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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) 

Theodore Tsekerides (pro hac vice) 

(theodore.tsekerides@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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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 DEBTOR 

PACIFIC GAS AND ELECTRIC 

COMPANY AND MICHAEL 

MARROQUIN TO CONTINUE HEARING 

AND FOR LIMITED RELIEF FROM THE 

AUTOMATIC STAY 

[Relates to Dkt. Nos. 4606-4610] 

[Resolving Motion Set for Hearing 

December 11, 2019 at 10:00 a.m.] 

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# 4874 Filed: 11/26/19 Entered: 11/26/19 17:43:42 Page 1 of

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

This stipulation (the “Stipulation”) is entered into by and between Pacific Gas and Electric 

Company (the “Utility” or the “Debtor”), as debtor and debtor in possession, and movant Michael 

Marroquin (“Marroquin”). The Debtor and Marroquin are referred to in this Stipulation 

collectively as the “Parties,” and each as a “Party.” The Parties hereby stipulate and agree as 

follows: 

RECITALS 

A. On November 7, 2019, Marroquin filed the Motion to Abstain and for Relief from 

the Automatic Stay to Permit Lawsuit to Proceed to Trial and Conclusion [Dkt. 4606] (the 

“Motion”). 

B. Through the Motion, Marroquin seeks relief from the automatic stay to prosecute 

his personal injury claims against the Utility in Marroquin v. Pacific Gas & Electric Company et 

al., Case No. BCV-18-100020 (the “State Court Action”) pending in the Superior Court of 

California, County of Kern (the “State Court”). 

C. The State Court Action arises out of injuries that Marroquin allegedly suffered 

resulting from a May 25, 2017 automobile crash in which the other driver was an employee of the 

Utility. The Utility’s employee is also a named defendant in the State Court Action. 

D. Marroquin filed the State Court Action on January 4, 2018. 

E. The Debtor and its parent, PG&E Corporation (collectively with the Utility, the 

“Debtors”), filed these Chapter 11 Cases on January 29, 2019 (the “Petition Date”). 

F. The Utility filed a Notice of Stay of Proceedings in the State Court Action on 

February 11, 2019. The automatic stay applicable to the State Court Action has remained in effect 

as to the Debtors since the Petition Date. On April 4, 2019, the State Court extended the automatic 

stay to the Utility’s employee. 

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. This Stipulation shall be effective upon entry of an order by this Court 

approving it. 

Case: 19-30088 Doc# 4874 Filed: 11/26/19 Entered: 11/26/19 17:43:42 Page 2 of

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2. The hearing on the Motion (the “Hearing”) shall be continued to March 25, 

2020 at 10:00 a.m. (Pacific Time). 

3. The automatic stay shall immediately be modified, to the extent necessary, 

to permit the Parties to engage in settlement negotiations including, if helpful, through mediation 

(collectively, the “Settlement Negotiations”). The Parties shall use their best efforts to commence 

the Settlement Negotiations as promptly as possible. The automatic stay shall remain in place for 

all other purposes. 

4. The Parties may agree in writing to one or more further continuances of the 

Hearing, without further order of the Court, by filing a notice of continuance. The limited stay 

relief provided in paragraph 3 above shall continue in effect pending the continued Hearing on the 

Motion. 

5. If the Settlement Negotiations do not result in a settlement, the Hearing will 

go forward on the continued date, and the Debtors’ opposition to the Motion shall be filed and 

served not later than 4:00 p.m. Pacific time on the date that is five (5) calendar days before the 

continued Hearing date. 

Dated: November 26, 2019 Dated: November 26, 2019

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

LAW OFFICES OF 

LEONARD K. WELSH 

/s/ Peter J. Benvenutti /s/ Leonard K. Welsh

Peter J. Benvenutti

Attorneys for Debtors 

and Debtors in Possession

Leonard K. Welsh

Attorneys for Movant Michael Marroquin 

Case: 19-30088 Doc# 4874 Filed: 11/26/19 Entered: 11/26/19 17:43:42 Page 3 of

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