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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) 

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) 

Worldwide Plaza 

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 - 

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

STIPULATION AMONG PARTIES 

EXTENDING TIME TO FILE 

SUBMISSIONS WITH RESPECT TO FEE 

EXAMINER PROTOCOL 

Re: Dkt. No. 3950 

[No Hearing Requested] 

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# 4252 Filed: 10/17/19 Entered: 10/17/19 13:30:41 Page 1 of

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This stipulation and agreement for order (“Stipulation and Agreement for Order”) is 

entered into by and among Bruce Markell, as Court-appointed Fee Examiner (the “Fee 

Examiner”) in the above-captioned cases, the Office of the United States Trustee (the “U.S. 

Trustee”), and the undersigned professionals (collectively, the “Parties,” and each, a “Party”). 

The Parties hereby stipulate and agree as follows: 

RECITALS 

A. On September 19, 2019, the Fee Examiner filed the Motion to Approve Fee 

Procedures [Dkt. No. 3950] (the “Fee Examiner Protocol Motion”), which the Court heard on 

October 7, 2019 (the “Hearing”). 

B. At the conclusion of the Hearing, the Court directed that the Parties meet and 

confer with respect to the protocol proposed by the Fee Examiner (the “Fee Examiner 

Protocol”), and that the following be filed by October 17, 2019 (collectively, the “Further 

Submissions”): 

a. A revised Fee Examiner Protocol based upon the Parties’ meet-andconfer; 

b. A response by the Fee Examiner to the oppositions filed to the Fee 

Examiner Protocol; and 

c. A statement from a senior officer of PG&E Corporation regarding his or 

her position on the matters. 

C. Based upon productive discussions held pursuant to the Court’s meet and confer 

suggestion, the Parties are working towards amending the existing protocol to address all 

objections made to date and have mutually agreed to extend the deadline for the filing of the 

Further Submissions. 

NOW, THEREFORE, UPON THE FOREGOING RECITALS, WHICH ARE 

INCORPORATED AS THOUGH FULLY SET FORTH HEREIN, IT HEREBY IS 

STIPULATED AND AGREED, BY AND BETWEEN THE PARTIES, THROUGH THE 

UNDERSIGNED, AND THE PARTIES JOINTLY REQUEST THE COURT TO ORDER, 

THAT:

Case: 19-30088 Doc# 4252 Filed: 10/17/19 Entered: 10/17/19 13:30:41 Page 2 of

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1. The time for the Parties to file the Further Submissions is extended through October 

24, 2019. 

[Signatures on Next Page] 

Case: 19-30088 Doc# 4252 Filed: 10/17/19 Entered: 10/17/19 13:30:41 Page 3 of

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Dated: October 17, 2019

KELLER & BENVENUTTI LLP OFFICE OF THE UNITED STATES 

TRUSTEE 

/s/ Jane Kim /s/ Jason Blumberg

Jane Kim

Attorneys for Debtors 

and Debtors in Possession

BRUCE MARKELL 

/s/ Bruce Markell 

Jason Blumberg

Trial Attorney 

Attorney for Andrew R. Vara, 

Acting United States Trustee for Region 31

MILBANK LLP 

/s/ Thomas Kreller 

Bruce Markell

Court-Appointed Fee Examiner 

CRAVATH, SWAINE & MOORE LLP 

/s/ Paul H. Zumbro 

Thomas Kreller

Attorneys for the Official Committee of 

Unsecured Creditors

BAKER & HOSTETLER LLP 

/s/ Elizabeth A. Green 

Paul H. Zumbro

Attorneys for Debtors 

and Debtors in Possession

Elizabeth A. Green

Attorneys for the Official Committee of 

Tort Claimants 

1 Andrew R. Vara, Acting United States Trustee for Region 3, is acting in this appointment for Tracy Hope Davis, 

United States Trustee for Region 17, who is recused from the above-captioned cases.

Case: 19-30088 Doc# 4252 Filed: 10/17/19 Entered: 10/17/19 13:30:41 Page 4 of

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