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68868850.1

POLSINELLI LLP

Randye B. Soref (SBN 99146)

2049 Century Park East, Suite 2900

Los Angeles, CA 90067

Telephone: 310.556.1801

Facsimile: 310.556.1802

Email: rsoref@polsinelli.com

Attorneys for Whitebox Multi-Strategy Partners, LP

And Whitebox Asymmetric Partners, LP

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION

and

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 No. 19-30088 (DM)

Chapter 11

(Jointly Administered) (Lead Case)

NOTICE OF APPEARANCE AND

REQUEST FOR SPECIAL NOTICE

PLEASE TAKE NOTICE that the undersigned, hereby files their appearances as attorneys

for Whitebox Multi-Strategy Partners, LP and Whitebox Asymmetric Partners, LP (collectively

“Whitebox”), by and through their legal counsel, Polsinelli, LLP, hereby enters this appearance

pursuant to section 1109(b) of title 11 of the United States Code (the “Bankruptcy Code”), and

Rule 9010(b) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and request

that the counsel listed below be added to the official mailing matrix, CM/ECF, and service lists in

the above entitled Bankruptcy Cases. Whitebox further requests, pursuant to Bankruptcy Rules

Case: 19-30088 Doc# 2292 Filed: 05/30/19 Entered: 05/30/19 17:18:19 Page 1 of

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68868850.1

2002, 3017 and 9007 and section 1109(b) of the Bankruptcy Code, that copies of all notices and

pleadings given or required to be given in the Bankruptcy Cases and copies of all papers served or

required to be served in the Bankruptcy Cases, including but not limited to, all notices (including

those required by Bankruptcy Rule 2002), reports, pleadings, motions, applications, lists,

schedules, statements, and all other matters arising herein or in any way related to the Bankruptcy

Cases, including in adversary proceedings, be given and served upon Polsinelli, LLP, at the

following address:

Randye B. Soref

Polsinelli LLP

2049 Century Park East, Suite 2900

Los Angeles, CA 90067

Telephone: 310.556.1801

Facsimile: 310.556.1802

Email: rsoref@polsinelli.com

PLEASE TAKE FURTHER NOTICE that, pursuant to section 1109(b) of the Bankruptcy

Code, the foregoing request applies to and includes not only the notices and papers referenced in the

Bankruptcy Rules and Bankruptcy Code, but also includes, without limitation, all orders, notices and

pleadings relating to any application, motion, petition, objection, pleading, request, complaint or

demand, whether formal or informal, whether written or oral, and whether transmitted or conveyed

by mail, telephone, courier services, hand delivery, facsimile transmission, electronic mail, telex or

otherwise that (i) affects, or seeks to affect, or may potentially affect in any way, any rights or

interests of any creditor or party-in-interest in these Cases; (ii) affects, or seeks to affect (a) the

above-captioned Debtors and/or their estates or (b) property or proceeds thereof in the possession,

custody, or control of others that any of the Debtors or their estates may seek to use; or (iii) requires

or seeks to require any act, delivery of any property, payment or other conduct by Unsecured

Creditor.

PLEASE TAKE FURTHER NOTICE that neither the request for notice, nor any

subsequent appearance, pleading, claim, proof of claim, document, suit, motion, or any other writing

or conduct shall constitute a waiver by Unsecured Creditor of any:

a. Right to have any final orders in any non-core matters entered only after de novo

review by a United States District Court Judge;

Case: 19-30088 Doc# 2292 Filed: 05/30/19 Entered: 05/30/19 17:18:19 Page 2 of

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68868850.1

b. Right to trial by jury in any proceeding in which this right exists, whether the

right to be designated legal or private; whether the right is asserted in any related case,

controversy or proceeding, notwithstanding the designation vel non of the proceeding as “core”

under section 157(b)(2)(H) of the United States Bankruptcy Code, and whether the right is

asserted under statute or the United States Constitution;

c. Right to have the United States District Court withdraw the reference of this

matter in any proceeding subject to mandatory or discretionary withdrawal; or

d. Other rights, claims, actions, defenses, set-offs, recoupments of other matters to

which this party in interest is entitled under any agreements, at law or in equity, or under the

United States Constitution;

e. Unsecured Creditor expressly reserves all rights listed above. Filing this request

for notice or participating in this bankruptcy case should not be deemed to constitute a

concession or admission of jurisdiction in this case or before this Court.

Dated: May 30, 2019 Respectfully submitted,

POLSINELLI PC

By: /s/ Randye B. Soref

Randye B. Soref

Counsel for Whitebox Multi-Strategy Partners,

LP and Whitebox Asymmetric Partners, LP

Case: 19-30088 Doc# 2292 Filed: 05/30/19 Entered: 05/30/19 17:18:19 Page 3 of

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