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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 7, 2019

Time: 9:30 a.m. 

Place: Courtroom 17, 16th Floor 

450 Golden Gate Avenue 

San Francisco, California 

DKT # 3940

SUPPLEMENT TO JOINDER BY TURN IN JOINT MOTION OF THE 

OFFICIAL COMMITTEE OF TORT CLAIMANTS AND AD HOC COMMITTEE OF 

SENIOR UNSECURED NOTEHOLDERS TO TERMINATE THE 

DEBTORS’ EXCLUSIVE PERIODS PURSUANT TO SECTION 1121(d)(1) 

OF THE BANKRUPTCY CODE

Case: 19-30088 Doc# 4048 Filed: 10/01/19 Entered: 10/01/19 15:26:55 Page 1 of

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The Utility Reform Network (“TURN”) previously joined in the Joint Motion of the Official 

Committee of Tort Claimants and Ad Hoc Committee of Senior Unsecured Noteholders to 

Terminate Debtors’ Exclusive Periods Pursuant to Section 1121(d)(1) of the Bankruptcy Code [Dkt. 

#3940] (the “Joint Motion”). The CPUC has now formally approved the OII that TURN referenced 

in its previous Joinder pleading.

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TURN is filing this Supplement to focus the parties and Court on paragraph 2(c) of the OII: 

the obligation of CPUC to find pursuant to AB 1054 that the “... plan is neutral, on average, to

PG&E’s ratepayers; and ... recognizes the contributions of PG&E’s ratepayers, if any, to resolving 

the insolvency proceeding and compensates them accordingly through mechanisms approved by the 

Commission.”

The Debtors’ plan will not be approved by CPUC if it cannot meet the requirements of AB 

1054 and may therefore be incapable of confirmation by this Court because it will not have met the 

requirement to comply with Bankruptcy Code section 1129(a)(6). 

TURN believes that the best way to ensure that the Debtors meet the requirements of AB 

1054 would be to terminate exclusivity and allow competing plans to move forward. Competition

among plans will provide different alternatives for achieving the required compliance with AB 1054, 

which will better inform the CPUC’s required determinations under that statute and increase the 

likelihood of adoption of the best plan under the circumstances. 

Dated: October 1, 2019 BINDER & MALTER, LLP

By: /s/ Robert G. Harris

Robert G. Harris

Attorneys for TURN, the Utility Reform Network

 

1 Order Instituting Investigation on the Commission's Own Motion to Consider the Ratemaking and 

Other Implications of a Proposed Plan for Resolution of Voluntary Case filed by Pacific Gas and 

Electric Company Pursuant to Chapter 11 of the Bankruptcy Code, in the United States Bankruptcy 

Court, Northern District of California, San Francisco Division, In re Pacific Gas and Electric 

Corporation and Pacific Gas and Electric Company, Case No. 19-30088 (the “OII”).

Case: 19-30088 Doc# 4048 Filed: 10/01/19 Entered: 10/01/19 15:26:55 Page 2 of

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