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Adam C. Harris (pro hac vice pending)

James T. Bentley (pro hac vice pending)

Kelly (Bucky) Knight (pro hac vice pending)

SCHULTE ROTH & ZABEL LLP

919 Third Avenue

New York, New York 10022

Telephone: (212) 756-2000

Facsimile: (212) 593-5955

Email: adam.harris@srz.com

Email: james.bentley@srz.com

Email: kelly.knight@srz.com

David M. Guess (SBN 238241)

BIENERT | KATZMAN PC

903 Calle Amanecer, Suite 350

San Clemente, California 92673

Telephone: (949) 369-3700

Facsimile: (949) 369-3701

Email: dguess@bienertkatzman.com

Counsel to certain Utility Bondholders

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) 

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11

(Lead Case)

(Jointly Administered) 

AMENDED VERIFIED STATEMENT OF 

SCHULTE ROTH & ZABEL LLP AND BIENERT 

KATZMAN PC PURSUANT TO FEDERAL RULE 

OF BANKRUPTCY PROCEDURE 2019

Case: 19-30088 Doc# 4407 Filed: 10/23/19 Entered: 10/23/19 06:13:24 Page 1 of

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Pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), 

Schulte Roth & Zabel LLP (“Schulte Roth”) and Bienert | Katzman PC (“Bienert Katzman”) submit this 

amended verified statement (this “Amended Statement”) with respect to certain beneficial holders or 

investment advisers or managers for certain beneficial holders of unsecured notes (the “Utility Bonds”) 

issued by Pacific Gas and Electric Company (the “Utility”), each as identified on Exhibit A hereto (each, 

a “Utility Bondholder”), and in support hereof states as follows:

In October 2019, the Utility Bondholders retained Schulte Roth and Bienert Katzman to advise 

them, solely in their capacity as Utility Bondholders, in connection with the chapter 11 cases of the Utility 

and PG&E Corporation (“PG&E” and, together with the Utility, the “Debtors”). The Utility Bondholders 

hold, or manage or advise funds and/or accounts that hold, disclosable economic interests in relation to the 

Debtors. Attached hereto as Exhibit A is a list of the names, addresses, nature, and amount of all 

disclosable economic interests of each Utility Bondholder in relation to the Debtors as of October 16, 2019. 

The information set forth in Exhibit A is based on information provided to Schulte Roth and Bienert 

Katzman by each applicable Utility Bondholder. Schulte Roth and Bienert Katzman submit this Amended 

Statement in an abundance of caution and without conceding that the provisions of Bankruptcy Rule 2019 

apply to their representation of the Utility Bondholders.

As of the date of this Amended Statement, Schulte Roth and Bienert Katzman represent only the 

Utility Bondholders, solely in their capacity as Utility Bondholders, in connection with the Debtors’ 

restructuring. The Utility Bondholders determined to jointly retain Schulte Roth and Bienert Katzman, to 

protect their legal rights in connection with the Joint Chapter 11 Plan of Reorganization of Official 

Committee of Tort Claimants and Ad Hoc Committee of Senior Unsecured Noteholders, dated October 17, 

2019 (as the same may be amended, modified or supplemented from time to time, the “TCC/Ad Hoc 

Committee Plan”), including (without limitation) (a) the right of all holders of Utility Bonds (who are not 

members of the Ad Hoc Committee) to be treated equally and fairly, and to not be discriminated against, 

in relation to the holders of Utility Bonds that are members of the Ad Hoc Committee, and (b) the right to 

ensure that any debt and/or equity financings contemplated by the TCC/Ad Hoc Committee Plan are

subjected to a market test so as to permit the Debtors to obtain the most favorable terms available. 

Case: 19-30088 Doc# 4407 Filed: 10/23/19 Entered: 10/23/19 06:13:24 Page 2 of

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Schulte Roth and Bienert Katzman do not represent or purport to represent any other person or 

entities with respect to these chapter 11 cases. Schulte Roth and Bienert Katzman do not represent the 

Utility Bondholders as a “committee” (as such term is used in the Bankruptcy Code and Bankruptcy Rules) 

and do not undertake to represent the interests of, and are not a fiduciary for, any other creditor, party in 

interest, or other entity. In addition, as of the date of this Amended Statement, no Utility Bondholder 

represents or purports to represent any other entity in connection with these chapter 11 cases. Moreover, 

no Utility Bondholder has or is a party to any agreement to act as a group or in concert with respect to its 

interests in the Debtors and each Utility Bondholder has the unrestricted right to act as it chooses in respect 

of such interests without respect to the actions or interests of any other party.

Upon information and belief formed after due inquiry, Schulte Roth and Bienert Katzman do not 

hold any disclosable economic interest (as that term is defined in Bankruptcy Rule 2019(a)(1)) in relation 

to the Debtors.

The undersigned verify that the foregoing is true and correct to the best of their knowledge, as of 

the date of this Amended Statement.

Nothing contained in this Amended Statement is intended or shall be construed to constitute: 

(a) a waiver or release of the rights of any Utility Bondholder to have any final order entered by, or other 

exercise of the judicial power of the United States performed by, an Article III court; (b) a waiver or release 

of the rights of any Utility Bondholder to have any and all final orders in any and all non-core matters 

entered only after de novo review by a United States District Judge; (c) consent to the jurisdiction of the 

Court over any matter; (d) an election of remedy; (e) a waiver or release of any rights any Utility 

Bondholder may have to a jury trial; (f) a waiver or release of the right to move to withdraw the reference 

with respect to any matter or proceeding that may be commenced in the chapter 11 cases against or 

otherwise involving any Utility Bondholder; (g) a waiver or release of any other rights, claims, actions, 

defenses, setoffs or recoupments to which any Utility Bondholder is or may be entitled, in law or in equity, 

under any agreement or otherwise, with all such rights, claims, actions, defenses, setoffs or recoupments 

being expressly reserved; or (h) an admission or acknowledgement that Bankruptcy Rule 2019 applies to 

Schulte Roth’s or Bienert Katzman’s representation of the Utility Bondholders.

Case: 19-30088 Doc# 4407 Filed: 10/23/19 Entered: 10/23/19 06:13:24 Page 3 of

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Schulte Roth and Bienert Katzman reserve the right to amend or supplement this Amended 

Statement in accordance with the requirements of Bankruptcy Rule 2019 with any additional information 

that may become available.

Dated: October 23, 2019 BIENERT | KATZMAN PC

By: /s/ David M. Guess 

 David M. Guess (SBN 238241)

SCHULTE ROTH & ZABEL LLP

By: /s/ Adam C. Harris

 Adam C. Harris (pro hac vice pending)

James T. Bentley (pro hac vice pending)

Kelly (Bucky) Knight (pro hac vice pending)

Counsel to certain Utility Bondholders

Case: 19-30088 Doc# 4407 Filed: 10/23/19 Entered: 10/23/19 06:13:24 Page 4 of

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DOC ID - 32883300.10

Exhibit A

Name and Address Disclosable Economic Interests

Anchorage Capital Group, L.L.C., 

on behalf of certain funds and 

accounts 

610 Broadway, 6th Floor 

New York, NY 10012

Utility Bonds: $157,000,000

DIP Loan Obligations: $22,500,0001

PG&E Common Shares: 24,905,000

Centerbridge Partners, L.P., on 

behalf of certain funds and 

accounts

375 Park Avenue, 11th Floor

New York, NY 10152

Utility Bonds: $338,618,000

Utility Revolver: $4,935,725

Subrogation Claims: $189,875,301

PG&E Common Shares: 8,826,985

Utility Preferred Shares: 80,884

Fidelity Management & Research

Company, on behalf of certain 

funds and accounts

245 Summer Street

Boston, MA 02210

Utility Bonds: $376,750,000

PG&E Common Shares: 11,788,000

Silver Point Capital, L.P., on 

behalf of certain funds and 

accounts

Two Greenwich Plaza

Greenwich, CT 06830

Utility Debt: $134,646,158.802

Subrogation Claims: $74,934,854.02

Trade Vendor Claims: $11,166,029.27

PG&E Common Shares: 17,887,000

SteelMill Master Fund LP

c/o PointState Capital LP

40 West 57th Street, 25th Floor

New York, NY 10019

Utility Bonds: $209,046,000

PG&E Common Shares: 6,251,765

 1 DIP Loan Obligations include undrawn commitments, if any.

2 Utility Debt includes both Utility bank debt and Utility Bonds.

Case: 19-30088 Doc# 4407 Filed: 10/23/19 Entered: 10/23/19 06:13:24 Page 5 of

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