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LABATON SUCHAROW LLP 

Thomas A. Dubbs 

Louis Gottlieb 

Carol C. Villegas 

Jeffrey A. Dubbin (SBN 287199) 

140 Broadway 

New York, New York 10005 

LOWENSTEIN SANDLER LLP 

Michael S. Etkin (pro hac vice)

Andrew Behlmann (pro hac vice) 

One Lowenstein Drive 

Roseland, New Jersey 07068

Lead Counsel to Lead Plaintiff and the 

Proposed Class 

Bankruptcy Counsel to Lead Plaintiff 

and the Proposed Class 

MICHELSON LAW GROUP 

Randy Michelson (SBN 114095) 

220 Montgomery Street, Suite 2100 

San Francisco, California 94104 

Additional counsel listed on Exhibit A 

Bankruptcy Counsel to Lead Plaintiff 

and the Proposed Class 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

 - and – 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

☒ Affects Both Debtors 

☐ Affects PG&E Corporation 

☐ Affects Pacific Gas and Electric Company 

Case No. 19-30088 (DM) (Lead Case) 

Chapter 11 

(Jointly Administered) 

SECURITIES LEAD PLAINTIFF’S 

LIMITED OBJECTION TO SIXTH 

MONTHLY FEE STATEMENT OF 

SIMPSON THACHER & BARTLETT LLP 

FOR ALLOWANCE AND PAYMENT OF 

COMPENSATION AND 

REIMBURSEMENT OF EXPENSES FOR 

THE PERIOD OF SEPTEMBER 1, 2019 

THROUGH SEPTEMBER 30, 2019 [ECF 

NO. 4892] 

Objection Deadline: December 18, 2019 at 

4:00 PM (Pacific Time) 

 

(No hearing set) 

Case: 19-30088 Doc# 5158 Filed: 12/18/19 Entered: 12/18/19 08:41:42 Page 1 of

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Public Employees Retirement Association of New Mexico (“Lead Plaintiff” or “PERA”), 

the court-appointed lead plaintiff in the securities class action captioned as In re PG&E 

Corporation Securities Litigation, Case No. 18-03509 (the “Securities Litigation”) pending in 

the U.S. District Court for the Northern District of California (the “District Court”), on behalf of 

itself and the proposed class it represents in the Securities Litigation (the “Class”), together with 

York County on behalf of the County of York Retirement Fund, City of Warren Police and Fire 

Retirement System, and Mid-Jersey Trucking Industry & Local No. 701 Pension Fund, hereby 

submit this limited and continuing objection (the “Limited Objection”) to the Sixth Monthly Fee 

Statement of Simpson Thacher & Bartlett LLP for Allowance and Payment of Compensation and 

Reimbursement of Expenses for the Period of September 1, 2019 Through September 30, 2019

(the “Sixth Fee Statement”) [ECF No. 4892] filed by Simpson Thacher & Bartlett LLP 

(“Simpson Thacher”) in connection with its representation of certain defendants in the Securities 

Litigation who are current and former independent directors (the “Independent Director 

Defendants”) of the debtors in possession (the “Debtors”) in the above-captioned chapter 11 

cases (the “Chapter 11 Cases”). In support of this Limited Objection, Lead Plaintiff relies upon 

(a) Securities Lead Plaintiff's Limited Objection to Fourth Monthly Fee Statement of Simpson 

Thacher & Bartlett LLP for Allowance and Payment of Compensation and Reimbursement of 

Expenses for the Period of July 1, 2019 Through July 31, 2019 (ECF No. 4032) (the “Initial 

Objection”) [ECF No. 4351], which Lead Plaintiff incorporates herein by reference, and (b) the 

declaration of Ty R. Sagalow submitted with the Initial Objection. Capitalized terms used but 

not defined in this Limited Objection have the meanings given thereto in the Initial Objection. In 

support of this Limited Objection, Lead Plaintiff respectfully states as follows: 

Case: 19-30088 Doc# 5158 Filed: 12/18/19 Entered: 12/18/19 08:41:42 Page 2 of

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LIMITED OBJECTION 

For the reasons set forth in the Initial Objection, Lead Plaintiff objects to payment of the 

fees requested by Simpson Thacher under Task Code L200 in Exhibit B to the Sixth Fee 

Statement (the “Disputed Fees”), totaling $380,184.50, all of which appear to relate to Simpson 

Thacher’s defense of the Independent Director Defendants in the Securities Litigation. 

CONCLUSION 

For the reasons set forth in the Initial Objection, Lead Plaintiff respectfully requests that 

the Court enter an order (a) finding that the Debtors are prohibited from paying the Disputed 

Fees or any other defense costs incurred by the Independent Director Defendants in the 

Securities Litigation and (b) direct the Debtors and Independent Director Defendants to instead 

seek payment of the Disputed Fees (to the extent reasonable and necessary), and any other 

reasonable and necessary defense costs incurred by the Independent Director Defendants in the 

Securities Litigation, from the Side A D&O Coverage under the D&O Policies. 

Dated: December 18, 2019 LOWENSTEIN SANDLER LLP 

MICHELSON LAW GROUP 

By: /s/ Randy Michelson 

Randy Michelson (SBN 114095) 

Bankruptcy Counsel to Lead Plaintiff and the Class 

Case: 19-30088 Doc# 5158 Filed: 12/18/19 Entered: 12/18/19 08:41:42 Page 3 of

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EXHIBIT A 

COUNSEL 

LOWENSTEIN SANDLER LLP 

Michael S. Etkin (pro hac vice) 

Andrew Behlmann (pro hac vice) 

One Lowenstein Drive 

Roseland, New Jersey 07068 

Telephone 973-597-2500 

Facsimile 973-597-2333 

metkin@lowenstein.com 

abehlmann@lowenstein.com 

MICHELSON LAW GROUP 

Randy Michelson, Esq. (SBN 114095) 

220 Montgomery Street, Suite 2100 

San Francisco, CA 94104 

Telephone 415-512-8600 

Facsimile 415-512-8601 

randy.michelson@michelsonlawgroup.com 

Bankruptcy Counsel to Lead Plaintiff and the Proposed Class 

LABATON SUCHAROW LLP

Thomas A. Dubbs 

Louis Gottlieb 

Carol C. Villegas 

Jeffrey A. Dubbin (SBN 287199) 

Aram Boghosian 

140 Broadway 

New York, New York 10005 

Telephone 212-907-0700 

tdubbs@labaton.com 

lgottlieb@labaton.com 

cvillegas@labaton.com 

jdubbin@labaton.com 

aboghosian@labaton.com 

Lead Counsel to Lead Plaintiff and the 

Proposed Class 

WAGSTAFFE, VON LOEWENFELDT, 

BUSCH & RADWICK, LLP 

James M. Wagstaffe (SBN 95535) 

Frank Busch (SBN 258288) 

100 Pine Street, Suite 725 

San Francisco, California 94111 

Telephone 415-357-8900 

wagstaffe@wvbrlaw.com 

busch@wvbrlaw.com 

Liaison Counsel for the Proposed Class

ROBBINS GELLER RUDMAN & DOWD LLP 

Darren J. Robbins (SBN 168593) 

Brian E. Cochran (SBN 286202) 

655 West Broadway, Suite 1900 

San Diego, California 92101 

Telephone 619-231-1058 

darrenr@rgrdlaw.com 

bcochran@rgrdlaw.com 

ROBBINS GELLER RUDMAN & DOWD LLP 

Willow E. Radcliffe (SBN 200089) 

Kenneth J. Black (SBN 291871) 

Post Montgomery Center 

One Montgomery Street, Suite 1800 

San Francisco, California 94104 

Telephone 415-288-4545 

willowr@rgrdlaw.com 

kennyb@rgrdlaw.com 

VANOVERBEKE, MICHAUD & 

TIMMONY, P.C.

Thomas C. Michaud 

79 Alfred Street 

Detroit, Michigan 48201 

Telephone 313-578-1200 

tmichaud@vmtlaw.com 

Additional Counsel for the Securities Act Plaintiffs 

Case: 19-30088 Doc# 5158 Filed: 12/18/19 Entered: 12/18/19 08:41:42 Page 4 of

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EXHIBIT B 

RESERVATION OF RIGHTS 

This Limited Objection and any subsequent pleading, appearance, argument, claim, 

or suit made or filed by Lead Plaintiff, either individually or for the Class or any member 

thereof, do not, shall not, and shall not be deemed to: 

a. constitute a submission by Lead Plaintiff, either individually or for the Class 

or any member thereof, to the jurisdiction of the Bankruptcy Court; 

b. constitute consent by Lead Plaintiff, either individually or for the Class or 

any member thereof, to entry by the Bankruptcy Court of any final order or 

judgment, or any other order having the effect of a final order or judgment, 

in any non-core proceeding, which consent is hereby withheld unless, and 

solely to the extent, expressly granted in the future with respect to a specific 

matter or proceeding; 

c. waive any substantive or procedural rights of Lead Plaintiff or the Class or 

any member thereof, including but not limited to (a) the right to challenge 

the constitutional authority of the Bankruptcy Court to enter a final order or 

judgment, or any other order having the effect of a final order or judgment, 

on any matter; (b) the right to have final orders and judgments, and any 

other order having the effect of a final order or judgment, in non-core 

matters entered only after de novo review by a United States District Court 

judge; (c) the right to trial by jury in any proceedings so triable herein, in the 

Chapter 11 Cases, including all adversary proceedings and other related 

cases and proceedings (collectively, “Related Proceedings”), in the Securities 

Litigation, or in any other case, controversy, or proceeding related to or 

arising from the Debtors, the Chapter 11 Cases, any Related Proceedings, or 

the Securities Litigation; (d) the right to seek withdrawal of the bankruptcy 

reference by a United States District Court in any matter subject to 

mandatory or discretionary withdrawal; or (e) all other rights, claims, 

actions, arguments, counterarguments, defenses, setoffs, or recoupments to 

which Lead Plaintiff or the Class or any member thereof are or may be 

entitled under agreements, at law, in equity, or otherwise, all of which are 

expressly reserved. 

 For the avoidance of doubt, Lead Plaintiff, on behalf of itself and the Class, does 

not, and will not impliedly, consent to this Court’s adjudication of, including through any 

order of this Court purporting to adjudicate, release, waive, enjoin, or otherwise impact, 

the claims of Lead Plaintiff and the Class or any member thereof against any defendant 

now or hereafter named in the Securities Litigation. 

Case: 19-30088 Doc# 5158 Filed: 12/18/19 Entered: 12/18/19 08:41:42 Page 5 of

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