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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

DEBTORS’ EX PARTE UNOPPOSED 

APPLICATION FOR ORDER PURSUANT TO 

L.B.R. 9006-1(a) SHORTENING NOTICE OF 

HEARING ON MOTION FOR ENTRY OF 

PROTECTIVE ORDER PURSUANT TO FED. 

R. BANKR. P. 7026 AND 9014(c) AND 11 U.S.C. 

§ 105(a) GOVERNING DISCOVERY 

MATERIALS AND OTHER INFORMATION 

Related Document: Dkt. No. 2459 

[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# 2461 Filed: 06/07/19 Entered: 06/07/19 20:12:07 Page 1 of

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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”), hereby submit this Ex Parte

Unopposed Application (the “Application”), pursuant to Rule 9006-1(a) 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 shortening notice of a hearing on June 26, 2019, at 9:30 a.m. 

(Pacific Time), on the Motion for Entry of Protective Order Pursuant to Fed. R. Bankr. P. 7026 

and 9014(c) and 11 U.S.C. § 105(a) Governing Discovery Materials and Other Information (the 

“Protective Order Motion”)1 [Dkt. No. 2459], which the Debtors filed on June 7, 2019. 

In support of this Application, the Debtors refer to and rely upon the Declaration of 

Richard W. Slack (the “Slack Declaration”), filed today in support of the Protective Order Motion 

[Dkt. No. 2460]. 

MEMORANDUM OF POINTS AND AUTHORITIES 

I. JURISDICTION 

The Court has jurisdiction to consider this matter 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). This is a core proceeding pursuant to 

28 U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

II. BACKGROUND 

On January 29, 2019 (the “Petition Date”), the Debtors commenced with the Court 

voluntary cases under chapter 11 of the Bankruptcy Code. The Debtors continue to operate their 

businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 

1108 of the Bankruptcy Code. The Debtors’ Chapter 11 Cases are being jointly administered for 

procedural purposes only pursuant to Bankruptcy Rule 1015(b). 

 

1

 Capitalized terms used but not defined herein have the meanings ascribed to them in the Protective 

Order Motion. 

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On February 12, 2019, the United States Trustee (the “U.S. Trustee”) appointed an 

Official Committee of Unsecured Creditors (the “UCC”). On February 15, 2019, the U.S. Trustee 

appointed an Official Committee of Tort Claimants (the “TCC”; collectively with the UCC, the 

“Committees”). 

Additional information regarding the circumstances leading to the commencement 

of the Chapter 11 Cases and information regarding the Debtors’ businesses and capital structure is 

set forth in the Amended Declaration of Jason P. Wells in Support of the First Day Motions and 

Related Relief [Dkt. No. 263]. 

III. SHORTENED NOTICE FOR THE MOTION ON THE PROTECTIVE ORDER IS 

WARRANTED 

Pursuant to Bankruptcy Local Rule 9014-1(b)(3)(A) and the Second Amended Order 

Implementing Certain Notice and Case Management Procedures entered on May 14, 2019 [Dkt. No. 

1996], paragraph 25, a hearing on the Protective Order Motion normally requires at least twenty-one 

(21) days’ notice. Bankruptcy Local Rule 9006-1(a) provides that, except as set forth therein, 

“approval of the Court is required to enlarge or to shorten time to perform any act or file any paper 

pursuant to the Federal Rules of Civil Procedure, the Bankruptcy Rules, or these Bankruptcy Local 

Rules.” By this Application, the Debtors seek to shorten notice to 19 days, so the Protective Order 

Motion can be heard on June 26, 2019. 

As the Court is aware, the Debtors have for some time been engaged in the 

preparation of a standard form of protective order. After extensive internal communications and 

coordination with co-counsel and Debtors’ internal legal staff, the Debtors circulated their proposed 

form of protective order to the Committees on May 17. Slack Decl. ¶ 5. Since that time, the Debtors 

have engaged in extensive communications and negotiations with both Committees in an effort to 

resolve concerns raised by the UCC and TCC, and if possible to reach consensus with them on the 

form of protective order. Ibid., ¶¶ 6-17. This was a time-consuming process, as each significant 

revision involved discussions not only with the respective Committees’ counsel but also with 

multiple co-counsel and in-house counsel for the Debtors, in light of the potential scope and breadth, 

and the significance of the impact on the Debtors, of the order once adopted by the Court. Ibid., ¶ 19. 

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These efforts to reach agreement produced considerable progress, and continued up to 

June 5, when an impasse was reached between the Debtors and the TCC. On the evening of June 4, 

the TCC informed the Debtors that, if the Debtors did not agree to the TCC’s position on one 

particular issue by noon the following day, the TCC intended to file a motion to approve its own 

form of protective order. The Debtors continued to try to reach agreement, but late the next day the 

TCC filed its motion. Ibid., ¶¶ 1 –16. Because they had been focused on efforts to reach a 

consensual agreement and anticipated filing a motion to approve an agreed form of protective order 

up until receiving the TCC’s email the night of June 4, and due to the relatively time-consuming 

process for obtaining approvals from multiple co-counsel and client representatives, the Debtors 

needed until today to file their Protective Order Motion. Ibid., ¶ 18. 

The Motion of the Official Committee of Tort Claimants for Entry of a Protective 

Order [Dkt. No. 2419] (“TCC Motion”) is set to be heard at the omnibus hearing on June 26, 2019. 

The TCC Motion seeks entry of a standard form of protective order for these Chapter 11 Cases that 

differs in certain material respects from the form of order prepared by the Debtors. The Debtors 

believe that it is necessary to the efficient administration of these Chapter 11 Cases that the Court, in 

deciding the appropriate form of standard protective order, have before it not only the form of order 

proposed by the TCC, but also the Debtors’ proposed form of order that has been shaped by many 

weeks of internal effort and three weeks of negotiation among the Debtors and the two Committees. 

To that end, the Debtors seek shortened notice so their Protective Order Motion can be heard on June 

26 at the same time as the TCC Motion. (Alternatively, and while this is not their preferred option, 

the Debtors request that the hearing on both motions be set for a date after June 26.) 

The TCC and the UCC do not object to shortening notice as requested herein. Slack 

Decl. ¶ 21. 

Accordingly, the Debtors request the Court to authorize shortened notice for hearing 

of the Protective Order Motion as follows: 

a. June 7, 2019 – Protective Order Motion filed and served; 

b. June 19, 2019, at 4:00 pm – deadline for responses to Protective Order Motion 

c. June 26, 2019, at 9:30 am – hearing on Protective Order Motion. 

Case: 19-30088 Doc# 2461 Filed: 06/07/19 Entered: 06/07/19 20:12:07 Page 4 of

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There have been no prior requests for shortened notice relating to the Protective 

Order Motion. 

IV. NOTICE 

Notice of this Application will be provided to (i) the Office of the United States Trustee 

for Region 17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Creditors 

Committee; (iii) counsel to the Tort Claimants Committee; (iv) the Securities and Exchange 

Commission; (v) the Internal Revenue Service; (vi) the Office of the California Attorney General; (vii) 

the California Public Utilities Commission; (viii) the Nuclear Regulatory Commission; (ix) the Federal 

Energy Regulatory Commission; (x) the Office of the United States Attorney for the Northern District 

of California; (xi) counsel for the agent under the Debtors’ debtor in possession financing facility; and 

(xii) those persons who have formally appeared in these Chapter 11 Cases and requested service 

pursuant to Bankruptcy Rule 2002. The Debtors respectfully submit that no further notice is required. 

No previous request for the relief sought herein has been made by the Debtors to this 

or any other court. 

WHEREFORE, the Debtors respectfully request entry of an order shortening time for 

notice of hearing on the Protective Order Motion. 

Dated: June 7, 2019 WEIL, GOTSHAL & MANGES LLP 

 KELLER & BENVENUTTI LLP 

 By: /s/ Peter J. Benvenutti 

 Peter J. Benvenutti 

Attorneys for Debtors and Debtors in Possession 

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