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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,

Case No. 19-30088 (DM)

Chapter 11 

(Lead Case) (Jointly Administered) 

NOTICE OF FILING OF REVISED 

PROPOSED ORDER APPROVING 

DE MINIMIS ASSET SALE 

PROCEDURES MOTION 

Re: Dkt. No. 3575 

Date: September 11, 2019 

Time: 9:30 a.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

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# 3861 Filed: 09/10/19 Entered: 09/10/19 15:00:44 Page 1 of

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

PLEASE TAKE NOTICE that on January 29, 2019, PG&E Corporation and Pacific Gas and 

Electric Company, as debtors and debtors in possession (collectively, the “Debtors”) in the abovecaptioned chapter 11 cases, each filed a voluntary petition for relief under chapter 11 of title 11 of the 

United States Code with the United States Bankruptcy Court for the Northern District of California 

(San Francisco Division) (the “Bankruptcy Court”). 

PLEASE TAKE FURTHER NOTICE that on August 16, 2019, the Debtors filed the Motion 

of Debtors Pursuant to 11 U.S.C. §§ 363 and 105(a) and Fed. R. Bankr. P. 2002 for Authority to 

Establish De Minimis Asset Sale Procedures [Docket No. 3575] (the “Motion”). A hearing on the 

Motion is scheduled to be held on September 11, 2019, at 9:30 a.m. (Pacific Time) (the “Omnibus 

Hearing”) at the Bankruptcy Court in the courtroom of the Honorable Dennis Montali, United States 

Bankruptcy Judge, Courtroom 17, 16th Floor, 450 Golden Gate Avenue, San Francisco, California 

94102. 

PLEASE TAKE FURTHER NOTICE that a proposed form of order with respect to the relief 

sought therein was attached as Exhibit A to the Motion (the “Original Proposed Order”). 

PLEASE TAKE FURTHER NOTICE that on September 4, 2019, the lead plaintiff in the 

securities class action captioned as In re PG&E Corporation Securities Litigation, Case No. 18-03509 

(the “Lead Plaintiffs”) timely filed a limited objection to the Motion [Docket No. 3802]. 

PLEASE TAKE FURTHER NOTICE that on September 6, 2019, the Bankruptcy Court 

issued a tentative ruling on the Motion [Docket No. 3836] (the “Tentative Ruling”) in which the 

Court stated that if the Debtors agreed with the Court’s Tentative Ruling they should revise the 

Original Proposed Order to be consistent with the Tentative Ruling, obtain approval of the Lead 

Plaintiffs to the revised form of order, and submit the revised order to the Court for approval, at which 

time, the Motion would be dropped from the Omnibus Hearing.

PLEASE TAKE FURTHER NOTICE that, attached hereto as Exhibit 1-1 and Exhibit 1-2, 

respectively, are copies of the Debtors’ revised proposed order on the Motion (the “Revised Proposed 

Order”) and a redline comparison of the Revised Proposed Order against the Original Proposed Order. 

The Revised Proposed Order incorporates changes that are consistent with the Tentative Ruling, which 

have been approved by the Lead Plaintiffs, as well as additional informal comments and revisions from 

various parties, including the Creditors Committee, the Tort Claimants Committee, the California 

Attorney General’s Office, and certain insurers. Consistent with the Tentative Ruling, the Debtors 

have, contemporaneously hereto, submitted the Revised Proposed Order to the Bankruptcy Court for 

approval. 

PLEASE TAKE FURTHER NOTICE that copies of the pleadings and other documents 

identified herein can be viewed and/or obtained: (i) by accessing the Bankruptcy 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 e-mail at: 

pgeinfo@primeclerk.com. Note that a PACER password is needed to access documents on the 

Bankruptcy Court’s website. 

//// 

//// 

Case: 19-30088 Doc# 3861 Filed: 09/10/19 Entered: 09/10/19 15:00:44 Page 2 of

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

Dated: September 10, 2019 

WEIL, GOTSHAL & MANGES LLP 

 KELLER & BENVENUTTI LLP 

/s/ Thomas B. Rupp 

 Thomas B. Rupp 

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 3861 Filed: 09/10/19 Entered: 09/10/19 15:00:44 Page 3 of

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