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Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice) 

MILBANK LLP 

55 Hudson Yards 

New York, New York 10001-2163 

Telephone: (212) 530-5000 

Facsimile: (212) 530-5219 

and 

Gregory A. Bray (SBN 115367) 

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor 

Los Angeles, CA 90067 

Telephone: (424) 386-4000 

Facsimile: (213) 629-5063 

Counsel for the Official Committee 

of Unsecured Creditors

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

 -andPACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors.

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered)

☐ 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) 

JOINDER OF OFFICIAL COMMITTEE 

OF UNSECURED CREDITORS TO EX 

PARTE MOTION OF DEBTORS FOR 

ORDER CONTINUING THE HEARING 

ON THE MOTIONS OF THE OFFICIAL 

COMMITTEE OF TORT CLAIMANTS 

AND THE AD HOC GROUP OF 

SUBROGATION CLAIM HOLDERS FOR 

RELIEF FROM AUTOMATIC STAY 

Related Documents: Dkt. No. 3111 

[No hearing requested] 

Case: 19-30088 Doc# 3115 Filed: 07/21/19 Entered: 07/21/19 12:12:41 Page 1 of

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The Official Committee of Unsecured Creditors (the “Official Committee”) appointed in 

the above-captioned chapter 11 cases, by its attorneys, Milbank LLP, hereby submits this joinder 

to the Ex Parte Motion of Debtors for Order Continuing the Hearing on the Motions of the 

Official Committee of Tort Claimants and the Ad Hoc Group of Subrogation Claim Holders for 

Relief from the Automatic Stay [Docket No. 3111] (the “Motion for Continuance”),1 and 

respectfully states as follows: 

1. On July 2 and 3, 2019, the TCC and Ad Hoc Subrogation Group filed the Stay 

Relief Motions, which seek relief from the automatic stay to request permission for certain 

Tubbs wildfire cases to proceed in California Superior Court on the issue of causation [Docket 

Nos. 2842, 2863].2

 

2. On July 18, 2019, the Debtors filed the Estimation Motion, which contemplates 

that a hearing on proposed claims estimation procedures will be held on August 14, 2019. 

3. As stated in its opposition to the Stay Relief Motions (the “Opposition”) [Docket 

No. 3101], the Official Committee believes that a centralized claims estimation proceeding is a 

superior alternative to the relief requested in the Stay Relief Motions. 

4. Following the Official Committee’s filing of its Opposition, the Debtors filed the 

Motion for Continuance, seeking to continue the hearing on the Stay Relief Motions until the 

August 14 hearing on the Estimation Motion. The Debtors note that the Stay Relief Motions and 

the Estimation Motion present “competing proposals” on how to address the issue of “the 

Debtors’ liability (if any) for the Tubbs fire.” Motion for Continuance at 6:5-7. 

5. The Official Committee agrees with the Debtors that resolution of these 

“competing proposals” should be addressed together at a single hearing. In order to allow time 

for discussion of the appropriate claims estimation procedures in these cases, the Official 

Committee joins in the Motion for Continuance. 

 

1

 Capitalized terms not defined herein have the meanings ascribed to them in the Motion for Continuance. 

2

 The TCC filed an amended form of its motion on July 9, 2019 [Docket No. 2904]. 

Case: 19-30088 Doc# 3115 Filed: 07/21/19 Entered: 07/21/19 12:12:41 Page 2 of

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DATED: July 21, 2019 MILBANK LLP 

 /s/ Gregory A. Bray 

DENNIS F. DUNNE 

SAMUEL A. KHALIL 

GREGORY A. BRAY 

THOMAS R. KRELLER 

Counsel for the Official Committee of Unsecured 

Creditors

Case: 19-30088 Doc# 3115 Filed: 07/21/19 Entered: 07/21/19 12:12:41 Page 3 of

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