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Bruce S. Bennett (SBN 105430) 

Joshua M. Mester (SBN 194783) 

James O. Johnston (SBN 167330) 

JONES DAY 

555 South Flower Street 

Fiftieth Floor 

Los Angeles, CA 90071.2300 

Telephone: (213) 489-3939 

Facsimile: (213) 243-2539 

E-mail: bbennett@jonesday.com 

 jmester@jonesday.com 

 jjohnston@jonesday.com 

Attorneys for PG&E Shareholders 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

- and - 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

Debtors. 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

JOINDER OF CERTAIN PG&E 

SHAREHOLDERS TO THE DEBTORS’ 

REPLY IN SUPPORT OF 

SUBROGATION CLAIMS 

SETTLEMENT AND RSA MOTION 

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 23, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Judge: Hon. Dennis Montali 

Re: Docket Nos. 3992, 3993, and 4339

Case: 19-30088 Doc# 4367 Filed: 10/21/19 Entered: 10/21/19 17:16:24 Page 1 of

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Certain owners of common stock of PG&E Corporation (the “PG&E Shareholders”)1

hereby join in the Debtors’ Reply In Support Of Subrogation Claims Settlement And RSA Motion

[ECF 4339] (the “Reply”) filed by PG&E Corporation and Pacific Gas and Electric Company as 

debtors and debtors in possession (collectively, the “Debtors”) in the above-captioned chapter 11 

cases (the “Chapter 11 Cases”). 

1. On September 24, 2019, the Debtors filed the Debtors’ Motion Pursuant to 11 

U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9019 for Entry of an Order 

(i) Authorizing the Debtors to Enter into Restructuring Support Agreement with the Consenting 

Subrogation Claimholders, (ii) Approving the Terms of Settlement with Such Consenting 

Subrogation Claimholders, including the Allowed Subrogation Claim Amount, and (iii) Granting 

Related Relief [ECF 3992] (the “RSA Motion”).2

2. The PG&E Shareholders support the relief requested in the RSA Motion and agree 

that, for the reasons explained in the Reply, the various Objections filed with respect thereto 

should be overruled. 

3. The PG&E Shareholders believe that the Subrogation Settlement is a key 

milestone in the administration of these Chapter 11 Cases and an important achievement that will 

help enable the Debtors to meet the statutory deadline to resolve these Chapter 11 Cases by June 

30, 2020. 

4. Accordingly, the PG&E Shareholders join in the Debtors’ request that the Court 

approve the RSA Motion, overrule the remaining Objections, and grant such other relief as is 

necessary and appropriate. 

 1

 The PG&E Shareholders are the entities identified on Exhibit A to the Fourth Amended 

Verified Statement Of Jones Day Pursuant To Federal Rule Of Bankruptcy Procedure 2019 [ECF 

4366]. The PG&E Shareholders are acting in their individual capacities but authorized the filing of 

this single submission for the purpose of administrative efficiency. Each of the PG&E Shareholders 

is expressing its independent views, and counsel does not have the actual or apparent authority to 

obligate any one entity to act in concert with any other entity with respect to PG&E equity securities. 

The PG&E Shareholders have not agreed to act in concert with respect to their respective interests in 

PG&E equity securities. 

2

 Capitalized terms used but not otherwise defined herein have the meanings assigned to them 

in the Reply or the RSA Motion, as applicable. 

Case: 19-30088 Doc# 4367 Filed: 10/21/19 Entered: 10/21/19 17:16:24 Page 2 of

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Dated: October 21, 2019 JONES DAY 

By: /s/ James O. Johnston

James O. Johnston 

Attorneys for PG&E Shareholders 

Case: 19-30088 Doc# 4367 Filed: 10/21/19 Entered: 10/21/19 17:16:24 Page 3 of

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