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

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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) 

767 Fifth Avenue 

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: 650 636 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 - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF MATTHEW P. GOREN 

IN SUPPORT OF EX PARTE APPLICATION 

FOR ORDER PURSUANT TO L.B.R. 9013-1(c) 

AUTHORIZING OVERSIZE BRIEFING FOR 

MEMORANDUM OF POINTS AND 

AUTHORITIES IN SUPPORT OF THE 

DEBTORS’ BAR DATE MOTION 

Related Document: Dkt. No. 1784 

[No hearing requested] 

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# 1819 Filed: 05/02/19 Entered: 05/02/19 18:08:30 Page 1 of

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I, Matthew P. Goren, pursuant to section 1746 of title 28 of the United States Code, hereby 

declare under penalty of perjury that the following is true and correct to the best of my knowledge, 

information and belief: 

1. I am counsel at the law firm of Weil, Gotshal & Manges LLP, counsel to PG&E 

Corporation and Pacific Gas and Electric Company, as debtors and debtors in possession 

(collectively, “PG&E” or the “Debtors”) in the above-captioned chapter 11 cases (the “Chapter 11 

Cases”). I submit this declaration in support of the Debtors’ Ex Parte Application (the 

“Application”), pursuant to Rule 9013-1(c) of the Bankruptcy Local Rules for the United States 

District Court for the Northern District of California (the “Bankruptcy Local Rules”), for an order 

authorizing the Debtors to file an oversize memorandum of points and authorities (the “MPA”) in 

support of the Motion of Debtors Pursuant to 11 U.S.C. §§ 502(b)(9) and 105(a), Fed. R. Bankr. P. 

2002, 3003(c)(3), 5005, and 9007, and L.B.R. 3003-1 For Order (I) Establishing Deadline for Filing 

Proofs of Claim, (II) Establishing the Form and Manner of Notice Thereof, and (III) Approving 

Procedures for Providing Notice of Bar Date and Other Information to All Creditors and Potential 

Creditors (the “Bar Date Motion”) [Dkt. No. 1784], which the Debtors filed on May 1, 2019. 

2. The Bar Date Motion seeks an order (i) establishing deadlines for filing proofs of 

claim (the “Bar Date”), (ii) establishing the form and manner of notice thereof, and (iii) approving 

the Debtors’ plan for providing notice of the Bar Date and other important deadlines and information 

to all creditors and potential creditors. Due to the unique nature of these Chapter 11 Cases, the 

Debtors are proposing special procedures to facilitate the submission and evaluation of Wildfire 

Claims, including, as discussed in the Bar Date Motion, a simpler Wildfire Claim Bar Date Notice 

and customized Proof of Claim Forms for both Wildfire Claimants and Wildfire Subrogation 

Claimants. The Debtors are also proposing special procedures for providing notice of the Bar Date 

to their 16 million Customers, including a simpler Customer Bar Date Notice. In addition to serving 

the Bar Date Notices, as set forth in the Bar Date Motion, the Debtors intend to provide 

supplemental notice of the Bar Date to unknown creditors, including Unknown Wildfire Claimants, 

through a multi-faceted Supplemental Notice Plan that has been designed to reach its target 

audiences in a variety of different ways, including: (i) multiple newspaper publication notices, (ii) 

Case: 19-30088 Doc# 1819 Filed: 05/02/19 Entered: 05/02/19 18:08:30 Page 2 of

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digital advertising, including social media and other paid internet search listings, (iii) television and 

radio advertising, (iv) email notice, and (v) dedicated claim service centers.. 

3. To adequately describe the Debtors’ unique circumstances, which necessitate and 

justify the Notice Procedures, and detail the special procedures of which the Debtors seek the 

Court’s approval pursuant to the Bar Date Motion, the Debtors believe it is appropriate to request 

authority for the MPA to exceed the 25 pages allowed under Bankruptcy Local Rule 9013-1(c). 

I declare under penalty of perjury that, to the best of my knowledge and after reasonable 

inquiry, the foregoing is true and correct and that this declaration was executed at New York, New 

York, on May 2, 2019. 

 

/s/ Matthew P. Goren

Matthew P. Goren 

Case: 19-30088 Doc# 1819 Filed: 05/02/19 Entered: 05/02/19 18:08:30 Page 3 of

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