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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) 

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 

Attorneys for Debtors and 

Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

NOTICE OF AGENDA FOR 

NOVEMBER 19, 2019, 10:00 A.M. 

OMNIBUS HEARING 

Date: November 19, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

San Francisco, CA 94102

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) 

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PROPOSED AGENDA FOR 

NOVEMBER 19, 2019, 10:00 A.M. (PACIFIC TIME) 

OMNIBUS HEARING 

I: MATTERS SCHEDULED TO BE HEARD IN ADVERSARY PROCEEDING: 

Official Committee of Tort Claimants v. Ad Hoc Group of Subrogation Claim Holders, 

Adv. Proc. No. 19-03053 

1. Status Conference

Status: Pursuant to Docket Text Order dated November 10, 2019, the Court 

wishes to hear from the Debtors, the TCC, and the Ad Hoc Group of Subrogation 

Claim Holders about scheduling matters. 

II: MATTERS SCHEDULED TO BE HEARD IN MAIN CASE: No. 19-30088 (DM) 

CONTESTED MATTER GOING FORWARD 

2. Inverse Condemnation: Joint Brief of Debtors and the Official Committee of 

Unsecured Creditors and Supplemental Statement of the PG&E Shareholders Concerning the 

Applicability of Inverse Condemnation [Dkt. 4485]. 

Response Deadline: November 15, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Memorandum of Points and Authorities in Support of Opposition to 

Debtors’ Motion re Inverse Condemnation [Dkt. 4768]. 

B. Declaration of Dario de Ghetaldi in Support of Opposition to Debtors’ 

Motion re Inverse Condemnation [Dkt. 4769]. 

C. Response Brief of the Official Committee of Tort Claimants Concerning 

the Applicability of Inverse Condemnation [Dkt. 4773]. 

D. Declaration of David B. Rivkin, Jr. in Support of Response Brief of the 

Official Committee of Tort Claimants Concerning the Applicability of 

Inverse Condemnation [Dkt. 4775]. 

E. Joinder in the Response Brief of the Official Committee of Tort Claimants 

Concerning the Applicability of Inverse Condemnation [Dkt. 4780]. 

F. Partial Joinder of the City and County of San Francisco to Reply Brief of 

the Official Committee of Tort Claimants Concerning the Applicability of 

Inverse Condemnation [Dkt. 4781]. 

Related Documents: 

G. Declaration of Kevin J. Orsini in Support of Joint Brief of Debtors and the 

Official Committee of Unsecured Creditors and Supplemental Statement 

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of the PG&E Shareholders Concerning the Applicability of Inverse 

Condemnation [Dkt. 4486]. 

Status: This matter is going forward on a contested basis. 

RESOLVED AND CONTINUED MATTERS 

3. Second Lease Assumption Motion: Seventh Omnibus Motion of the Utility 

Pursuant to 11 U.S.C § 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 for an Order 

Approving Assumption of Certain Real Property Leases [Dkt. 4390]. 

Response Deadline: November 5, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: No responses were filed. 

Related Documents: 

A. Declaration of Andrew K. Williams in Support of Second Lease 

Assumption Motion [Dkt. 4391]. 

B. Request for Entry of Order by Default Granting the Seventh Omnibus 

Motion of the Utility Pursuant to 11 U.S.C § 365(a), Fed. R. Bankr. P. 

6006, and B.L.R. 6006-1 for an Order Approving Assumption of Certain 

Real Property Leases [Dkt. 4600]. 

Related Orders: 

C. Order Pursuant to 11 U.S.C § 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 

6006-1 Approving Assumption of Certain Real Property Leases 

[Dkt. 4668]. 

Status: This Motion was granted on November 12, 2019 [Dkt. 4668]. 

4. Ruckman Stay Relief Motion: Motion to Abstain and for Relief from Automatic 

Stay to Permit Lawsuit to Proceed to Trial and Conclusion [Dkt. 4491]. 

Response Deadline: November 14, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Stipulation Between Debtor Pacific Gas and Electric Company and 

Ruckman and Leal Movants for Limited Relief from the Automatic Stay

[Dkt. 4683]. 

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Related Documents: 

B. Exhibits to Motion to Abstain and for Relief from Automatic Stay to 

Permit Lawsuit to Proceed to Trial and Conclusion [Dkt. 4492]. 

C. Declaration of Daniel Rodriguez in Support of Motion for Relief from 

Automatic Stay to Permit Lawsuit to Proceed to Trial and Conclusion 

[Dkt. 4493]. 

D. Declaration of Leonard K. Welsh in Support of Motion to Abstain and for 

Relief from Automatic Stay to Permit Lawsuit to Proceed to Trial and 

Conclusion [Dkt. 4494]. 

E. Relief from Stay Cover Sheet [Dkt. 4495]. 

Related Orders: 

F. Order Approving Stipulation Between Debtor Pacific Gas and Electric 

Company and Ruckman and Leal Movants for Limited Relief from the 

Automatic Stay [Dkt. 4728]. 

Status: This matter has been continued to the first omnibus hearing date on or 

after February 12, 2020 [Dkt. 4683, 4728]. The Movants will file a Notice of 

Continued Hearing to this effect promptly after dates are set for omnibus hearings 

in February. 

5. Exit Financing Motion: Debtors’ Motion for Entry of Orders (I) Approving 

Terms of, and Debtors’ Entry into and Performance Under, Exit Financing Commitment Letters 

and (II) Authorizing Incurrence, Payment and Allowance of Related Fees and/or Premiums, 

Indemnities, Costs and Expenses as Administrative Expense Claims [Dkt. 4446]. 

Response Deadline: November 13, 2019 at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Letter from the Official Committee of Unsecured Creditors to the 

Honorable Dennis Montali Regarding Exit Financing Discovery 

[Dkt. 4562]. 

B. Letter from the Ad Hoc Committee of Senior Unsecured Noteholders to 

the Honorable Dennis Montali in Regards to November 4, 2019 Letter 

from Creditors’ Committee [Dkt. 4566]. 

C. Letter from the Official Committee of Tort Claimants to the Honorable 

Dennis Montali Regarding Exit Financing Discovery [Dkt. 4575]. 

D. Letter from the Debtors to the Honorable Dennis Montali in Response to 

Letters Filed by Requesting Parties [Dkt. 4577]. 

Related Documents: 

E. Declaration of Kenneth S. Ziman in Support of Debtors’ Motion for Entry 

of Orders (I) Approving Terms of, and Debtors’ Entry into and 

Performance Under, Exit Financing Commitment Letters and (II) 

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Authorizing Incurrence, Payment and Allowance of Related Fees and/or 

Premiums, Indemnities, Costs and Expenses as Administrative Expense 

Claims [Dkt. 4447]. 

Status: This matter has been continued to December 17, 2019 [Dkt. 4639]. 

6. Tiger Natural Gas, Inc.’s Motion for Relief from Stay: Tiger Natural Gas, 

Inc.’s Motion for Relief from Stay Pursuant to 11 U.S.C. § 362(d)(1); Memorandum of Points 

and Authorities in Support [Dkt. 4322]. 

Response Deadline: November 8, 2019 at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Debtors’ Preliminary Opposition to Tiger Natural Gas, Inc.’s Motion for 

Relief from Stay Pursuant to 11 U.S.C. § 362(d)(1) [Dkt. 4622]. 

B. Declaration of Elizabeth Collier in Support of Debtor’s Preliminary 

Opposition to Tiger Natural Gas, Inc.’s Motion for Relief from Stay 

Pursuant to 11 U.S.C. § 362(d)(1) [Dkt. 4623]. 

Related Documents: 

C. Declaration of Leah E. Capritta in Support of Tiger Natural Gas, Inc.’s 

Motion for Relief from the Automatic Stay [Dkt. 4322-2]. 

D. Tiger Natural Gas, Inc.’s Request for Judicial Notice in Support of Its 

Motion for Relief from the Automatic Stay [Dkt. 4322-4]. 

E. Relief from Stay Cover Sheet [Dkt. 4322-5]. 

F. Tiger Natural Gas, Inc.’s Reply in Support of Motion for Relief from Stay 

Pursuant to 11 U.S.C. § 362(d)(1) [Dkt. 4661]. 

G. Declaration of Leah E. Capritta in Support of Tiger Natural Gas, Inc.’s 

Reply in Support of Motion for Relief from Stay Pursuant to 11 U.S.C. § 

362(d)(1) [Dkt. 4661-1]. 

Status: The Court issued a tentative ruling by Docket Text Order on November 

10, 2019 that Tiger’s motion would be continued until late February 2020. Tiger 

has accepted the tentative ruling. 

7. Debtors’ Second Motion Enlarging Time to File Notices of Removal: Debtors’ 

Second Motion Pursuant to Fed. R. Bankr. P. 9006(b) and 9027 Enlarging the Time Within 

Which to File Notices of Removal of Related Proceedings [Dkt. 4481]. 

Response Deadline: November 12, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: No responses were filed. 

Related Documents: 

B. Declaration of John Boken in Support of Debtors’ Second Motion 

Pursuant to Fed. R. Bankr. P. 9006(b) and 9027 Enlarging the Time 

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Within Which to File Notices of Removal of Related Proceedings [Dkt. 

4482]. 

Related Orders: 

C. Second Order Pursuant to Fed. R. Bankr. P. 9006(b) and 9027 Enlarging 

the Time Within Which to File Notices of Removal of Related 

Proceedings [Dkt. 4756]. 

Status: This Motion was granted [Dkt. 4756] and taken off calendar by Docket 

Text Order on November 13, 2019. 

8. Motion to Allow Class Proofs of Claim: Class Representative’s Motion to 

Extend Application of Federal Rule of Civil Procedure 23 to Class Proofs of Claim [Dkt. 4370]. 

Response Deadline: November 12, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Objection to Class Representative’s Motion to Extend Application of 

Federal Rule of Civil Procedure 23 to Class Proof of Claim [Dkt. 4684]. 

B. Declaration of Robb C. McWilliams in Support of Debtors’ Objection to 

Class Representative’s Motion to Extend Application of Federal Rule of 

Civil Procedure 23 to Class Proof of Claim [Dkt. 4685]. 

C. Declaration of Richard W. Slack in Support of Debtors’ Objection to Class 

Representative’s Motion to Extend Application of Federal Rule of Civil 

Procedure 23 to Class Proof of Claim [Dkt. 4686]. 

D. Declaration of Benjamin P.D. Schrag (I) Regarding Implementation of the 

Debtors’ Notice Procedures and Supplemental Notice Plan and (II) in 

Support of the Debtors’ Objection to Class Representative’s Motion to 

Extend Application of Federal Rule of Civil Procedure 23 to Class Proof 

of Claim [Dkt. 4687]. 

E. Declaration of Jeanne C. Finegan (I) Regarding Implementation of the 

Debtors’ Notice Procedures and Supplemental Notice Plan and (II) in 

Support of the Debtors’ Objection to Class Representative’s Motion to 

Extend Application of Federal Rule of Civil Procedure 23 to Class Proof 

of Claim [Dkt. 4688]. 

Related Documents: 

F. Declaration of John E. Lattin in Support of Class Representative’s 

Motion to Extend Application of Federal Rule of Civil Procedure 23 to 

Class Proofs of Claim [Dkt. 4370-1]. 

Status: This Motion was denied by Docket Text Order on November 14, 2019 

and was dropped from the calendar by Docket Text Order on November 15, 2019. 

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9. Motion to Disallow Claims: Debtors’ First Omnibus Report and Objection to 

Claims Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 2896]. 

Response Deadline: July 31, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Response in Opposition to Debtors’ First Omnibus Report and Objection 

to Claims Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 3263]. 

B. Response of C.H. Reynolds Electric, Inc. to Debtors’ First Omnibus 

Report and Objection to Claims Asserted Pursuant to 11 U.S.C. § 

503(b)(9) [Dkt. 3267]. 

C. Opposition of Shiloh IV Lessee, LLC to Debtors’ First Omnibus Report 

and Objection to Claims Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 

3284]. 

D. Opposition of Marsh Landing, LLC to Debtors’ First Omnibus Report and 

Objection to Claims Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 

3286]. 

E. Response of Claimant Global Ampersand LLC to Objection of Debtor to 

Claim Asserted by Claimant Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 

3288]. 

F. Response of Surf to Snow Environmental Resource Management, Inc. to 

Debtors’ First Omnibus Report and Objection to Claims Asserted Pursuant 

to 11 U.S.C. § 503(b)(9) [Dkt. 3302]. 

G. Omnibus Stipulation Between Debtors and Certain Claimants Extending 

Time to Respond to Debtors’ First Omnibus Report and Objection to 

Claims Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 3306]. 

H. Letter to Court filed by Hypower, Inc. [Dkt. 3315]. 

I. Exhibit A to Response of C.H. Reynolds Electric, Inc. to Debtors’ First 

Omnibus Report and Objection to Claims Asserted Pursuant to 11 U.S.C. 

§ 503(b)(9) [Dkt. 3324]. 

Related Documents: 

J. Declaration of Robb C. McWilliams in Support of Debtors’ First Omnibus 

Report and Objection to Claims Asserted Pursuant to 11 U.S.C. § 

503(b)(9) [Dkt. 2897]. 

K. Notice of Filing of Revised Proposed Order Approving Debtors’ First 

Omnibus Report and Objection to Claims Asserted Pursuant to 11 U.S.C. 

§ 503(b)(9) [Dkt. 3522]. 

Related Orders: 

L. Order Granting Omnibus Stipulation Between Debtors and Certain 

Claimants Extending Time to Respond to Debtors’ First Omnibus Report 

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and Objection to Claims Asserted Pursuant to 11 U.S.C. § 503(b)(9) 

[Dkt. 3365]. 

M. Order Granting Debtors’ First Omnibus Report and Objection to Claims 

Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 3564]. 

Status: This matter has been continued to January 29, 2020 [Dkt. 4786]. 

10. Motion to Compel Payment of Pass-Through Amounts: Motion and 

Memorandum of the Ad Hoc Group of Interconnection Customers to Compel Payment of PassThrough Amounts Withheld by Pacific Gas and Electric Company [Dkt. 4400]. 

Response Deadline: November 14, 2019 at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Stipulation Between Debtors and Ad Hoc Group of Interconnection 

Customers to Continue Hearing on Motion to Compel Payment of PassThrough Amounts Withheld by Pacific Gas and Electric Company 

[Dkt. 4621]. 

B. Order Approving Stipulation Between Debtors and Ad Hoc Group of 

Interconnection Customers to Continue Hearing on Motion to Compel 

Payment of Pass-Through Amounts Withheld by Pacific Gas and Electric 

Company [Dkt. 4671]. 

C. Stipulation Between the Debtors and Ad Hoc Group of Interconnection 

Customers to Permit Payment of Certain Pass-Through Amounts [Dkt. 

4779]. 

Related Documents: 

D. Declaration of Jennifer Mersing in Support of the Motion by the Ad Hoc 

Group of Interconnection Customers to Compel Payment of Pass-Through 

Amounts Withheld by Pacific Gas and Electric Company [Dkt. 4402]. 

E. Declaration of Ryan Liddell in Support of the Motion by the Ad Hoc 

Group of Interconnection Customers to Compel Payment of Pass-Through 

Amounts Withheld by Pacific Gas and Electric Company [Dkt. 4403]. 

F. Declaration of Anand Narayanan in Support of the Motion by the Ad Hoc 

Group of Interconnection Customers to Compel Payment of Pass-Through 

Amounts Withheld by Pacific Gas and Electric Company [Dkt. 4404]. 

G. Declaration of Jon C. Yoder in Support of the Motion by the Ad Hoc 

Group of Interconnection Customers to Compel Payment of Pass-Through 

Amounts Withheld by Pacific Gas and Electric Company [Dkt. 4405]. 

H. Relief from Stay Cover Sheet [Dkt. 4406]. 

Status: This matter was resolved by stipulation on November 15, 2019 

[Dkt. 4779]. 

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11. Subrogation Settlement and RSA Motion: Debtors’ Motion Pursuant to 

11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9010 for Entry of an Order (I) 

Authorizing the Debtors to Enter into Restructuring Support Agreement with the Consenting 

Subrogation Claimholders, (II) Approving the Terms of Settlement with Such Consenting 

Subrogation Claimholders, Including the Allowed Subrogation Amount, and (III) Granting 

Related Relief [Dkt. 3992]. 

Response Deadline: October 16, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Limited Objection of California Governor’s Office of Emergency Services 

and California Department of Veterans Affairs to Debtors’ Subrogation 

Settlement and RSA Motion [Dkt. 4220]. 

B. Objection of BOKF, NA as Indenture Trustee to Debtors’ Motion 

Pursuant to 11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 

and 9010 for Entry of an Order (I) Authorizing the Debtors to Enter into 

Restructuring Support Agreement with the Consenting Subrogation 

Claimholders, (II) Approving the Terms of Settlement with Such 

Consenting Subrogation Claimholders, Including the Allowed Subrogation 

Amount, and (III) Granting Related Relief [Dkt. 4231]. 

C. Opposition of Official Committee of Tort Claimants to Debtors’ Motion 

Pursuant to 11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 

and 9010 for Entry of an Order (I) Authorizing the Debtors to Enter into 

Restructuring Support Agreement with the Consenting Subrogation 

Claimholders, (II) Approving the Terms of Settlement with Such 

Consenting Subrogation Claimholders, Including the Allowed Subrogation 

Amount, and (III) Granting Related Relief [Dkt. 4232]. 

D. Declaration of David J. Richardson in Support of Opposition of Official 

Committee of Tort Claimants to Debtors’ Motion Pursuant to 

11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9010 for 

Entry of an Order (I) Authorizing the Debtors to Enter into Restructuring 

Support Agreement with the Consenting Subrogation Claimholders, (II) 

Approving the Terms of Settlement with Such Consenting Subrogation 

Claimholders, Including the Allowed Subrogation Amount, and (III) 

Granting Related Relief [Dkt. 4235]. 

E. Objection of the Official Committee of Unsecured Creditors to the 

Debtors’ Subrogation Settlement and RSA Motion [Dkt. 4236]. 

F. Objection of the United States of America to Debtors’ Motion Pursuant to 

11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9010 for 

Entry of an Order (I) Authorizing the Debtors to Enter into Restructuring 

Support Agreement with the Consenting Subrogation Claimholders, (II) 

Approving the Terms of Settlement with Such Consenting Subrogation 

Claimholders, Including the Allowed Subrogation Amount, and (III) 

Granting Related Relief [Dkt. 4237]. 

G. The Adventist Claimants’ Objection to the Debtors’ Motion Pursuant to 

11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9010 for 

Entry of an Order (I) Authorizing the Debtors to Enter into Restructuring 

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Support Agreement with the Consenting Subrogation Claimholders, (II) 

Approving the Terms of Settlement with Such Consenting Subrogation 

Claimholders, Including the Allowed Subrogation Amount, and (III) 

Granting Related Relief [Dkt. 4239]. 

H. Objection of the Ad Hoc Committee of Senior Unsecured Noteholders to 

Debtors’ Motion to Enter into Restructuring Support Agreement with the 

Consenting Subrogation Claimholders [Dkt. 4241]. 

I. Ad Hoc Group of Subrogation Claim Holders’ Reply in Support of 

Debtors’ Motion Pursuant to 11 U.S.C. §§ 363(b) and 105(a) and Fed. R. 

Bankr. P. 6004 and 9010 for Entry of an Order (I) Authorizing the Debtors 

to Enter into Restructuring Support Agreement with the Consenting 

Subrogation Claimholders, (II) Approving the Terms of Settlement with 

Such Consenting Subrogation Claimholders, Including the Allowed 

Subrogation Amount, and (III) Granting Related Relief [Dkt. 4348]. 

J. Declaration of Benjamin P. McCallen in Support of Ad Hoc Group of 

Subrogation Claim Holders’ Reply in Support of Debtors’ Motion 

Pursuant to 11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 

and 9010 for Entry of an Order (I) Authorizing the Debtors to Enter into 

Restructuring Support Agreement with the Consenting Subrogation 

Claimholders, (II) Approving the Terms of Settlement with Such 

Consenting Subrogation Claimholders, Including the Allowed Subrogation 

Amount, and (III) Granting Related Relief [Dkt. 4348-1]. 

K. Declaration of Homer Parkhill in Support of the Ad Hoc Group of 

Subrogation Claim Holders’ Statement in Support of the Subrogation 

Settlement and RSA Motion [Dkt. 4348-2]. 

L. The Baupost Group, L.L.C.’s Joinder in the Ad Hoc Group of Subrogation 

Claim Holders’ Reply in Support of Debtors’ Motion Pursuant to 

11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9010 for 

Entry of an Order (I) Authorizing the Debtors to Enter into Restructuring 

Support Agreement with the Consenting Subrogation Claimholders, (II) 

Approving the Terms of Settlement with Such Consenting Subrogation 

Claimholders, Including the Allowed Subrogation Amount, and (III) 

Granting Related Relief [Dkt. 4365]. 

M. Joinder of Certain PG&E Shareholders to the Debtors’ Reply in Support 

of Subrogation Claims Settlement and RSA Motion [Dkt. 4367].

N. Joinder by TURN in Objections and Opposition to Debtors’ Motion 

Pursuant to 11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 

and 9010 for Entry of an Order (I) Authorizing the Debtors to Enter into 

Restructuring Support Agreement with the Consenting Subrogation 

Claimholders, (II) Approving the Terms of Settlement with Such 

Consenting Subrogation Claimholders, Including the Allowed Subrogation 

Amount, and (III) Granting Related Relief [Dkt. 4377]. 

O. Response of Official Committee of Tort Claimants to Debtors’ Restated 

Restructuring Support and Settlement Agreement with the Consenting 

Subrogation Claimholders [Dkt No. 4554-1] [Dkt. 4629]. 

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P. Declaration of Lauren T. Attard in Support of Response of Official 

Committee of Tort Claimants to Debtors’ Restated Restructuring Support 

and Settlement Agreement with the Consenting Subrogation Claimholders 

[Dkt. No. 4554-1] [Dkt. 4630]. 

Q. Declaration of Brent C. Williams in Support of Response of Official 

Committee of Tort Claimants to Debtors’ Restated Restructuring Support 

and Settlement Agreement with the Consenting Subrogation Claimholders 

[Dkt. No. 4554-1] [Dkt. 4631]. 

R. The Adventist Claimants’ Renewed Objection to the Debtors’ Motion for 

Entry of an Order Authorizing the Debtors to Enter into Restructuring 

Support Agreement with the Consenting Subrogation Claimholders, Etc. 

[DE # 3992], and Objection to Debtor’s Notice of Filing of Amended and 

Restated Restructuring Support Agreement [DE # 4554] [Dkt. 4637]. 

S. Objection of Governor Gavin Newsom to Debtors’ Motion Pursuant to 11 

U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9019 for 

Entry of an Order (I) Authorizing the Debtors to Enter into Restructuring 

Support Agreement with the Consenting Subrogation Claimholders, (II) 

Approving Such Consenting Subrogation Claimholders, Including the 

Allowed Subrogation Claim Amount, and (III) Granting Related Relief 

[Dkt. 4640]. 

T. Supplemental Objection of the Official Committee of Unsecured Creditors 

to the Debtors’ Subrogation Settlement and RSA Motion [Dkt. 4643]. 

U. Supplemental and Updated Objection of Bokf, NA, Indenture Trustee, to 

Debtors’ Motion Pursuant to 11 U.S.C. §§ 363(b) and 105(a) and Fed. R. 

Bankr. P. 6004 and 9019 for Entry of an Order (I) Authorizing the Debtors 

to Enter into Restructuring Support Agreement with the Consenting 

Subrogation Claimholders, (II) Approving Such Consenting Subrogation 

Claimholders, Including the Allowed Subrogation Claim Amount, and 

(III) Granting Related Relief [Dkt. 4657]. 

V. Errata Sheet Regarding Response of Official Committee of Tort Claimants 

to Debtors’ Restated Restructuring Support and Settlement Agreement 

with the Consenting Subrogation Claimholders [Dkt. No. 4629] [Dkt. 

4710]. 

Related Documents: 

W. Declaration of Jason P. Wells in Support of Debtors’ Motion Pursuant to 

11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9010 for 

Entry of an Order (I) Authorizing the Debtors to Enter into Restructuring 

Support Agreement with the Consenting Subrogation Claimholders, (II) 

Approving the Terms of Settlement with Such Consenting Subrogation 

Claimholders, Including the Allowed Subrogation Amount, and (III) 

Granting Related Relief [Dkt. 3993]. 

X. Debtors’ Reply in Support of Subrogation Claims Settlement and RSA 

Motion [Dkt. 4339]. 

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

Y. Notice of Filing of Amended and Restated Restructuring Support 

Agreement [Dkt. 4554]. 

Z. Statement of the Ad Hoc Group of Subrogation Claim Holders [Dkt. 

4644]. 

AA. Notice of Amendment to Amended and Restated Restructuring Support 

Agreement [Dkt. 4711]. 

Status: This matter has been continued to December 4, 2019 [Dkt. 4762]. 

12. McKinsey Retention Application: Application of Debtors Pursuant to 11 U.S.C. 

§§ 363(b) and 105(a) for Authority to Enter Into, Perform Under and Make Payments Under 

Certain Consulting Contracts with McKinsey & Company, Inc. United States [Dkt. 3919]. 

Response Deadline: November 12, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: No responses were filed. 

Status: This matter was continued to December 17, 2019 [Dkt. 4578]. 

PLEASE TAKE NOTICE that copies of any pleadings filed with the Court and 

referenced herein can be viewed and/or obtained: (i) by accessing the Court’s website at 

http://www.canb.uscourts.gov, (ii) by contacting the Office of the Clerk of the Court at 450 

Golden Gate Avenue, San Francisco, CA 94102, or (iii) from the Debtors’ notice and claims 

agent, Prime Clerk LLC, at https://restructuring.primeclerk.com/pge or by calling (844) 339-

4217 (toll free) for U.S.-based parties; or +1 (929) 333-8977 for International parties or by email at:pgeinfo@primeclerk.com. Note that a PACER password is needed to access documents 

on the Bankruptcy Court’s website. 

Dated: November 18, 2019 WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP 

 By: /s/ Dara L. Silveira 

 Dara L. Silveira 

 

Attorneys for Debtors and Debtors in Possession 

Case: 19-30088 Doc# 4791 Filed: 11/18/19 Entered: 11/18/19 12:13:16 Page 12

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