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STIPULATION TO EXTEND TIME FOR AD HOC

BONDHOLDER GROUP TO RESPOND TO MOTIONS 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) 

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 

Proposed 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) 

STIPULATION BETWEEN DEBTORS 

AND AD HOC GROUP OF 

INSTITUTIONAL BONDHOLDERS OF 

PACIFIC GAS AND ELECTRIC CO.

EXTENDING TIME TO RESPOND TO 

MOTIONS TO BE HEARD ON 

FEBRUARY 27, 2019 

[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# 498 Filed: 02/20/19 Entered: 02/20/19 13:30:52 Page 1 of 3
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STIPULATION TO EXTEND TIME FOR AD HOC

BONDHOLDER GROUP TO RESPOND TO MOTIONS PG&E, CASE NO. 19-30088 

- 2 - 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 and between PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric 

Company (the “Utility”), as debtors and debtors in possession (collectively, the “Debtors”) and 

the Ad Hoc Group of Institutional Bondholders of Pacific Gas and Electric Co. (the “Ad Hoc 

Group of Institutional Bondholders”). The Debtors and the Ad Hoc Group of Institutional 

Bondholders 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 February 6, 2019, the Debtors filed a notice of hearing [Dkt. 353] noticing 

sixteen (16) motions listed therein (the “Motions”) for a hearing before the Court at 9:30 a.m. on 

February 27, 2019. 

B. Under Local Bankruptcy Rule 9014-1(c)(2), any opposition or response to the 

Motions must be filed and served on counsel for the Debtors no later than February 20, 2019. 

C. On February 20, 2019, counsel for the Ad Hoc Group of Institutional Bondholders 

requested, and proposed counsel for the Debtors agreed, that the time for the Ad Hoc Group of 

Institutional Bondholders to respond to the Motions be extended by two days. 

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:

1. The time for the Ad Hoc Group of Institutional Bondholders to file and 

serve any response or opposition to the Motions be extended up to and including 4:00 p.m. (Pacific 

Standard Time) on February 22, 2019. 

[Signatures on Next Page] 

 

Case: 19-30088 Doc# 498 Filed: 02/20/19 Entered: 02/20/19 13:30:52 Page 2 of 3
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STIPULATION TO EXTEND TIME FOR AD HOC

BONDHOLDER GROUP TO RESPOND TO MOTIONS PG&E, CASE NO. 19-30088 

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

Dated: February 20, 2019 Dated: February 20, 2019

KELLER & BENVENUTTI LLP PROSKAUER ROSE LLP 

/s/ Jane Kim /s/ Brian S. Rosen

Jane Kim

Proposed Attorneys for Debtors 

and Debtors in Possession

Brian S. Rosen

 

Attorneys for Ad Hoc Group of 

Institutional Bondholders of Pacific Gas 

and Electric Company 

Case: 19-30088 Doc# 498 Filed: 02/20/19 Entered: 02/20/19 13:30:52 Page 3 of 3