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Exhibit A

[PROPOSED] Order

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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)

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

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice)

(pzumbro@cravath.com)

Kevin J. Orsini (pro hac vice)

(korsini@cravath.com)

Omid H. Nasab (pro hac vice)

(onasab@cravath.com)

David A. Herman (pro hac vice)

(dherman@cravath.com)

825 Eighth Avenue

New York, NY 10019

Tel: 212 474 1000

Fax: 212 474 3700

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. §§ 105(a) AND 502(c) FOR THE 

ESTABLISHMENT OF WILDFIRE CLAIMS 

ESTIMATION PROCEDURES

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). 

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Upon the Motion, dated July 18, 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) and 502(c) of title 11 of the United States Code 

(the “Bankruptcy Code”) for the establishment of wildfire claims estimation procedures, as more 

fully set forth in the Motion; and this Court having jurisdiction to consider the Application and the 

relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334, and the Order Referring 

Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24 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 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 this Court having found and determined that the relief sought in the 

Motion is in the best interests of the Debtors, their estates, creditors, shareholders, and all parties 

in interest; 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 Sections 105(a) and 502(c) of the Bankruptcy Code, this Court hereby 

establishes the following procedures and schedules for the estimation of the Debtors’ aggregate 

liability for contingent and/or unliquidated claims arising out of the 2015, 2017 and 2018 Northern 

California Wildfires (the “Wildfires” and the “Wildfire Claims”).

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

such terms in the Motion.

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3. Inverse Condemnation Hearing: The Court shall hold a hearing to determine the 

allowance or disallowance of Fire Claims that are based upon the doctrine of inverse 

condemnation. Briefs in support of Debtors’ position shall be filed one week from the entry of 

this Order. Briefs in opposition of Debtors’ position shall be filed three weeks from the filing of 

the opening briefs. Replies in support of Debtors’ position shall be filed two weeks from the filing 

of the opposition briefs. A hearing on this matter shall be held two weeks after the filing of the 

reply briefs, on ________________, 2019, at __:__ [AM/PM] Pacific Time. 

4. Tubbs Fire Hearing: The Court shall hold an evidentiary hearing to estimate the 

likelihood of success of Wildfire Claims arising out of the Tubbs Fire. Such hearing shall 

commence on October 7, 2019, and shall continue for no more than three weeks. The Debtors 

shall meet and confer with other parties in interest and shall present to the Court within two weeks

of the date of this Order a proposed schedule for discovery and other proceedings associated with 

this hearing. 

5. Final Estimation Hearing: The Court shall hold a final estimation to commence on 

December ___, 2019. The Debtors shall meet and confer with other parties in interest and shall 

present to the Court within three weeks of the date of this Order a proposed schedule for discovery 

and other proceedings associated with this hearing. 

6. 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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