1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

DAVID B. LEVANT (pro hac vice) 

david.levant@stoel.com

ANDREW H. MORTON (pro hac vice) 

andrew.morton@stoel.com

JENNIFER L. MERSING (pro hac vice) 

jennifer.mersing@stoel.com

JENNIFER N. SLOCUM (pro hac vice) 

jennifer.slocum@stoel.com

STOEL RIVES LLP

600 University Street, Suite 3600 

Seattle, WA 98101 

Telephone: 206.624.0900 

Facsimile: 206.386.7500

SETH D. HILTON (SBN 181899) 

seth.hilton@stoel.com

SARAH E. KOZAL (SBN 313043) 

sarah.kozal@stoel.com

BAO M. VU (SBN 277970) 

bao.vu@stoel.com

STOEL RIVES LLP

3 Embarcadero Center, Suite 1120 

San Francisco, CA 94111 

Telephone: 415.617.8900 

Facsimile: 415.617.8907

Attorneys for the Ad Hoc Group of 

Interconnection Customers

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)

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

VERIFIED STATEMENT OF 

STOEL RIVES LLP PURSUANT TO 

FEDERAL RULE OF BANKRUPTCY 

PROCEDURE 2019 

Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure, the Ad Hoc Group of 

Interconnection Customers of Pacific Gas and Electric Company (the “Ad Hoc Group of 

Interconnection Customers”), by and through its undersigned counsel, hereby submit this verified 

statement (this “Statement”), and in support thereof, state as follows: 

Case: 19-30088 Doc# 4399 Filed: 10/22/19 Entered: 10/22/19 22:18:21 Page 1 of

4
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

1. In or around August 2019, the Ad Hoc Group of Interconnection Customers engaged 

Stoel Rives LLP (“Stoel Rives”) to represent it in connection with certain Pass-Through Amounts 

being withheld Pacific Gas and Electric Company (the “Utility”, and together with PG&E 

Corporation, the “Debtors”). 

2. As of the date of this Statement, Stoel Rives represents numerous other parties in 

the Utility’s chapter 11 proceeding, in addition to the Ad Hoc Group of Interconnection Customers. 

The members of the Ad Hoc Group of Interconnection Customers have each retained Stoel Rives 

to represent them with respect to the administration and enforcement of their respective claims and 

interests in connection with the Debtors’ chapter 11 cases. Each client has been informed of and 

has consented to concurrent representation by Stoel Rives. 

3. In accordance with Bankruptcy Rule 2019, a list of the names, addresses and the 

“nature and amount of all disclosable economic interests” held in relation to the Debtors as of 

October 22, 2019, by each member of the Ad Hoc Group of Interconnection Customers follows: 

Name & Address of Creditor Nature of Claim Claim Amount1

CA Flats 130, LLC 

10 East 53rd Street, 17th Floor 

New York, NY 10022 

CA Flats 150, LLC 

10 East 53rd Street, 17th Floor 

New York, NY 10022 

Network Upgrade Reimbursements To be determined2

CA Flats 150, LLC 

10 East 53rd Street, 17th Floor 

New York, NY 10022 

Test Period Payment $274,159.67 

 

1

 The claim amounts for Network Upgrade Reimbursements are subject to interest at the regulated rate. The 

Network Upgrade Reimbursements are to be paid according to a schedule specific to each Interconnection 

Customer, with payments generally becoming due each financial quarter. Therefore, these amounts represent 

only a baseline amount that is currently owed as of the date of this filing, subject to amendment as more 

payments become due. 

2

 The Utility asserts that its obligations to begin making payments to these two members did not commence 

until after the Cal Flats 150 Project achieved commercial operation in March 2019, notwithstanding that the 

Cal Flats 130 Project had achieved commercial operation in November 2017. CA Flats 130, LLC believes it 

is entitled to $7,800,000 of payments over a five year period that should have already begun following its 

project’s commercial operation date, plus interest in the amount of at least $1,447,311.88. CA Flats 150, 

LLC believes it is entitled to $9,000,000 of payments over a five year period from its project’s commercial 

operation date, plus interest in the amount of at least $1,669,975.25. 

Case: 19-30088 Doc# 4399 Filed: 10/22/19 Entered: 10/22/19 22:18:21 Page 2 of

4
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Name & Address of Creditor Nature of Claim Claim Amount1

Solar Star California XIII, LLC 

10 East 53rd Street, 17th Floor 

New York, NY 10022 

Network Upgrade Reimbursements $6,000,000.00 

67RK 8me LLC 

c/o FTP Power LLC 

2180 South 1300 East, Suite 600 

Salt Lake City, Utah 84106 

65HK 8me LLC 

c/o FTP Power LLC 

2180 South 1300 East, Suite 600 

Salt Lake City, Utah 84106 

87RL 8me LLC 

c/o FTP Power LLC 

2180 South 1300 East, Suite 600 

Salt Lake City, Utah 84106 

Network Upgrade Reimbursements $462,171.42 

Adera Solar, LLC 

c/o FTP Power LLC 

2180 South 1300 East, Suite 600 

Salt Lake City, Utah 84106 

Network Upgrade Reimbursements $219,150.00 

RE Mustang LLC 

200 West St., 3rd Floor 

New York, NY 10282 

RE Mustang 3 LLC 

200 West St., 3rd Floor 

New York, NY 10282 

RE Mustang 4 LLC 

200 West St., 3rd Floor 

New York, NY 10282 

Network Upgrade Reimbursements $3,514,185.93 

4. As of the date hereof, Stoel Rives does not hold a claim against any of the Debtors 

or any interest in any of the Debtors. 

5. The information set forth in this Statement, which is based on information provided 

by the applicable members of the Ad Hoc Group of Interconnection Customers, is intended only to 

comply with Bankruptcy Rule 2019 and is not intended for any other purpose. 

Case: 19-30088 Doc# 4399 Filed: 10/22/19 Entered: 10/22/19 22:18:21 Page 3 of

4
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

6. Stoel Rives reserves the right to revise and supplement this verified statement in 

accordance with the requirements set forth in Bankruptcy Rule 2019 to the extent required and will 

obtain additional consents as necessary. 

7. Nothing contained in this Statement should be construed as a limitation upon, or 

waiver of, any rights of any member of the Ad Hoc Group of Interconnection Customers to assert, 

file, or amend their claims in accordance with applicable law and any orders entered in these chapter 

11 cases. 

The undersigned verifies under oath that the foregoing statement is true and accurate, to the 

best of the undersigned’s knowledge and belief. 

DATED: October 22, 2019. 

STOEL RIVES LLP 

/s/ David B. Levant 

David B. Levant (pro hac vice) 

Andrew H. Morton (pro hac vice) 

Jennifer L. Mersing (pro hac vice) 

Jennifer N. Slocum (pro hac vice) 

Stoel Rives LLP 

600 University Street, Suite 3600 

Seattle, WA 98101 

206.624.0900 

david.levant@stoel.com

Attorneys for Ad Hoc Group of 

Interconnection Customers 

Case: 19-30088 Doc# 4399 Filed: 10/22/19 Entered: 10/22/19 22:18:21 Page 4 of

4