STIPULATION AND [PROPOSED] ORDER REGARDING CASE MANAGEMENT CONFERENCE

SUSAN ILLSTON, District Judge.

WHEREAS on February 7, 2013, Plaintiff Iron Workers Mid-South Pension Fund ("Plaintiff") commenced this shareholder derivative action, captioned Iron Workers Mid-South Pension Fund v. Johns, et al., No. 3:13-cv-00550-SI ("Iron Workers Action"), on behalf of Nominal Defendant PG&E Corporation;

WHEREAS other shareholder derivative actions, putatively on behalf of PG&E and captioned San Bruno Fire Derivative Cases, JCCP No. 4648-C, and Tellardin v. Earley, et al., No. CIV 534119 (collectively, the "State Derivative Actions"), are pending before the Superior Court of California, County of San Mateo;

WHEREAS another shareholder derivative action, putatively on behalf of PG&E Corporation and its subsidiary Pacific Gas and Electric Company and captioned Bushkin v. Rambo, et al., No. 3:16-cv-00973-SI ("Bushkin Action"), was filed in this Court on February 27, 2016;

WHEREAS a criminal action against Pacific Gas and Electric Company, captioned United States v. Pacific Gas and Electric Company, No. 3:14-cr-00175-TEH (the "Criminal Action"), is pending in this District;

WHEREAS the court in the Criminal Action vacated the previously scheduled trial date of April 26, 2016, and is expected to set a new trial date at an upcoming conference;

WHEREAS the Iron Workers Action, the Bushkin Action, and the State Derivative Actions involve the same Nominal Defendant(s), many of the same individual defendants, and concern the events leading to the gas pipeline rupture in San Bruno, California on September 9, 2010 (the "San Bruno Fire");

WHEREAS following the San Bruno Fire, approximately 140 actions involving claims for personal injury and property damage in connection with the San Bruno Fire were filed and consolidated into Judicial Council Coordinated Proceeding No. 4648, captioned PG&E San Bruno Fire Cases (the "State Consolidated Action"), which was litigated in the Superior Court of California, County of San Mateo;

WHEREAS the State Derivative Actions have been stayed pending conclusion of the federal criminal proceedings;

WHEREAS, by agreement of the parties and with the approval of this Court, the Iron Workers Action has been stayed in its entirety pending resolution of the State Derivative Actions, and no date by which the defendants must respond to the Iron Workers complaint has been set;

WHEREAS on April 19, 2016, the Court clerk gave notice that the Court has continued a Case Management Conference in the Iron Workers Action to June 2, 2016; and

WHEREAS on May 3, 2016, the Court entered an order in the Bushkin Action that, among other things, vacated an Initial Case Management Conference scheduled in that action for June 17, 2016;

IT IS HEREBY STIPULATED THAT:

1. Counsel for all parties shall meet and confer within 30 days after conclusion of the trial in the Criminal Action and provide a status update to the Court.

2. The Case Management Conference currently scheduled in the Iron Workers Action for June 2, 2016 shall be vacated.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.