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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) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

767 Fifth Avenue 

New York, NY 10153-0119 

Tel: 212 310 8000 

Fax: 212 310 8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 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 -

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 (Lead Case) (Jointly Administered) 

DEBTORS’ REQUEST FOR JUDICIAL NOTICE IN 

SUPPORT OF DEBTORS’ OBJECTION TO CLASS 

REPRESENTATIVE’S MOTION TO EXTEND 

APPLICATION OF FEDERAL RULE OF CIVIL 

PROCEDURE 23 TO PROOF OF CLAIM 

Date: January 29, 2020 

Time: 10:00 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

 

 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# 5374 Filed: 01/14/20 Entered: 01/14/20 15:56:59 Page 1 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

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PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the “Utility”), as 

debtors and debtors in possession (collectively, “PG&E” or the “Debtors”) in the above-captioned 

chapter 11 cases (the “Chapter 11 Cases”), by and through its attorneys, hereby requests the Court to 

take judicial notice pursuant to Federal Rule of Evidence 201, as made applicable to this adversary 

proceeding by Bankruptcy Rule 9017, of the following facts: 

1. Attached as Exhibit A hereto is a true and correct copy of the Amended Stipulation and 

Order to Consolidate and File Third Amended Consolidated Class Action Complaint filed in In re PG&E 

Corporation Securities Litigation, Case No. 18-03509 (N.D. Cal.) (the “Securities Litigation”) on 

May 7, 2019 [Dkt. No. 117]. 

2. Attached as Exhibit B hereto is a true and correct copy of the Third Amended 

Consolidated Class Action Complaint filed on May 28, 2019 in the Securities Litigation [Dkt. No. 121]. 

3. Attached as Exhibit C hereto is a true and correct copy of the Order Denying Motion for 

Preliminary Injunction filed in PG&E Corp. v. Public Employees Retirement Association of New Mexico 

(PERA), Adv. Pro. No. 19-03039 (Bankr. N.D. Cal.) (the “PERA Adversary Proceeding”) on August 

28, 2019 [Dkt. No. 23]. 

4. Attached as Exhibit D hereto is a true and correct copy of the Stipulation and Agreement 

for Order Regarding Scheduling Only as to Public Employees Retirement Association of New Mexico 

filed in PG&E Corp. v. PERA et al., Adv. Pro. No. 19-03006 (Bankr. N.D. Cal.) (the “Non-Debtor 

Defendants Adversary Proceeding”) on April 3, 2019 [Dkt. No. 34]. 

5. Attached as Exhibit E hereto is a true and correct copy of the Stipulated Order Regarding 

Scheduling Only as to Public Employees Retirement Association of New Mexico filed in the Non-Debtor 

Defendants Adversary Proceeding on April 5, 2019 [Dkt. No. 37].

6. Attached as Exhibit F hereto is a true and correct copy of the Stipulation and Agreement 

for Order Between Debtors and the Public Employees Retirement Association of New Mexico filed in 

the Non-Debtor Defendants Adversary Proceeding on May 1, 2019 [Dkt. No. 42]. 

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767 Fifth Avenue 

New York, NY 10153-0119

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7. Attached as Exhibit G hereto is a true and correct copy of the Order Granting Stipulation 

Between Debtors and the Public Employees Retirement Association of New Mexico filed in the NonDebtor Defendants Adversary Proceeding on May 2, 2019 [Dkt. No. 44]. 

8. Attached as Exhibit H hereto is a true and correct copy of the Debtors’ Complaint for 

Preliminary and Permanent Injunctive Relief as to In re PG&E Corp. Securities Litig., 18-CV-03509 

(N.D. Cal.) filed in the PERA Adversary Proceeding on June 18, 2019 [Dkt. No. 1]. 

9. Attached as Exhibit I hereto is a true and correct copy of the Debtors’ Motion for a 

Preliminary Injunction as to In re PG&E Corp. Securities Litig., 18-CV-035059 (N.D. Cal.) and 

Memorandum of Points and Authorities in Support filed in the PERA Adversary Proceeding on June 18, 

2019 [Dkt. No. 2]. 

10. Attached as Exhibit J hereto is a true and correct copy of the Declaration of Elizabeth 

Collier in Support of Debtors’ Motion for a Preliminary Injunction as to In re PG&E Corp. Securities 

Litig., 18-CV-03509 (N.D. Cal.) filed in the PERA Adversary Proceeding on June 18, 2019 [Dkt. No. 

3]. 

11. Attached as Exhibit K hereto is a true and correct copy of the Securities Lead Plaintiff’s 

Memorandum of Points and Authorities in Opposition to Debtors’ Motion for Preliminary Injunction as 

to In re PG&E Corp. Securities Litig., 18-CV-03509 (N.D. Cal.) filed in the PERA Adversary Proceeding 

on June 18, 2019 [Dkt. No. 12]. 

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

By: /s/ Richard W. Slack Richard W. Slack 

Attorneys for Debtors 

and Debtors in Possession

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