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STIPULATION TO EXTEND TIME FOR

OCTC TO RESPOND TO MOTIONS

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

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: (415) 636-9251 

Proposed Attorneys for Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STIPULATION BETWEEN DEBTORS 

AND OFFICIAL COMMITTEE OF TORT 

CLAIMANTS EXTENDING TIME TO 

RESPOND TO MOTIONS TO BE HEARD 

ON FEBRUARY 27, 2019 

[No Hearing Requested] 

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: 19-30088 Doc# 488 Filed: 02/19/19 Entered: 02/19/19 18:43:31 Page 1 of 3
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STIPULATION TO EXTEND TIME FOR

OCTC TO RESPOND TO MOTIONS PG&E, CASE NO. 19--30088 

- 2 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by and between PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric 

Company (the “Utility”), as debtors and debtors in possession (collectively, the “Debtors”) and 

the Official Committee of Tort Claimants (the “Tort Committee”). The Debtors and the Tort 

Committee are referred to in this Stipulation and Agreement for Order collectively as the 

“Parties,” and each as a “Party.” The Parties hereby stipulate and agree as follows: 

RECITALS 

A. On February 6, 2019, the Debtors filed a notice of hearing [Dkt. 353] noticing 

sixteen (16) motions listed therein (the “Motions”) for a hearing before the Court at 9:30 a.m. on 

February 27, 2019. 

B. Under Local Bankruptcy Rule 9014-1(c)(2), any opposition or response to the 

Motions must be filed and served on counsel for the Debtors no later than February 20, 2019. 

C. The U.S. Trustee filed an Appointment of the Official Committee of Tort 

Claimants on February 15, 2019 [Dkt. 453]. 

D. Proposed Counsel to the Debtors offered to extend the time for the Tort 

Committee to respond to the Motions by two days, and the proposed Counsel to the Tort 

Committee agreed to the extension, subject to reserving the Tort Committee’s right to seek a 

further extension by stipulation with the Debtors or further order of the Court. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, 

THAT:

1. The time for the Tort Committee and to file and serve any response or 

opposition to the Motions be extended through 4:00 p.m. (Pacific Time) on February 22, 2019. 

[Signatures on Next Page] 

Case: 19-30088 Doc# 488 Filed: 02/19/19 Entered: 02/19/19 18:43:31 Page 2 of 3
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STIPULATION TO EXTEND TIME FOR

OCTC TO RESPOND TO MOTIONS PG&E, CASE NO. 19--30088 

- 3 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

Dated: February 19, 2019 Dated: February 19, 2019

KELLER & BENVENUTTI LLP BAKER & HOSTETLER LLP 

/s/ Tobias S. Keller /s/ Cecily A. Dumas

Tobias S. Keller

Proposed Attorneys for Debtors 

and Debtors in Possession

Cecily A. Dumas

 

Proposed Attorneys for Official Committee 

of Tort Claimants

Case: 19-30088 Doc# 488 Filed: 02/19/19 Entered: 02/19/19 18:43:31 Page 3 of 3