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LABATON SUCHAROW LLP

Thomas A. Dubbs

Louis Gottlieb

Carol C. Villegas

Jeffrey A. Dubbin (SBN 287199)

140 Broadway

New York, New York 10005

LOWENSTEIN SANDLER LLP

Michael S. Etkin (pro hac vice)

Andrew Behlmann (pro hac vice)

One Lowenstein Drive

Roseland, New Jersey 07068

Lead Counsel to Lead Plaintiff and the Class Bankruptcy Counsel to Lead Plaintiff

and the Class

MICHELSON LAW GROUP

Randy Michelson (SBN 114095)

220 Montgomery Street, Suite 2100

San Francisco, California 94104

Bankruptcy Counsel to Lead Plaintiff

and the Class

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION

- and –

PACIFIC GAS AND ELECTRIC COMPANY,

Debtors.

☒ Affects Both Debtors

☐ Affects PG&E Corporation

☐ Affects Pacific Gas and Electric Company

Case No. 19-30088 (DM) (Lead Case)

Chapter 11

(Jointly Administered)

STIPULATION REGARDING 

SCHEDULING WITH RESPECT TO 

SECURITIES LEAD PLAINTIFF’S 

MOTION TO APPLY BANKRUPTCY 

RULE 7023 TO CLASS PROOF OF 

CLAIM [ECF NO. 5042]

Objection Deadline: January 14, 2020 at 

4:00 PM (Pacific Time)

Reply Deadline: January 22, 2020 at 4:00 

PM (Pacific Time) 

Hearing Date: January 29, 2019 at 10:00 

AM (Pacific Time)

Case: 19-30088 Doc# 5198 Filed: 12/24/19 Entered: 12/24/19 14:03:10 Page 1 of

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WHEREAS, on December 9, 2019, Public Employees Retirement Association of New 

Mexico (“PERA”), the court-appointed lead plaintiff in the securities class action captioned as In 

re PG&E Corporation Securities Litigation, Case No. 18-03509 (the “Securities Litigation”) 

pending in the United States District Court for the Northern District of California, on behalf of 

itself and the proposed class it represents in the Securities Litigation (the “Class”), together with 

York County on behalf of the County of York Retirement Fund, City of Warren Police and Fire 

Retirement System, and Mid-Jersey Trucking Industry & Local No. 701 Pension Fund filed 

Securities Lead Plaintiff's Motion To Apply Bankruptcy Rule 7023 To Class Proof Of Claim Filed 

by Interested Party Securities Lead Plaintiff and the Proposed Class (the “Rule 7023 Motion”) 

[ECF No. 5042].

WHEREAS, concurrently with the filing of the Rule 7023 Motion, Lead Plaintiff filed a 

notice of hearing setting a hearing on the Rule 7023 Motion for the January 14, 2020 omnibus 

hearing [ECF No. 5043].

WHEREAS, PERA and the above-captioned debtors in possession (the “Debtors” and 

together with PERA, on behalf of itself and the Class, the “Parties”) have agreed to the briefing 

and hearing schedule set forth in this Stipulation for the Rule 7023 Motion.

NOW, THEREFORE, the Parties hereby stipulate and agree as follows, subject to approval 

of the Court:

1. The hearing on the Rule 7023 Motion is rescheduled to the January 29, 2020 omnibus 

hearing.

2. The Debtors shall have until January 14, 2020 at 4:00 p.m. (Pacific) to file their 

objection, if any, to the Rule 7023 Motion.

3. If the Debtors file an objection to the Rule 7023 Motion, PERA shall have until 

January 22, 2020 at 4:00 p.m. (Pacific) to file its reply, if any, in further support of the Rule 7023 

Motion.

Case: 19-30088 Doc# 5198 Filed: 12/24/19 Entered: 12/24/19 14:03:10 Page 2 of

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December 24, 2019

WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP

By: __/s/ Peter J. Benvenutti_______

Peter J. Benvenutti

Counsel to the Debtors in Possession

December 24, 2019

LOWENSTEIN SANDLER LLP 

MICHELSON LAW GROUP

By: ___/s/ Randy Michelson____

Randy Michelson

Bankruptcy Counsel to Lead Plaintiff and the Class

Case: 19-30088 Doc# 5198 Filed: 12/24/19 Entered: 12/24/19 14:03:10 Page 3 of

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