1 Case No. 19-30088-DM

551969

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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000

SAN FRANCISCO, CA 

94111

UNITED STATES BANKRUPTCY COURT

FOR THE 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 the Lead Case, 

No. 19-30088 (DM)

Case No.: 19-30088-DM

Chapter 11

JOINDER OF THE CITY AND 

COUNTY OF SAN FRANCISCO TO 

OPPOSITION OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

TO MOTION OF DEBTORS 

PURSUANT TO 11 USC §§105(a), 363 

(b) AND 503(c) FOR ENTRY OF AN 

ORDER (1) APPROVING DEBTOR’S 

INCENTIVE PROGRAM FOR 

CERTAIN KEY EMPLOYEES AND (II) 

GRANTING RELATED RELIEF.

DATE: July 24, 2019

TIME: 9:30 am

PLACE: Courtroom 17

450 Golden Gate Avenue, 16th Fl.

San Francisco, California

JUDGE: Hon. Dennis Montali

RELATED DOCKET NOS: 2664, 3030

///

EDWARD J. TREDINNICK (#84033)

GREENE RADOVSKY MALONEY 

 SHARE & HENNIGH LLP

Four Embarcadero Center, Suite 4000

San Francisco, California 94111-4106

Telephone: (415) 981-1400

Facsimile: (415) 777-4961

E-mail: etredinnick@greeneradovsky.com

Attorneys for Creditor,

City and County of San Francisco

Case: 19-30088 Doc# 3059 Filed: 07/18/19 Entered: 07/18/19 13:17:45 Page 1 of

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GREENE RADOVSKY 

MALONEY SHARE &

HENNIGH LLP

FOUR EMBARCADERO 

CTR, SUITE 4000

SAN FRANCISCO, CA 

94111

The City and County of San Francisco (“San Francisco”) in the above-captioned chapter 11 

cases of Pacific Gas and Electric Company (the “Utility”) and PG&E Corporation (“PG&E” and, 

together with the Utility, the “Debtors”), hereby joins, as further described herein, in the Opposition 

of the Official Committee of Tort Claimants (the “Tort Committee Opposition”) [Docket No. 3030] 

to Motion of Debtors Pursuant to 11 U.S.C. §§ 105(A), 363 (b), and 503 (C) for Entry of Order (I) 

Approving Debtor’s Incentive Program for Certain Key Employees and (II) Granting Related Relief 

[Dkt. No. 2664] (the “Motion”). 

San Francisco generally concurs with the Tort Committee Opposition filed herein and believes 

that any Key Employee Incentive Plan should be limited. San Francisco files this joinder to preserve 

its rights to object to the Motion on the specific grounds set forth herein. In support hereof, San 

Francisco respectfully represents as follows:

JOINDER

San Francisco’s interest in the Motion is both as a creditor and on behalf of the Utility’s 

ratepayers in San Francisco. 

San Francisco joins the Tort Committee Opposition and further contends that any incentive 

program should be designed to enhance safety and reliability and preserve funds for creditors, not 

reward highly-compensated management employees who bear responsibility for the Debtors’ financial 

condition and poor safety track record.

San Francisco expressly reserves all rights to join in any other parties’ objections to the 

Motion. 

CONCLUSION

For the reasons stated herein, San Francisco joins in the Tort Committee Opposition and 

requests that the Court deny the Motion as set forth in this Joinder.

Respectfully submitted,

Dated: July 18, 2019 GREENE RADOVSKY MALONEY 

SHARE & HENNIGH LLP

By: _____/s/ Edward Tredinnick_________________

Edward J. Tredinnick

Attorneys for Creditor,

City and County of San Francisco

Case: 19-30088 Doc# 3059 Filed: 07/18/19 Entered: 07/18/19 13:17:45 Page 2 of

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