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REBECCA J. WINTHROP (CA Bar No. 116386)

ROBIN BALL (CA Bar No. 159698)

NORTON ROSE FULBRIGHT US LLP

555 South Flower Street, Forty-First Floor

Los Angeles, California 90071

Telephone: (213) 892-9200

Facsimile: (213) 892-9494

rebecca.winthrop@nortonrosefulbright.com

robin.ball@nortonrosefulbright.com

Attorneys for Creditors ADVENTIST HEALTH 

SYSTEM/WEST and FEATHER RIVER 

HOSPITAL D/B/A ADVENTIST HEALTH 

FEATHER RIVER

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)

STIPULATION BY AND AMONG THE

DEBTORS, THE UNITED STATES OF 

AMERICA, CERTAIN CALIFORNIA 

STATE AGENCIES AND THE 

ADVENTIST CLAIMANTS RE: 

DESIGNATION OF CLAIMS AS 

UNLIQUIDATED AND SUBJECT TO 

ESTIMATION UNDER SECTION 502(c) 

OF THE BANKRUPTCY CODE [DE # 

4553]

 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).

Hearing Date and Time:

Date: December 17, 2019

Time: 10:00 a.m. (Pacific Time)

Place: Courtroom 17

 450 Golden Gate Ave., 16th Floor

 San Francisco, CA 94102

Case: 19-30088 Doc# 5066 Filed: 12/11/19 Entered: 12/11/19 09:04:57 Page 1 of

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TO THE HONORABLE DENNIS MONTALI, UNITED STATES BANKRUPTCY JUDGE:

PLEASE TAKE NOTICE that PG&E Corporation and Pacific Gas and Electric Company, 

as debtors and debtors in possession (collectively, the “Debtors”), Creditors Adventist Health 

System/West and Feather River Hospital d/b/a Adventist Health Feather River, each a California 

religious non-profit corporation (together, the “Adventist Health Claimants”), the United States of 

America, on behalf of various federal agencies (collectively, the “United States Agencies”), and 

the California Department of Forestry and Fire Protection, California Department of Toxic 

Substances Control, California Governor’s Office of Emergency Services, California Department 

of Veterans Affairs, California State University, Chico, California Department of Parks and 

Recreation, California Department of Transportation, California Department of Developmental 

Services and California Department of Water Resources (collectively, the “California State 

Agencies”), by and through their counsel of record, hereby request that this Court stay certain 

deadlines and hearing dates as further set forth below. In support of such request, the parties hereto 

respectfully represent as follows:

RECITALS

A. WHEREAS, on October 31, 2019, this Court entered its Order Establishing PreConfirmation Briefing and Hearing Schedule for Certain Legal Issues [Dkt. # 4540] (the 

“Scheduling Order”), which established, among other things, a briefing schedule and hearing date 

regarding whether certain claims asserted against the Debtors by the United States Agencies, by 

the California State Agencies and by the Adventist Claimants are unliquidated and thus subject to 

estimation under section 502(c) of the Bankruptcy Code (the “Liquidated Claims Issues”). The 

Scheduling Order established December 12, 2019, as the date by which the Adventist Claimants, 

the United States Agencies and the California State Agencies may file their separate reply briefs 

(collectively, the “Reply Briefs”), and December 17, 2019 at 10:00 a.m. as the date and time at 

which the Court will hear oral argument on the Estimation Issues (the “Hearing on Liquidated 

Claims Issues”).

B. WHEREAS, on December 9, 2019, the Debtors announced that they had entered 

into a Restructuring Support Agreement with the Official Committee of Tort Claimants 

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(the “TCC”) and various other parties (the “TCC RSA”), which obligates the Debtors to, among 

other things, file a motion seeking approval of the TCC RSA (the “TCC RSA Approval Motion”) 

on shortened notice and obtain a stay of the estimation proceedings currently pending before the 

U.S. District Court for the Northern District of California (the “District Court”).

C. WHEREAS, on December 9, 2019, the District Court issued a docket order stating 

that, “[i]n light of the settlement motion, the case is stayed pending further order of the Court.” 

[Dist. Ct. Dkt. # 265.]

D. WHEREAS, on December 9, 2019, the Debtors filed with this Court the TCC RSA 

Approval Motion [Dkt. # 5038] and a supporting declaration [Dkt. # 5039].

E. WHEREAS, pending this Court’s consideration of the TCC RSA Approval Motion, 

the parties have agreed to continue the deadline for submitting the Reply Briefs and the Hearing on 

Liquidated Claims Issues, all as further set forth below. 

STIPULATION

NOW, THEREFORE, and subject to the approval of this Court, the Debtors, the Adventist 

Health Claimants, the United States Agencies and the California State Agencies hereby agree as 

follows:

1. The recitals set forth above are hereby incorporated by reference as though fully set 

forth herein.

2. The Parties agree that the deadline for submission of the Reply Briefs and the 

Hearing on Liquidated Claims Issues shall be, and hereby are, continued to such further dates which 

may be ordered by this Court pursuant to Paragraph 3 below, assuming such dates become 

necessary as indicated below.

3. In the event that (a) the estimation proceedings in the District Court are no longer 

stayed, (b) the TCC RSA is not approved by this Court at the hearing therefor, (c) this Court 

adjourns the hearing on the TCC RSA to a later date, or (d) the TCC RSA is terminated for any 

reason whatsoever, then the parties shall, within seven (7) calendar days, meet and confer regarding 

the manner in which the Hearing on Liquidated Claims Issues shall go forward, including the dates 

on which the Reply Briefs may be filed and the Hearing on Liquidated Claims Issues shall take 

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place, and report to this Court concerning their agreements and/or respective positions concerning 

these matters. Upon receipt of such a report, the Court will determine the new date on which the 

Reply Briefs shall be filed and the new date and time at which the Hearing on Liquidated Claims 

Issues shall take place.

4. Nothing in this Stipulation shall constitute consent by the Adventist Claimants, the 

United States Agencies, or the California State Agencies to the TCC RSA Approval Motion, or a 

waiver of any of their rights with respect thereto, including filing any response to the TCC RSA 

Approval Motion.

Dated: December 11, 2019 RESPECTFULLY SUBMITTED:

REBECCA J. WINTHROP

ROBIN BALL

NORTON ROSE FULBRIGHT US LLP

By: /s/ Rebecca J. Winthrop

REBECCA J. WINTHROP

Attorney for Creditors ADVENTIST 

HEALTH SYSTEM/WEST and 

FEATHER RIVER HOSPITAL D/B/A 

ADVENTIST HEALTH FEATHER 

RIVER

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Dated: December 11, 2019 XAVIER BECERRA 

Attorney General of California

MARGARITA PADILLA

Supervising Deputy Attorney General

By: /s/ Paul J. Pascuzzi

STEVEN H. FELDERSTEIN

PAUL J. PASCUZZI

FELDERSTEIN FITZGERALD

WILLOUGHBY PASCUZZI & RIOS LLP

Attorneys for California Department of 

Forestry and Fire Protection, California 

Department of Toxic Substances Control, 

California Governor’s Office of 

Emergency Services, California 

Department of Veterans Affairs, California 

State University, California Department of 

Parks and Recreation, California 

Department of Transportation, California 

Department of Developmental Services 

and California Department of Water 

Resources

Dated: December 11, 2019 WEIL, GOTSHAL & MANGES LLP

CRAVATH, SWAINE & MOORE LLP

KELLER & BENVENUTTI LLP

By: /s/ Paul H. Zumbro

Counsel for the Debtors and Debtors in 

Possession

Dated: December 11, 2019 JOSEPH H. HUNT 

Assistant Attorney General

DAVID L. ANDERSON (CABN 149604)

United States Attorney

ROBIN M. WALL (CABN 235690)

Assistant United States Attorney

By: /s/ Matthew J. Troy

RUTH A. HARVEY

Director

KIRK MANHARDT

Deputy Director

MATTHEW J. TROY

Senior Trial Counsel

Attorneys for United States

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