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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)| 

767 Fifth Avenue 

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: 650 636 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 - 

PACIFIC GAS AND ELECTRIC COMPANY,

Bankruptcy Case 

No. 19 -30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STIPULATION CONSENTING TO 

EXTENSION OF DEADLINE TO 

ASSUME OR REJECT CERTAIN 

NONRESIDENTIAL REAL 

PROPERTY LEASES PURSUANT 

TO 11 U.S.C. § 365(d)(4) 

[No Hearing Requested] 

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# 5175 Filed: 12/19/19 Entered: 12/19/19 14:43:44 Page 1 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

PG&E Corporation (“PG&E Corp”) and Pacific Gas and Electric Company (the 

“Utility”, and together the “Debtors”) as debtors and debtors in possession in the above-captioned 

chapter 11 cases (the “Chapter 11 Cases”), and PPF Paramount One Market Plaza Owner, L.P. (the 

“Lessor”), hereby submit this stipulation (the “Stipulation”) consenting to a further extension of 

time for the Debtors to assume or reject unexpired leases of nonresidential real property pursuant to 

section 365(d)(4)(B)(ii) of title 11 of the United States Code (the “Bankruptcy Code”), and 

represent and agree as follows: 

RECITALS 

A. On January 29, 2019 (the “Petition Date”), the Debtors commenced the 

Chapter 11 Cases in the United States Bankruptcy Court for the Northern District of California (the 

“Bankruptcy Court”). 

B. By Order dated May 23, 2019 [Docket No. 2227], the Bankruptcy Court 

extended the time for the Debtors to assume or reject nonresidential real property leases to August 

27, 2019 pursuant to section 365(d)(4)(B)(i) of the Bankruptcy Code. 

C. By Order dated August 29, 2019 [Docket No. 3749], the Bankruptcy Court 

extended the time for the Debtors to assume or reject certain nonresidential real property leases, 

including those with the Lessor, as detailed in Schedule 1 therein (the “First Extended Deadline”). 

D. The Debtors propose to seek a further extension of time for the Debtors to 

assume or reject nonresidential real property leases with the Lessor from the Bankruptcy Court. 

Such an order requires the written consent of the Lessor pursuant to 11 U.S.C. § 365(d)(4)(B)(ii). 

E. The Lessor agrees to provide the Debtors with such consent. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, IT IS HEREBY 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THAT THE COURT ORDER 

THAT: 

1. The Lessor consents to—and this Stipulation hereby constitutes “prior written 

consent of the lessor,” as required by section 365(d)(4)(B)(ii) of the Bankruptcy Code for—an 

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

extension or extensions (the “Extension”) to the time within which a Debtor must assume or reject 

any nonresidential real property lease to which it and the Lessor are party (the “Leases”) until June 

30, 2020 (the “Second Extended Deadline”). 

2. Pursuant to section 365(d)(4) of the Bankruptcy Code, the time period within 

which the Debtors must assume or reject the Leases is extended from the First Extended Deadline

through and including the Second Extended Deadline.

3. No further consent of Lessor shall be required for the sole purpose of granting 

the Extension, and the consent granted pursuant to this Stipulation is without prejudice to the 

Debtors’ right to seek further extensions as provided in section 365(d)(4) of the Bankruptcy Code, 

including beyond the Second Extended Deadline. 

4. Nothing contained in this Stipulation or any actions taken by the Debtors 

pursuant to relief consented to herein is intended or should be construed as: (a) an admission as to 

the validity or amount of any particular claim against the Debtors; (b) a waiver of the Debtors’ rights 

to dispute any particular claim on any grounds; (c) a promise or requirement to pay any particular 

claim; (d) an admission by the Debtors that any contract or lease, including the Leases, are executory

or unexpired, as applicable; (e) a waiver or limitation of the Debtors’ rights under the Bankruptcy 

Code or any other applicable law, including the Debtors’ right to assume, reject, and/or seek any 

other related relief with respect to any contract or lease; or (f) an alteration, amendment, or other 

modification of the terms of the Leases. 

5. Nothing contained in this Stipulation shall impair in any way Lessor’s right to 

file a claim for any pre-petition amounts due under the Leases. 

6. This Stipulation may be executed in multiple counterparts, each of which shall 

be deemed an original but all of which together shall constitute one and the same instrument. 

7. The Debtors are authorized to take all actions necessary to effectuate the relief 

granted pursuant to and in accordance with this Stipulation. 

8. The terms and conditions of this Stipulation shall be immediately effective and 

enforceable upon entry of an order approving the Stipulation. 

Case: 19-30088 Doc# 5175 Filed: 12/19/19 Entered: 12/19/19 14:43:44 Page 3 of

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9. The Bankruptcy Court retains sole and exclusive jurisdiction to enforce the 

provisions of this Stipulation. 

Case: 19-30088 Doc# 5175 Filed: 12/19/19 Entered: 12/19/19 14:43:44 Page 4 of

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Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

EXECUTION PAGE 

Dated: December 19, 2019 WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP 

By: /s/ Jane Kim 

Jane Kim 

Attorneys for Debtors 

and Debtors in Possession 

 

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