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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

GREGG M. FICKS (State Bar No. 148093) 

COBLENTZ PATCH DUFFY & BASS LLP

One Montgomery Street, Suite 3000 

San Francisco, California 94104-5500 

Telephone: 415.391.4800 

Facsimile: 415.989.1663 

Email: ef-gmf@cpdb.com 

Special Counsel to Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION, 

-andPACIFIC GAS & ELECTRIC COMPANY,

Debtors.

 Affects PG&E Corporation

 Affects Pacific Gas and Electric Company

 Affects both Debtors

* All papers shall be filed in Lead Case No.

19-30088 (DM).

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

SUMMARY SHEET TO FIRST INTERIM 

FEE APPLICATION OF COBLENTZ 

PATCH DUFFY & BASS LLP FOR 

ALLOWANCE AND PAYMENT OF 

COMPENSATION AND 

REIMBURSEMENT OF EXPENSES 

(JANUARY 29, 2019 THROUGH 

SEPTEMBER 30, 2019)

Date: TBD

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

Place: United States Bankruptcy Court

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

Objection Deadline: December 4, 2019 at 

4:00 p.m. (Pacific Time)

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 1 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

GENERAL INFORMATION

Name of Applicant: Coblentz Patch Duffy & Bass LLP

Authorized to Provide Professional 

Services to: Special Counsel to Debtors and Debtors in Possession 

Petition Date: January 29, 2019

Retention Date: July 11, 2019 nunc pro tunc to January 29, 2019

Prior Applications: None

SUMMARY OF FEES AND EXPENSES SOUGHT IN THIS APPLICATION

Amount of Compensation Sought as Actual, Reasonable, and Necessary: $1,025,814.52

Amount of Expense Reimbursement Sought as Actual, Reasonable, and Necessary: $17,595.12

Total Compensation and Expenses Requested for the Compensation Period: $1,043,409.64

SUMMARY OF PRIOR MONTHLY FEE STATEMENTS

Date Filed Period 

Covered

Requested 

Fees

Requested 

Expenses

Paid Fees Paid 

Expenses

Holdback 

Fees 

Requested

08/23/19

[Dkt. No. 3679]

1/29/19 –

2/28/19

$80,809.70 $974.15 $64,647.76 $974.15 $16,161.94

08/28/19

[Dkt. No. 3741]

3/1/19 –

3/31/19

$124,443.40 $1,180.37 $99,554.72 $1,180.37 $24,888.68

08/28/19

[Dkt. No. 3742]

4/1/19 –

4/30/19

$162,499.20 $163.09 $129,999.36 $163.09 $32,499.84

08/30/19

[Dkt. No. 3763]

5/1/19 –

5/31/19

$178,126.20 $7,208.81 $142,500.96 $6,953.62 $35,625.24

08/30/19

[Dkt. No. 3765]

6/1/19 –

6/30/19

$148,515.80 $1,256.60 $118,812.64 $1,256.60 $29,703.16

08/30/19

[Dkt. No. 3771]

7/1/19 –

7/31/19

$93,200.68 $0.00 $74,560.54 $0.00 $18,640.14

09/30/19

[Dkt. No. 4038]

8/1/19 –

8/31/19

$124,991.08 $1,546.10 $99,992.86 $1,546.10 $24,998.22

10/31/19

[Dkt. No. 4528]

9/1/19 –

9/30/19

$113,228.46 $5,266.00 $0.00 $0.00 $22,645.69

$1,025,814.52 $17,595.12 $730,068.85 $12,329.12 $205,162.91

Summary of Any Objections to Monthly Fee Statements: None

Compensation and Expenses Sought in this Interim Application Not Yet Paid: $205,162.911

1

 Assumes Applicant receives payment on its Eighth Monthly Fee Statement (for September 2019) 

[Dkt. No. 4528] on, or prior to, the hearing on this Application. 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 2 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

COMPENSATION BY PROFESSIONAL

JANUARY 29, 2019 THROUGH SEPTEMBER 30, 2019 

The Coblentz attorneys and paraprofessionals who rendered legal services in these Chapter 

11 Cases during the Interim Fee Period are:

Name of Professional Position

Primary 

Practice 

Group2

Year 

Admitted

Reduced 

Hourly 

Rate for 

Debtors

Total 

Hours 

Billed

Total 

Compensation

Barbara Milanovich Partner RE 1980 $648.00 471.40 $305,467.20

Doug Sands Partner RE 1987 $648.00 550.40 $353,443.82

Ficks, Gregg Partner BCR/LIT 1990 $643.00 151.80 $94,571.40

David C. Beach Counsel LIT 2003 $540.00 0.40 $216.00

Robert B. Hodil Counsel RE 2003 $520.00 0.70 $364.00

Sean Coyle Partner LIT 2004 $500.00 305.30 $152,650.00

Misti M. Schmidt Counsel RE 2007 $450.00 2.10 $945.00

Mark Hejinian Associate LIT 2011 $400.00 40.60 $16,240.00

James F. McKee Associate LIT 2014 (TX);

2019 (CA) 

$400.00 106.10 $42,440.00

Joy L. Spezeski Associate RE 2013 (IL);

2016 (CA) 

$369.00 0.10 $36.90

Daniel P. Barsky Associate RE 2017 $334.00 14.60 $4,876.40

Leah Collins Associate RE 2016 $334.00 25.10 $8,383.40

Michael R. Wilson Paralegal RE N/A $302.00 61.60 $18,603.20

Doug B. Larson Paralegal RE N/A $284.00 0.70 $198.80

Yasmin Jayasuriya Paralegal LIT N/A $260.00 22.10 $5,746.00

Jordan V. Mendoza Paralegal LIT N/A $250.00 11.50 $2,875.00

Angie H. Brandt Paralegal RE N/A $248.00 3.80 $942.40

2 RE = Real Estate; LIT = Litigation; BCR = Bankruptcy and Creditors’ Rights; 

CORP = Corporate 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 3 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

Name of Professional Position

Primary 

Practice 

Group2

Year 

Admitted

Reduced 

Hourly 

Rate for 

Debtors

Total 

Hours 

Billed

Total 

Compensation

Dianne M. Sweeny Paralegal RE N/A $210.00 4.50 $945.00

Viet Doan Paralegal LIT N/A $175.00 96.40 $16,780.00

Total 

Professionals:

1,869.20 1,025,814.52

PROFESSIONALS

TOTALS 

BLENDED RATE TOTAL HOURS 

BILLED 

TOTAL 

COMPENSATION

Partners and Counsel $612.41 1,482.10 $907,657.42

Associates $385.93 186.50 $71,976.70

Blended Attorney Rate $587.10 1,668.60 $979,634.12

Paraprofessionals and other 

non-legal staff

$230.21 200.60 $46,180.40

Total Fees Incurred $548.80 1,869.20 1,025,814.52

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 4 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

COMPENSATION BY WORK TASK CODE

JANUARY 29, 2019 THROUGH SEPTEMBER 30, 2019 

The following Task Codes and Descriptions were used by Coblentz in conjunction with 

pre-petition time entries and invoices as required by Debtors prior to the filing of these 

Bankruptcy Cases. Coblentz has continued to use these Task Codes and Descriptions in 

conjunction with post-petition time entries and invoices in these Special Counsel matters. 

TASK

CODE DESCRIPTION HOURS AMOUNT

C100 Fact Gathering 83.10 $28,512.60 

C400 Third Party Communication 0.70 $350.00 

L110 Fact Investigation/Development 70.00 $28,000.00

L120 Analysis/Strategy 273.40 $136,290.00 

L130 Experts/Consultants 16.80 $7,840.00 

L143 eDiscovery - Identification and Preservation 0.50 $250.00

L200 Pre-Trial Pleadings and Motions 10.90 $5,260.00

L310 Written Discovery 13.40 $5,660.00 

L330 Depositions 49.00 $19,752.50 

L650 Review 38.80 $10,077.50

L653 First Pass Document Review 8.80 $3,520.00

L670 Production 98.70 $19,391.00 

P100 Project Administration 216.50 $136,797.00 

P240 Real and Personal Property 67.40 $30,837.10 

P280 Other 0.20 $100.00

P300 Structure/Strategy/Analysis 580.00 $372,208.82 

P400 Initial Document Preparation/Filing 226.60 $146,836.80 

P500 Negotiation/Revision/Responses 98.10 $63,568.80

P600 Completion/Closing 12.50 $8,100.00

P700 Post-Completion/Post/Closing 2.20 $1,425.60 

P800 Maintenance and Renewal 1.60 $1,036.80 

Total: 1,869.20 $1,025,814.52

In addition, in order to facilitate the Court’s, the United States Trustee’s, the Fee 

Examiner’s, and parties’ review of the fees for which Coblentz seeks approval and payment 

hereunder in the context of this Interim Fee Application, Coblentz provides the following 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 5 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

alternative Task (Matter Code) Table, which Table segregates the Special Counsel matters 

Coblentz has handled for the Debtors during the Interim Fee Period by the Coblentz Matter

Name/Matter Number for such matters. The following table reflects the same hours and same 

amounts as the preceding Task Code Table, but is organized in a different format that Coblentz 

believes is more consistent with the applicable Guidelines:

ALTERNATIVE TASK (MATTER) COMPENSATION TABLE

FOR JANUARY 29, 2019 THROUGH SEPTEMBER 30, 2019 

TASK 

(MATTER) 

CODE DESCRIPTION HOURS AMOUNT

02898-110 General Real Estate 21.80 $13,986.60 

02898-357 Land Stewardship 531.70 $341,337.88 

02898-376 Hinkley CA Purchases 26.90 $10,227.80 

02898-799

Contract Review - Real Estate / Shared 

Services 342.30 $207,835.40 

16213-043

Salinas MGP / California Water Service 

Company Purchase 0.30 $90.60 

16213-045 Richmond Substation S Land Sale 77.00 $33,875.40 

16213-047 Lyons Land and Cattle, Merced 11.50 $7,362.40 

16213-056 CPUC Regulatory Investigation 238.80 $113,453.00 

16213-058 LCC Conservation Easement Compliance 7.90 $4,711.54 

16213-060 DWR - Oroville Dam 343.20 $123,368.00 

16213-084 Sale of Sheridan Property Area (Placer Co.) 0.10 $36.90 

16213-089

General Advice and Counsel - Surplus 

Disposition 63.40 $41,083.20 

16213-094

Purchase of Gabany Property (Sonoma 

County) 0.40 $113.60 

16213-101

Bankruptcy Special Counsel-Related 

Services 175.60 $109,993.80 

16213-106 Local Community Energy Fire Resiliency 28.30 $18,338.40 

Total: 1,869.20 $1,025,814.52 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 6 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

EXPENSE SUMMARY

JANUARY 29, 2019 THROUGH SEPTEMBER 30, 2019 

The expenses incurred by the Debtors and billed by Coblentz to the Debtors in connection 

with the Special Counsel matters Coblentz has been handling during the Interim Fee Period are as 

follows: 

EXPENSES AMOUNTS

Computerized Research N/A

Meals N/A

Travel N/A

Transportation $121.18

Duplicating 633.37

Transcription (Deposition) Services $15,941.57

Third Party Consulting Fees N/A

Telephone Conferencing N/A

Messenger $436.70

Filing Fees 112.50

Litigation Support Vendors N/A

Sacramento Superior Court Case Access System Retrieval Fee 7.00

Court Website Subscription Fee for Case No. JCCP4974 $343.00

Total Expenses Requested: $17,595.12

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 7 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

GREGG M. FICKS (State Bar No. 148093) 

COBLENTZ PATCH DUFFY & BASS LLP

One Montgomery Street, Suite 3000 

San Francisco, California 94104-5500 

Telephone: 415.391.4800 

Facsimile: 415.989.1663 

Email: ef-gmf@cpdb.com 

Special Counsel to Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION, 

-andPACIFIC GAS & ELECTRIC COMPANY,

Debtors.

 Affects PG&E Corporation

 Affects Pacific Gas and Electric Company

 Affects both Debtors

* All papers shall be filed in Lead Case No.

19-30088 (DM).

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

FIRST INTERIM FEE APPLICATION OF 

COBLENTZ PATCH DUFFY & BASS LLP

FOR ALLOWANCE AND PAYMENT OF 

COMPENSATION AND 

REIMBURSEMENT OF EXPENSES 

(JANUARY 29, 2019 THROUGH 

SEPTEMBER 30, 2019)

Date: TBD

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

Objection Deadline: December 4, 2019 at 

4:00 p.m. (Pacific Time)

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 8 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

Coblentz Patch Duffy & Bass LLP (“Coblentz” or the “Firm”), Special Counsel to PG&E 

Corporation and Pacific Gas and Electric Company (the “Debtors”) in the above-captioned 

chapter 11 cases (the “Chapter 11 Cases”), hereby submits its First Interim Fee Application (the 

“Interim Application”) for allowance and payment of compensation for professional services 

rendered and for reimbursement of actual and necessary expenses incurred for the period 

commencing January 29, 2019, through September 30, 2019 (the “Interim Fee Period”), pursuant 

to the Order Pursuant to 11 U.S.C. §§ 331 and 105(a) and Fed. R. Bankr. P. 2016 for Authority to 

Establish Procedures for Interim Compensation and Reimbursement of Expenses of Professionals, 

entered on February 27, 2019 [Docket No. 701] (the “Interim Compensation Procedures 

Order”), sections 330 and 331 of title 11 of the United States Code (the “Bankruptcy Code”), 

Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), the 

Guidelines for Compensation and Expense Reimbursement of Professionals and Trustees (the 

“Northern District Guidelines”), the United States Trustee Guidelines for Reviewing 

Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 (the 

“UST Guidelines”), and the Local Bankruptcy Rules for the Northern District of California.

The Interim Application is based upon the points and authorities cited herein, the 

Certification of Gregg M. Ficks filed concurrently herewith, the exhibits attached hereto and/or

thereto, the pleadings, papers, and records on file in this case, and any evidence or argument that 

the Court may entertain at the time of the hearing on the Interim Application.

CASE BACKGROUND AND STATUS

A. The Debtors’ Bankruptcy Proceedings

The Debtors filed voluntary petitions for relief under Chapter 11 of the Bankruptcy Code

on January 29, 2019 (the “Petition Date”). The Debtors continue to operate their businesses and 

manage their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the 

Bankruptcy Code. No trustee or examiner has been appointed. 

On February 12, 2019, the Office of the United States Trustee for the Northern District of 

California (the “U.S. Trustee”) appointed an Official Committee of Unsecured Creditors in the 

Debtors’ cases (the “Creditors’ Committee”). On February 15, 2019, the U.S. Trustee appointed 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 9 of

25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

an Official Committee of Tort Claimants (the “TCC”). On May 29, 2019, upon the request of the 

U.S. Trustee, the Court appointed Professor Bruce A. Markell as the fee examiner in these Chapter 

11 Cases (the “Fee Examiner”).

Based on information and belief, a description of the Debtors’ business, capital structure, 

and the circumstances leading to the filing of these Chapter 11 Cases is set forth in the Amended 

Declaration of Jason P. Wells in Support of First Day Motions and Related Relief [Docket No. 

263]. 

B. The Debtors’ Retention of Coblentz

On July 11, 2019, the Court entered the Order Authorizing Debtors Pursuant to 11 U.S.C.

§ 327(a) and Fed. R. Bankr. P. 2014(a) and 2016 to Retain and Employ Coblentz Patch Duffy &

Bass LLP Nunc Pro Tunc to the Petition Date [Docket No. 2926] (the “Retention Order”). A

copy of the Retention Order is attached hereto as Exhibit A.

The Retention Order authorizes the Debtors to compensate and reimburse the Firm 

pursuant to the Bankruptcy Code, the Bankruptcy Rules, the Northern District Guidelines, and the 

Interim Compensation Order. Subject to the Firm’s application to the Court, the Debtors also are 

authorized by the Retention Order to compensate Coblentz for services performed at hourly rates 

that Coblentz has discounted for the Debtors as described in the application seeking the Firm’s 

employment [Docket No. 2595], and to reimburse Coblentz for actual and necessary expenses 

incurred. 

The Retention Order authorizes Coblentz to provide the following services to the Debtors: 

• advise and represent PG&E in real estate purchase and sale transactions and matters,

lease transactions and matters, and related or similar work, as further described in the

Debtor’s Application to retain Coblentz as Special Counsel (the “Retention

Application”) and the Declarations of Gregg M. Ficks filed in support thereof (the

“Ficks Declarations”);

• advise and represent PG&E in land conservation commitment transactions and matters,

and related or similar work, as further described in the Retention Application and the

Ficks Declarations;

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 10

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

• advise and represent PG&E in litigation, investigatory, and regulatory matters,

including in the DWR Matter, and related or similar work, as further described in the

Retention Application and the Ficks Declarations;

• advise and represent PG&E in the Ex Parte OII Matter, and related or similar work, as

further described in the Retention Application and the Ficks Declarations; and

• perform any other necessary legal services requested by the Debtors, and accepted by

Coblentz, during the pendency of these Chapter 11 cases.

C. Professional Compensation and Reimbursement of Expenses Requested

By this Interim Application, the Firm seeks interim allowance of compensation in the

amount of $1,025,814.52, and allowance of actual and necessary expenses in the amount of 

$17,595.12, for a total allowance of $1,043,409.64. 

By this Interim Application, Coblentz further seeks Court approval and authority for 

Debtors to make payment of the $205,162.90 hold-back accrued during the Interim Fee Period

(i.e., Coblentz requests approval and payment of the 20 percent of the requested fees that the 

Debtors held-back from payment to Coblentz during the Interim Fee Period in accordance with the 

Interim Compensation Procedures Order). 

All services for which Coblentz requests compensation were performed for or on behalf of 

the Debtors. Coblentz has received no payment and no promises for payment from any source 

other than the Debtors for services rendered or to be rendered in any capacity whatsoever in 

connection with the matters covered by this Interim Application. 

There is no agreement or understanding between Coblentz and any other person other than 

the partners of Coblentz for the sharing of compensation to be received for services rendered by 

Coblentz in these cases. As of the Petition Date, the Firm had no retainer from, or balance owing 

to, the Debtors. In connection with the Special Counsel matters for which Coblentz has been 

retained in these Chapter 11 Cases, as of this date Coblentz has been paid $730,068.85 in postpetition fees and reimbursed $12,329.12 in post-petition expenses, and Coblentz anticipates 

receiving payment of $90,582.77 in post-petition fees and $5,266.00 in post-petition expenses on 

account of its Eighth Monthly Fee Statement (for September 2019 Invoices) [Dkt. No. 4528] on, 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 11

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

or prior to, the hearing on this Application. The immediately preceding amounts, consisting of a 

total of $820,651.62 in fees and $17,595.12 in costs ($838,246.74 combined), have been paid, or 

will be paid prior to the hearing on this Interim Fee Application, pursuant to the Interim 

Compensation Procedures Order, but have not yet allowed, and Coblentz requests allowance 

hereby.

The Firm has billed the Debtors in these Chapter 11 Cases in accordance with its existing 

billing rates, as discounted for the Debtors as described in the Retention Application and/or Ficks 

Declarations, and in accordance with procedures in effect during the Interim Fee Period. These 

rates are the same rates Coblentz charges for services rendered by its attorneys and 

paraprofessionals in comparable matters, less the discounts provided, and are reasonable given the 

compensation charged by comparably skilled practitioners in similar matters. The Summary Sheet 

filed herewith contains tables listing the Coblentz attorneys and paraprofessionals who have 

performed services for the Debtors during the Interim Fee Period, including their job titles, hourly 

rates, aggregate number of hours worked in this matter, and, for attorneys, the year in which each 

professional was licensed to practice law. The Summary Sheet also contains tables summarizing 

the hours worked by the Firm’s attorneys and paraprofessionals broken down by project billing 

code, and further broken down for each matter for which the Firm is providing services to for the 

Debtors. Coblentz maintains computerized time records, which have been filed on the docket in 

invoice format with the Firm’s monthly fee statements and furnished to the Debtors, counsel for 

the Creditors’ Committee and the TCC, the U.S. Trustee, and the Fee Examiner in the format 

requested by the Interim Compensation Procedures Order, and/or in the format requested by those 

parties. 

D. Voluntary Discounts and Write-Offs Coblentz Previously Provided to the

Debtors Related to Fees and Costs Incurred During the Interim Fee Period

The fees and costs for which Coblentz requests approval and payment under this Interim 

Fee Application are net of $247,024.41 in voluntary fee and cost reductions Coblentz already has 

provided to the Debtors in connection with the Interim Fee Period: (1) as pre-invoicing write-offs 

Coblentz provided to the Debtors prior to issuing the invoices; (2) as agreed hourly rate discounts 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 12

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

Coblentz provided to the Debtors, as approved under the Retention Order; and/or (3) in order to 

avoid billing for fees or costs that may have been inconsistent with applicable Orders, Guidelines, 

or the Protocol in these Bankruptcy Cases. This $247,024.11 reduction consists of the following: 

• Coblentz’s previously agreed reduced rates in these Special Counsel matters

resulted in a reduction of $204,204.98 in legal fees from Coblentz’s standard

hourly rates for the services performed for the Debtors during the Interim Fee

Period;

• Coblentz reduced its professional hours spent in these Special Counsel matters

during the Interim Fee Period by 82 hours prior to issuing applicable invoices,

resulting in a voluntary reduction of $28,858.50 in legal fees;

• Coblentz wrote-off $10,745.55 in costs incurred during the Interim Fee Period prior

to issuing applicable invoices; and

• Coblentz provided a previously agreed volume discount of $3,215.38 to the

Debtors for land conservation work performed during the Interim Fee Period.

E. Budget and Budget-to-Actual Performance

Debtors provide annual budgets to Coblentz for some (but not all) of the matters Coblentz

handles for them. These budgets are subject to periodic review and adjustments by the Debtors 

during the course of each year. To the extent the Debtors have provided current budgets to 

Coblentz for the matters Coblentz is handling for it, Coblentz has not exceeded those budgets 

during the Interim Fee Period. 

JURISDICTION

This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. sections 157 and 

1334. This is a core proceeding pursuant to 28 U.S.C. section 157(b). Venue is proper before this 

Court pursuant to 28 U.S.C. sections 1408 and 1409. 

PROJECT BILLING AND NARRATIVE STATEMENT OF SERVICES RENDERED

During the Interim Fee Period, Coblentz professionals expended 1869.20 hours on behalf 

of the Debtors. Of this, 1482.10 hours were expended by partners and of counsel, 1863.50 by 

associates, and 200.60 by paraprofessionals. Under this engagement, Coblentz’s attorneys who 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 13

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

billed during the time period covered by this Application billed at discounted hourly rates ranging 

from $334.00 to $648.00, for a blended attorney rate of $587.10 during the Interim Fee Period.

In accordance with the Interim Compensation Procedures Order, the Northern District 

Guidelines, and the Local Rules, the Firm has classified the services it has performed for the 

Debtors during the Interim Fee Period into the following fourteen (14) categories, which 

categories reflect the Coblentz Matter Names/Matter Numbers under which Coblentz has invoiced 

the Debtors during the Interim Fee Period. Detailed time entries for the following categories

previously have been filed with the Court and served in accordance with the Interim 

Compensation Procedures Order under Coblentz’s First through Eighth Monthly Fee Statements 

[Dkt. Nos. 3679, 3741, 3742, 3763, 3765, 3771, 4038, and 4528] following entry of the Retention 

Order. Coblentz hereby incorporates those time entries into this Interim Fee Application, and 

refers any interested party to them. 

I. Real Estate/Land/Conservation Easement/Eminent Domain

A. Contract Review – Real Estate/Shared Services (Coblentz Matter

No. 02898-799)

This matter includes time spent on real property transactions, primarily drafting and 

negotiating lease documents. During this time period, Coblentz worked on 11 leases for customer 

service, warehouse and yard, office, and hangar spaces, 16 lease amendments for existing PG&E 

facilities, and numerous notices to landlords exercising options to extend or hold over. This 

matter also includes time spent in interpreting leases, representing PG&E in any disputes with 

landlords, and communicating with PG&E representatives and opposing counsel.

Total Hours: 342.30 Total Fees: $207,835.40

B. General Advice and Counsel – Surplus Disposition (Coblentz Matter

No. 16213-089)

This matter includes time working with PG&E representatives to develop four Purchase 

and Sale Agreement templates for the sale of PG&E surplus properties. The four templates will be 

used in circumstances in which (1) the subject property has no or minor environmental issues and 

no CPUC approval is required, (2) the subject property has no or minor environmental issues and 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 14

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

CPUC approval is required, (3) the subject property has environmental issues and no CPUC 

approval is required, and (4) the subject property has environmental issues and CPUC approval is 

required. The Purchase Agreements contain alternate provisions and numerous notes to the drafter 

that are intended to facilitate preparation of initial drafts of Purchase Agreements by nonattorneys. This matter also includes time to develop a form letter of intent for such sales.

Total Hours: 63.40 Total Fees: $41,083.20

C. Richmond Substation S Land Parcel (Coblentz Matter No. 16213-045)

This matter reflects time devoted to PG&E’s acquisition of a parcel of land adjoining

property currently owned by PG&E in Richmond, California. The matter includes preparing and 

monitoring a checklist of critical dates and closing documents and coordinating due diligence 

review with PG&E representatives. This matter required extensive title review, including analysis 

of not only title of the subject property, but also title of private roads and an adjoining parcel 

owned by the City of Richmond. This matter also involved preparing a title objection letter, 

drafting a notice waiving contingencies, and extensive communications with the title company.

Total Hours: 77.00 Total Fees: $33,875.40

D. Hinkley, CA Purchases (Coblentz Matter No. 02898-376)

This matter reflects time assisting PG&E in acquiring properties in Hinkley, California.

During this time period, Coblentz worked on transactions with 8 different property owners. Tasks 

include drafting and approving Purchase Agreements as to form, reviewing title, preparing escrow 

instructions, and coordinating closings. This matter also includes time tracking the status of 

transactions, participating in bi-monthly conference calls to review pending transactions, and 

communicating with PG&E representatives and the title company.

Total Hours: 26.90 Total Fees: $10,227.80

E. Local Community Energy Fire Resiliency (Coblentz Matter No. 16213-106)

This matter reflects time working with PG&E representatives to develop a form License

Agreement and a form Amendment to existing License Agreements to provide for customer 

resource centers during Public Safety Power Shutoff Events. This matter also includes advising 

PG&E in negotiating and interpreting license agreements for particular locations.

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 15

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

Total Hours: 28.30 Total Fees: $18,338.40

F. Lyons Land and Cattle, Merced (Coblentz Matter No. 16213-047)

This matter reflects attention to post-closing agreements following PG&E’s acquisition of

property for construction of a service center in Merced. The time includes negotiations with the 

Merced Irrigation District regarding a Deferred Fee Subdivision Drainage Agreement, analysis of 

the status of the Pipeline Construction Agreement with the adjoining property owner, and 

communications with PG&E representatives.

Total Hours: 11.50 Total Fees: $7,362.40

G. General Real Estate (Coblentz Matter No. 02898-110)

This matter reflects time in tracking the status of various real estate transactions and

updating a monthly status report delivered to PG&E’s in-house counsel. 

Total Hours: 21.80 Total Fees: $13,986.60

H. Purchase of Gabany Property (Coblentz Matter No. 16213-094)

This matter reflects paralegal time to review the final title policy for conformance with the

pro forma policy in connection with a PG&E acquisition of real property. 

Total Hours: 0.40 Total Fees: $113.60

I. Salinas MGP/California Water Service Company Purchase (Coblentz Matter

No. 16213-043)

This matter reflects the time of a paralegal to review the title policy for conformance with 

the pro forma policy following PG&E’s acquisition of property in Salinas from the California 

Water Service Company.

Total Hours: 0.30 Total Fees: $90.60

J. Sale of Sheridan Property (Placer County) (Coblentz Matter No. 16213-084)

This matter reflects communications with the title company to wind up an escrow

following the buyer’s termination of an agreement to purchase PG&E property.

Total Hours: 0.10 Total Fees: $36.90

K. Land Stewardship (Coblentz Matter No. 02898-357)

This matter involves the implementation of PG&E's "Land Conservation Commitment"

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 16

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

pursuant to its 2003 bankruptcy settlement. The settlement requires PG&E to ensure that 

approximately 140,000 acres of PG&E's watershed lands are protected through conservation 

easements or similar instruments together, in some cases, with fee title transfers. The Land 

Conservation Commitment involves roughly 100 transactions. Coblentz provided services for 

approximately 36 transactions of these transactions during the Interim Fee Period. 

Coblentz serves as primary transactional counsel for this matter. Coblentz’s work involves 

a broad range of tasks. Coblentz has primary responsibility for drafting, reviewing, and 

negotiating documents such as deeds, access easements, conservation easements, donation letters, 

environmental indemnity agreements, powers of termination, baseline documentation reports, 

Transaction Agreements (the equivalent of a purchase and sale agreement in a sale context), 

subdivision documentation, title reports, property descriptions, and escrow instructions. 

Coblentz’s work also involves assistance with various real estate issues associated with the 

involved properties, including issues relating to title report items (e.g., access issues, title 

encumbrances, subdivision issues, third party rights), leases, licenses, and permits. Once 

documents have been drafted and negotiated, Coblentz assists with PG&E's internal approval 

process, providing final documents, legal approval of such documents as to form, and providing 

transaction summaries for review by PG&E personnel approving PG&E's execution of such 

documentation. After regulatory approval, Coblentz is responsible for preparing and/or reviewing

the final conveyance documents and coordinating the closings. Coblentz participates in regular 

teleconferences and meetings with PG&E representatives to review the portfolio of pending 

transactions, discussing the status of transactions, identifying issues to be pursued, and updating a 

schedule for completion of deliverables by the PG&E and other participants in the transactions. 

Total Hours: 531.70 Total Fees: $341,337.88

L. LCC Conservation Easement Compliance (Coblentz Matter No. 16213-060)

Ownership of certain of the properties covered by PG&E's Land Conservation

Commitment are retained by PG&E, and such properties are encumbered by conservation 

easements entered into by PG&E with the holders of such easements (e.g., non-profit conservation 

organizations). The conservation easements require PG&E to perform certain obligations (e.g., 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 17

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

annual reporting and consultation with the easement holders), and restrict certain activities on the 

properties. Coblentz is the primary outside counsel assisting PG&E in its performance of these 

duties. This work includes assistance with PG&E's annual reporting and consultation 

requirements, including review of annual reports and advice on how PG&E's duties should be 

satisfied. Coblentz also provides assistance with the interpretation of conservation easement 

provisions and the development of policies relating to the performance of duties under such 

conservation easements.

Total Hours: 7.90 Total Fees: $4,711.54

II. Litigation, Including CPUC, Regulatory, and Investigative

A. CPUC Regulatory Investigation (Coblentz Matter No. 16213-056)

Coblentz’s work on the matter has included review and analysis of thousands of records

from the files of the utility concerning potential interactions with the CPUC to determine 

relevance and potential discoverability in the OII, as well as managing production of relevant 

materials and negotiating the scope of discovery with CPUC staff and other interested parties 

participating in the OII. Coblentz negotiated with CPUC staff and interested parties concerning a 

case management schedule, and the appropriate manner of creating a record of the case upon 

which the CPUC may base a decision, culminating in a joint case management submission and a 

pretrial conference before the assigned Administrative Law Judge at the CPUC.

Following the completion of discovery, Coblentz negotiated with CPUC staff and 

interested parties concerning the contents of an appropriate factual record for the CPUC’s 

consideration. This involved the review and analysis of dozens of materials potentially to be 

included in the record (as well as the implications of including those materials), the drafting and 

revising of written factual stipulations, narrative summaries concerning certain issues in the case, 

and the creation of a joint evidentiary record to be submitted to the CPUC. 

Coblentz then negotiated a settlement of this matter with CPUC staff and the interested 

parties, as well as a joint motion in support of the settlement to be submitted to the CPUC. 

Coblentz has taken substantial drafting responsibility for each of the joint written materials 

described above. The work has also involved strategic discussions with the client concerning 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 18

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

discovery issues and settlement.

Coblentz also handled various ancillary e-discovery projects, such as searching for and 

managing electronic materials relevant to discovery, and analyzing preservation issues. 

Total Hours: 238.80 Total Fees: $113,453.00

B. PG&E v. DWR / Oroville Dam Crisis Litigation (Coblentz Matter

No. 16213-060)

In this litigation matter, Coblentz has traveled to Sacramento for, and participation in, case 

management conferences, and telephonically participated in various case management and 

discovery conferences involving the coordinated plaintiffs and DWR. Coblentz also has reviewed, 

analyzed, and revised various joint discovery and case management materials common to the 

coordinated plaintiffs. Coblentz also has monitored and analyzed various pleadings submitted by 

the coordinated plaintiffs and DWR for relevance to PG&E’s claims in the matter. 

Coblentz’s work on this matter also has included telephonically attending numerous 

depositions of DWR personnel and analyzing the strategic implications of information developed 

through these depositions. Coblentz has also devised search strategies for identifying and 

analyzing the most relevant materials among more than 900,000 documents produced by DWR in 

discovery in the coordinated proceedings, as well as materials used in various depositions in the 

matter, and analyzing those materials. Coblentz also has analyzed and summarized the utility’s 

damages claims in accordance with a case management order in the matter. Coblentz also has

begun the process of reviewing and analyze potentially responsive materials from the files of the 

utility in response to discovery requests from DWR. Coblentz also has prepared and propounded 

discovery requests to DWR. 

Coblentz’s work on the matter also has involved strategic conferences with the client and 

analysis of e-discovery issues relevant to discovery from both DWR and the utility. Coblentz also 

has assessed potential expert candidates. 

Total Hours: 343.20 Total Fees: $123,368.00

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 19

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

III. Bankruptcy Special Counsel-Related Services (Coblentz Matter No. 16213-101)

Total Hours: 175.60 Total Fees: $109,993.80

The following sub-category calculations were made by best effort manual subcategorization and sub-calculation. They are good faith calculations. 

A. Coblentz First Through Seventh Monthly Fee Statements

This sub-category relates to work preparing Coblentz’s First though Seventh Monthly Fee

Statement, including communications with the Fee Examiner’s office, United States Trustee, and 

related communications.

Total Hours: 50.10 Total Fees: $31,212.30

B. Coblentz First Interim Fee Application

During the Interim Fee Period, the Firm began preparation of its First Interim Fee

Application. Most of the work related to this First Interim Fee Application has been performed 

after the Interim Fee Period, however, and will be included in Coblentz’s Second Interim Fee 

Application. 

Total Hours: 4.9 Total Fees: $3,052.70

C. Coblentz Retention and Disclosures

Coblentz attorneys prepared the Debtors’ application for retention of Coblentz as Special

Counsel, and related Court filings. Coblentz also reviewed materials for disclosures regarding its 

retention, investigated actual or potential disclosures, reported applicable disclosures, and updated 

the disclosures. Coblentz filed a supplemental Declaration in support of the Retention 

Application, and attended a hearing thereon. 

Total Hours: 116.20 Total Fees: $74,233.60

D. Fee Examiner Motion for Approval of Fee Protocols

During the Interim Fee Period, the Firm reviewed and analyzed the Fee Examiner’s

Motion for Approval of Fee Protocols, participated in a joint opposition re same, and 

communicated with other Debtors’ counsel re same. 

Total Hours: 2.4 Total Fees: $1,495.20

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 20

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

EXPENSE SUMMARY

JANUARY 29, 2019 THROUGH SEPTEMBER 30, 2019 

During the Interim Fee Period, the Firm advanced costs on behalf of the Debtors in 

connection with the discharge of the duties described in the Interim Application. During the 

Interim Fee Period, Coblentz incurred a total of $17,595.12 in expenses. These expenses are

further specified on the last page of the Summary Sheet filed herewith, and are reasonable and 

necessary to the Special Counsel services Coblentz has provided. Receipts for all significant 

expenses have been provided to the Debtors and to the Fee Examiner.

LEGAL BASIS FOR INTERIM COMPENSATION

The professional services for which Coblentz requests interim allowance of compensation 

and reimbursement of expenses were rendered and incurred in connection with the Special 

Counsel matters for which Coblentz has been employed, and in the discharge of Coblentz’s 

professional responsibilities as Special Counsel for the Debtors during these Chapter 11 Cases. 

Coblentz’s services have been necessary and beneficial to the Debtors and their estates, creditors, 

and other parties in interest. 

In accordance with the factors enumerated in section 330 of the Bankruptcy Code, 

Coblentz respectfully submits that the amount requested by Coblentz is fair and reasonable given 

the complexity of these Special Counsel matters, the time expended, the nature and extent of the 

services rendered, the value of such services, and the costs of comparable services other than in 

connection with a case under the Bankruptcy Code. Moreover, Coblentz has reviewed the 

requirements of the Interim Compensation Procedures Order, the Northern District Guidelines, 

and the UST Guidelines, and believes that the Interim Application substantially complies with 

those documents, except as follows: 

A. The project categories described in the Interim Application sometimes include fees

beyond the generally applicable $20,000 project billing threshold (Court Guideline For 

Compensation I.3.) due to the impracticality of further breaking-out the categories, the cost/benefit 

balance of further dissecting these categories especially in light of the narrow margin above the 

ordinary course professional threshold that has caused Coblentz to undertake participation in 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 21

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

Special Counsel procedures and requirements, as opposed to being considered an ordinary course 

professional in these cases, and Coblentz's relatively small role in these Bankruptcy Cases, relative 

to larger firms handling larger parts of the cases; 

B. Time entries in this Interim Fee Application include some time (approximately 5.2

hours resulting in $3,239.60 in fees) for revising and reducing proposed invoices prior to issuance 

of the invoices in order to try to conform the fees and costs therein to the applicable Guidelines 

and requirements. Coblentz requests that these fees be allowed for the same reasons as set forth in 

Item A, above; and

C. Time entries during the Interim Fee Period include time related to the extensive

conflicts check and review required in these large Bankruptcy Cases. Coblentz requests that the 

Court approves the fees for these time entries for the same reasons set forth in Item A, above. 

To the extent the fees or costs for which Coblentz seeks approval herein are inconsistent 

with the Revised Fee Examiner Protocol (the “Protocol”) [Dkt. No. 4473-1], Coblentz, for the 

reasons set forth above, objects to the Protocol pursuant to the procedure established in the Notice 

of Filing of the Protocol [Dkt. No. 4473] at pg. 2-3. 

AVAILABLE FUNDS

The Firm understands that the Debtors’ estates have sufficient funds available to pay the 

fees and costs sought herein. 

NOTICE

Notice of the Interim Application has been provided to parties-in-interest in accordance 

with the procedures set forth in the Interim Compensation Order. Coblentz submits that, in view 

of the facts and circumstances of these Chapter 11 Cases, such notice is sufficient and no other or 

further notice need be provided. 

CONCLUSION

Coblentz respectfully requests allowance of compensation to Coblentz in the amount of 

$1,025,814.52, and allowance of actual and necessary expenses in the amount of $17,595.12, for a 

total allowance of $1,043,409.64. Coblentz further respectfully requests authorization for the 

Debtors to pay the previously held-back amount $205,162.90 (20% of the allowed fees), and for 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 22

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

such other and further relief as this Court deems proper. 

DATED: November 14, 2019 Respectfully submitted,

COBLENTZ PATCH DUFFY & BASS LLP

By: /s/ Gregg M. Ficks

Gregg M. Ficks

Special Counsel to Debtors

and Debtors in Possession

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 23

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

NOTICE PARTIES

PG&E Corporation

c/o Pacific Gas & Electric Company

77 Beale Street

San Francisco, CA 94105 

Attn: Janet Loduca, Esq. 

Keller & Benvenutti LLP

650 California Street, Suite 1900 

San Francisco, CA 94108 

Attn: Tobias S. Keller, Esq. 

Jane Kim, Esq. 

Weil, Gotshal & Manges LLP

767 Fifth Avenue 

New York, NY 10153-0019 

Attn: Stephen Karotkin, Esq. 

Jessica Liou, Esq. 

Matthew Goren, Esq. 

The Office of the United States Trustee for Region 17

450 Golden Gate Avenue, 5th Floor, Suite #05-0153 

San Francisco, CA 94102 

Attn: James L. Snyder, Esq.

Timothy Laffredi, Esq. 

Milbank LLP

55 Hudson Yards 

New York, NY 10001-2163 

Attn: Dennis F. Dunne, Esq. 

Sam A Kahlil, Esq.

Milbank LLP

2029 Century Park East, 33rd Floor 

Los Angeles, CA 90067 

Attn: Paul S. Aronzon, Esq. 

Gregory A. Bray, Esq. 

Thomas R. Kreller, Esq. 

Baker & Hostetler LLP

11601 Wilshire Blvd, Suite 1400 

Los Angeles, CA 90025-0509 

Attn: Eric E. Sagerman, Esq. 

Lauren T. Attard, Esq. 

Bruce A. Markell

Fee Examiner

541 N. Fairbanks Court, Suite 2200 

Chicago, IL 60611-3710 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 24

of 25
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

COBLENTZ 

PATCH 

DUFFY & BASS LLP

One Montgomery Street, Suite 3000, San Francisco, California 94104 -5500

415.391.4800 • Fax 415.989.1663

Scott H. McNutt

324 Warren Road 

San Mateo, CA 94401 

Case: 19-30088 Doc# 4754 Filed: 11/14/19 Entered: 11/14/19 18:37:42 Page 25

of 25