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

Exhibit C 

 

Case: 19-30088 Doc# 13016-3 Filed: 09/29/22 Entered: 09/29/22 16:46:13 Page 1

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

WEIL, GOTSHAL & MANGES LLP 

Richard W. Slack (pro hac vice) 

(richard.slack@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 KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Thomas B. Rupp (#278041) 

(trupp@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (415) 636-9251 

Attorneys for Debtors and Reorganized Debtors 

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) 

[PROPOSED] ORDER (I) APPROVING THE 

INSURANCE SETTLEMENTS, AND 

(II) GRANTING RELATED RELIEF  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# 13016-3 Filed: 09/29/22 Entered: 09/29/22 16:46:13 Page 2

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

Upon the motion, dated September 29, 2022 [Docket No. [●]] (the “Motion”), of PG&E 

Corporation (“PG&E”) and Pacific Gas and Electric Company (the “Utility” and together with PG&E, 

the “Debtors” or “Reorganized Debtors”) in the above-captioned chapter 11 cases (the “Chapter 11 

Cases”), pursuant to sections 363(b) and 105(a) of title 11 of the United States Code (the “Bankruptcy 

Code”) and Rule 9019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), for an 

order (i) approving the two settlement agreements entered into by and among the Reorganized Debtors 

and certain of their insurers in connection with PG&E Corporation et al. v. Associated Electric & Gas 

Insurance Services Limited, et al., CPR File No. G-20-56-S (the “Insurance Settlements”), and (ii) 

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. § 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; 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, and it appearing that no other or further notice need be provided; 

and this Court having reviewed the Motion and the Declarations of John R. Simon, David B. Goodwin, 

and Richard W. Slack; 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 Reorganized Debtors, the Debtors’ estates, creditors, shareholders, 

and all parties in interest; and 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. 

2. The Insurance Settlements are hereby approved. 

3. The Reorganized Debtors are authorized to take all actions necessary to implement the 

Insurance Settlements, including to use the proceeds of the Insurance Settlements for costs, expenses 

and settlements in connection with securities claims and the claims by the PG&E Fire Victim Trust and 

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

any insurer party to the Insurance Settlements is authorized to fund the payments as required pursuant 

to the terms thereof, as set forth in the Motion. 

4. This Court shall retain exclusive jurisdiction to hear and determine all matters arising 

from or related to the implementation, interpretation, or enforcement of this Order and the Insurance 

Settlements. 

** END OF ORDER ** 

Case: 19-30088 Doc# 13016-3 Filed: 09/29/22 Entered: 09/29/22 16:46:13 Page 4

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