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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 TORT CLAIMANTS RSA 

MOTION 

Related Document: Dkt. 5038 

[No hearing requested] 

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# 5041 Filed: 12/09/19 Entered: 12/09/19 18:05:21 Page 1 of

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I, Jessica Liou, do 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 Motion of the Debtors (the “Motion to 

Shorten”), pursuant to Rule 9006-1 of the Bankruptcy Local Rules for the United States Bankruptcy 

Court for the Northern District of California, for entry of an order shortening time for a hearing on 

December 17, 2019, at 10:00 a.m. (prevailing Pacific Time), on the 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 and TCC to Enter Into Restructuring Support Agreement With the TCC, 

Consenting Fire Claimant Professionals, and Shareholder Proponents and (II) Granting Related 

Relief (the “Tort Claimants RSA Motion”), filed contemporaneously herewith.1 The Debtors 

request that any responses or objections be in writing and filed with the Court and served by 

4:00 p.m. (prevailing Pacific Time) on December 13, 2019. 

3. The December 17, 2019 Omnibus Hearing was already scheduled on the Court’s 

calendar in these Chapter 11 Cases, with several other motions set for hearing. 

4. On December 9, 2019, I reached out to the U.S. Trustee, the TCC and the Creditors 

Committee to seek their respective consent to hearing the Tort Claimants RSA Motion on shortened 

notice. The TCC consented. As of the filing of the Motion to Shorten, the U.S. Trustee and the 

Creditors Committee have not yet provided their consent. 

5. Given the exigencies and the sensitivities concerning the relief requested in the Tort 

Claimants RSA 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 Tort Claimants RSA Motion on shortened 

time, as described in the Motion to Shorten. 

1

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

Claimants RSA Motion or the Motion to Shorten, as applicable. 

Case: 19-30088 Doc# 5041 Filed: 12/09/19 Entered: 12/09/19 18:05:21 Page 2 of

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6. As described in the Motion to Shorten and the Tort Claimants RSA Motion, the Tort 

Claimants RSA reflects a substantial compromise of the asserted Fire Victim Claims. The Tort 

Claimants RSA fairly resolves the largest remaining category of disputed claims asserted against the 

Debtors and will expedite the successful resolution of these Chapter 11 Cases by dispensing with the 

pending estimation proceedings and Tubbs trial and will pave the way toward confirmation of the 

Amended Plan well within the June 30, 2020 deadline established under AB 1054. 

7. Time is of the absolute essence. As an initial matter, because of the pending Tubbs 

trial and estimation proceedings, if the Tort Claimants RSA is not approved by this Court by 

December 20, 2019, it automatically terminates. The Tubbs trial is scheduled to begin with jury 

selection on January 7, 2020, with the estimation proceedings to commence before the District Court 

shortly thereafter on February 18, 2020. The parties are devoting massive amounts of time and 

resources in anticipation of moving ahead with those proceedings in accordance with the compressed 

schedules previously established. Consideration of the Tort Claimants RSA on shortened notice is 

essential for the parties to know whether the estimation proceedings and the Tubbs trial will be 

proceeding as scheduled or will be resolved as provided in the Tort Claimants RSA. Pursuant to the 

Tort Claimants RSA, the estimation proceedings have been temporarily stayed by the District Court 

and the parties have agreed to seek a 15-day continuance of the Tubbs trial and are scheduled to 

appear before the Superior Court of the State of California tomorrow morning. Whether the 

estimation proceedings or Tubbs trial will recommence depends on the outcome of the hearing on 

the Tort Claimants RSA Motion, and accordingly, the parties need to know promptly whether those 

proceedings will move forward or not. 

I declare under penalty of perjury that, after reasonable inquiry, the foregoing is true and 

correct to the best of my knowledge, information, and belief, and this declaration was executed at 

Jackson Heights, NY, on December 9, 2019. 

/s/ Jessica Liou

Jessica Liou 

Case: 19-30088 Doc# 5041 Filed: 12/09/19 Entered: 12/09/19 18:05:21 Page 3 of

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