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Simpson Thacher & Bartlett LLP

425 Lexington Ave

New York, NY 10017

Jonathan Sanders (No. 228785)

SIMPSON THACHER & BARTLETT LLP

2475 Hanover Street 

Palo Alto, CA 94304

Telephone: (650) 251-5000

Facsimile: (650) 251-5002

Michael H. Torkin

Nicholas Goldin

Kathrine A. McLendon

Jamie J. Fell 

SIMPSON THACHER & BARTLETT LLP

425 Lexington Avenue

New York, NY 10017

Telephone: (212) 455-2000

Facsimile: (212) 455-2502

Counsel for the Board of Each of PG&E Corporation and 

Pacific Gas and Electric Company and for Certain

Current and Former Independent Directors

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

 In re:

 PG&E CORPORATION,

- and –

 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).

Bankruptcy Case 

No. 19-30088 (DM)

Chapter 11

(Lead Case)

(Jointly Administered)

CERTIFICATE OF NO OBJECTION 

REGARDING SIXTH MONTHLY FEE 

STATEMENT OF SIMPSON THACHER 

& BARTLETT FOR ALLOWANCE AND 

PAYMENT OF COMPENSATION AND 

REIMBURSEMENT OF EXPENSES FOR 

THE PERIOD OF SEPTEMBER 1, 2019 

THROUGH SEPTEMBER 30, 2019

Re: Docket No. 4892

Objection Deadline: December 18, 2019 at 

4:00 p.m. (Pacific Time) 

Case: 19-30088 Doc# 5234 Filed: 12/31/19 Entered: 12/31/19 11:19:34 Page 1 of

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Simpson Thacher & Bartlett LLP

425 Lexington Ave

New York, NY 10017

On November 27, 2019, Simpson Thacher & Bartlett LLP (“Simpson Thacher”), 

counsel for (i) the Board of Directors (the “Board”) of each of PG&E Corporation and Pacific 

Gas and Electric Company (the “Debtors”), as the Board may be constituted from time to time, 

and for the members of the Board from time to time in their capacities as members of the Board, 

and (ii) certain current and former independent directors in their individual capacities who serve 

or served as independent directors prior to and/or as of the Petition Date (as defined below) (each 

an “Independent Director” and collectively, the “Independent Directors”), filed its Sixth 

Monthly Fee Statement of Simpson Thacher & Bartlett LLP for Allowance and Payment of 

Compensation and Reimbursement of Expenses for the Period September 1, 2019 through 

September 30, 2019 [Docket No. 4892], pursuant to the Order Pursuant to 11 U.S.C. §§ 331 and 

105(a) and Fed. R. Bankr. P. 2016 for Authority to Establish Procedures for Interim 

Compensation and Reimbursement of Expenses of Professionals, dated February 27, 2019 

[Docket No. 701] (the “Interim Procedures Order”).

The Sixth Monthly Fee Statement was served as described in the Certificate of Service of 

Alain B. Francoeur [Docket No. 4969]. The deadline to file responses or oppositions to the Sixth 

Monthly Fee Statement was December 18, 2019 at 4:00 pm (PT). On December 18, a limited 

objection was filed by the Public Employees Retirement Association of New Mexico objecting 

to a portion of Simpson Thacher’s fees totaling $380,184.50 [Docket No. 5158] (the “PERA 

Objection”).1

 No other oppositions or responses have been filed with the Court or received by 

Simpson Thacher. Pursuant to the Interim Compensation Order, the Debtors are authorized to 

pay Simpson Thacher eighty percent (80%) of the remaining fees that are not subject to an 

objection and one hundred percent (100%) of the expenses requested in the Sixth Monthly Fee 

Statement upon the filing of this certification without the need for a further order of the Court. A 

summary of the fees and expenses sought by Simpson Thacher is annexed hereto as Exhibit A.

 1 Simpson Thacher does not agree with the assertions made in the PERA Objection and reserves all rights to dispute 

the PERA Objection, and any future objections made on similar grounds, either before or in connection with any 

hearing to consider the applicable interim fee applications.

Case: 19-30088 Doc# 5234 Filed: 12/31/19 Entered: 12/31/19 11:19:34 Page 2 of

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Simpson Thacher & Bartlett LLP

425 Lexington Ave

New York, NY 10017

The undersigned hereby declares, pursuant to 28 U.S.C. § 1746, under penalty of perjury, 

that: 

1. I am a counsel at the law firm Simpson Thacher & Bartlett LLP, counsel to the 

Board and the Independent Directors. 

2. I certify that I have reviewed or caused the review of the Court’s docket in these 

chapter 11 cases and that Simpson Thacher has not received any response or opposition to the 

Sixth Monthly Fee Statement other than the PERA Objection. 

3. This declaration was executed in Palo Alto, California.

Dated: December 31, 2019

SIMPSON THACHER & BARTLETT LLP

Palo Alto, California

/s/ Jonathan C. Sanders

Jonathan C. Sanders (No. 228785)

Counsel for the Board of Each of PG&E 

Corporation and Pacific Gas and Electric 

Company and for Certain Current and Former 

Independent Directors

Case: 19-30088 Doc# 5234 Filed: 12/31/19 Entered: 12/31/19 11:19:34 Page 3 of

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