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

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) 

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) 

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,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

EX PARTE MOTION OF DEBTORS PURSUANT TO 

B.L.R. 9006-1 REQUESTING ORDER SHORTENING 

TIME FOR HEARING ON TORT CLAIMANTS RSA 

MOTION 

Related Document: Dkt. 5038 

[No hearing requested] 

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# 5040 Filed: 12/09/19 Entered: 12/09/19 18:03:02 Page 1 of

6
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 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

PG&E Corporation and Pacific Gas and Electric Company, as debtors and debtors in 

possession (collectively, “PG&E” or the “Debtors”) in the above-captioned chapter 11 cases (the 

“Chapter 11 Cases”), hereby submit this Motion (the “Motion to Shorten”), pursuant to Rule 

9006-1 of the Bankruptcy Local Rules for the United States Bankruptcy Court for the Northern 

District of California (the “Bankruptcy Local Rules”), for entry of an order shortening time for a 

hearing on December 17, 2019, at 10:00 a.m. (prevailing Pacific Time), on the 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 and TCC to Enter Into Restructuring Support Agreement With 

the TCC, Consenting Fire Claimant Professionals, and Shareholder Proponents and (II) Granting 

Related Relief (the “Tort Claimants RSA Motion”), filed contemporaneously herewith. The 

Debtors request that any responses or objections be in writing and filed with the Court and served 

by 4:00 p.m. (prevailing Pacific Time) on December 13, 2019. 

In support of this Motion to Shorten, the Debtors submit the Declaration of Jessica 

Liou (the “Liou Declaration”), filed contemporaneously herewith. A proposed form of order 

granting the relief requested herein will be uploaded contemporaneously herewith. 

MEMORANDUM OF POINTS AND AUTHORITIES

I. JURISDICTION 

The Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 

1334, the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 

24 (N.D. Cal.), and Bankruptcy Local Rule 5011-1(a). This is a core proceeding pursuant to 28 

U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

II. BACKGROUND 

On January 29, 2019 (the “Petition Date”), the Debtors commenced with the Court 

voluntary cases under chapter 11 of the Bankruptcy Code. 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 in either of the Chapter 

11 Cases. The Debtors’ Chapter 11 Cases are being jointly administered for procedural purposes 

Case: 19-30088 Doc# 5040 Filed: 12/09/19 Entered: 12/09/19 18:03:02 Page 2 of

6
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

only pursuant to Bankruptcy Rule 1015(b). 

On February 12, 2019, the United States Trustee (the “U.S. Trustee”) appointed an 

Official Committee of Unsecured Creditors (the “Creditors Committee”). On February 15, 2019, 

the U.S. Trustee appointed an Official Committee of Tort Claimants (the “TCC”). 

Additional information regarding the circumstances leading to the commencement of 

the Chapter 11 Cases and information regarding the Debtors’ businesses and capital structure is set 

forth in the Amended Declaration of Jason P. Wells in Support of the First Day Motions and Related 

Relief [Docket No. 263] (the “Wells Declaration”). 

III. RELIEF REQUESTED IN THE TORT CLAIMANTS RSA MOTION 

The Tort Claimants RSA Motion seeks entry of an order (i) authorizing the Debtors 

and TCC to enter into and perform under that certain Restructuring Support Agreement, dated as of 

December 6, 2019 (the “Tort Claimants RSA”), among the Debtors, the TCC, the Consenting Fire 

Claimant Professionals1, and the Shareholder Proponents parties thereto, a copy of which is annexed 

to the Tort Claimants RSA Motion as Exhibit A, and (ii) granting related relief. 

IV. SHORTENING TIME FOR HEARING ON THE TORT CLAIMANTS RSA MOTION 

IS WARRANTED 

Pursuant to Bankruptcy Local Rule 9014-1(b)(3)(A), a hearing on the Tort Claimants 

Motion requires twenty-one (21) days’ notice of an opportunity for a hearing. Bankruptcy Local Rule 

9006-1(a) provides that, except as set forth therein, “approval of the Court is required to enlarge or to 

shorten time to perform any act or file any paper pursuant to the Federal Rules of Civil Procedures, 

the Bankruptcy Rules, or these Bankruptcy Local Rules.” B.L.R. 9006-1(a). 

As described in the Tort Claimants RSA Motion, the Tort Claimants RSA reflects a 

substantial compromise of the asserted Fire Victim Claims. The Tort Claimants RSA fairly resolves 

the largest remaining category of disputed claims asserted against the Debtors and will expedite the 

successful resolution of these Chapter 11 Cases by dispensing with the pending estimation proceedings 

1

 Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Tort 

Claimants RSA Motion. 

Case: 19-30088 Doc# 5040 Filed: 12/09/19 Entered: 12/09/19 18:03:02 Page 3 of

6
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

and Tubbs trial and will pave the way toward confirmation of the Amended Plan well within the June 

30, 2020 deadline established under AB 1054. 

Time is of the absolute essence. As an initial matter, because of the pending Tubbs 

trial and estimation proceedings, if the Tort Claimants RSA is not approved by this Court by December 

20, 2019, it automatically terminates. The Tubbs trial is scheduled to begin with jury selection on 

January 7, 2020, with the estimation proceedings to commence before the District Court shortly 

thereafter on February 18, 2020. The parties are devoting massive amounts of time and resources in 

anticipation of moving ahead with those proceedings in accordance with the compressed schedules 

previously established. Consideration of the Tort Claimants RSA on shortened notice is essential for 

the parties to know whether the estimation proceedings and the Tubbs trial will be proceeding as 

scheduled or will be resolved as provided in the Tort Claimants RSA. Pursuant to the Tort Claimants 

RSA, the estimation proceedings have been temporarily stayed by the District Court and the parties 

have agreed to seek a 15-day continuance of the Tubbs trial and are scheduled to appear before the 

Superior Court of the State of California tomorrow morning. Whether the estimation proceedings or 

Tubbs trial will recommence depends on the outcome of the hearing on the Tort Claimants RSA 

Motion, and accordingly, the parties need to know promptly whether those proceedings will move 

forward or not. 

Expedited consideration and approval of the Tort Claimants RSA will eliminate the 

costs, litigation, and risks associated with the estimation of the Fire Victim Claims currently pending 

before three separate courts. If the Tort Claimants RSA is not approved, the Fire Victim Claims would 

be subject to the pending estimation proceedings before the District Court and this Court, and a jury 

trial in the California State Superior Court. As the Court is aware, estimation will be a timeconsuming, expensive, and highly uncertain process involving complicated issues of state and federal 

law and fact-specific issues relating to causation, liability, and damages involving not less than twentytwo separate wildfires and literally thousands of individual loss claims. The Tort Claimants RSA 

avoids the risks and uncertainties of the estimation proceedings to the Debtors and their other 

economic stakeholders with respect to a major claims constituency, providing greater certainty to the 

plan process and the Debtors’ timely emergence from chapter 11. Moreover, as stated in the Tort 

Case: 19-30088 Doc# 5040 Filed: 12/09/19 Entered: 12/09/19 18:03:02 Page 4 of

6
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

Claimants RSA Motion, approval of the Tort Claimants RSA will result in the support of the Amended 

Plan by all impaired classes, facilitating a successful conclusion of these Chapter 11 Cases. 

As discussed above, the exigencies of the cases warrant limited notice. In this regard, 

the Debtors note that they publicly disclosed their entry into the Tort Claimants RSA by press release 

on Friday, December 6, 2019 and 8-K filing early this morning. The press release resulted in 

widespread publicity, including articles published on Friday evening by the Wall Street Journal, 

Bloomberg News, and other national publications. 

Based on the foregoing, the Debtors request that notice be shortened to permit the Tort 

Claimants RSA Motion to be heard on December 17, 2019, at 10:00 a.m. (prevailing Pacific Time), 

and for written objections, if any, to be filed and served by 4:00 p.m. (prevailing Pacific Time) on 

December 13, 2019. As stated in the Liou Declaration, the TCC consents to the relief sought in this 

Motion to Shorten. The Debtors also sought consent from the U.S. Trustee and Creditors’ Committee, 

however, the U.S. Trustee and Creditors Committee have not yet provided their consent. 

In view of the foregoing, the Debtors believe more than ample cause exists to grant the 

relief requested herein. 

V. NOTICE 

Notice of this Motion to Shorten will be provided to (i) the Office of the United States 

Trustee for Region 17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the 

Creditors Committee; (iii) counsel to the TCC; (iv) the Securities and Exchange Commission; (v) the 

Internal Revenue Service; (vi) the Office of the California Attorney General; (vii) the California Public 

Utilities Commission; (viii) the Nuclear Regulatory Commission; (ix) the Federal Energy Regulatory 

Commission; (x) the Office of the United States Attorney for the Northern District of California; (xi) 

counsel for the agent under the Debtors’ debtor in possession financing facility; (xii) the Consenting 

Fire Claimant Professionals; (xiii) counsel for the Shareholder Proponents; and (xiv) those persons 

who have formally appeared in these Chapter 11 Cases and requested service pursuant to Bankruptcy 

Rule 2002. The Debtors respectfully submit that no further notice is required. 

No previous request for the relief sought herein has been made by the Debtors to this 

or any other court. 

Case: 19-30088 Doc# 5040 Filed: 12/09/19 Entered: 12/09/19 18:03:02 Page 5 of

6
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

WHEREFORE the Debtors respectfully request entry of the Proposed Order granting 

the relief requested herein and such other and further relief as the Court may deem just and appropriate. 

Dated: December 9, 2019 

 WEIL, GOTSHAL & MANGES LLP 

 CRAVATH SWAINE & MOORE LLP 

 KELLER & BENVENUTTI LLP 

/s/ Jessica Liou

 Jessica Liou

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 5040 Filed: 12/09/19 Entered: 12/09/19 18:03:02 Page 6 of

6