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STIPULATION TO EXTEND TIME FOR UST 

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 UNITED STATES TRUSTEE 

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# 502 Filed: 02/20/19 Entered: 02/20/19 14:35:26 Page 1 of 3
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STIPULATION TO EXTEND TIME FOR UST 

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 - 2 - Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

This stipulation and agreement for order (“Stipulation”) is entered into by 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 Office of the United States 

Trustee (the “U.S. Trustee”). The Debtors and the U.S. Trustee are referred to in this Stipulation 

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. On February 19, 2019, counsel for the U.S. Trustee requested, and proposed 

counsel for the Debtors agreed, that the time for the U.S. Trustee to respond to the Motions be 

extended by two days. 

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 U.S. Trustee to file and serve any response or opposition 

to the Motions is extended through 4:00 p.m. on February 22, 2019. 

[Signatures on Next Page] 

Case: 19-30088 Doc# 502 Filed: 02/20/19 Entered: 02/20/19 14:35:26 Page 2 of 3
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STIPULATION TO EXTEND TIME FOR UST 

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 - 3 - Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Dated: February 19, 2019 Dated: February 20, 2019

KELLER & BENVENUTTI LLP OFFICE OF THE UNITED STATES 

TRUSTEE 

/s/ Jane Kim /s/ Marta E. Villacorta

Jane Kim

Proposed Attorneys for Debtors 

and Debtors in Possession

Marta E. Villacorta

Trial Attorney 

Attorney for Andrew R. Vara, 

Acting United States Trustee for Region 31

 

1

 Andrew R. Vara, Acting United States Trustee for Region 3, is acting in this appointment for Tracy Hope Davis, 

United States Trustee for Region 17, who is recused from the above-captioned cases. 

Case: 19-30088 Doc# 502 Filed: 02/20/19 Entered: 02/20/19 14:35:26 Page 3 of 3