1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

STIPULATION TO EXTEND TIME FOR OCUC 

TO RESPOND TO MOTIONS

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) 

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) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 636-9251 

Proposed 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 DEBTORS 

AND OFFICIAL COMMITTEE OF 

UNSECURED CREDITORS EXTENDING 

TIME TO RESPOND TO MOTIONS TO 

BE HEARD ON FEBRUARY 27, 2019 

[No Hearing Requested]

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# 487 Filed: 02/19/19 Entered: 02/19/19 18:42:10 Page 1 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

STIPULATION TO EXTEND TIME FOR OCUC 

TO RESPOND TO MOTIONS

- 2 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the 

“Utility”), as debtors and debtors in possession (collectively, the “Debtors”), on the one hand, 

and the Official Committee of Unsecured Creditors (the “Creditors Committee”). The Debtors 

and Creditors Committee are referred to in this Stipulation and Agreement for Order collectively 

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

RECITALS 

A. On February 6, 2019, the Debtors filed a notice of hearing [Dkt. 353] noticing 

sixteen (16) motions listed therein (the “Motions”) for a hearing before the Court at 9:30 a.m. on 

February 27, 2019. 

B. Under Local Bankruptcy Rule 9014-1(c)(2), any opposition or response to the 

Motions must be filed and served on counsel for the Debtors no later than February 20, 2019. 

C. The Office of the United States Trustee filed an Appointment of the Official 

Committee of Unsecured Creditors on February 12, 2019 [Dkt. 409]. 

D. On February 14, 2019, proposed counsel to the Creditors Committee requested, 

and proposed counsel for the Debtors agreed, that the time for the Creditors Committee to 

respond to the Motions be extended by two days. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, 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. The time for the Creditors Committee to file and serve any response or 

opposition to the Motions is extended through February 22, 2019. 

[Signatures on Next Page] 

Case: 19-30088 Doc# 487 Filed: 02/19/19 Entered: 02/19/19 18:42:10 Page 2 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

STIPULATION TO EXTEND TIME FOR OCUC 

TO RESPOND TO MOTIONS

- 3 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

Dated: February 15, 2019 Dated: February 15, 2019

KELLER & BENVENUTTI LLP MILBANK, TWEED, HADLEY & 

MCCLOY LLP 

/s/ Tobias S. Keller /s/ Thomas R. Kreller

Tobias S. Keller

Proposed Attorneys for Debtors 

and Debtors in Possession

Thomas R. Kreller

 

Proposed Attorneys for Official Committee 

of Unsecured Creditors

Case: 19-30088 Doc# 487 Filed: 02/19/19 Entered: 02/19/19 18:42:10 Page 3 of 3