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EXHIBIT A 

[Proposed] Order 

Case: 19-30088 Doc# 1759-1 Filed: 04/29/19 Entered: 04/29/19 18:37:40 Page 1

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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) 

825 Eighth Avenue 

New York, NY 10019 

Tel: 212 474 1000 

Fax: 212 474 3700 

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 GRANTING EX PARTE 

MOTION OF DEBTORS PURSUANT TO B.L.R. 

9006-1 REQUESTING ORDER SHORTENING 

TIME FOR HEARING ON APPLICATION OF 

DEBTORS PURSUANT TO 11 U.S.C. § 327(a) 

AND FED. R. BANKR. P. 2014(a) AND 2016 FOR 

AUTHORITY TO RETAIN AND EMPLOY 

COMPASS LEXECON, LLC AS ECONOMIC 

CONSULTANTS TO DEBTORS NUNC PRO 

TUNC TO PETITION DATE 

Related Document: Dkt. 1756 

[No hearing requested] 

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# 1759-1 Filed: 04/29/19 Entered: 04/29/19 18:37:40 Page 2

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Upon the Motion, dated April 29, 2019 (the “Motion to Shorten”),1 of Pacific Gas 

and Electric Company and PG&E Corporation, as debtors and debtors in possession (collectively, 

“PG&E” or the “Debtors”), pursuant to Rule 9006-1 of the Bankruptcy Local Rules for the United 

States Bankruptcy Court for the Northern District of California (the “Bankruptcy Local Rules”), 

for entry of an order shortening time for a hearing on the Application of the Debtors Pursuant to 11 

U.S.C. § 327(a) and Fed. R. Bankr. P. 2014(a) and 2016 for Authority to Retain and Employ 

Compass Lexecon, LLC, Nunc Pro Tunc to the Petition Date (the “Application”), as more fully set 

forth in the Motion to Shorten; and upon consideration of the Kim Declaration submitted in support 

of the Motion to Shorten; and this Court having jurisdiction to consider the Motion to Shorten and 

the relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334, the 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 to Shorten 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 due and proper notice of the Motion to Shorten having been provided 

to the parties listed therein, and it appearing that no other or further notice need be provided; and 

this Court having reviewed the Motion to Shorten; and this Court having determined that the legal 

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

and it appearing that the relief requested in the Motion to Shorten is in the best interests of the 

Debtors, their estates, creditors, shareholders, and all parties in interests; 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 to Shorten is granted as provided herein. 

2. The hearing on the Application shall be held on May 9, 2019, at 9:30 a.m. 

(Pacific Time) (the “Hearing”). 

3. Any oppositions or responses to the Application must be in writing, filed with 

the Bankruptcy Court, and served on the counsel for the Debtors at the above-referenced addresses 

 

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

terms in the Motion to Shorten.

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so as to be received by no later than 4:00 p.m. (Pacific Time) on May 3, 2019. Any oppositions 

or responses must be filed and served on all “Standard Parties” as defined in, and in accordance 

with, the Amended Order Implementing Certain Notice and Case Management Procedures entered 

on March 27, 2019 [Dkt No. 1093] (“Case Management Order”). 

4. The Debtors are authorized to take all steps necessary or appropriate to carry 

out this Order. 

5. 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** 

Case: 19-30088 Doc# 1759-1 Filed: 04/29/19 Entered: 04/29/19 18:37:40 Page 4

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