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HUNTONANDREWS KURTH LLP

Paul N. Silverstein Pro Hac Vice Pending

Brian M. Clarke Pro Hac Vice Pending

200 Park Avenue

New York, NY 10166

Telephone: (212) 309-1000

Email: paulsilverstein@HuntonAK.com

brianclarke@HuntonAK.com

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SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

A Limited Liability Partnership

Including Professional Corporations

ROBERT K. SAHYAN, Cal. Bar No. 253763

Four Embarcadero Center, 17th Floor

San Francisco, California 94111-4106

Telephone: 415-434-9100

Facsimile: 415-434-3947

Email: rsahyan@sheppardmullin.com

Attorneys for Columbus Hill Capital Management, L.P.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re: Bankruptcy Case 

No. 19-30088 (DM)

PG&E CORPORATION

Chapter 11 

-and- (Lead Case)

(Jointly Administered)

PACIFIC GAS AND ELECTRIC

COMPANY OBJECTION OF COLUMBUS HILL

CAPITAL MANAGEMENT, L.P.

TO MOTION OF THE AD HOC 

COMMITTEE OF SENIOR UNSECURED 

Debtors. NOTEHOLDERS TO TERMINATE THE 

DEBTORS’ EXCLUSIVE PERIODS

☐ Affects PG&E Corporation Date: July 24, 2019

☐ Affects Pacific Gas and Electric Company Time: 9:30 a.m. (Pacific Time)

☒ Affects both Debtors Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

*All papers shall be filed in the Lead Case, 450 Golden Gate Avenue

No. 19-30088 (DM). San Francisco, CA 94102

Re: Docket No. 2741

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Case: 19-30088 Doc# 3079 Filed: 07/18/19 Entered: 07/18/19 16:43:28 Page 1 of

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Columbus Hill Capital Management, L.P. (“Columbus Hill”), the manager of funds 

that hold claims against, and interests in, Pacific Gas and Electric Company and PG&E 

Corporation (collectively, the “Debtors”), for its objection to the Motion of the Ad Hoc 

Committee of Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Period (the 

“Termination Motion”) [Docket No. 2741], respectively represents:

1. The Debtors filed for relief under Chapter 11 of the Bankruptcy Code on 

January 29, 2019, less than six months ago. On May 23, 2019, after full briefing and a 

contested hearing, this Court entered an Order granting the Debtors’ request for an extension 

of their exclusive period to file a plan of reorganization until September 26, 2019 (and, 

accordingly, to extend the exclusive solicitation period).

2. The Termination Motion does not, because it cannot, demonstrate any cause 

under Section 1121(d) of the Bankruptcy Code to terminate the Debtors’ plan exclusivity 

period as previously extended by this Court. The factors typically relied upon by courts to 

determine whether to extend or reduce exclusivity clearly require denying the Termination 

Motion. See, e.g., In re Dow Corning Corp., 208 B.R. 661, 663–670 (Bankr. E.D. Mich. 

1997) (denying motion to terminate exclusivity). The Debtors chapter 11 cases are among the 

largest and most complex chapter 11 cases ever filed, and the Debtors have been in chapter 11 

for under six months. While progress toward a framework for a plan has been made, 

unresolved contingencies still exist (as discussed further in this Objection). The Termination 

Motion contains no justification for ignoring these facts and terminating prematurely an 

exclusivity extension granted less than two months ago to Debtors that filed bankruptcy less 

than six months ago. “Cause” to terminate exclusivity does not revolve around satisfying the 

narrow interest of a particular constituent, as the Termination Motion suggests. On the 

contrary, maintaining exclusivity will benefit the Debtors’ estates, creditors and other 

stakeholders. 

3. Termination of exclusivity would be chaotic and disruptive to, and would 

impede, the Debtors’ reorganization efforts. Material progress has been made toward that 

end. For example, as this Court is aware, on July 12, 2019, AB 1054 legislation was enacted. 

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Passage of such legislation provides an enhanced regulatory framework that supports the 

formulation and confirmation of a feasible reorganization plan for the Debtors. AB 1054, 

however, also imposes numerous conditions on the Debtors’ eligibility to access the benefits 

of the legislation, including, among others, the requirement that it exit from bankruptcy by 

June 30, 2020 and that it meet various safety-related and other regulatory conditions. The 

Debtors must be permitted to use their exclusive periods to address all of the issues that are 

preconditions to a successful reorganization, including finalizing a mechanism or process for 

resolving, allowing and satisfying pre-petition wildfire claims and liabilities and meeting such 

safety and other applicable regulatory requirements.

4. The Debtors must continue such reorganization efforts without unnecessary 

disruptions and distraction, and they are entitled to that as debtors in possession here. Efforts 

to disrupt, distract and/or delay the Debtors’ reorganization efforts are unwarranted and 

unwise. Accordingly, Columbus Hill respectfully requests that the Termination Motion be 

denied in all respects.

Respectfully submitted, 

Dated: July 18, 2019 /s/ Robert Sahyan

SHEPPARD, MULLIN, RICHTER & 

HAMPTON LLP

Attorneys for Columbus Hill Capital 

Management, L.P.

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