Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Exhibit A

[PROPOSED] Order

Case: 19-30088 Doc# 1738-1 Filed: 04/26/19 Entered: 04/26/19 18:24:53 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 

FED R. BANKR. P. 9006(B) AND 9027 

ENLARGING THE TIME WITHIN 

WHICH TO FILE NOTICES OF 

REMOVAL OF RELATED 

PROCEEDINGS

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# 1738-1 Filed: 04/26/19 Entered: 04/26/19 18:24:53 Page 2

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Upon the Motion, dated April ___, 2019 [Docket No. #] (the “Motion”),2 of PG&E 

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

“PG&E” or the “Debtors”) in the above-captioned Chapter 11, pursuant to Bankruptcy Rules 9006(b) 

and 9027, and Bankruptcy Local Rule 9006-1, seeking an extension of time for the Debtors to file 

notices of removal of the civil actions and proceedings to which the Debtors are parties (the “Civil 

Actions”) from April 29, 2019 until October 28, 2019, 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, the Wells Declaration (as amended on February 2, 2019

[Docket No. 263]), 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 it appearing 

that cause exists to grant the relief requested in the Motion; 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 deadline by which the Debtors may file notices of removal under 

Bankruptcy Rule 9027(a) is extended through and including October 28, 2019. 

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

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

terms in the Motion.

Case: 19-30088 Doc# 1738-1 Filed: 04/26/19 Entered: 04/26/19 18:24:53 Page 3

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

out this Order.

4. This Order shall be without prejudice to any position the Debtors may take 

regarding whether section 362 of the Bankruptcy Code applies to stay any litigation pending against 

the Debtors.

5. Notwithstanding entry of this Order, nothing herein shall create, nor is it 

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

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 **

Case: 19-30088 Doc# 1738-1 Filed: 04/26/19 Entered: 04/26/19 18:24:53 Page 4

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