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

Exhibit A 

[PROPOSED] Order 

Case: 19-30088 Doc# 1805-1 Filed: 05/01/19 Entered: 05/01/19 20:19:30 Page 1

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

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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) 

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. §§ 365(d)(4) AND B.L.R 6006-1 

EXTENDING TIME TO ASSUME OR 

REJECT UNEXPIRED LEASES OF 

NONRESIDENTIAL REAL PROPERTY 

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 _______, 2019 [Docket No. #] (the “Motion”),2 of PG&E 

Corporation and Pacific Gas and Electric Company, as debtors and debtors in possession (collectively, 

the “Debtors”) in the above-captioned chapter 11 cases, pursuant to section 365(d)(4)(B)(i) of title 11 

of the United States Code (the “Bankruptcy Code”) and Rule 6006-1 of the Bankruptcy Local Rules 

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

Rules”), for an extension of time to assume or reject unexpired leases of nonresidential real property 

(the “Unexpired Leases”), 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 Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District Court for the Northern 

District of California; 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 Boken 

Declaration; 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 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 time by which the Debtors may assume or reject the Unexpired Leases is 

extended from May 29, 2019 for an additional (90) days through and including August 27, 2019. 

 

2

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

terms in the Motion. 

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

3. The entry of this Order is without prejudice to the Debtors’ right to request 

further extensions of time to assume or reject the Unexpired Leases in accordance with section 

365(d)(4) of the Bankruptcy Code with the consent of its lessors. 

4. Nothing in the Motion or this Order shall be construed as (i) an admission as to 

the characterization or validity of any Unexpired Lease or other claim against the Debtors, (ii) a waiver 

of the Debtors’ or any appropriate party in interest’s rights to dispute any Unexpired Lease or other 

claim, or (iii) an approval, rejection or assumption of any Unexpired Lease, or any other agreement, 

contract, program, policy, or lease under section 365 of the Bankruptcy Code. 

5. Any and all of the Debtors’ rights, claims, and defenses with respect to the 

characterization of the Unexpired Leases under Bankruptcy Code sections 365(d)(3) and 365(d)(4) or 

otherwise are reserved. 

6. 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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