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

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WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock, P.C. 

(ray.schrock@weil.com) (pro hac vice) 

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 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

Related Docket Ref: 4540, 4886, 4893, and 

4897 

STIPULATION AMENDING ORDER 

ESTABLISHING PRECONFIRMATION 

BRIEFING AND HEARING SCHEDULE 

FOR CERTAIN LEGAL ISSUES 

[No Hearing Date 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# 5254 Filed: 01/03/20 Entered: 01/03/20 11:32:51 Page 1 of

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

possession (collectively, the “Debtors”) in the above-captioned chapter 11 cases (the “Chapter 11 

Cases”), the Ad Hoc Group of Subrogation Claimholders (the “Ad Hoc Group”), and the Official 

Committee of Unsecured Creditors (the “UCC”), by and through their respective counsel, hereby 

submit this stipulation (the “Stipulation”) for an Order approving their agreement to amend and 

revise the Court’s Order Establishing Pre-Confirmation Briefing and Hearing Schedule for Certain 

Legal Issues, dated October 31, 2019 [Docket No. 4540] (the “Scheduling Order1”), solely with 

respect to the briefing and oral argument for the Subrogation Claim Impairment Issue (Section V 

of the Scheduling Order), and represent and agree as follows: 

RECITALS 

A. On January 29, 2019, the Debtors commenced the Chapter 11 Cases in the 

United States Bankruptcy Court for the Northern District of California (the “Bankruptcy Court”). 

B. On October 31, 2019, the Bankruptcy Court entered the Scheduling Order, 

which, among other things, scheduled the oral argument on the Subrogation Claim Impairment 

Issue for the hearing on January 14, 2020 at 10:00 a.m. (Prevailing Pacific Time) and set the 

following related briefing schedule: (i) consolidated opening briefs to be filed on or before 

November 27, 2019 (with briefs not to exceed 25 pages for each side); and (ii) consolidated 

opposition briefs to be filed on or before December 20, 2019 (with briefs not to exceed 25 pages 

for each side). 

C. On November 27, 2019, the Debtors and the Ad Hoc Group timely filed their 

consolidated opening brief in accordance with the Scheduling Order [Docket No. 4886] (the 

“Debtors/Ad Hoc Opening Brief”). 

D. Also on November 27, 2019, the UCC and the Ad Hoc Committee of Senior 

Unsecured Noteholders of the Utility (the “Ad Hoc Committee”),2 each timely filed statements 

1

 Capitalized terms used but not otherwise herein defined have the meanings ascribed to such terms 

in the Scheduling Order. 

2

 The Ad Hoc Committee is not a party to this Stipulation, but by the Order approving this 

Stipulation, the briefing schedule set forth herein shall apply to the Ad Hoc Committee as well. 

Case: 19-30088 Doc# 5254 Filed: 01/03/20 Entered: 01/03/20 11:32:51 Page 2 of

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[Docket Nos. 4893 and 4897], among other things, reserving their rights to brief the Subrogation 

Claim Impairment Issue after the Court rules 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 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 Claim Amount, and (iii) Granting Related Relief

[Docket No. 3992] (the “Subrogation RSA Motion”). 

E. At the omnibus hearing on December 17, 2019, the Court, among other 

things, approved the Subrogation RSA Motion and directed the parties to meet and confer on a 

revised briefing and oral argument schedule with respect to the Subrogation Claim Impairment 

Issue. 

F. Accordingly, the parties have agreed on a revised briefing and oral argument 

schedule with respect to the Subrogation Claim Impairment Issue as set forth herein. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, IT IS HEREBY 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, THAT: 

1. The briefing schedule for the Subrogation Claim Impairment Issue shall be 

revised as follows: 

a. The UCC and Ad Hoc Committee may file a consolidated opposition 

brief to the Debtors/Ad Hoc Group Opening Brief, not to exceed 25 

pages (the “UCC/Ad Hoc Committee Opposition Brief”), no later 

than January 10, 2020 at 4:00 p.m. (Prevailing Pacific Time). 

b. The Debtors and Ad Hoc Subrogation Group may file a consolidated 

reply to the UCC/Ad Hoc Committee Opposition Brief, not to exceed 

25 pages, no later than January 22, 2020 at 4:00 p.m. (Prevailing 

Pacific Time). 

c. The hearing before the Bankruptcy Court on the Subrogation Claim 

Impairment Issue shall be held on January 29, 2020 at 10:00 a.m. 

(Prevailing Pacific Time), subject to the availability of the 

Bankruptcy Court. 

Case: 19-30088 Doc# 5254 Filed: 01/03/20 Entered: 01/03/20 11:32:51 Page 3 of

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2. Except as expressly set forth herein, all other provisions of the Scheduling 

Order shall remain in full force and effect and shall not be impacted by this Stipulation. 

3. This Stipulation shall constitute the entire agreement and understanding of 

the parties relating to the subject matter hereof and shall supersede all prior agreements and 

understandings relating to the subject matter hereof. 

4. This Stipulation may be executed in counterparts, each of which shall be 

deemed an original but all of which together shall constitute one and the same agreement. 

5. The Bankruptcy Court shall retain jurisdiction to resolve any disputes or 

controversies arising from this Stipulation. 

DATED: January 3, 2020 

/s/ Matthew Goren 

WEIL, GOTSHAL & MANGES LLP 

767 Fifth Avenue 

New York, NY 10153-0119 

Stephen Karotkin, Esq. 

Ray C. Schrock, P.C. 

Jessica Liou, Esq. 

Matthew Goren, Esq. 

Attorneys for Debtors 

and Debtors in Possession 

DATED: January 3, 2020 

/s/ Thomas R. Kreller 

MILBANK LLP 

55 Hudson Yards 

New York, New York 10001-2163 

Dennis F. Dunne, Esq. 

Samuel A. Kahlil, Esq. 

Gregory A. Bray, Esq. 

Thomas R. Kreller, Esq. 

Attorneys for the Official Committee of 

Unsecured Creditors 

DATED: January 3, 2020 

/s/ Matthew A. Feldman 

WILLKIE FARR & GALLAGHER LLP 

787 Seventh Avenue 

New York, New York 10019-6099 

Matthew A. Feldman, Esq. 

Joseph G Minias Esq. 

Benjamin P. McCallen Esq. 

Daniel I. Foreman Esq. 

Attorneys for the Ad Hoc Group of 

Subrogation Claim Holders

Case: 19-30088 Doc# 5254 Filed: 01/03/20 Entered: 01/03/20 11:32:51 Page 4 of

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