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WEIL, GOTSHAL & MANGES LLP 

Stephen Karotkin (pro hac vice) 

(stephen.karotkin@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 

Proposed 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,

Debtors.

Bankruptcy Case 

No. 19 - 30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

INTERIM ORDER PURSUANT TO 11 U.S.C. 

§§ 105(a), 362(d), 363(b), 363(c), AND 364 AND 

FED. R. BANKR. P. 4001, 6003, AND 6004 (I) 

AUTHORIZING THE DEBTORS TO (A) 

MAINTAIN INSURANCE POLICIES, 

WORKERS’ COMPENSATION PROGRAM, 

AND SURETY BOND PROGRAM AND (B) 

PAY ALL OBLIGATIONS WITH RESPECT 

THERETO; AND (II) GRANTING RELIEF 

FROM THE AUTOMATIC STAY WITH 

RESPECT TO WORKERS’ 

Signed and Filed: January 31, 2019

________________________________________

DENNIS MONTALI

U.S. Bankruptcy Judge

Entered on Docket 

January 31, 2019

EDWARD J. EMMONS, CLERK 

U.S. BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA

Case: 19-30088 Doc# 211 Filed: 01/31/19 Entered: 01/31/19 18:24:34 Page 1 of 6
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COMPENSATION CLAIMS

□ Affects PG& Corporation 

□ Affects Pacific Gas and Electric 

 Company 

x Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM).

Case: 19-30088 Doc# 211 Filed: 01/31/19 Entered: 01/31/19 18:24:34 Page 2 of 6
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Upon the Motion, dated January 29, 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), 362(d), 363(b), 363(c), and 364 of title 11 of the United States 

Code (the “Bankruptcy Code”) and Rules 4001, 6003, and 6004 of the Federal Rules of Bankruptcy 

Procedure (the “Bankruptcy Rules”), for interim and final authority (i) to (a) maintain their Insurance 

Policies, Workers’ Compensation Program, and Surety Bond Program and to perform their obligations 

with respect thereto during these Chapter 11 Cases, and (b) pay any prepetition obligations arising under 

or related to the Insurance Policies, Workers’ Compensation Program, or Surety Bond Program; and 

(ii) modifying the automatic stay to the extent necessary to permit the Debtors’ employees to proceed 

with any claims they may have under the Workers’ Compensation Program; and granting related relief; 

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, the 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 necessary to avoid immediate 

and irreparable harm to the Debtors and their estates as contemplated by Bankruptcy Rule 6003, and is 

in the best interests of the Debtors, their estates, creditors, shareholders, and all parties in interest; and 

 

1

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

terms in the Motion. 

Case: 19-30088 Doc# 211 Filed: 01/31/19 Entered: 01/31/19 18:24:34 Page 3 of 6
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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 on an interim basis, as provided herein. 

2. The Debtors are authorized, but not directed, pursuant to sections 105(a), 363, and 364 of 

the Bankruptcy Code, to continue and maintain all Insurance Policies,2 the Workers’ Compensation 

Program (including providing additional Collateral), and the Surety Bond Program, and to perform all 

of their obligations with respect thereto, and to pay any amounts owed with respect to the Insurance 

Policies, the Service Provider Fees, the Workers’ Compensation Program, the Workers’ Compensation 

Claims, and the Surety Bond Program; provided, that, the Debtors are authorized to pay only amounts 

due and payable as of the Petition Date and amounts that are or become due and payable between the 

Petition Date and the date that a final order on the Motion is entered, unless otherwise ordered by the 

Court. 

3. The Debtors are authorized, but not directed, in the ordinary course of business to revise, 

renew, roll over, replace, extend, supplement or otherwise modify their insurance coverage as needed, 

including, without limitation, through the purchase of new or the renewal of existing Insurance Policies. 

4. The Debtors are authorized, but not directed, to renew or to obtain and provide additional 

or new Surety Bonds, and to take all appropriate actions in connection therewith, including providing 

any cash or other collateral, as required under existing, renewed or new Surety Bonds. 

5. Pursuant to section 362(d) of the Bankruptcy Code, to the extent any of the Debtors’ 

employees hold claims under or in connection with the Workers’ Compensation Program, in the Debtors’ 

sole discretion, such employees are authorized to proceed with their Workers’ Compensation Claims 

through and including the collection or payment of any judgment or claim in the appropriate judicial or 

administrative forum under the Workers’ Compensation Program; provided, that, the prosecution of such 

claims is in accordance with the Workers’ Compensation Program and the recoveries are limited to the 

 

2

 For the avoidance of doubt, the term Insurance Policies shall include all insurance policies issued or 

providing coverage to the Debtors at any time, whether expired, current or prospective, and any 

agreements related thereto. 

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proceeds available under the Workers’ Compensation Program. 

6. Nothing herein alters or amends the terms and conditions of any of the Insurance Policies 

or relieves the Debtors of any of their obligations under the Insurance Policies. 

7. Applicable banks and financial institutions are authorized, but not directed, at the 

Debtors’ request, to receive, process, honor and pay, to the extent of funds on deposit, any and all checks 

issued or to be issued or electronic funds transfers requested or to be requested by the Debtors relating 

to the Insurance Obligations, the Workers’ Compensation Claims, the Surety Bond Obligations or the 

Service Provider Fees. 

8. The Debtors are authorized, but not directed, to issue new postpetition checks, or effect 

new electronic funds transfers on account of the Insurance Obligations, the Workers’ Compensation 

Claims, the Surety Bond Obligations and the Service Provider Fees, to replace any prepetition checks or 

electronic funds transfer requests that may be lost, dishonored, or rejected as a result of the 

commencement of the Chapter 11 Case. 

9. Nothing contained in this Interim Order or in the Motion is intended to be or shall be 

construed as (a) an admission as to the validity of any claim against the Debtors, (b) a waiver of the 

Debtors’ or any appropriate party in interest’s rights to dispute any claim, or (c) an approval or 

assumption of any agreement, contract, program, policy, or lease under section 365 of the Bankruptcy 

Code. Likewise any payment made pursuant to this Interim Order is not intended to be and shall not be 

construed as an admission to the validity of any claim or a waiver of the Debtors’ rights to dispute such 

claim subsequently. 

10. Notwithstanding entry of this Interim Order, nothing herein shall create, nor is intended 

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

11. The requirements for immediate entry of this Interim Order pursuant to Bankruptcy Rule 

6003(b) have been satisfied. 

12. The requirements of Bankruptcy Rules 4001(d) and 6004(a) are waived. 

13. Notwithstanding the provisions of Bankruptcy Rules 4001(a)(2) and 6004(h), this Interim 

Order shall be immediately effective and enforceable upon its entry. 

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

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Interim Order. 

15. A final hearing to consider the relief requested in the Motion shall be held on February 

27, 2019 at 9:30 a.m. (Prevailing Pacific Time) and any objections or responses to the Motion shall be 

filed and served so as to be actually received on or prior to February 20, 2019 at 4:00 p.m. (Prevailing 

Pacific Time). 

16. This Court shall retain jurisdiction to hear and determine all matters arising from or 

related to the implementation, interpretation, or enforcement of this Interim Order. 

** END OF ORDER ** 

Case: 19-30088 Doc# 211 Filed: 01/31/19 Entered: 01/31/19 18:24:34 Page 6 of 6