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3491555.1

Isaac M. Pachulski (CA Bar No. 62337)

Debra I. Grassgreen (CA Bar No. 169978)

PACHULSKI STANG ZIEHL & JONES LLP

150 California Street, 15th Floor

San Francisco, CA 94111

Telephone: (415) 263-7000

Facsimile: (415) 263-7010

Email: dgrassgreen@pszjlaw.com

Eric Seiler (admitted pro hac vice)

Jason C. Rubinstein (admitted pro hac vice)

FRIEDMAN KAPLAN SEILER AND ADELMAN LLP

7 Times Square

New York, NY 10036-6516

Telephone (212) 833-1103

Facsimile (212) 373-7903

Email: eseiler@fklaw.com

Attorneys for The Baupost Group, L.L.C., 

as the managing general partner and investment 

manager for certain entities that indirectly 

hold subrogation claims

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)

Chapter 11 

Bankr. Case No. 19-30088 (DM) 

(Jointly Administered)

JOINDER OF THE BAUPOST GROUP, L.L.C. 

IN THE AD HOC GROUP OF SUBROGATION 

CLAIM HOLDERS’ OBJECTION TO THE 

MOTION OF THE AD HOC COMMITTEE OF 

SENIOR UNSECURED NOTEHOLDERS FOR 

RECONSIDERATION AND RELIEF FROM 

ORDERS PURSUANT TO FEDERAL RULES 

OF CIVIL PROCEDURE 59(e) AND 60(b)

Date: January 21, 2020

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

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

The Baupost Group, L.L.C., as the managing general partner and investment manager for 

certain entities that indirectly hold subrogation claims (“Baupost”) hereby submits this Joinder (the 

“Joinder”) in the Objection of the Ad Hoc Group of Subrogation Claim Holders to the Motion of the 

Case: 19-30088 Doc# 5376 Filed: 01/14/20 Entered: 01/14/20 16:14:27 Page 1 of

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3491555.1

Ad Hoc Committee of Senior Unsecured Noteholders for Reconsideration and Relief from Order 

Pursuant to Federal Rules of Civil Procedure 59(e) and 60(b) [Dkt. No. 5366] (the “Subrogation 

Group Opposition”). Baupost is a substantial creditor of these estates, a major holder of insurance 

subrogation claims, and a member of the Steering Committee of the Ad Hoc Group of Subrogation 

Claim Holders. 

For the reasons set forth in the Subrogation Group Opposition, the Motion of the Ad Hoc 

Committee of Senior Unsecured Noteholders for Reconsideration and Relief from Order Pursuant to 

Federal Rules of Civil Procedure 59(e) and 60(b) [Dkt. No. 5241] (the “Motion”) falls well short of 

the Ninth Circuit’s established standard for reconsideration under Federal Rules of Civil Procedure 

59 and 60. Put simply, the Bondholders’1 deliberate tactical decision to wait until after this Court 

approved the RSAs to announce their intention to amend their plan and pay individual wildfire 

victims in cash does not constitute “newly discovered evidence” that justifies reconsideration of this 

Court’s Orders of December 19, 2019 [Dkt. Nos. 5173 & 5174]. 

Baupost joins in in the Subrogation Group Opposition in full and respectfully submits that 

the Motion should be denied. 

Dated: January 14, 2020 PACHULSKI STANG ZIEHL & JONES LLP

/s/ Debra I. Grassgreen

Isaac M. Pachulski

Debra I. Grassgreen

- and -

Eric Seiler (admitted pro hac vice)

Jason C. Rubinstein (admitted pro hac vice)

FRIEDMAN KAPLAN SEILER 

AND ADELMAN LLP

Attorneys for The Baupost Group, L.L.C., 

as the managing general partner and investment 

manager for certain entities that indirectly 

hold subrogation claims

 1 Capitalized terms not defined herein shall have the meanings ascribed to them in the Subrogation Group 

Opposition.

Case: 19-30088 Doc# 5376 Filed: 01/14/20 Entered: 01/14/20 16:14:27 Page 2 of

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