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1

GROOM LAW GROUP, CHARTERED

David N. Levine, pro hac vice

dnl@groom.com

Katherine B. Kohn, pro hac vice

kkohn@groom.com

1701 Pennsylvania Ave. NW

Washington, D.C. 20006

Tel: (202) 857-0620

Fax: (202) 659-4503

Special Counsel 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, 

Debtors.

□ Affects PG&E Corporation

□ Affects Pacific Gas and Electric Company

x Affects both Debtors

* All papers shall be filed in the Lead Case 

No. 19-30088 (DM).

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case)

(Jointly Administered)

CERTIFICATE OF NO OBJECTION 

REGARDING SECOND 

CONSOLIDATED FEE STATEMENT OF 

GROOM LAW GROUP, CHARTERED

FOR ALLOWANCE AND PAYMENT OF 

COMPENSATION AND 

REIMBURSEMENT OF EXPENSES FOR 

THE PERIOD OF SEPTEMBER 1, 2019 

THROUGH OCTOBER 31, 2019

Re: Docket No. 5022

Objection Deadline: December 30, 2019 at 

4:00 p.m. (Pacific Time)

Case: 19-30088 Doc# 5225 Filed: 12/30/19 Entered: 12/30/19 16:03:11 Page 1 of

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2

On December 8, 2019, The Groom Law Group, Chartered (“Groom” or “Applicant”), 

special employee benefits counsel to PG&E Corporation and Pacific Gas and Electric Company 

(together, “Debtors”), filed its Second Consolidated Fee Statement (“Fee Statement”) for 

allowance and payment of compensation for professional services rendered and for 

reimbursement of actual and necessary expenses incurred for the period commencing September

1, 2019, through October 31, 2019 [Docket No. 5022] (the “Fee Period”) pursuant to the Order 

Pursuant to 11 U.S.C. §§ 331 and 105(a) and Fed. R. Bank. P. 2016 for Authority to Establish 

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals dated 

February 27, 2019 [Dkt. 701] (the “Interim Compensation Procedures Order”) and the Order 

Appointing Fee Examiner And Establishing Procedures For Consideration Of Requested Fee 

Compensation And Reimbursement Of Expenses, [Dkt. 2267].

The Fee Statement was served by ECF to all interested parties. The deadline to file 

oppositions or responses to the Fee Statement was December 30, 2019 at 4:00 p.m. (PT), and no 

oppositions or responses have been filed with the Court or received by the Applicant. Pursuant to 

the Interim Compensation Procedures Order, the Debtors are authorized to pay the Applicant 

eighty percent (80%) of the fees and one hundred percent (100%) of the expenses requested in 

the Fee Statement upon the filing of this certification without the need for a further order of the 

Court. A summary of the fees and expenses sought by the Applicant is annexed hereto as 

Exhibit A.

Case: 19-30088 Doc# 5225 Filed: 12/30/19 Entered: 12/30/19 16:03:11 Page 2 of

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3

DECLARATION OF NO RESPONSE RECEIVED

The undersigned hereby declares, pursuant to 28 U.S.C §1746, under penalty of perjury, that:

1. I am an Of Counsel at the law firm of Groom Law Group, Chartered, counsel to PG&E 

Corporation and Pacific Gas and Electric Company.

2. I certify that I have reviewed or caused the review of the Court’s docket in these chapter 

11 cases and that Applicant has not received any response or opposition to the Fee 

Statement.

3. This declaration was executed in Washington D.C.

Dated: December 30, 2019 GROOM LAW GROUP, CHARTERED

By: /s/ Katherine B. Kohn

Special Counsel for Debtors and 

Debtors in Possession

Case: 19-30088 Doc# 5225 Filed: 12/30/19 Entered: 12/30/19 16:03:11 Page 3 of

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EXHIBIT A

Fee Statement – Professional Fees and Expenses

Applicant

Fee 

Application 

Period, 

Filing Date, 

Docket No.

Total Fees 

Requested

Total

Expenses 

Requested

Objection 

Deadline

Amount of 

Fees 

Authorized 

to be Paid 

Pursuant to 

Interim 

Comp. 

Order 

(80% )

Amount of 

Expenses 

Authorized 

to be Paid 

Pursuant to 

Interim 

Comp. 

Order 

(100% )

Amount 

of 

Holdback 

Fees 

Requested

Groom 

Law 

Group, 

Chartered

9/1/2019 –

10/31/2019

12/8/2019

[Docket 

No. 5022]

$130,150.10 $620

12/30/19 

at

4:00 p.m. 

(PT)

$104,120.08 $620 $26,030.02

Case: 19-30088 Doc# 5225 Filed: 12/30/19 Entered: 12/30/19 16:03:11 Page 4 of

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Notice Parties

PG&E Corporation

c/o Pacific Gas & Electric Company

77 Beale Street

San Francisco, CA 94105

Attn: Janet Loduca, Esq.

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, New York 10153

Attn: Stephen Karotkin, Esq.

Rachael Foust, Esq.

Keller & Benvenutti LLP

650 California Street, Suite 1900

San Francisco, CA 94108

Attn: Tobias S. Keller, Esq.,

Jane Kim, Esq.

The Office of the United States Trustee for Region 17

450 Golden Gate Avenue, 5th Floor, Suite #05-0153

San Francisco, CA 94102

Attn: James L. Snyder, Esq.,

Timothy Laffredi, Esq.

Milbank LLP

55 Hudson Yards

New York, NY 10001-2163

Attn: Dennis F. Dunne, Esq.,

Sam A. Khalil, Esq.

Milbank LLP

2029 Century Park East, 33rd Floor

Los Angeles, CA 90067

Attn: Paul S. Aronzon, Esq.,

Gregory A. Bray, Esq.,

Thomas R. Kreller, Esq.

Baker & Hostetler LLP

11601 Wilshire Boulevard, Suite 1400

Los Angeles, CA 90025-0509

Attn: Eric Sagerman, Esq.,

Cecily Dumas, Esq.

Case: 19-30088 Doc# 5225 Filed: 12/30/19 Entered: 12/30/19 16:03:11 Page 5 of

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Bruce Markell

Fee Examiner

Northwestern University Pritzker School of Law

375 East Chicago Avenue 

Chicago, IL 60611-3069

Case: 19-30088 Doc# 5225 Filed: 12/30/19 Entered: 12/30/19 16:03:11 Page 6 of

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