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

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 - 

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

SECOND STIPULATION BETWEEN THE 

DEBTORS AND THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

EXTENDING TIME TO RESPOND TO 

THE TORT CLAIMANTS 

COMMITTEE’S MOTION TO EXTEND 

THE BAR DATE 

Re: Dkt. No. 4292 

[No Hearing Requested]

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) 

 

Case: 19-30088 Doc# 4613 Filed: 11/08/19 Entered: 11/08/19 09:47:58 Page 1 of

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

This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

debtors in possession (collectively, the “Debtors”), on the one hand, and the Official Committee 

of Tort Claimants (“Tort Claimants Committee”), on the other hand. The Debtors and the Tort 

Claimants Committee are referred to in this Stipulation and Agreement for Order collectively as 

the “Parties,” and each as a “Party.” The Parties hereby stipulate and agree as follows: 

RECITALS 

A. On October 18, 2019, the Tort Claimants Committee filed the Motion of the 

Official Committee of Tort Claimants Pursuant to 11 U.S.C. §§ 105 and 501 and Fed. R. Bankr. 

P. 3003(c) for Entry of an Order Extending the Bar Date [Dkt. No. 4292] (the “TCC Bar Date 

Extension Motion”), which is set for a hearing before the Court at 10:00 a.m. on November 13, 

2019. Any response or opposition to the TCC Bar Date Extension Motion was due by 4:00 p.m. 

(Pacific Time) on November 6, 2019. 

B. The Parties previously entered into the Stipulation Between the Debtors and the 

Tort Claimants Committee Extending Time to Respond to the Tort Claimants Committee’s 

Motion to Extend the Bar Date (“First Stipulation”), filed on November 4, 2019 [Docket 

No. 4565], requesting that the time for the Debtors to respond to the TCC Bar Date Extension 

Motion be extended to 4:00 p.m. (Pacific Time) on November 8, 2019. An order approving the 

First Stipulation was entered on November 6, 2019 [Docket No. 4585]. 

C. Counsel for the Debtors has requested, and counsel for the Tort Claimants 

Committee has agreed, that the time for Debtors to respond to the TCC Bar Date Extension 

Motion be further extended. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS 

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

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

THAT:

Case: 19-30088 Doc# 4613 Filed: 11/08/19 Entered: 11/08/19 09:47:58 Page 2 of

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

1. The time for the Debtors to file and serve any response or opposition to the TCC 

Bar Date Extension Motion is extended through 4:00 p.m. (Pacific Time) on November 11, 2019. 

Dated: November 8, 2019 Dated: November 8, 2019

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

BAKER HOSTETLER LLP 

 

/s/ Thomas B. Rupp /s/ David J. Richardson

Thomas B. Rupp

Attorneys for Debtors 

and Debtors in Possession

David J. Richardson

Attorneys for Official Committee of Tort 

Claimants 

Case: 19-30088 Doc# 4613 Filed: 11/08/19 Entered: 11/08/19 09:47:58 Page 3 of

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