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Dennis F. Dunne (admitted pro hac vice) 

Samuel A. Khalil (admitted pro hac vice) 

MILBANK LLP 

55 Hudson Yards 

New York, New York 10001-2163 

Telephone: (212) 530-5000 

Facsimile: (212) 530-5219 

and 

Gregory A. Bray (SBN 115367) 

Thomas R. Kreller (SBN 161922) 

MILBANK LLP 

2029 Century Park East, 33rd Floor 

Los Angeles, CA 90067 

Telephone: (424) 386-4000 

Facsimile: (213) 629-5063 

Counsel for the Official Committee 

of Unsecured Creditors

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STATEMENT OF THE OFFICIAL 

COMMITTEE OF UNSECURED 

CREDITORS IN SUPPORT OF THE 

DEBTORS’ SECOND OMNIBUS MOTION 

PURSUANT TO 11 U.S.C § 365(a), FED. R. 

BANKR. P. 6006, AND B.L.R. 6006-1 FOR 

AN ORDER (I) APPROVING 

ASSUMPTION OF CONTRACTS IN 

CONNECTION WITH THE 

COMMUNITY PIPELINE SAFTETY 

INITIATIVE AND (II) GRANTING 

RELATED RELIEF

Date: August 14, 2019 

Time: 9:30 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 450 Golden Gate Avenue 

 San Francisco, CA 94102 

Re: Docket No. 3176 

 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# 3384 Filed: 08/06/19 Entered: 08/06/19 13:47:46 Page 1 of

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44553.00001

The Official Committee of Unsecured Creditors (the “Official Committee”) respectfully 

submits this statement in support of the Debtors’ Second Omnibus Motion Pursuant to 11 U.S.C 

§ 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 for an Order (I) Approving Assumption of 

Contracts in Connection with the Community Pipeline Safety Initiative and (II) Granting Related 

Relief (the “CPSI Motion”) [Docket No. 3176].1 

STATEMENT 

The Official Committee fully supports efforts by the Debtors to enhance and ensure the 

safe and reliable operation of their businesses. The Official Committee views the CPSI Motion as 

a positive step towards protecting the Debtors’ customers and other community residents in the 

areas where the Pipeline System is located. By assuming the CPSI Agreements, the Debtors will 

better be able to safeguard continued access to their Pipeline System to: (i) inspect, maintain and 

monitor the system’s integrity; (ii) undertake preventative measures; (iii) implement the CPSI 

safety program; and (iv) grant access to first responders and safety crews in emergency situations. 

Assuring such access is critical to both the continued safe operation of the Pipeline System and 

allowing the Debtors to comply with various federal, state and local safety and operational 

regulations. As such, the Official Committee believes that assuming the CPSI Agreements is a 

sound exercise of the Debtors’ “business judgement” and supports the Court’s approval of the 

relief sought in the CPSI Motion. 

[Remainder of Page Intentionally Left Blank] 

 

1

 Capitalized terms not defined herein have the meaning ascribed to them in the CPSI Motion. 

Case: 19-30088 Doc# 3384 Filed: 08/06/19 Entered: 08/06/19 13:47:46 Page 2 of

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44553.00001

CONCLUSION

For the reasons set forth above, the Official Committee respectfully requests that the Court 

grant the CPSI Motion and such other relief as may be appropriate.

Dated: August 6, 2019 

MILBANK LLP 

/s/Gregory A. Bray . 

DENNIS F. DUNNE 

SAMUEL A. KHALIL 

GREGORY A. BRAY 

THOMAS R. KRELLER 

Counsel for the Official Committee of 

Unsecured Creditors 

Case: 19-30088 Doc# 3384 Filed: 08/06/19 Entered: 08/06/19 13:47:46 Page 3 of

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