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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Exhibit A 

[PROPOSED] Order 

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@weil.com) 

Ray C. Schrock (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 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) 

(Jointly Administered) 

[PROPOSED] ORDER PURSUANT TO 

11 U.S.C. §§ 502(b)(9) AND 105(a), 

FED. R. BANKR. P. 2002, 3003(c)(3), 

5005, AND 9007, AND L.B.R. 3003-1 (I) 

ESTABLISHING DEADLINE FOR FILING 

PROOFS OF CLAIM, (II) ESTABLISHING 

THE FORM AND MANNER OF NOTICE 

THEREOF, AND (III) APPROVING 

PROCEDURES FOR PROVIDING 

NOTICE OF BAR DATE AND OTHER 

INFORMATION TO ALL CREDITORS 

AND POTENTIAL CREDITORS 

 

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). 

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28 Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

Upon the Motion, dated May 1, 2019 [Docket No. #] (the “Motion”),1 of PG&E 

Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the “Utility”), as debtors and 

debtors in possession (collectively, “PG&E” or the “Debtors”) in the above-captioned chapter 11 

cases (the “Chapter 11 Cases”), pursuant to sections 502(b)(9) and 105(a) of title 11 of the United 

States Code (the “Bankruptcy Code”), Rules 2002, 3003(c)(3), 5005, and 9007 of the Federal Rules 

of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 3003-1 of the Bankruptcy Local Rules 

for the United States District Court for the Northern District of California (the “Bankruptcy Local 

Rules”), for entry of an order (i) establishing deadlines for filing proofs of claim, (ii) establishing the 

form and manner of notice thereof, and (iii) approving the Debtors’ plan for providing notice of the 

Bar Date and other important deadlines and information to all creditors and potential creditors, 

including publication and other supplemental noticing procedures, all as more fully set forth in the 

Motion; and this Court having jurisdiction to consider the Motion and the relief requested therein 

pursuant to 28 U.S.C. §§ 157 and 1334, Order Referring Bankruptcy Cases and Proceedings to 

Bankruptcy Judges, General Order 24 (N.D. Cal.), and Bankruptcy Local Rule 5011-1(a); and 

consideration of the Motion and the requested relief being a core proceeding pursuant to 28 U.S.C. 

§ 157(b); and venue being proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the 

Court having found and determined that notice of the Motion as provided to the parties listed therein 

is reasonable and sufficient under the circumstances, and it appearing that no other or further notice 

need be provided; and this Court having reviewed the Motion and the Wells Declaration (as amended 

on February 2, 2019 [Docket No. 263]), the Orsini Declaration, and the Prime Clerk Declarations; and 

this Court having held a hearing on the Motion; and this Court having determined that the legal and 

factual bases set forth in the Motion establish just cause for the relief granted herein; and it appearing 

 

1

 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such 

terms in the Motion. 

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that the relief requested in the Motion is in the best interests of the Debtors, their estates, creditors, 

shareholders, and all parties in interest; and upon all of the proceedings had before this Court and after 

due deliberation and sufficient cause appearing therefor, 

IT IS HEREBY ORDERED THAT: 

1. The Motion is granted as provided herein. 

2. The Notice Procedures (including the Supplemental Notice Plan) are hereby 

approved and the Debtors are authorized to provide notice of the Bar Date as set forth in the Motion 

and this Order. 

3. The following procedures for filing Proofs of Claim are approved: 

(a) Except as otherwise noted herein, the Bar Date for filing all Proofs of 

Claim in the Chapter 11 Cases (including all claims of Wildfire 

Claimants, Wildfire Subrogation Claimants, Governmental Units, and 

Customers) shall be September 16, 2019 at 5:00 p.m. (Prevailing 

Pacific Time). 

(b) Standard Proof of Claim Forms (which include Proofs of Claim to 

be filed by any Customers or Governmental Units (other than a 

Proof of Claim filed by a Governmental Unit on account of a 

Wildfire Claim)) must: (i) be written in the English language; (ii) be 

denominated in lawful currency of the United States as of the Petition 

Date (using the exchange rate, if applicable, as of the Petition Date); 

(iii) conform substantially to the Standard Proof of Claim Form 

annexed to the Motion as Exhibit C-1 or Official Bankruptcy Form 

No. 410;2 (iv) specify by name and case number the Debtor against 

which the Standard Proof of Claim is filed; (v) set forth with 

specificity the legal and factual basis for the alleged claim; (vi) include 

supporting documentation for the claim or an explanation as to why 

such documentation is not available; and (vii) be signed by the 

claimant or, if the claimant is not an individual, by an authorized agent 

of the claimant. 

 

2

 Official Bankruptcy Form No. 410 can be found at http://www.uscourts.gov/forms/bankruptcyforms/proof-claim-0, the Official Website for the United States Bankruptcy Courts. A Proof of 

Claim Form that has been customized for these Chapter 11 Cases can also be obtained on the 

website established in these Chapter 11 Cases, https://restructuring.primeclerk.com/pge/ (the “Case 

Website”). 

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(c) Wildfire Claimant Proof of Claim Forms must: (i) be written in the 

English language; (ii) be denominated in lawful currency of the United 

States as of the Petition Date (using the exchange rate, if applicable, as 

of the Petition Date); (iii) conform substantially to the Wildfire Proof 

of Claim Form annexed to the Motion as Exhibit C-2; (iv) set forth 

with specificity the legal and factual basis for the alleged claim, 

including all of the information requested in the Wildfire Claimant 

Proof of Claim Form; and (v) be signed by the Wildfire Claimant or, if 

the Wildfire Claimant is not an individual, by an authorized agent of 

the Wildfire Claimant. 

(d) Wildfire Subrogation Claimant Proof of Claim Forms must: (i) be 

written in the English language; (ii) be denominated in lawful currency 

of the United States as of the Petition Date (using the exchange rate, if 

applicable, as of the Petition Date); (iii) conform substantially to the 

Wildfire Subrogation Claimant Proof of Claim Form annexed to the 

Motion as Exhibit C-3; (iv) set forth with specificity the legal and 

factual basis for the alleged claim, including all of the information 

requested in the Wildfire Subrogation Claimant Proof of Claim Form; 

and (v) be signed by an authorized agent of the Wildfire Subrogation 

Claimant. 

(e) Any holder of a Wildfire Claim that has either (i) filed a lawsuit 

against the Debtors prior to the Petition Date or (ii) filed a Proof of 

Claim in the Chapter 11 Cases prior to the entry of this Order, must 

submit the applicable Wildfire Proof of Claim Form. Any holder of a 

Wildfire Claim must file the applicable Wildfire Proof of Claim Form 

even if such claimant may be included in, or represented by, a 

purported class action, class suit, class Proof of Claim, or similar 

representative action filed against the Debtors with respect to such 

claimant’s Wildfire Claim. 

(f) If a claimant asserts a claim against more than one Debtor or has 

claims against different Debtors, the claimant must file a separate 

Proof of Claim against each Debtor. All timely filed Wildfire Proof 

of Claim Forms and Wildfire Subrogation Proof of Claim Forms will 

be deemed filed against both PG&E Corp. and the Utility (without 

prejudice to the Debtors’ right to assert that any such claim should be 

allowed only as to one of the Debtors). 

(g) All Proofs of Claim must be filed either (i) electronically through 

Prime Clerk’s website using the interface available on the Case 

Website under the link entitled “Submit a Claim” (the “Electronic 

Filing System”) or (ii) by delivering the original Proof of Claim form 

by hand, or mailing the original Proof of Claim form so that is 

received on or before the Bar Date as follows: 

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If by first class mail: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

Grand Central Station, PO Box 4850 

New York, NY 10163-4850 

If by overnight courier: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

850 Third Avenue, Suite 412 

Brooklyn, NY 11232 

If by hand delivery: 

PG&E Corporation Claims Processing Center 

c/o Prime Clerk LLC 

850 Third Avenue, Suite 412 

Brooklyn, NY 11232 

-orAt one of the Debtors’ Claim Service Centers located at the 

following PG&E locations: (i) 350 Salem Street, Chico, CA 

95928; (ii) 231 “D” Street, Marysville, CA 95901; (iii) 1567 

Huntoon Street, Oroville, CA 95965; (iv) 3600 Meadow View 

Road, Redding, CA 96002; (v) 111 Stony Circle, Santa Rosa, 

CA 95401; or (vi) 1850 Soscol Ave. Ste 105, Napa, CA 94559. 

(h) A Proof of Claim Form shall be deemed timely filed only if it is 

actually received by Prime Clerk (i) at the addresses listed above in 

subparagraph (g) or (ii) electronically through the Electronic Filing 

System on or before the Bar Date. 

(i) Proofs of Claim sent by facsimile, telecopy, or electronic mail 

transmission (other than Proofs of Claim filed electronically through 

the Electronic Filing System) will not be accepted. 

(j) Any person or entity (including, without limitation, individuals, 

partnerships, corporations, joint ventures, trusts, and Governmental 

Units) that asserts a claim that arises from the rejection of an executory 

contract or unexpired lease must file a Standard Proof of Claim Form 

based on such rejection by the later of (i) the Bar Date, and (ii) the date 

that is thirty (30) days following the entry of the Court order approving 

such rejection, (which order may be the order confirming a chapter 11 

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plan in the Debtors’ Chapter 11 Cases) or be forever barred from doing 

so. 

(k) Notwithstanding the foregoing, a party to an executory contract or 

unexpired lease that asserts a claim on account of unpaid amounts 

accrued and outstanding as of the Petition Date pursuant to such 

executory contract or unexpired lease (other than a rejection damages 

claim) must file a Standard Proof of Claim Form for such amounts on 

or before the Bar Date unless an exception identified in paragraph (o) 

below applies. 

(l) In the event that the Debtors amend or supplement their Schedules 

subsequent to the date of entry of this Order, the Debtors shall give 

notice of any amendment or supplement to the holders of claims or 

interests affected thereby, and such holders shall have until the later of 

(i) the Bar Date and (ii) thirty (30) days from the date of such notice to 

file a Proof of Claim or be barred from doing so and shall be given 

notice of such deadline. 

(m) Any person or entity that relies on the Schedules has the responsibility 

to determine that its claim is accurately listed in the Schedules. 

(n) Notwithstanding anything herein to the contrary, any person asserting 

a claim arising under section 503(b)(9) of the Bankruptcy Code 

(“503(b)(9) Claims”) against any Debtor shall be required to file such 

claim by the deadline established in the Court’s Amended Order 

Pursuant to 11 U.S.C. §§ 503(b)(9) and 105(a) Establishing 

Procedures for the Assertion, Resolution, and Satisfaction of Claims 

Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Docket No. 724], and 

nothing herein shall be deemed to amend, modify, extend, or toll the 

deadlines and procedures with respect to the filing of 503(b)(9) Claims 

set forth therein. 

(o) The following persons or entities are not required to file a Proof of 

Claim on or before the Bar Date, solely with respect to the claims 

described below: 

(1) any person or entity whose claim is listed on the Schedules; 

provided that (i) the claim or interest is not listed on the 

Schedules as “disputed,” “contingent,” or “unliquidated,” (ii) 

the person or entity does not dispute the amount, nature, and 

priority of the claim as set forth in the Schedules, and (iii) the 

person or entity does not dispute that the claim is an obligation 

of the specific Debtor against which the claim or interest is 

listed in the Schedules; 

(2) any person or entity whose claim has been paid in full; 

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(3) any holder of a claim allowable under section 503(b) and 

507(a)(2) of the Bankruptcy Code as an administrative expense 

(other than any party asserting a 503(b)(9) Claim as set forth in 

paragraph (n) above); 

(4) any person or entity who holds a claim that heretofore has been 

allowed by Order of this Court entered on or before the Bar 

Date; 

(5) any holder of a claim for which a separate deadline has been 

fixed by this Court; 

(6) any person or entity (other than the holder of a Wildfire Claim) 

who has already filed a Proof of Claim with Prime Clerk 

against the Debtors with respect to the claim being asserted, 

utilizing a claim form that substantially conforms to the 

Standard Proof of Claim Form or Official Form No. 4103; 

(7) any person or entity that holds an equity security interest in the 

Debtors, which interest is based exclusively upon the 

ownership of common or preferred stock, membership 

interests, partnership interests, or warrants, options, or rights to 

purchase, sell, or subscribe to such a security or interest; 

provided, however, that if any such holder asserts a claim (as 

opposed to an ownership interest) against the Debtors 

(including a claim relating to an equity interest or the purchase 

or sale of such equity interest), a Standard Proof of Claim must 

be filed on or before the Bar Date; 

(8) any person or entity whose claim is limited exclusively to the 

repayment of principal, interest, and other fees and expenses 

under any agreements (a “Debt Claim”) governing any 

prepetition, unsecured revolving credit loan, term loan, notes, 

bonds, debentures, or other debt securities, in each case, issued 

by or on behalf of any of the Debtors (collectively, the “Debt 

Instruments”); provided, however, that (i) the foregoing 

exclusion shall not apply to the indenture trustee, owner 

trustee, pass-through trustee, subordination agent, registrar, 

paying agent, administrative, loan or collateral agent, or any 

other entity serving in a similar capacity however designated 

 

3

 Pursuant to paragraph 3(e) above, any holder of a Wildfire Claim (including any Wildfire 

Subrogation Claimant) that already has filed a Proof of Claim nevertheless shall be required to file 

another timely Proof of Claim by the Bar Date in the form of the applicable Wildfire Proof of Claim 

Form. 

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(collectively, an “Indenture Trustee”) under the applicable 

Debt Instrument, (ii) each such Indenture Trustee shall be 

required to file a Standard Proof of Claim against the 

applicable Debtor, on or before the Bar Date, on account of all 

Debt Claims against such Debtor under the applicable Debt 

Instrument, and (iii) any holder of a Debt Claim that has a 

claim arising out of or relating to a Debt Instrument other than 

a Debt Claim must file a Standard Proof of Claim with respect 

to such claim on or before the Bar Date, unless another 

exception identified herein applies; 

(9) any Customer whose claim is limited exclusively to ordinary 

and customary refunds, overpayments, billing credits, deposits, 

or similar billing items; or 

(10) either Debtor having a claim against the other Debtor in these 

Chapter 11 Cases. 

4. The supporting documentation submitted in connection with Wildfire Proof of 

Claim Forms shall remain confidential in these Chapter 11 Cases and shall not be made available to 

the general public. Copies of such information shall be provided to counsel for the Committees, the 

U.S. Trustee and any additional parties the Court directs but only after each such party agrees to keep 

the information provided in the Wildfire Proof of Claim Forms confidential. 

5. Pursuant to Bankruptcy Rule 3003(c)(2), all holders of claims, including 

Wildfire Claimants, Wildfire Subrogation Claimants, and Customers, that fail to comply with this 

Order by timely filing a Proof of Claim in the appropriate form shall (i) be forever barred, estopped, 

and enjoined from asserting such claims against the Debtors, their property, or their estates (or 

submitting a Proof of Claim with respect thereto) and (ii) not be treated as a creditor with respect to 

such claim for the purposes of voting and distribution with respect to any chapter 11 plan or plans of 

reorganization that may be filed in these Chapter 11 Cases. 

Procedures for Mailing of the Bar Date Notices 

6. The Standard Bar Date Notice. At least ninety-five (95) days prior to the 

Bar Date, the Debtors shall cause to be mailed at their last known address as reflected in the Debtors’ 

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records (i) a Standard Proof of Claim Form, and (ii) the Standard Bar Date Notice on the following 

parties: 

(a) The Office of the United States Trustee for Region 17; 

(a) the attorneys for the Committees; 

(b) all parties actually known to the Debtors as having claims or potential 

claims against either of the Debtors (but excluding holders of Wildfire 

Claims) which, for the avoidance of doubt, excludes any person or entity 

that holds an equity security interest in the Debtors, which interest is based 

exclusively upon the ownership of common or preferred units, membership 

interests, partnership interests, or warrants, options, or rights to purchase, 

sell, or subscribe to such a security or interest; 

(c) all persons or entities that have filed Proofs of Claims as of the date of entry 

of this Order; 

(d) all counterparties to the Debtors’ executory contracts and unexpired leases 

as of the date of entry of this Order; 

(e) all parties to pending litigation against the Debtors as of the date of entry of 

this Order (other than holders of Wildfire Claims); 

(f) all current and former employees, directors, and officers (to the extent that 

contact information for former employees, directors, and officers is 

available in the Debtors’ records); 

(g) all regulatory authorities that regulate the Debtors’ businesses as of the date 

of entry of this Order; 

(h) the Offices of the California Attorney General and the U.S. Attorney for the 

Northern District of California; 

(i) the office of the attorney general for each state in which the Debtors 

maintain or conduct business; 

(j) the District Director of the Internal Revenue Service for the District of 

California; 

(k) all other taxing authorities for the jurisdictions in which the Debtors 

maintain or conduct business; 

(l) all parties who have requested notice pursuant to Bankruptcy Rule 2002 as 

of the date of entry of this Order; and 

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(m) such additional persons and entities deemed appropriate by the Debtors. 

7. The Wildfire Claim Bar Date Notice. At least ninety-five (95) days prior to 

the Bar Date, the Debtors shall cause to be mailed to all Known Wildfire Claimants at the address for 

the attorney of record set forth in the complaint initiating such Known Wildfire Claimant’s prepetition 

action (or other document or correspondence notifying the Debtors of an intention to commence a 

prepetition action) (i) the Wildfire Claim Bar Date Notice, and (ii) a Wildfire Claimant Proof of Claim 

Form or Wildfire Subrogation Claimant Proof of Claim Form, as applicable. 

8. The Customer Bar Date Notice. At least ninety-five (95) days prior to the 

Bar Date, the Debtors shall cause to be mailed to all Customers at their last known address as reflected 

in the Debtors’ records (i) a Standard Proof of Claim Form, and (ii) the Customer Bar Date Notice. 

9. The Debtors shall post each of the Standard Bar Date Notice, the Wildfire Claim 

Bar Date Notice, and the Customer Bar Date Notice on the Case Website. 

The Supplemental Notice Plan 

10. The Supplemental Notice Plan is hereby approved and the Debtors are 

authorized to implement the components of the Supplemental Notice Plan as set forth in the Motion. 

11. In addition to the other provisions of the Supplemental Notice Plan which are 

hereby approved, the Debtors shall publish notice of the Bar Date, with any necessary modifications 

for ease of publication, three times in each of the Wall Street Journal, USA Today, the Los Angeles 

Times, San Francisco Chronicle, The Bakersfield Californian, The Fresno Bee, The Modesto Bee, The 

Sacramento Bee, The Santa Rosa Press Democrat, The San Jose Mercury News, The East Bay Times, 

The Stockton Record, the Paradise Post, and the Chico Enterprise-Record. 

12. The Notice Procedures, including the Supplemental Notice Plan (including, 

without limitation, the publication of the Bar Date Notice as set forth in this Order), are reasonably 

calculated to provide notice of the Bar Date to known and unknown creditors and parties in interest, 

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including Known Wildfire Claimants and Unknown Wildfire Claimants, and no other or further notice 

shall be required. 

13. Nothing contained in this Order or in the Motion is intended to be or shall be 

construed as (a) an admission as to the validity of any claim against the Debtors, (b) a waiver of the 

Debtors’ or any appropriate party in interest’s rights to dispute any claim, or (c) an approval or 

assumption of any agreement, contract, program, policy, or lease under section 365 of the Bankruptcy 

Code. 

14. Notwithstanding entry of this Order, nothing herein shall create, nor is intended 

to create, any rights in favor of or enhance the status of any claim held by any party. 

15. The Debtors and Prime Clerk are authorized to take all steps necessary or 

appropriate to carry out this Order. 

16. Entry of this Order is without prejudice to the right of the Debtors to seek a 

further order of this Court fixing the date by which holders of claims not subject to the Bar Date 

established herein must file such claims against the Debtors or be forever barred from so doing. 

17. This Court shall retain jurisdiction to hear and determine all matters arising 

from or related to the implementation, interpretation, or enforcement of this Order. 

** END OF ORDER ** 

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