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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) 

(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) 

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: (415) 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 - 

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

NOTICE OF AGENDA FOR 

AUGUST 9, 2019, 11:30 A.M. OMNIBUS 

HEARING 

Date: August 9, 2019 

Time: 11:30 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

San Francisco, CA 94102

PACIFIC GAS AND ELECTRIC 

COMPANY, 

 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# 3463 Filed: 08/08/19 Entered: 08/08/19 12:02:26 Page 1 of

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

PROPOSED AGENDA FOR 

AUGUST 9, 2019, 11:30 A.M. (PACIFIC TIME) 

OMNIBUS HEARING 

I: MATTERS SCHEDULED TO BE HEARD IN MAIN CASE: No. 19-30088 (DM) 

STATUS CONFERENCE 

1. Noteholder Committee’s Exclusivity Termination Motion: Motion of the Ad 

Hoc Committee of Senior Unsecured Noteholders to Terminate the Debtors’ Exclusive Periods 

Pursuant to Section 1121(d)(1) of the Bankruptcy Code [Dkt. 2741]. 

Related Documents: 

A. Statement Regarding Status of Competing Plan Protocol and Ad Hoc 

Committee Proposal [Dkt. 3416]. 

B. Declaration of Alexander Tracy in Support of Statement Regarding Status 

of Competing Plan Protocol and Ad Hoc Committee Proposal [Dkt. 3417]. 

 Status: The Court will hold a status conference regarding the negotiations of a 

 protocol for the submission of plan proposals.

CONTESTED MATTERS GOING FORWARD 

2. KEIP Motion: Motion of the Debtors Pursuant to 11 U.S.C §§ 105(a), 363(b), 

and 503(c) for Entry of an Order (I) Approving Debtors’ Incentive Program for Certain Key 

Employees and (II) Granting Related Relief [Dkt. 2664]. 

Response Deadline: July 17, 2019, at 4:00 p.m. (Pacific Time), except for the 

Official Committee of Unsecured Creditors, for whom the deadline was extended, 

by stipulation and order, to August 2, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. Letter to the Court by James M. Eaneman [Dkt. 2778]. 

B. United States Trustee’s Objection to Motion of Debtors for Entry of an 

Order Approving Key Employee Incentive Plan [Dkt. 3029]. 

C. Opposition of the Official Committee of Tort Claimants to Motion of the 

Debtors Pursuant to 11 U.S.C §§ 105(a), 363(b), and 503(c) for Entry of 

an Order (I) Approving Debtors’ Incentive Program for Certain Key 

Employees and (II) Granting Related Relief [Dkt. 3030]. 

D. Declaration of Laurie A. Brugger in Support of United States Trustee’s 

Objection to Motion of Debtors for Entry of an Order Approving Key 

Employee Incentive Plan [Dkt. 3031]. 

E. Opposition by TURN to Motion of the Debtors Pursuant to 11 U.S.C §§ 

105(a), 363(b), and 503(c) for Entry of an Order (I) Approving Debtors’ 

Incentive Program for Certain Key Employees and (II) Granting Related 

Relief [Dkt. 3035]. 

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F. Joinder of the City and County of San Francisco to Opposition of the 

Official Committee of Tort Claimants to Motion of the Debtors Pursuant 

to 11 U.S.C §§ 105(a), 363(b), and 503(c) for Entry of an Order (I) 

Approving Debtors’ Incentive Program for Certain Key Employees and 

(II) Granting Related Relief [Dkt. 3059]. 

G. Ghost Ship Warehouse Plaintiffs’ Executive Committee’s Joinder in the 

Opposition to Motion of Debtors Pursuant to 11 USC §§ 105(a), 363(b), 

and 503(c) for Entry of an Order (I) Approving Debtors’ Incentive 

Program for Certain Key Employees and (II) Granting Related Relief 

Filed by: (1) The Official Committee of Tort Claimants; and (2) the 

United States Trustee; and (3) TURN, the Utility Reform Network 

[Dkt. 3086]. 

Related Documents: 

H. Declaration of Douglas J. Friske in Support of Motion of the Debtors 

Pursuant to 11 U.S.C §§ 105(a), 363(b), and 503(c) for Entry of an Order 

(I) Approving Debtors’ Incentive Program for Certain Key Employees and 

(II) Granting Related Relief [Dkt. 2667]. 

I. Declaration of John Lowe in Support of Motion of the Debtors Pursuant to 

11 U.S.C §§ 105(a), 363(b), and 503(c) for Entry of an Order 

(I) Approving Debtors’ Incentive Program for Certain Key Employees and 

(II) Granting Related Relief [Dkt. 2668]. 

J. Notice of Filing of Revised Proposed Order Approving Motion of the 

Debtors Pursuant to 11 U.S.C §§ 105(a), 363(b), and 503(c) for Entry of 

an Order (I) Approving Debtors’ Incentive Program for Certain Key 

Employees and (II) Granting Related Relief [Dkt. 3435]. 

K. Reply Memorandum of Points and Authorities in Further Support of 

Motion of Debtors Pursuant to 11 U.S.C §§ 105(a), 363(b), and 503(c) for 

Entry of an Order (I) Approving Debtors’ Incentive Program for Certain 

Key Employees and (II) Granting Related Relief [Dkt. 3439]. 

Status: This matter is going forward on a contested basis.

3. CEO Terms of Employment Motion: Motion of Debtors Pursuant to 11 U.S.C. 

§§ 363 and 105(a) for an Order Approving Terms of Employment for New Chief Executive 

Officer and President of PG&E Corporation [Dkt. 2662]. 

Response Deadline: July 17, 2019, at 4:00 p.m. (Pacific Time), except for the 

Official Committee of Tort Claimants, for whom the deadline was extended, by 

stipulation and order, to July 19, 2019, at 9:00 a.m. (Pacific Time), and for the 

Official Committee of Unsecured Creditors, for whom the deadline was extended, 

by stipulation and order, to August 2, 2019, at 4:00 p.m. (Pacific Time). 

Responses Filed: 

A. United States Trustee’s Objection to Motion of Debtors for Entry of an 

Order Approving Employment Terms of New Chief Executive Officer 

[Dkt. 3032]. 

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B. Ghost Ship Warehouse Plaintiffs’ Executive Committee’s Joinder in the 

Opposition to Motion of Debtors Pursuant to 11 USC §§ 363 and 105(a) 

for an Order Approving Terms of Employment for New Chief Executive 

Officer and President of PG&E Corporation Filed by the United States 

Trustee [Dkt. 3085]. 

Related Documents: 

C. Declaration of Nora Mead Brownell in Support of Motion of Debtors 

Pursuant to 11 U.S.C. §§ 363 and 105(a) for an Order Approving Terms of 

Employment for New Chief Executive Officer and President of PG&E 

Corporation [Dkt. 2665]. 

D. Declaration of Douglas J. Friske in Support of Motion of Debtors Pursuant 

to 11 U.S.C. §§ 363 and 105(a) for an Order Approving Terms of 

Employment for New Chief Executive Officer and President of PG&E 

Corporation [Dkt. 2666]. 

E. Notice of Filing of Revised Proposed Order Approving Motion of Debtors 

Pursuant to 11 U.S.C. §§ 363 and 105(a) for an Order Approving Terms of 

Employment for New Chief Executive Officer and President of PG&E 

Corporation [Dkt. 3433]. 

F. Reply Memorandum of Points and Authorities in Further Support of 

Motion of Debtors Pursuant to 11 U.S.C. §§ 363 and 105(a) for an Order 

Approving Terms of Employment for New Chief Executive Officer and 

President of PG&E Corporation [Dkt. 3453]. 

G. Supplemental Declaration of Douglas J. Friske in Support of Motion of 

Debtors Pursuant to 11 U.S.C. §§ 363 and 105(a) for an Order Approving 

Terms of Employment for New Chief Executive Officer and President of 

PG&E Corporation [Dkt. 3454]. 

Status: This matter is going forward on a contested basis. 

PLEASE TAKE NOTICE that copies of any pleadings filed with the Court and 

referenced herein can be viewed and/or obtained: (i) by accessing the Court’s website at 

http://www.canb.uscourts.gov, (ii) by contacting the Office of the Clerk of the Court at 450 

Golden Gate Avenue, San Francisco, CA 94102, or (iii) from the Debtors’ notice and claims 

agent, Prime Clerk LLC, at https://restructuring.primeclerk.com/pge or by calling (844) 339-

4217 (toll free) for U.S.-based parties; or +1 (929) 333-8977 for International parties or by email at:pgeinfo@primeclerk.com. Note that a PACER password is needed to access documents 

on the Bankruptcy Court’s website. 

Dated: August 8, 2019 WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP 

 By: /s/ Dara L. Silveira 

 Dara L. Silveira 

 

Attorneys for Debtors and Debtors in Possession 

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