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017558.0085\5684390.1 STIPULATION 1 Wendel Rosen LLP 1111 Broadway, 24t h Floor Oakland, California 94607-4036 

Mark S. Bostick (Bar No. 111241) 

Lisa Lenherr (Bar No. 258091) 

WENDEL ROSEN LLP 

1111 Broadway, 24th Floor 

Oakland, California 94607-4036 

Telephone: (510) 834-6600 

Fax: (510) 834-1928 

Email: mbostick@wendel.com 

Email: llenherr@wendel.com 

Attorneys for Michael G. Kasolas, Claims 

Representative 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

-andPACIFIC 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) 

STIPULATION TO ADVANCE FUNDS 

TO CLAIMS REPRESENTATIVE

This Stipulation to Advance Funds to Claims Representative (the “Stipulation”) is entered 

into between Michael G. Kasolas, the Court appointed claims representative (the “Claims 

Representative”) and PG&E Corporation and Pacific Gas and Electric Company, the abovecaptioned debtors (the “Debtors”). 

RECITALS 

A. On November 11, 2019, the Honorable Dennis Montali, United States Bankruptcy 

Case: 19-30088 Doc# 4966 Filed: 12/03/19 Entered: 12/03/19 17:18:00 Page 1 of

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017558.0085\5684390.1 STIPULATION 2 Wendel Rosen LLP 1111 Broadway, 24t h Floor Oakland, California 94607-4036 

Court, Northern District of California, entered the Order Extending Bar Date for Fire Claimants 

and Appointment of Claims Representative (the “Bar Date Extension Order”). (Docket No. 4672, 

filed Nov. 11, 2019.) 

B. The Bar Date Extension Order provides that the Claims Representative shall be 

given broad discretion to conduct certain tasks described in the Bar Date Extension Order (the 

“Tasks”) for the benefit of Unfiled Fire Claimants.1

C. On December 3, 2019, the Claims Representative filed his First Report, which 

includes a description of the proposed strategy, current status, and projected budget (the “First 

Report”). (Docket No. 4963.) 

D. The Bar Date Extension Order provides that the Claims Representative may apply 

to the Court for approval of advance fees or costs if deemed necessary in order to successfully 

complete the Tasks. 

E. The Claims Representative has determined that advance funds in the amount of 

$395,000.00 are required in order to successfully initiate efforts to complete the Tasks (the 

“Advance”). 

F. The Advance will be used to purchase and pay for advertising and third-party nonTeam member services as described in the First Report. 

G. Receipt of the Advance is required as soon as possible to ensure that media and 

other third-party services can be timely purchased and paid for. 

STIPULATION 

1. Subject to Bankruptcy Court approval, the Debtors agree to advance the requested 

funds. 

2. The Advance will be paid via wire(s) to the Claims Representative and/or to a 

member(s) of his Team (instructions to be provided) so that it is received within three (3) business 

day following entry of the Order approving this Stipulation. 

 

1

 Capitalized terms not defined herein shall have the meaning ascribed to them in the Bar Date 

Extension Order. 

Case: 19-30088 Doc# 4966 Filed: 12/03/19 Entered: 12/03/19 17:18:00 Page 2 of

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017558.0085\5684390.1 STIPULATION 3 Wendel Rosen LLP 1111 Broadway, 24t h Floor Oakland, California 94607-4036 

THE FOREGOING IS AGREED. 

DATED: December 3, 2019 WENDEL ROSEN LLP 

By: /s/ Lisa Lenherr

 Mark S. Bostick 

Lisa Lenherr 

Attorneys for Michael G. Kasolas, Claims 

Representative

DATED: December 3, 2019 WEIL GOTSHAL & MANGES, LLP 

By: /s/ Matthew P. Goren 

 Matthew P. Goren 

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 4966 Filed: 12/03/19 Entered: 12/03/19 17:18:00 Page 3 of

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