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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

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019

Tel: 212 474 1000 

Fax: 212 474 3700 

UNITED STATES BANKRUPTCY COURT 

 NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DECLARATION OF JESSICA LIOU IN 

SUPPORT OF EX PARTE MOTION OF 

DEBTORS PURSUANT TO B.L.R. 9006-1 

REQUESTING ORDER SHORTENING TIME 

FOR HEARING ON DEBTORS’ MOTION 

PURSUANT TO 11 U.S.C. §§ 363(b) AND 105(a) 

AND FED. R. BANKR. P. 6004 AND 9019 FOR 

ENTRY OF AN ORDER (I) AUTHORIZING 

THE DEBTORS TO SETTLE THE CLAIMS 

OF TUBBS PREFERENCE CLAIMANTS AND 

(II) GRANTING RELATED RELIEF 

[No Hearing Requested] 

Related Document: Dkt. 5287 

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# 5288 Filed: 01/06/20 Entered: 01/06/20 22:23:41 Page 1 of

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 I, Jessica Liou, pursuant to section 1746 of title 28 of the United States Code, hereby declare 

under penalty of perjury that the following is true and correct to the best of my knowledge, 

information, and belief: 

1. I am a partner at Weil, Gotshal & Manges LLP, attorneys for PG&E Corporation and 

Pacific Gas and Electric Company, as debtors and debtors in possession (collectively, “PG&E” or 

the “Debtors”). 

2. I submit this Declaration in support of the Ex Parte Motion of Debtors Pursuant To 

B.L.R. 9006-1 Requesting Order Shortening Time for Hearing on Debtors’ Motion Pursuant to 11 

U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9019 for Entry of an Order (i) 

Authorizing the Debtors to Settle the Claims of Tubbs Preference Claimants and (ii) Granting Related 

Relief (the “Motion to Shorten”), filed contemporaneously herewith.1 Except as otherwise indicated 

herein, the facts set forth in this Declaration are based upon my personal knowledge, information 

provided to me by the Debtors’ employees, or my opinion based upon my knowledge and experience. 

I am authorized to submit this Declaration on behalf of the Debtors. 

3. In the Motion to Shorten, the Debtors request that the Tubbs Settlement Motion be 

heard on an expedited basis at 10:00 a.m. (prevailing Pacific Time) on January 21, 2020, and that any 

responses or objections to the Tubbs Settlement Motion be in writing and filed with the Court and 

served by 4:00 p.m. (prevailing Pacific Time) on January 15, 2020. 

4. A hearing on January 21, 2020, was already scheduled on the Court’s calendar in these 

Chapter 11 Cases, with other matters already set for hearing involving the major constituencies. 

5. Prompt approval of the Tubbs Settlements as provided in the Tort Claimants RSA will 

allow the Debtors to expedite the plan confirmation timeline, their successful emergence from chapter 

11, and distributions to fire victims. 

1

 Capitalized terms used but not defined herein have the meanings ascribed to them in the Debtors’ 

Motion Pursuant to 11 U.S.C. §§ 363(b) and 105(b) and Fed. R. Bankr. P. 6004 and 9019 for Entry 

of an Order (i) Authorizing the Debtors to Settle the Claims of Tubbs Preference Claimants and (ii) 

Granting Related Relief (the “Tubbs Settlement Motion”) or the Motion to Shorten, as applicable. 

Case: 19-30088 Doc# 5288 Filed: 01/06/20 Entered: 01/06/20 22:23:41 Page 2 of

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6. Shortening time for a hearing on the Tubbs Settlement Motion will also save the 

Debtors and their estates significant time and attorneys’ fees that would otherwise be devoted to 

preparing for the contingency of a Tubbs jury trial, and allow the Debtors and their professionals to 

turn their full efforts toward expeditiously confirming the Debtors’ Amended Plan. 

7. The Debtors previewed the relief requested in the Motion to Shorten with the TCC and 

the TCC consents to the relief sought therein. The Debtors also sought consent from the U.S. Trustee 

and Creditors Committee to the relief requested in the Motion to Shorten, however, the U.S. Trustee 

and Creditors Committee have not yet provided their consent. 

8. Given the exigencies and the sensitivities concerning the relief requested in the Tubbs 

Settlement Motion, it was not feasible to seek consent from other parties prior to the filing of the 

Motion to Shorten. However, cause exists to hear the Tubbs Settlement Motion on shortened time, as 

described therein, in the Motion to Shorten, and in the related filings. 

 

Case: 19-30088 Doc# 5288 Filed: 01/06/20 Entered: 01/06/20 22:23:41 Page 3 of

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I declare under penalty of perjury that, to the best of my knowledge and after reasonable 

inquiry, the foregoing is true and correct and that this Declaration was executed in New York, NY, on 

January 6, 2020. 

/s/ Jessica Liou

Jessica Liou 

Case: 19-30088 Doc# 5288 Filed: 01/06/20 Entered: 01/06/20 22:23:41 Page 4 of

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