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Heinz Binder (SBN 87908)

Robert G. Harris (SBN 124678)

BINDER & MALTER, LLP

2775 Park Avenue

Santa Clara, CA 95050

Tel: (408) 295-1700

Fax: (408) 295-1531

Email: Heinz@bindermalter.com

Email: Rob@bindermalter.com

Attorneys for TURN, The Utility Reform Network

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re

PG&E CORPORATION

and

PACIFIC GAS AND ELECTRIC 

COMPANY,

 Debtors.

Case Nos. 19-30088 DM (Lead Case)

 19-30089 DM

Chapter 11

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.

Date: October 23, 2019

Time: 10:00 a.m. 

Place: Courtroom 17

450 Golden Gate Avenue 

San Francisco, California 

DKT NO. 3992

JOINDER BY TURN IN OBJECTIONS AND OPPOSITIONS TO 

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

Case: 19-30088 Doc# 4377 Filed: 10/22/19 Entered: 10/22/19 10:08:04 Page 1 of

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 The Utility Reform Network (“TURN”) hereby joins in the following objections and 

oppositions to 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 [DKT NO. 3992]:

1. [Dkt. #4232] OPPOSITION OF OFFICIAL COMMITTEE OF TORT CLAIMANTS TO 

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 [DKT NO. 3992]

2. [Dkt. #4236] OBJECTION OF THE OFFICIAL COMMITTEE OF UNSECURED

CREDITORS TO THE DEBTORS’ SUBROGATION SETTLEMENT AND RSA 

MOTION.

3. [Dkt. #4237] OBJECTION OF THE UNITED STATES OF AMERICA TO 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

4. [Dkt. #4239] THE ADVENTIST CLAIMANTS’ OBJECTION TO 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 [DE # 3992]

5. [Dkt. #4241] OBJECTION OF THE AD HOC COMMITTEE OF SENIOR UNSECURED

NOTEHOLDERS TO DEBTORS’ MOTION TO ENTER INTO RESTRUCTURING

SUPPORT AGREEMENT WITH THE CONSENTING SUBROGATION

CLAIMHOLDERS.

Case: 19-30088 Doc# 4377 Filed: 10/22/19 Entered: 10/22/19 10:08:04 Page 2 of

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Dated: October 22, 2019 BINDER & MALTER, LLP

By: /s/ Robert G. Harris 

Robert G. Harris

 Attorneys for TURN, the Utility Reform Network 

6.

Case: 19-30088 Doc# 4377 Filed: 10/22/19 Entered: 10/22/19 10:08:04 Page 3 of

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