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

Exhibit A 

[PROPOSED] Order 

 

Case: 19-30088 Doc# 1795-1 Filed: 05/01/19 Entered: 05/01/19 18:14:04 Page 1

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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, 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. § 1121(d) EXTENDING 

Debtors. EXCLUSIVE PERIODS 

 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”)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 section 1121(d) of title 11 of the United States Code (the 

“Bankruptcy Code”), for entry of an order extending the Debtors’ exclusive periods in which to file 

a chapter 11 plan (the “Exclusive Filing Period”) and solicit acceptances thereof (the “Exclusive 

Solicitation Period,” and together with the Exclusive Filing Period, the “Exclusive Periods”), 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 

(the “Bankruptcy Local Rules”); 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 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. Pursuant to section 1121(d) of the Bankruptcy Code, the Debtors’ Exclusive 

 

1

 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

Filing Period in which to file a chapter 11 plan is extended to and including November 29, 2019. 

3. Pursuant to section 1121(d) of the Bankruptcy Code, the Debtors’ Exclusive 

Solicitation Period in which to solicit acceptances of their chapter 11 plan is extended to and including 

January 28, 2020. 

4. The extensions of the Exclusive Periods granted herein are without prejudice to 

such further requests that may be made pursuant to section 1121(d) of the Bankruptcy Code by the 

Debtors or any party in interest, for cause shown, upon notice and a hearing. 

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 ** 

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