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04392-00007/11176592.5

Case No. 19-30088 (DM)

TITLE

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

 Bennett Murphy (Bar No. 174536) 

 bennettmurphy@quinnemanuel.com 

865 South Figueroa Street, 10th Floor 

Los Angeles, CA 90017-2543 

Telephone: (213) 443-3000 

Facsimile: (213) 443-3100 

Attorneys for Canyon Capital Advisors LLC

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

-andPACIFIC 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)

Case No. 19-30088 (DM) 

Chapter 11 

(Jointly Administered)

JOINDER IN CONSOLIDATED 

OPENING BRIEF OF THE OFFICIAL 

COMMITTEE OF UNSECURED 

CREDITORS AND OTHER CREDITOR 

GROUPS AND REPRESENTATIVES 

REGARDING THE APPROPRIATE 

POSTPETITION INTEREST RATE 

PAYABLE ON UNSECURED CLAIMS IN 

A SOLVENT DEBTOR CASE 

Date: December 11, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 450 Golden Gate Avenue 

 San Francisco, CA 94102

Case: 19-30088 Doc# 4636 Filed: 11/08/19 Entered: 11/08/19 18:25:12 Page 1 of

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04392-00007/11176592.5

1 Case No. 19-30088 (DM)

TITLE

Canyon Capital Advisors LLC, acting on behalf of its managed funds and accounts 

(“Canyon”), hereby submits this joinder in the Consolidated Opening Brief of the Official 

Committee of Unsecured Creditors and Other Creditor Groups and Representatives Regarding the 

Appropriate Postpetition Interest Rate Payable on Unsecured Claims in a Solvent Debtor Case 

[Docket No. 4634] (the “Consolidated Creditor Brief”). Canyon is a substantial creditor in these 

cases.1

The Debtors propose that equity holders should retain their interests in the Debtors, while 

holders of claims in senior classes are denied the right to vote to accept or reject the Debtors’ Plan. 

The Debtors’ premise for this – that the senior creditor claims are unimpaired – is simply untrue. 

The Debtors’ Plan fails to “leave unaltered the legal, equitable, and contractual rights to which 

such claim . . entitles the holder of such claim . . ..” 11 U.S.C § 1124(1) (emphasis added). The 

Debtors’ Plan alters a right to which Canyon and like creditors are entitled: to receive interest at 

the applicable contract rate, and no other rate, through the date the Debtors’ obligations are paid in 

full. For the reasons set forth in the Consolidated Creditor Brief, Section 1124(1) of the 

Bankruptcy Code means what it says. The Debtors’ designation of senior creditor claims as 

unimpaired is contrary to law, and cannot be sustained. 

DATED: November 8, 2019 QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

By s/ Bennett Murphy 

 Bennett Murphy 

Attorneys for Canyon Capital Advisors LLC 

 

1

 Canyon has claims as a holder of Utility Senior Notes, as a lender under each of the Utility 

Revolver Credit Agreement; the HoldCo Revolver Credit Agreement, and the HoldCo Term Loan 

Credit Agreement, and under one or more of the PC Bond LOC Documents (each as defined in the 

Debtors’ Joint Chapter 11 Plan of Reorganization Dated November 4, 2019 (the “Debtors’ Plan”)).

Case: 19-30088 Doc# 4636 Filed: 11/08/19 Entered: 11/08/19 18:25:12 Page 2 of

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