1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 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) 

Ray C. Schrock, P.C. (pro hac vice) 

(ray.schrock@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 

Attorneys for Debtors and 

Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

NOTICE OF AGENDA FOR 

JANUARY 14, 2020, 10:00 A.M. 

OMNIBUS HEARING 

Date: January 14, 2020 

Time: 10:00 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

San Francisco, CA 94102

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# 5354 Filed: 01/13/20 Entered: 01/13/20 12:01:36 Page 1 of

 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

PROPOSED AGENDA FOR 

JANUARY 14, 2020, 10:00 A.M. (PACIFIC TIME) 

OMNIBUS HEARING 

I: MATTERS SCHEDULED TO BE HEARD IN MAIN CASE: No. 19-30088 (DM) 

CONTESTED MATTER GOING FORWARD 

1. Make-Whole Premiums Brief: Debtors’ Brief Regarding Utility Funded Debt 

Claims’ Entitlement to Make-Whole Premiums and Joinder of PG&E Shareholders [Dkt. 4896]. 

Response Deadline: December 20, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Consolidated Opening Brief of Certain Creditor Groups and 

Representatives Regarding the Entitlement of Holders of Utility Funded 

Debt Claims to Optional Early Redemption, Make-Whole, or Similar 

Amounts in a Solvent Debtor Case [Dkt. 4902]. 

B. Declaration of Andrew I. Silfen in Support of Consolidated Opening Brief 

of Certain Creditor Groups and Representatives Regarding the Entitlement 

of Holders of Utility Funded Debt Claims to Optional Early Redemption, 

Make-Whole, or Similar Amounts in a Solvent Debtor Case [Dkt. 4903]. 

C. Consolidated Opposition Brief of Certain Creditor Groups and 

Representatives Regarding the Entitlement of Holders of Utility Funded 

Debt Claims to Optional Early Redemption, Make-Whole, or Similar 

Amounts in a Solvent Debtor Case [Dkt. 5189]. 

Related Documents: 

D. Declaration of Theodore E. Tsekerides, Esq. in Support of Debtors’ 

Moving Brief Regarding Utility Funded Debt Claims’ Entitlement to 

Make-Whole Premiums [Dkt. 4898]. 

E. Debtors’ Opposition to the Consolidated Opening Brief of Certain 

Creditor Groups and Representatives Regarding the Entitlement of 

Holders of Utility Funded Debt Claims to Optional Early Redemption, 

Make-Whole, or Similar Amounts in a Solvent Debtor Case; Joinder of 

PG&E Shareholders [Dkt. 5190]. 

Status: This matter is going forward on a contested basis. 

STATUS CONFERENCE 

2. Notice of Filing of Joint Chapter 11 Plan: Notice of Filing of Debtors’ and 

Shareholder Proponents’ Joint Chapter 11 Plan of Reorganization Dated December 12, 2019 

[Dkt. 5102]. 

A. Joint Chapter 11 Plan of Reorganization of Official Committee of Tort 

Claimants and Ad Hoc Committee of Senior Unsecured Noteholders 

[Dkt. 4257]. 

Case: 19-30088 Doc# 5354 Filed: 01/13/20 Entered: 01/13/20 12:01:36 Page 2 of

 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

B. Debtors’ and Shareholder Proponents’ Joint Chapter 11 Plan of 

Reorganization Dated December 12, 2019 [Dkt. 5101]. 

C. Statement of the United States of America in Response to the Court’s 

Memorandum Regarding Confirmation Issues [Dkt. 5087]. 

D. Statement of the California State Agencies in Response to the Court’s 

Memorandum Regarding Confirmation Issues [Dkt. 5104]. 

E. Stipulation Amending Order Establishing Preconfirmation Briefing and 

Hearing Schedule for Certain Legal Issues [Dkt. 5254]. 

Related Order: 

F. Order Approving Stipulation Amending Order Establishing 

Preconfirmation Briefing and Hearing Schedule for Certain Legal Issues 

[Dkt. 5312]. 

Status: The status conference was continued to January 14, 2020 by 

December 17, 2019 Docket Text Order. 

RESOLVED AND CONTINUED MATTERS 

3. Motion to Permit Contract Termination: Notice of Motion and Motion of 

Henrietta D Energy Storage LLC for Entry of an Order Modifying the Automatic Stay to Permit 

Contract Termination [Dkt. 4850]. 

Response Deadline: December 12, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: No responses were filed. 

Related Documents: 

A. Relief from Stay Cover Sheet [Dkt. 4851]. 

B. Declaration of Christopher Streeter in Support of Motion of Henrietta D 

Energy Storage, LLC for Entry of an Order Modifying the Automatic Stay 

to Permit Contract Termination [Dkt. 4852]. 

C. Corrected Stipulation Between Debtor Pacific Gas and Electric Company 

and Henrietta D Energy Storage LLC for Limited Relief from the 

Automatic Stay [Dkt. 5341]. 

Related Order: 

D. Order Approving Corrected Stipulation Between Debtor Pacific Gas and 

Electric Company and Henrietta D Energy Storage LLC for Limited Relief 

from the Automatic Stay [Dkt. 5349]. 

Status: This matter has been resolved by stipulation [Dkt. 5341] and order 

[Dkt. 5349] and taken off calendar by January 10, 2020 Docket Text Order. 

Case: 19-30088 Doc# 5354 Filed: 01/13/20 Entered: 01/13/20 12:01:36 Page 3 of

 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

4. Debtor’s Application for McKinsey & Company, Inc.: Application of Debtors 

Pursuant to U.S.C. §§ 363(b) and 105(a) for Authority to Enter Into, Perform Under and Make 

Payments Under Certain Consulting Contracts with McKinsey & Company, Inc. United States 

[Dkt. 3919]. 

Response Deadline: February 19, 2020, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

F. Statement of Jay Alix [Dkt. 4426]. 

G. Conditional Consent of the Official Committee of Tort Claimants to 

Application of Debtors Pursuant to 11 U.S.C. §§ 363(b) and 105(a) for 

Authority to Enter Into, Perform Under and Make Payments Under 

Certain Consulting Contracts with McKinsey & Company, Inc. United 

States [Dkt. No. 3919] [Dkt. 5308]. 

Status: This matter has been continued to February 26, 2020 by Dkt. 5293. 

5. Exit Financing Motion: Debtors’ Motion for Entry of Orders (I) Approving 

Terms of, and Debtors’ Entry Into and Performance Under, Exit Financing Commitment Letters 

and (II) Authorizing Incurrence, Payment and Allowance of Related Feed and/or Premiums, 

Indemnities, Costs and Expenses as Administrative Expense Claims [Dkt. 4446]. 

Response Deadline: January 14, 2020, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Letter from the Official Committee of Unsecured Creditors to the 

Honorable Dennis Montali Regarding Exit Financing Discovery 

[Dkt. 4562]. 

B. Letter from the Ad Hoc Committee of Senior Unsecured Noteholders to 

the Honorable Dennis Montali in Regards to November 4, 2019 Letter 

from Creditors’ Committee [Dkt. 4566]. 

C. Letter from the Official Committee of Tort Claimants to the Honorable 

Dennis Montali Regarding Exit Financing Discovery [Dkt. 4575]. 

D. Letter from the Debtors to the Honorable Dennis Montali in Response to 

Letters Filed by Requesting Parties [Dkt. 4577]. 

E. Letter Regarding Continuance of the December 17, 2019 Hearing on the 

Debtors’ Motion for Entry of Orders (I) Approving Terms of, and 

Debtors’ Entry Into and Performance Under, Exit Financing Commitment 

Letters and (II) Authorizing Incurrence, Payment, and Allowance of 

Related Fees and/or Premiums, Indemnities, Costs and Expenses as 

Administrative Expense Claims (the Motion) and Extension of Time to 

Respond to that Motion [Dkt. 4968]. 

F. Letter Joining the Official Committee of Unsecured Creditors Request for 

a Continuance of the December 17, 2019 Hearing on the Debtors’ Motion 

for Entry of Orders (I) Approving Terms of, and Debtors’ Entry Into and 

Performance Under, Exit Financing Commitment Letters and (II) 

Case: 19-30088 Doc# 5354 Filed: 01/13/20 Entered: 01/13/20 12:01:36 Page 4 of

 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

Authorizing Incurrence, Payment, and Allowance of Related Fees and/or 

Premiums, Indemnities, Costs and Expenses as Administrative Expense 

Claims (the Motion) and Extension of Time to Respond to that Motion 

[Dkt. 4970]. 

G. Letter Brief of the TCC to the Honorable Dennis Montali [Dkt. 4971]. 

Related Documents: 

H. Declaration of Kenneth S. Ziman in Support of Debtors’ Motion for Entry 

of Orders (I) Approving Terms of, and Debtors’ Entry into and 

Performance Under, Exit Financing Commitment Letters and (II) 

Authorizing Incurrence, Payment and Allowance of Related Fees and/or 

Premiums, Indemnities, Costs and Expenses as Administrative Expense 

Claims [Dkt. 4447]. 

I. Debtors’ Amended Motion for Entry of Orders (I) Approving Terms of, 

and Debtors’ Entry Into and Performance Under, Equity Backstop 

Commitment Letters, (II) Approving Terms of, and Debtors’ Entry Into 

and Performance Under, Debt Financing Commitment Letters and (III) 

Authorizing Incurrence, Payment and Allowance of Related Fees and/or 

Premiums, Indemnities, Costs and Expenses as Administrative Expense 

Claims [Dkt. 5267]. 

J. Declaration of Kenneth S. Ziman in Support of Debtors’ Amended Motion 

for Entry of Orders (I) Approving Terms of, and Debtors’ Entry Into and 

Performance Under, Equity Backstop Commitment Letters, (II) Approving 

Terms of, and Debtors’ Entry Into and Performance Under, Debt 

Financing Commitment Letters and (III) Authorizing Incurrence, Payment 

and Allowance of Related Fees and/or Premiums, Indemnities, Costs and 

Expenses as Administrative Expense Claims [Dkt. 5268]. 

Status: This matter has been continued to January 29, 2020 by agreement of the 

parties. 

6. Subrogation Claims Impairment Issue Brief: Debtors’ and Ad Hoc 

Subrogation Group’s Joint Brief in Support of the Subrogation Wildfire Claims as Impaired 

Classes for All Purposes Under the Debtors’ Joint Chapter 11 Plan or Reorganization

[Dkt. 4886]. 

Response Deadline: January 10, 2020, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Reservation of Rights of the Ad Hoc Committee of Senior Unsecured 

Noteholders with Respect to Subrogation Claims Impairment Issue 

[Dkt. 4893]. 

B. Statement and Reservation of Rights of the Official Committee of 

Unsecured Creditors Regarding Subrogation Claim Impairment Issue 

[Dkt. 4897]. 

C. Stipulation Amending Order Establishing Preconfirmation Briefing and 

Hearing Schedule for Certain Legal Issues [Dkt. 5254]. 

Case: 19-30088 Doc# 5354 Filed: 01/13/20 Entered: 01/13/20 12:01:36 Page 5 of

 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

Related Order: 

D. Order Approving Stipulation Amending Order Establishing 

Preconfirmation Briefing and Hearing Schedule for Certain Legal Issues 

[Dkt. 5312]. 

Status: This matter has been continued to January 29, 2020 by stipulation [Dkt. 

5254] and taken off calendar by Order [Dkt. 5312]. 

7. Class Proof of Claim Motion: Securities Lead Plaintiff’s Motion to Apply 

Bankruptcy Rule 7023 to Class Proof of Claim [Dkt. 5042]. 

Response Deadline: January 14, 2020, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Stipulation Regarding Scheduling with Respect to Securities Lead 

Plaintiff’s Motion to Apply Bankruptcy Rule 7023 to Class Proof of Claim 

[ECF No. 5042] [Dkt. 5198]. 

Related Order: 

B. Order Approving Stipulation Regarding Scheduling with Respect to 

Securities Lead Plaintiff’s Motion to Apply Bankruptcy Rule 7023 to 

Class Proof of Claim [ECF No. 5042] [Dkt. 5211]. 

Status: This matter has been continued to January 29, 2020 by stipulation [Dkt. 

5198] and taken off calendar by Order [Dkt. 5211]. 

8. FEMA Claims Objection: Omnibus Objection of the Official Committee of Tort 

Claimants (Substantive) to No Liability Claims Filed by the Department of Homeland 

Security/Federal Emergency Management Agency (Claim Nos. 59692, 59734 & 59783) [Dkt. 

4943]. 

Response Deadline: January 28, 2020, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Letter to Court from Sharon Zimmerman [Dkt. 5164]. 

B. Letter to Court from Jerry Gladstone [Dkt. 5213]. 

C. Letter to Court from Brenda S. Wright [Dkt. 5298]. 

Related Documents: 

D. Declaration of Eric Goodman in Support of Omnibus Objection of the 

Official Committee of Tort Claimants (Substantive) to No Liability 

Claims Filed by the Department of Homeland Security/Federal Emergency 

Management Agency (Claim Nos. 59692, 59734 & 59783) [Dkt. 4943-2]. 

E. FEMA Claims [Dkt. 4943-5]. 

Case: 19-30088 Doc# 5354 Filed: 01/13/20 Entered: 01/13/20 12:01:36 Page 6 of

 7
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

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

F. Supplement to Omnibus Objection of the Official Committee of Tort 

Claimants (Substantive) to No Liability Claims Filed by the Department of 

Homeland Security/Federal Emergency Management Agency (Claim Nos. 

59692, 59734 & 59783) [Dkt. 5319]. 

Status: This matter has been continued to February 11, 2020 by Dkt. 5136. 

9. Cal OES Claims Objection: Omnibus Objection of the Official Committee of 

Tort Claimants (Substantive) to Claims Filed by California Governor’s Office of Emergency 

Services [Dkt. 5096]. 

Response Deadline: January 28, 2020, at 4:00 p.m. (Pacific Time). 

Responses Filed: No responses were filed. 

Related Documents: 

A. CAL OES Claims [Dkt. 5096-3]. 

B. Declaration of Eric Goodman in Support of Omnibus Objection of the 

Official Committee of Tort Claimants (Substantive) to No Liability 

Claims Filed by the Department of Homeland Security/Federal emergency 

Management Agency (Claims Nos. 59692, 59734, & 59783) [Dkt. 4943-

2]. 

C. Supplement to Omnibus Objection of the Official Committee of Tort 

Claimants (Substantive) to Claims Filed by California Governor’s Office 

of Emergency Services (Claim Nos. 87748, 87754, & 87755) [Dkt. 5320]. 

Status: This matter has been continued to February 11, 2020 by Dkt. 5136. 

PLEASE TAKE NOTICE that copies of any pleadings filed with the Court and 

referenced herein can be viewed and/or obtained: (i) by accessing the Court’s website at 

http://www.canb.uscourts.gov, (ii) by contacting the Office of the Clerk of the Court at 450 

Golden Gate Avenue, San Francisco, CA 94102, or (iii) from the Debtors’ notice and claims 

agent, Prime Clerk LLC, at https://restructuring.primeclerk.com/pge or by calling (844) 339-

4217 (toll free) for U.S.-based parties; or +1 (929) 333-8977 for International parties or by email at:pgeinfo@primeclerk.com. Note that a PACER password is needed to access documents 

on the Bankruptcy Court’s website. 

Dated: January 13, 2020 WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP 

 By: /s/ Dara L. Silveira 

 Dara L. Silveira 

 

Attorneys for Debtors and Debtors in Possession 

Case: 19-30088 Doc# 5354 Filed: 01/13/20 Entered: 01/13/20 12:01:36 Page 7 of

 7