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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) 

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) 

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: 650 636 9251 

Attorneys for Debtors

and Debtors in Possession

CRAVATH, SWAINE & MOORE LLP 

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019

Tel: 212 474 1000 

Fax: 212 474 3700 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION 

- and - 

PACIFIC GAS AND ELECTRIC 

COMPANY

Debtors.

Bankruptcy Case No. 19 - 30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF KEVIN J. ORSINI IN 

SUPPORT OF EX PARTE MOTION OF 

DEBTORS FOR ORDER CONTINUING 

THE HEARING ON THE MOTIONS OF 

THE OFFICIAL COMMITTEE OF TORT 

CLAIMANTS AND THE AD HOC 

GROUP OF SUBROGATION CLAIM 

HOLDERS FOR RELIEF FROM 

AUTOMATIC STAY 

Related Documents: Dkt. 2863, 2904 

[No hearing requested]

 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# 3112 Filed: 07/19/19 Entered: 07/19/19 18:41:10 Page 1 of

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I, Kevin J. Orsini, hereby declare under penalty of perjury as follows: 

1. I am a partner at Cravath, Swaine & Moore LLP, attorneys for PG&E Corporation 

and Pacific Gas and Electric Company, as debtors and debtors in possession (collectively, 

“PG&E” or the “Debtors”). 

2. I submit this declaration pursuant to Rule 9006-1 of the Bankruptcy Local Rules 

for the United States Bankruptcy Court for the Northern District of California (the “Local Rules”) 

in support of the Debtors’ ex parte motion (the “Motion to Continue”), pursuant to section 105(a) 

of title 11, United States Code, Rule 9006 of the Federal Rules of Bankruptcy Procedure, and Local 

Rule 9001-1, for entry of an order continuing the hearing date of the Official Committee of Tort 

Claimants’ (“Tort Claimants Committee” or “TCC”) Amended Motion for Relief from the 

Automatic Stay to Permit a State Court Jury Trial of the 2017 Tubbs Wildfire Claims [Docket No. 

2904] and the Ad Hoc Group of Subrogation Claim Holders’ (“Ad Hoc Subrogation Group”) 

Motion for Relief from the Automatic Stay [Dkt. No. 2863] (collectively, the “Stay Relief 

Motions”), so that they may be heard together with the Debtors’ Motion for the Establishment of 

Wildfire Claims Estimation Procedures [Dkt. No. 3091] (the “Estimation Motion”) on August 

14, 2019, or on such other date as the Court may schedule. 

3. By the Motion to Continue, the Debtors seek to have the hearing on the TCC’s and 

Ad Hoc Subrogation Group’s Stay Relief Motions, currently set for July 24, 2019, continued so 

that the Stay Relief Motions may be heard on the same date as the Debtors’ Estimation Motion, 

which is currently scheduled to be heard on August 14, 2019. 

4. The central issues raised in the TCC’s and Ad Hoc Subrogation Group’s Stay Relief 

Motions are also at the heart of the Debtors’ Estimation Motion. The Debtors, the TCC and the Ad 

Hoc Subrogation Group all agree that the issue of PG&E’s liability for the Tubbs Fire is a critical 

threshold issue in these cases and should be addressed promptly. However, the TCC’s and Ad 

Hoc Subrogation Group’s proposal for resolving this critical issue, seeking relief from the stay so 

a handful of claimants may proceed to liquidate their unrepresentative claims in state court, differs 

significantly from the Debtors’ proposal of addressing the likelihood of success as part of an 

Case: 19-30088 Doc# 3112 Filed: 07/19/19 Entered: 07/19/19 18:41:10 Page 2 of

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estimation proceeding in this Court. Given the importance of this threshold valuation issue to the 

resolution of these Chapter 11 Cases, the Court should have the benefit of reviewing briefing on 

the proposals of both the TCC and Ad Hoc Subrogation Group and the Debtors and hearing 

arguments on these Motions contemporaneously before making this critical ruling. 

5. I believe that deciding the TCC’s and Ad Hoc Subrogation Group’s Stay Relief 

Motions separate and apart from the Debtors’ Estimation Motion would be inefficient and 

prejudicial to Debtors’ ability to emerge from chapter 11 prior to the June 30, 2020, legislative 

deadline. 

6. There have been no previous modifications to the date of the hearing of either the 

TCC’s or the Ad Hoc Subrogation Group’s Stay Relief Motions. 

7. Because the Debtors’ Estimation Motion already is scheduled to be heard on 

August 14, 2019, continuing the TCC’s and Ad Hoc Subrogation Group’s Stay Relief Motions to 

that same date will not have a negative effect on the schedule for these Chapter 11 Cases. 

8. I spoke today with Matthew Feldman of Willkie Farr & Gallagher LP, counsel for 

the Ad Hoc Subrogation Group, to seek consent to the relief sought in the Motion to Continue. 

My firm also sent an e-mail to Robert Julian at Baker & Hostetler LLP, counsel to the TCC, 

requesting consent. The Ad Hoc Subrogation Group and the TCC have refused to consent to the 

relief sought. The Ad Hoc Subrogation Group did not provide a reason. A copy of the TCC’s 

response is attached hereto as Exhibit A. 

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

reasonable inquiry, the foregoing is true and correct 

Dated: July 19, 2019 

/s/ Kevin J. Orsini 

 Kevin J. Orsini 

Case: 19-30088 Doc# 3112 Filed: 07/19/19 Entered: 07/19/19 18:41:10 Page 3 of

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