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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

Exhibit A

[PROPOSED] Order

Case: 19-30088 Doc# 17-1 Filed: 01/29/19 Entered: 01/29/19 01:22:35 Page 1 of

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DEBTORS’ MOTION WAIVING REQUIREMENTS TO

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

WEIL, GOTSHAL & MANGES LLP

Stephen Karotkin (pro hac vice pending) 

(stephen.karotkin@weil.com) 

Jessica Liou (pro hac vice pending) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice pending) 

(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 

Proposed Attorneys for Debtors 

and Debtors in Possession

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re: 

PG&E CORPORATION,

Debtor.

Tax I.D. No. 94-3234914

Case Nos. 19 -_____ (___)

19 -_____ (___) 

Chapter 11 

[PROPOSED] ORDER PURSUANT TO 11 U.S.C. 

§§ 105(a), 342(a), AND 521(a)(1) AND FED. R.

BANKR. P. 1007 AND 2002 (I) WAIVING THE

REQUIREMENTS TO FILE LISTS OF

CREDITORS AND EQUITY SECURITY HOLDERS

AND GRANTING RELATED RELIEF; AND

(II) AUTHORIZING AND APPROVING

PROCEDURES FOR PROVIDING NOTICE OF

THE COMMENCEMENT OF CHAPTER 11 CASES

Date:

Time:

Place:

In re: 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtor.

Tax I.D. No. 94-0742640

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DEBTORS’ MOTION WAIVING REQUIREMENTS TO 

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Upon the Motion, dated _______, 2019 (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 sections 105(a), 342(a), and 521(a)(1) of title 11 of the United States Code 

(the “Bankruptcy Code”) and Rules 1007(a) and (d) and 2002(a), (d), and (f) of the Federal Rules of 

Bankruptcy Procedure (the “Bankruptcy Rules”), for entry of an order (i) waiving the requirements that 

the Debtors file their lists of creditors and equity holders on the Petition Date, as set forth in section 

521(a)(1) of the Bankruptcy Code, Bankruptcy Rules 1007(a)(1) and (a)(3), and Amended General Order 

13 (the “General Order”) of the United States Bankruptcy Court for the Northern District of California; 

and (ii) authorizing the Debtors to implement certain procedures (the “Procedures”) for the mailing and 

publication of the notice announcing the commencement of these Chapter 11 Cases and the meeting of 

creditors to be held pursuant to section 341 of the Bankruptcy Code (the “Notice of Commencement”), 

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 

and the Wells 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 

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

terms in the Motion.

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DEBTORS’ MOTION WAIVING REQUIREMENTS TO 

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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 requirements under section 521(a)(1) of the Bankruptcy Code, Bankruptcy Rule 

1007(a)(1), and the General Order that the Debtors file with the Court a consolidated list containing the 

names and last known addresses of the Debtors’ creditors (the “List of Creditors”) are waived.

3. The requirement under Bankruptcy Rule 1007(a)(3) that PG&E Corp. file a List of Equity 

Holders is waived.

4. As soon as practicable after entry of an order authorizing the engagement of Prime Clerk 

LLC, as the Debtors’ claims and noticing agent (the “Prime Clerk”), the Debtors shall furnish to Prime 

Clerk a List of Creditors.

5. The Procedures are hereby approved. 

6. The Notice of Commencement, substantially in the form attached hereto as Exhibit 1, is 

hereby approved.

7. On or before the date that is 21 days prior to the date on which the Section 341 Meeting 

is scheduled to take place, the Debtors, with the assistance of Prime Clerk, shall mail the Notice of 

Commencement to all creditors on the List of Creditors. 

8. Notwithstanding anything herein to the contrary, the requirement under Bankruptcy Rule 

2002(d) that the Debtors mail the Notice of Commencement to all equity security holders of PG&E Corp. 

is waived.

9. Pursuant to Bankruptcy Rule 2002(l), the Debtors, with the assistance of Prime Clerk, 

shall (a) cause the Notice of Commencement to be published (i) once in the national editions of the Wall 

Street Journal and USA Today, and (ii) once in each of the Los Angeles Times, San Francisco Chronicle, 

The Bakersfield Californian, The Fresno Bee, The Modesto Bee, The Sacramento Bee, The Santa Rosa 

Press Democrat, The San Jose Mercury News, The East Bay Times, The Stockton Record, the Paradise 

Post, and the Chico Enterprise-Record; and (b) post the Notice of Commencement on the website to be 

established by Prime Clerk and on the Debtors’ website.

Case: 19-30088 Doc# 17-1 Filed: 01/29/19 Entered: 01/29/19 01:22:35 Page 4 of

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10. The form and manner of notice as provided herein and in the Procedures are reasonably 

calculated to inform interested parties of these Chapter 11 Cases and are hereby approved.

11. The Debtors are authorized to take all steps necessary or appropriate to carry out this 

Order.

12. 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# 17-1 Filed: 01/29/19 Entered: 01/29/19 01:22:35 Page 5 of

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DEBTORS’ MOTION WAIVING REQUIREMENTS TO 

FILE LISTS OF CREDITORS & EQUITY HOLDERS – EXHIBIT 1 TO [PROPOSED] ORDER

Exhibit 1

Proposed Form of Notice of Commencement

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Information to identify the case:

Debtor PG&E Corporation. et al. EIN 94-3234914

 Name

United States Bankruptcy Court for the: Northern District of California

Date case filed in chapter 11: [ ]

MM / DD / YYYY 

19 Case number:

Official Form 309F (For Corporations or Partnerships)

Notice of Chapter 11 Bankruptcy Case 12/17

For the debtor listed above, a case has been filed under chapter 11 of the Bankruptcy Code. An order for relief has been 

entered. This notice has important information about the case for creditors, debtors, and trustees, including information about 

the meeting of creditors and deadlines. Read both pages carefully.

The filing of the case imposed an automatic stay against most collection activities. This means that creditors generally may not 

take action to collect debts from the debtor or the debtor’s property. For example, while the stay is in effect, creditors cannot 

sue, assert a deficiency, repossess property, or otherwise try to collect from the debtor. Creditors cannot demand repayment 

from the debtor by mail, phone, or otherwise. Creditors who violate the stay can be required to pay actual and punitive 

damages and attorney’s fees.

Confirmation of a chapter 11 plan may result in a discharge of debt. A creditor who wants to have a particular debt excepted 

from discharge may be required to file a complaint in the bankruptcy clerk’s office within the deadline specified in this notice. 

(See line 11 below for more information.)

To protect your rights, consult an attorney. All documents filed in the case may be inspected at the bankruptcy clerk’s office at 

the address listed below or through PACER (Public Access to Court Electronic Records at www.pacer.gov).

The staff of the bankruptcy clerk’s office cannot give legal advice.

Do not file this notice with any proof of claim or other filing in the case.

1. Debtors’ full names (Jointly Administered Cases):

Debtor Address Case No. EIN#

PG&E Corporation 77 Beale Street, P.O. Box 77000, San 

Francisco, California 94177. 19-_____ 94-3234914

Pacific Gas and Electric Company 77 Beale Street, P.O. Box 77000, San 

Francisco, California 94177. 19-_____ 94-0742640

2. All other names used in the last 8 years: Other names, if any, used by any of the Debtors in the last 8 years may be found in the 

Debtors’ chapter 11 petitions.

3. Address: See above

4. Debtors’ attorneys

Tobias S. Keller (#151445)

KELLER & BENVENUTTI LLP

650 California Street, Suite 1900

San Francisco, CA 94108 Telephone: (844) 339-4217 (Toll Free)

 +1 (929) (333)-8977 (Int’l)

Email: pgeinfo@primeclerk.com

Stephen Karotkin (pro hac vice pending)

WEIL, GOTSHAL & MANGES LLP

767 Fifth Avenue

New York, New York 10153

5. Bankruptcy clerk’s office:

Documents in this case may be filed at this 

address. You may inspect all records filed in 

this case at this office or online at 

www.pacer.com.

U.S. Bankruptcy Court

450 Golden Gate Avenue

Mail Box 36099

San Francisco, CA 94102

Hours open: Monday-Friday, 9 a.m.- 4:30 p.m. (CT)

Contact phone: 888-821-7606

Case: 19-30088 Doc# 17-1 Filed: 01/29/19 Entered: 01/29/19 01:22:35 Page 7 of

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Debtor PG&E Corporation, et al., Case number (if known)

Name

Official Form 309F (For Corporations of Partnerships) Notice of Chapter 11 Bankruptcy Case page 2

6. Meeting of creditors

The debtor’s representative 

must attend the meeting to be 

questioned under oath.

Creditors may attend, but are 

not required to do so.

at

Date Time

The meeting may be continued or 

adjourned to a later date. If so, the date 

will be on the court docket.

Location: [______]

 

7. Proof of claim deadline Deadline for filing proof of claim: To Be Determined

A proof of claim is a signed statement describing a creditor’s claim. A proof of claim form may be obtained 

at www.uscourts.gov or any bankruptcy clerk’s office.

Your claim will be allowed in the amount scheduled unless:

 your claim is designated as disputed, contingent, or unliquidated;

 you file a proof of claim in a different amount; or

 you receive another notice.

If your claim is not scheduled or if your claim is designated as disputed, contingent, or unliquidated, you 

must file a proof of claim or you might not be paid on your claim and you might be unable to vote on a 

plan. You may file a proof of claim even if your claim is scheduled.

You may review the schedules at the bankruptcy clerk’s office or online at www.pacer.gov.

Secured creditors retain rights in their collateral regardless of whether they file a proof of claim. Filing a 

proof of claim submits a creditor to the jurisdiction of the bankruptcy court, with consequences a lawyer 

can explain. For example, a secured creditor who files a proof of claim may surrender important 

nonmonetary rights, including the right to a jury trial.

8. Exception to discharge 

deadline

The bankruptcy clerk’s 

office must receive a 

complaint and any 

required filing fee by the 

following deadline.

If § 523(c) applied to you claim and you seek to have it excepted from discharge, you must start a judicial 

proceeding by filing a complaint by the deadline statement below.

Deadline for filing the complaint: To Be Determined

9. Creditors with a foreign 

address

If you are a creditor receiving notice mailed to a foreign address, you may file a motion asking the court to 

extend the deadlines in this notice. Consult an attorney familiar with United States bankruptcy law if you 

have any questions about your rights in this case.

10.Filing a Chapter 11 

bankruptcy case

Chapter 11 allows debtors to reorganize or liquidate according to a plan. A plan is not effective unless the 

court confirms it. You may receive a copy of the plan and a disclosure statement telling you about the 

plan, and you may have the opportunity to vote on the plan. You will receive notice of the date of the 

confirmation hearing, and you may object to confirmation of the plan and attend the confirmation hearing. 

Unless a trustee is serving, the debtor will remain in possession of the property and may continue to 

operate its business.

11.Discharge of debts Confirmation of a chapter 11 plan may result in a discharge of debts, which may include all or part of your 

debt. See 11 U.S.C. § 1141(d). A discharge means that creditors may never try to collect the debt from 

the debtor except as provided in the plan. If you want to have a particular debt owed to you excepted from 

the discharge under 11 U.S.C. § 1141(d)(6)(A), you must start a judicial proceeding by filing a complaint 

and paying the filing fee in the bankruptcy clerk’s office by the deadline.

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