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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 

AKIN GUMP STRAUSS HAUER & FELD LLP 

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) 

DECLARATION OF ALEXANDER TRACY 

IN SUPPORT OF STATEMENT 

REGARDING STATUS OF COMPETING 

PLAN PROTOCOL AND AD HOC 

COMMITTEE PROPOSAL 

Status Conference 

Date: August 9, 2019 

Time: 11:30 a.m. (Pacific Time) 

Place: Courtroom 17 

 450 Golden Gate Ave, 16th Floor 

 San Francisco, CA 94102 

Hearing on Termination Motion 

Date: August 13, 2019 

Time: 9:30 a.m. (Pacific Time) 

Place: Courtroom 17 

 450 Golden Gate Ave, 16th Floor 

 San Francisco, CA 94102 

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).

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I, Alexander Tracy, pursuant to 28 U.S.C. § 1746, declare the following under penalty of perjury: 

1. I am a Partner at Perella Weinberg Partners LP (“PWP”), which has its principal 

office at 767 Fifth Avenue, New York, New York 10153 and is an independent, privately-held, global 

financial services firm headquartered in New York, New York. I am authorized to make this declaration 

(this “Supplemental Declaration”) on behalf of PWP. Unless otherwise stated in this Declaration, I have 

personal knowledge of the facts set forth herein. 

2. PWP was engaged as financial advisor to the Ad Hoc Committee effective as of 

January 28, 2019. I lead a team of PWP professionals on this engagement. I submit this Declaration in 

support of the Statement Regarding Status of Competing Plan Protocol and Ad Hoc Committee Proposal

(the “Statement”), filed contemporaneously herewith. 

3. Except where specifically noted, all statements in this Declaration are based upon 

my personal knowledge developed during the course of my engagement with the Ad Hoc Committee of 

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

called to testify, I could and would testify to each of the facts set forth herein based on such personal 

knowledge, discussions, review of documents and/or professional opinion. 

4. The Debtors filed petitions for relief under chapter 11 of the Bankruptcy Code on 

January 29, 2019. The Debtors have been in chapter 11 in excess of six months and have not presented 

a plan of reorganization. 

5. On June 25, 2019, the Ad Hoc Committee filed the 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 [ECF No. 2741] (the “Motion”). The Ad Hoc Committee 

attached a Term Sheet as Exhibit B to the Motion, which provided the terms for a proposed investment 

of new capital of up to $30 billion (the “Ad Hoc Committee Proposal”). This amount was subsequently 

increased to $31 billion in the amended Term Sheet filed by the Ad Hoc Committee on July 17, 2019 

(the “Amended Term Sheet”) as Exhibit A to the commitment letter (the “Commitment Letter”) relating 

to the new equity and unsecured debt investments contemplated the Ad Hoc Committee Proposal. See 

Notice of Filing of Commitment Letter and Amended Plan Term Sheet [Docket No. 3024]. As set forth 

in the amended Commitment Letter attached as Exhibit B to the Statement, the new money financing 

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contemplated by the Ad Hoc Committee Proposal is fully committed by certain members of the Ad Hoc 

Committee. 

6. Since the Ad Hoc Committee filed the Motion, the Debtors have not approached 

me, or, to the best of my knowledge, any other PWP team member or other representatives or individual 

members of the Ad Hoc Committee, to negotiate or discuss the terms of the Ad Hoc Committee Proposal. 

[Remainder of page left intentionally blank] 

 

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