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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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) 

Theodore Tsekerides (pro hac vice) 

(theodore.tsekerides@weil.com) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

New York, NY 10153-0119 

Tel: (212) 310-8000 

Fax: (212) 310-8007 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 636-9251 

Attorneys for Debtors and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

Bankruptcy Case

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

STIPULATION BETWEEN DEBTOR 

PACIFIC GAS AND ELECTRIC 

COMPANY AND TIGER NATURAL GAS, 

INC. FOR LIMITED RELIEF FROM THE 

AUTOMATIC STAY 

[Relates to Dkt. Nos. 4321-4322] 

[Regarding Motion Set for Hearing 

February 26, 2020 at 10:00 am] 

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) 

Case: 19-30088 Doc# 5431 Filed: 01/21/20 Entered: 01/21/20 16:34:10 Page 1 of

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This stipulation (the “Stipulation”) is entered into by and between Pacific Gas and Electric 

Company (the “Utility” or the “Debtor”), as debtor and debtor in possession, and movant Tiger 

Natural Gas, Inc. (“Tiger”). The Debtor and Tiger are referred to in this Stipulation collectively 

as the “Parties,” and each as a “Party.” The Parties hereby stipulate and agree as follows: 

RECITALS 

A. On October 18, 2019, Tiger filed the Motion for Relief from Stay Pursuant to 11 

U.S.C. § 362(d)(1) [Dkt. 4322] (the “Motion”). The Debtors filed their Preliminary Opposition 

to Tiger Natural Gas, Inc.’s Motion for Relief from the Automatic Stay Pursuant to 11 U.S.C. § 

362(d)(1) [Dkt. 4622] on November 8, 2019. On November 10, 2019, the Court issued a tentative 

ruling proposing to drop the hearing on the Motion (the “Hearing”) from the November 13, 2019 

omnibus calendar and resetting it for 2020. Tiger did not contest this tentative ruling. 

B. On January 7, 2020, the Court set the Hearing for February 26, 2020 at 10:00 a.m. 

C. In the Motion, Tiger seeks relief from the automatic stay to prosecute its claims in 

the case pending in the United States District Court for the Northern District of California (the 

“District Court”), Tiger Natural Gas, Inc. v. Pacific Gas and Electric Company, et al., Case No. 

4:16-CV-06711 (JSW) (the “Tiger Action”). 

D. Tiger filed the Tiger Action on November 18, 2016. Its complaint alleges claims 

against the Utility and three individual Utility employees (the “Individual Defendants”) relating 

to the Debtors’ billing and collection practices, based on causes of action asserted under California 

State law for intentional and negligent misrepresentation, intentional interference with contract, 

breach of contract, breach of fiduciary duty and the California Unfair Competition Law, and under 

the federal RICO and antitrust statutes. 

E. The Debtors and the Individual Defendants filed their answer, denying all 

allegations, on November 8, 2017. 

F. The Debtor and its parent, PG&E Corporation (collectively the “Debtors”), filed 

these Chapter 11 Cases on January 29, 2019 (the “Petition Date”). 

Case: 19-30088 Doc# 5431 Filed: 01/21/20 Entered: 01/21/20 16:34:10 Page 2 of

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G. On February 4, 2019, the Debtors filed a Notice of Bankruptcy Proceeding in the 

Tiger Action based on these Chapter 11 Cases. On February 27, 2019, the District Court entered 

the Order Staying Case and Requiring Joint Status Reports, staying the Tiger Action as to both 

the Utility and the Individual Defendants. 

 NOW, THEREFORE, IT HEREBY IS STIPULATED AND AGREED BY AND 

BETWEEN THE PARTIES, THROUGH THE UNDERSIGNED, AND THE PARTIES 

JOINTLY REQUEST THE COURT TO ORDER, THAT:

1. This Stipulation shall be effective upon entry of an order by this Court 

approving it. 

2. The February 26 Hearing shall be taken off calendar. 

3. The Parties shall promptly engage in good faith settlement negotiations with 

respect to the Tiger Action. To that end, the Parties agree to engage a mediation neutral – Hon. 

Carl J. West (ret.), who has assisted the Parties in prior settlement efforts, if he is available; and if 

not, a neutral selected by mutual agreement – to serve as a settlement facilitator in the Parties’ 

informal settlement negotiations and, if those negotiations do not result in a settlement of the Tiger 

Action, to conduct a formal mediation session (the “Mediation”) on a mutually agreeable date that 

will afford sufficient time for informal settlement efforts before the Mediation. 

4. The automatic stay shall immediately be modified, to the extent necessary, 

to permit the Parties to engage in the settlement and mediation activities described in para. 3 above. 

The automatic stay shall remain in place for all other purposes. 

5. If the Parties’ settlement efforts, including the Mediation, do not result in a 

settlement between Utility and Tiger, Tiger may put the Motion back on calendar on reasonable 

notice. 

6. This Court shall retain jurisdiction to resolve any dispute regarding, and to 

enforce, the terms of this Stipulation and the order approving it. 

Case: 19-30088 Doc# 5431 Filed: 01/21/20 Entered: 01/21/20 16:34:10 Page 3 of

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Dated: January 21, 2020 Dated: January 21, 2020

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

HOLLAND & KNIGHT LLP 

/s/ Peter J. Benvenutti /s/ Leah E. Capritta

Peter J. Benvenutti

Attorneys for Debtors 

and Debtors in Possession

Leah E. Capritta

Attorneys for Tiger Natural Gas, Inc. 

Case: 19-30088 Doc# 5431 Filed: 01/21/20 Entered: 01/21/20 16:34:10 Page 4 of

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