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- 1 -

NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE

Gibson, Dunn & 

Crutcher LLP

DAVID M. FELDMAN, NY SBN 2633881

 dfeldman@gibsondunn.com

 (pro hac vice application pending)

MATTHEW K. KELSEY, NY SBN 4250296

 mkelsey@gibsondunn.com

 (pro hac vice application pending)

GIBSON, DUNN & CRUTCHER LLP

200 Park Avenue

New York, NY 10166-0193

Telephone: 212.351.4000

Facsimile: 212.351.4035

MICHAEL S. NEUMEISTER, SBN 274220

 mneumeister@gibsondunn.com

MICHELLE CHOI, SBN 313557

 mchoi@gibsondunn.com

GIBSON, DUNN & CRUTCHER LLP

333 South Grand Avenue

Los Angeles, CA 90071-3197

Telephone: 213.229.7000

Facsimile: 213.229.7520

Attorneys for the Ad Hoc Committee of

Holders of Trade Claims

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION 

-andPACIFIC GAS & 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)

NOTICE OF APPEARANCE AND 

REQUEST FOR SPECIAL NOTICE

Case: 19-30088 Doc# 4180 Filed: 10/10/19 Entered: 10/10/19 14:48:28 Page 1 of

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NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE

Gibson, Dunn & 

Crutcher LLP

PLEASE TAKE NOTICE that the Ad Hoc Committee of Holders of Trade Claims (the “Ad 

Hoc Trade Committee”), a party in interest in the above-captioned bankruptcy cases (the 

“Bankruptcy Cases”), by and through its counsel, Gibson, Dunn & Crutcher LLP, hereby enters this 

appearance pursuant to section 1109(b) of title 11 of the United States Code, 11 U.S.C. §§ 101-1532 

(the “Bankruptcy Code”), Rule 9010-1 of the Bankruptcy Local Rules for the Northern District of 

California, and Rule 9010(b) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy 

Rules”), and requests that the counsel listed below be added to the official mailing matrix, CM/ECF, 

and service lists in the Bankruptcy Cases. The Ad Hoc Trade Committee requests, pursuant to 

Bankruptcy Rules 2002, 3017 and 9007 and section 1109(b) of the Bankruptcy Code, that copies of 

all notices and pleadings given or required to be given in the Bankruptcy Cases and copies of all 

papers served or required to be served in the Bankruptcy Cases, including but not limited to, all 

notices (including those required by Bankruptcy Rule 2002), reports, pleadings, motions, 

applications, lists, schedules, statements, and all other matters arising herein or in any way related to 

the Bankruptcy Cases, including in adversary proceedings, be given and served upon Gibson, Dunn 

& Crutcher LLP at the following addresses:

David M. Feldman

Matthew K. Kelsey

GIBSON, DUNN & CRUTCHER LLP

200 Park Avenue

New York, NY 10166-0193

E-mail: dfeldman@gibsondunn.com

 mkelsey@gibsondunn.com

Telephone: 212.351.4000

Facsimile: 212.351.4035

Matthew D. McGill

GIBSON, DUNN & CRUTCHER LLP

1050 Connecticut Avenue, N.W.

Washington, DC 20036-5306

E-mail: mmcgill@gibsondunn.com

Telephone: 202.955.8500

Facsimile: 202.467.0539

Michael S. Neumeister

Michelle Choi

GIBSON, DUNN & CRUTCHER LLP

333 South Grand Avenue

Los Angeles, CA 90071-3197

E:mail: mneumeister@gibsondunn.com

 mchoi@gibsondunn.com

Telephone: 213.229.7000

Facsimile: 213.229.7520

PLEASE TAKE FURTHER NOTICE that, pursuant to section 1109(b) of the Bankruptcy 

Code, the foregoing request applies to and includes not only the notices and papers referenced in the 

Bankruptcy Rules and Bankruptcy Code, but also includes, without limitation, all orders, notices and 

pleadings relating to any application, motion, petition, objection, pleading, request, complaint or 

Case: 19-30088 Doc# 4180 Filed: 10/10/19 Entered: 10/10/19 14:48:28 Page 2 of

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NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE

Gibson, Dunn & 

Crutcher LLP

demand, whether formal or informal, whether written or oral, and whether transmitted or conveyed 

by mail, telephone, courier services, hand delivery, facsimile transmission, electronic mail, telex or 

otherwise that (i) affects, or seeks to affect, or may potentially affect in any way, any rights or 

interests of any creditor or party-in-interest in these Bankruptcy Cases; (ii) affects, or seeks to affect 

(a) the above-captioned Debtors and/or their estates or (b) property or proceeds thereof in the 

possession, custody, or control of others that any of the Debtors or their estates may seek to use; or 

(iii) requires or seeks to require any act, delivery of any property, payment or other conduct by the 

Ad Hoc Trade Committee.

PLEASE TAKE FURTHER NOTICE that the Ad Hoc Trade Committee does not, by filing 

this Notice of Appearance and Request for Service nor any subsequent appearance, pleading, claim or 

suit, waive or otherwise impair any of its rights: (i) to have final orders in non-core matters entered 

only after de novo review by a District Court Judge; (ii) to have all core matters heard and decided by 

a District Court Judge; (iii) to trial by jury in any proceeding so triable in these cases, or any 

controversy or proceeding related to these cases; (iv) to have the District Court withdraw the 

reference in any matter subject to mandatory or discretionary withdrawal; or (v) any other rights, 

claims, actions, defenses, setoffs or recoupments to which the Ad Hoc Trade Committee is or may be 

entitled, in law or in equity, all of which rights, claims, actions, defenses, setoffs and recoupments the 

Ad Hoc Trade Committee expressly reserves.

Dated: October 10, 2019 GIBSON, DUNN & CRUTCHER LLP

By: /s/ Michael S. Neumeister

David M. Feldman*

Matthew K. Kelsey*

Matthew D. McGill*

Michael S. Neumeister

Michelle Choi

*pro hac vice applications pending

Attorneys for the Ad Hoc Committee of

Holders of Trade Claims

Case: 19-30088 Doc# 4180 Filed: 10/10/19 Entered: 10/10/19 14:48:28 Page 3 of

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Gibson, Dunn & 

Crutcher LLP

CERTIFICATE OF SERVICE

I, Duke Amponsah, declare:

1. I am over the age of 18 years and not a party to this action. My business address is 

Gibson, Dunn & Crutcher LLP, 200 Park Avenue, New York, NY 10166-0193, which is located in 

the country where the service described below occurred.

2. I hereby certify that on October 10, 2019, I electronically filed the above Notice of 

Appearance and Request for Special Notice with the Clerk of the Court using the CM/ECF system, 

which will send notification of such filing to e-mail addresses on file with the Court’s ECF system.

I certify and declare under penalty of perjury that the foregoing is true and correct.

 Duke Amponsah /s/Duke Amponsah 

 (type) (signature)

Case: 19-30088 Doc# 4180 Filed: 10/10/19 Entered: 10/10/19 14:48:28 Page 4 of

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