of Pacific Gas and 

Electric Company 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

-andPACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

EX PARTE MOTION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

AND AD HOC COMMITTEE OF SENIOR 

UNSECURED NOTEHOLDERS 

PURSUANT TO B.L.R. 9006-1 

REQUESTING ORDER SHORTENING 

TIME FOR HEARING ON JOINT 

MOTION TO TERMINATE THE 

DEBTORS’ EXCLUSIVE PERIODS 

[No hearing requested]

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# 3944 Filed: 09/19/19 Entered: 09/19/19 16:01:50 Page 1 of

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ATTORNEYS AT LAW

SAN FRANCISCO

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The Official Committee of Tort Claimants (the “TCC”) and the Ad Hoc Committee of 

Senior Unsecured Noteholders of Pacific Gas and Electric Company (the “Ad Hoc Committee”)1

in the above-captioned chapter 11 cases of Pacific Gas and Electric Company (the “Utility”) and 

PG&E Corporation (“PG&E” and, together with the Utility, the “Debtors”), by their respective 

undersigned counsel, Baker & Hostetler LLP and Akin Gump Strauss Hauer & Feld LLP, hereby 

submit this motion (the “Motion”) pursuant to Rule 9006-1 of the Bankruptcy Local Rules for the 

United States Bankruptcy Court for the Northern District of California (the “Bankruptcy Local 

Rules”), for entry of an order, substantially in the form attached as Exhibit A hereto, shortening 

time for a hearing on Joint Motion of the Official Committee of Tort Claimants and Ad Hoc 

Committee of Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods Pursuant 

to Section 1121(d)(1) of the Bankruptcy Code (the “Joint Exclusivity Termination Motion”) 

[Docket No. 3940]. In support of this Motion, the TCC and the Ad Hoc Committee submit the 

Declaration of Cecily A. Dumas filed concurrently herewith and respectfully state the following: 

JURISDICTION AND VENUE

1. The Court has jurisdiction to consider this matter pursuant to 28 U.S. C. §§ 157 and 

1334, the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General 

Order 24 (N.D. Cal.), and Rule 5011-1(a) of the Bankruptcy Local Rules. 

2. This is a core proceeding pursuant to 28 U.S.C. §157(b). 

3. Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409.

RELIEF REQUESTED

4. By this Motion, the TCC and the Ad Hoc Committee seek entry of an order 

shortening time for a hearing on the Joint Exclusivity Termination Motion and request the hearing 

to be set for September 24, 2019, the next omnibus hearing date, or as soon thereafter as practicable, 

with responsive filings due at a time set by the Court. A proposed form of order approving the 

relief requested herein is annexed hereto as Exhibit A. 

 1 The Ad Hoc Committee filed a statement pursuant to Rule 2019 of the Federal Rules of Bankruptcy 

Procedure on July 18, 2019 [Docket No. 3083]. Members of the Ad Hoc Committee hold in excess of $10 billion of 

funded debt claims against the Debtors. 

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BASIS FOR RELIEF

5. Pursuant to Bankruptcy Local Rule 9014-1(c)(2), a hearing on the Joint Exclusivity 

Termination Motion requires at least twenty-one (21) days’ notice of an opportunity for a hearing. 

Bankruptcy Local Rule 9006-1(a) provides that, except as set forth therein, “approval of the Court 

is required to enlarge or to shorten time to perform any act or file any paper pursuant to the Federal 

Rules of Civil Procedures, the Bankruptcy Rules, or these Bankruptcy Local Rules.” B.L.R. 9006-

1(a).

6. There is sufficient cause to warrant shortening of the notice period here so that the 

Joint Exclusivity Termination Motion can be heard on September 24, 2019, at the same time as the 

status conference on the Debtors’ Joint Chapter 11 Plan of Reorganization [Docket No. 3841] (the 

“Placeholder Plan”). As set forth in greater detail in the Joint Exclusivity Termination Motion, the 

Placeholder Plan is not viable and does nothing to bring these cases closer to resolution. In contrast, 

the Court now has before it a fully financed and committed alternative plan (the “Alternative Plan”) 

centered on a settlement that proposes to compensate wildfire victims fully and fairly and thereby 

provides a clear path to emergence well in advance of the June 30, 2020 deadline under AB 1054. 

Nothing is gained by allowing the Debtors to maintain exclusivity for the next several weeks on 

the basis of procedural formality. 

7. Importantly, shortening notice here will not prejudice any party in interest. All 

relevant parties in interest already will be expected to attend the status conference on September 

24, 2019, and, therefore, expanding the hearing to include consideration of the Joint Exclusivity 

Termination Motion will not impose an additional burden on parties. In addition, there is no need 

to delay a hearing on the Joint Exclusivity Termination Motion to allow parties time to assess the 

Alternative Plan. With the exception of the wildfire claims settlement and certain modifications 

relating thereto, the terms of the Alternative Plan have changed little from the plan term sheet filed 

by the Ad Hoc Committee in connection with its original motion to terminate exclusivity,2 which 

 2 See Motion of the Ad Hoc Committee of Senior Unsecured Noteholders to Terminate the Debtors’ 

Exclusive Periods Pursuant to Section 1121(d)(1) of the Bankruptcy Code [Docket No. 2742], as supplemented from 

time to time. 

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has been a matter of public record and comment for several months. As recited in the Dumas 

Declaration, the Debtors do not consent to this Motion.

CONCLUSION

8. For the foregoing reasons, the TCC and the Ad Hoc Committee respectfully request 

that this Court enter an order shortening time for Joint Exclusivity Termination Motion to be heard 

on September 24, 2019 and setting a date for responsive filings as the Court finds appropriate. In 

the event that the Court does not allow the Joint Exclusivity Termination Motion to be heard on 

September 24, 2019, the TCC and Ad Hoc Committee request that the motion be set for a hearing 

as soon as reasonably practicable thereafter.

NOTICE

Notice of this Motion will be provided to (i) counsel to the Debtors; (ii) the Office of the 

U.S. Trustee for Region 17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (iii) counsel 

to the Creditors Committee; (iv) the Securities and Exchange Commission; (v) the Internal Revenue 

Service; (vi) the Office of the California Attorney General; (vii) the California Public Utilities 

Commission; (viii) the Nuclear Regulatory Commission; (ix) the Federal Regulatory Commission; 

(x) the Office of the United States Attorney for the Northern District of California; (xi) counsel for 

the agent under the Debtors’ debtor in possession financing facility; and (xii) those persons who 

have formally appeared in these chapter 11 cases and requested service pursuant to Bankruptcy 

Rule 2002. The TCC and the Ad Hoc Committee respectfully submit that no further notice is 

required.

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WHEREFORE the TCC and the Ad Hoc Committee respectfully request entry of an order 

granting (i) the relief requested herein for cause shown and (ii) such other and further relief as the 

Court may deem just and proper.

Dated: September 19, 2019 BAKER & HOSTETLER LLP

By: /s/ Cecily A. Dumas

Robert A. Julian (SBN 88469)

Cecily A. Dumas (SBN 111449)

Eric E. Sagerman (SBN 155496)

Lauren T. Attard (SBN 320898)

Counsel to the Official Committee of Tort Claimants

AKIN GUMP STRAUSS HAUER & FELD LLP

By: /s/ Ashley Vinson Crawford

Ashley Vinson Crawford (SBN 257246)

Michael S. Stamer (pro hac vice)

Ira S. Dizengoff (pro hac vice)

David H. Botter (pro hac vice)

Abid Qureshi (pro hac vice)

Counsel to the Ad Hoc Committee of Senior Unsecured 

Noteholders of Pacific Gas and Electric Company 

Case: 19-30088 Doc# 3944 Filed: 09/19/19 Entered: 09/19/19 16:01:50 Page 5 of

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