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Sim

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425 Lexington

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Jonathan Sanders (No. #228785) 

SIMPSON THACHER & BARTLETT LLP 

2475 Hanover Street 

Palo Alto, CA 94304 

Telephone: (650) 251-5000 

Facsimile: (650) 252-5002 

Michael H. Torkin 

Nicholas Goldin 

Kathrine A. McLendon 

Jamie J. Fell 

SIMPSON THACHER & BARTLETT LLP 

425 Lexington Avenue 

New York, NY 10017 

Telephone: (212) 455-2000 

Facsimile: (212) 455-2502 

Counsel for the Board of Each of PG&E Corporation 

and Pacific Gas and Electric Company and for 

CertainCurrent and Former Independent Directors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

- and – 

PACIFIC 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). 

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

CERTIFICATE OF NO OBJECTION 

REGARDING FIFTH MONTHLY FEE 

STATEMENT OF SIMPSON THACHER & 

BARTLETT LLP FOR ALLOWANCE AND 

PAYMENT OF COMPENSATION AND 

REIMBURSEMENT OF EXPENSES FOR 

THE PERIOD OF AUGUST 1, 2019 

THROUGH AUGUST 31, 2019 

Re: Docket No. 4521 

Objection Deadline: November 20, 2019 

 4:00 pm (Pacific Time) 

Case: 19-30088 Doc# 4848 Filed: 11/22/19 Entered: 11/22/19 13:52:01 Page 1 of

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425 Lexington

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017

On October 30, 2019, Simpson Thacher & Bartlett LLP (“Simpson Thacher”), counsel 

for (i) the Board of Directors (the “Board”) of each of PG&E Corporation and Pacific Gas and 

Electric Company (the “Debtors”), as the Board may be constituted from time to time, and for 

the members of the Board from time to time in their capacities as members of the Board, and (ii) 

certain current and former independent directors in their individual capacities who serve or 

served as independent directors prior to and/or as of the Petition Date (as defined below) (each 

an “Independent Director” and collectively, the “Independent Directors”), filed its Fifth 

Monthly Fee Statement of Simpson Thacher & Bartlett LLP for Allowance and Payment of 

Compensation and Reimbursement of Expenses for the Period August 1, 2019 through August 

31, 2019, pursuant to the Order Pursuant to 11 U.S.C. §§ 331 and 105(a) and Fed. R. Bankr. P. 

2016 for Authority to Establish Procedures for Interim Compensation and Reimbursement of 

Expenses of Professionals, dated February 27, 2019 [Docket No. 701] (the “Interim Procedures 

Order”). 

The Fifth Monthly Fee Statement was served as described in the Certificate of Service of 

Sonia Akter [Docket No. 4567]. The deadline to file responses or oppositions to the Fifth 

Monthly Fee Statement was November 20, 2019 at 4:00 pm (PT). On November 20, an 

objection was filed by the Public Employees Retirement Association of New Mexico objecting 

to a portion of Simpson Thacher’s fees totaling $5,003.00 [Docket No. 4822] (the “PERA 

Objection”).1 No other oppositions or responses have been filed with the Court or received by 

Simpson Thacher. Pursuant to the Interim Compensation Order, the Debtors are authorized to 

pay Simpson Thacher eighty percent (80%) of the remaining fees that are not subject to an 

objection and one hundred percent (100%) of the expenses requested in the Fifth Monthly Fee 

Statement upon the filing of this certification without the need for a further order of the Court. A 

summary of the fees and expenses sought by Simpson Thacher is annexed hereto as Exhibit A. 

 

1

 Simpson Thacher does not agree with the assertions made in the PERA Objection and reserves all rights to dispute 

the PERA Objection, and any future objections made on similar grounds, either before or in connection with any 

hearing to consider the applicable interim fee applications. 

Case: 19-30088 Doc# 4848 Filed: 11/22/19 Entered: 11/22/19 13:52:01 Page 2 of

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The undersigned hereby declares, pursuant to 28 U.S.C. § 1746, under penalty of perjury, 

that: 

1. I am a counsel at the law firm Simpson Thacher & Bartlett LLP, counsel 

to the Board and the Independent Directors. 

2. I certify that I have reviewed or caused the review of the Court’s docket in 

these chapter 11 cases and that Simpson Thacher has not received any response or opposition to 

the Fifth Monthly Fee Statement other than the PERA Objection. 

3. This declaration was executed in Palo Alto, California. 

Dated: November 22, 2019 

 Palo Alto, California 

SIMPSON THACHER & BARTLETT LLP 

/s/ Jonathan Sanders 

Jonathan Sanders (No. 228785)

Counsel for the Board of Each of PG&E 

Corporation and Pacific Gas and Electric 

Company and for Certain Current and 

Former Independent Directors 

Case: 19-30088 Doc# 4848 Filed: 11/22/19 Entered: 11/22/19 13:52:01 Page 3 of

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