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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) 

Theodore Tsekerides (pro hac vice) 

(theodore.tsekerides@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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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) 

STIPULATION BETWEEN DEBTOR 

PACIFIC GAS AND ELECTRIC 

COMPANY AND RUCKMAN AND LEAL 

MOVANTS FOR LIMITED RELIEF 

FROM THE AUTOMATIC STAY 

[Relates to Dkt. Nos. 4491-4496] 

[Resolving Motion Set for Hearing 

November 19, 2019 at 10:00 am] 

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# 4683 Filed: 11/12/19 Entered: 11/12/19 15:13:47 Page 1 of

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

This stipulation (the “Stipulation”) is entered into by and between Pacific Gas and Electric 

Company (the “Utility” or the “Debtor”), as debtor and debtor in possession, and movants Gloria 

Ruckman, Robert Ruckman, a minor by and through his guardian ad litem Robert Ruckman, 

Robert Ruckman, Amalia Leal, and Gilardo Leal (the “Movants”). The Debtor and the Movants 

are referred to in this Stipulation collectively as the “Parties,” and each as a “Party.” The Parties 

hereby stipulate and agree as follows: 

RECITALS 

A. On October 28, 2019, the Movants filed the Motion to Abstain and for Relief from 

the Automatic Stay to Permit Lawsuit to Proceed to Trial and Conclusion [Dkt. 4491] (the 

“Motion”). 

B. Movants seek relief from the automatic stay to prosecute their personal injury 

claims against the Utility in Ruckman v. Big N Deep Ag Development Co., Case No. BCV-15-

101699-SDS (the “State Court Action”) pending in the Superior Court of California, County of 

Kern (the “State Court”). 

C. The State Court Action arises out of injuries and property damage that Movants 

suffered resulting from a November 13, 2015 explosion caused by an agricultural excavator with 

an expired permit striking one of the Utility’s gas lines. 

D. The Movants filed the State Court Action on December 16, 2015. The Utility 

served its answer on February 8, 2016. The operative Third Amended Complaint (the “TAC”) 

was filed on March 7, 2017. The State Court Action was set for jury trial on June 17, 2019. 

E. The Debtor and its parent, PG&E Corporation (collectively the “Debtors”), filed 

these Chapter 11 Cases on January 29, 2019 (the “Petition Date”). 

F. The Utility filed a Notice of Stay of Proceedings in the State Court Action on 

February 5, 2019; on that date, the State Court stayed the State Court Action in its entirety as to 

all parties and all consolidated action. The automatic stay applicable to the State Court Action has 

remained in effect as to the Debtors since the Petition Date. The State Court’s stay of the entire 

action remains in effect. 

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 NOW, THEREFORE, 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. This Stipulation shall be effective upon entry of an order by this Court 

approving it. 

2. The hearing on the Motion (the “Hearing”) shall be continued for 

approximately three months, and shall be rescheduled for the next omnibus hearing date on or after 

February 19, 2020. The Movants shall file a Notice of Continued Hearing to that effect promptly 

after dates are set for omnibus hearings in February. 

3. The automatic stay shall immediately be modified solely as follows: 

a. To permit the Parties to participate in a mediation to attempt to 

globally resolve the claims against the Utility and its co-defendants 

alleged in the State Court Action (the “Mediation”). The Parties 

shall use their best efforts to schedule the Mediation as promptly as 

possible. If fewer than all parties to the State Court Action agree to 

participate, the Mediation shall nevertheless proceed between 

Movants, the Utility, and other parties that wish to participate. 

b. To permit counsel for the Movants to obtain and file a stipulation in 

the State Court Action among all the parties to that action (including 

the Debtor) confirming the Parties’ agreement to the proposed 

schedule laid out herein. 

c. The automatic stay shall remain in place for all other purposes. 

4. The Parties may agree in writing to one or more further continuances of the 

Hearing, without further order of the Court, by filing a notice of continuance. The limited stay 

relief provided in paragraph 3 above shall continue in effect pending the continued Hearing on the 

Motion. 

5. If the Mediation does not result in a settlement as between Utility and the 

Movants, the Hearing will go forward on the continued date, and the Debtors’ opposition to the 

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