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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)|

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 

DEBTORS’ FIRST OMNIBUS REPORT AND 

OBJECTION TO CLAIMS ASSERTED 

PURSUANT TO 11 U.S.C. § 503(b)(9)

Re: Dkt. No. 2896

Date: August 14, 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# 3522 Filed: 08/12/19 Entered: 08/12/19 18:11:54 Page 1 of

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767 Fifth Avenue

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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 (the “Bankruptcy 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 March 1, 2019, the Bankruptcy Court entered 

that certain Amended Order Pursuant to 11 U.S.C. §§ 503(b)(9) and 105(a) Establishing Procedures for 

the Assertion, Resolution, and Satisfaction of Claims Asserted Pursuant to 11 U.S.C. § 503(b)(9) [Dkt. 

No. 725] (the “503(b)(9) Procedures Order”), pursuant to which the Court established certain 

procedures (the “503(b)(9) Procedures”) to govern the resolution of any claims (the “503(b)(9) 

Claims”) that may be asserted against the Debtors by various claimants (each a “Claimant”) pursuant 

to section 503(b)(9) of the Bankruptcy Code.

PLEASE TAKE FURTHER NOTICE that on July 8, 2019, in accordance with the 503(b)(9) 

Procedures Order, the Debtors filed their first omnibus report and objection (“Objection”) to the 

503(b)(9) Claims [Dkt No. 2896]. A proposed form of Order with respect to the relief sought therein 

was attached as Exhibit A to the Objection (the “Original Proposed Order”).

PLEASE TAKE FURTHER NOTICE that the hearing on the Objection is scheduled to be 

held on August 14, 2019, at 9:30 a.m. (Pacific Time) (the “August 14 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. Unless 

previously agreed to by stipulation, oppositions or responses, if any, to the relief requested in the 

Objection were required to be filed and served on or before July 31, 2019 at 4:00 p.m. (Pacific Time) 

(the “Objection Deadline”).

PLEASE TAKE FURTHER NOTICE that, on July 29, 2019, the Debtors filed a stipulation, 

[Docket No. 3306] (the “Omnibus Extension Stipulation”), which Stipulation was granted by the 

Bankruptcy Court on August 2, 2019 [Docket No. 3365] (the “Omnibus Extension Order”), 

extending the deadline to respond to the Objection for the holders of the following 503(b)(9) Claims: 

503(b)(9) Claim Nos. 999, 1376, 1379, 2122, 2129, 2165, 2355, 2391, 2445, 2449, 2454, 2477, 2478, 

2519, 2530, 2538, 2549, 2556, 2560, 2575, 2577, 2598, 2605, 2610, 2633, 2642, 2645, 2646, 2653, 

2655, and 2830 (collectively, the “Extended 503(b)(9) Claims”) and excluding the Extended 

503(b)(9) Claims from any Order to be submitted by the Debtors on the Objection at the August 14 

Omnibus Hearing.

PLEASE TAKE FURTHER NOTICE that the Debtors received formal responses to the 

Objection from the holders of the following 503(b)(9) Claims: Petro-Canada America Lubricants, Inc. 

(503(b)(9) Claim No. 2505) [Dkt No. 3263], C.H. Reynolds Electric, Inc. (503(b)(9) Claim No. 2639) 

[Dkt No. 3267], Shiloh IV Lessee, LLC (503(b)(9) Claim No. 2447) [Dkt No. 3284], Marsh Landing 

LLC (503(b)(9) Claim No. 2026) [Dkt No. 3286], Global Ampersand LLC (503(b)(9) Claim Nos. 1378 

and 1842) [Dkt No. 3288], and Hypower, Inc. (503(b)(9) Claim No. 1386) [Dkt No. 3315] 

(collectively, the “Responses” and the claims subject to the Responses, the “Responding 503(b)(9) 

Claims,” and, together with the Extended 503(b)(9) Claims, the “Continued 503(b)(9) Claims”). A 

notice of continued hearing with respect to the Continued 503(b)(9) Claims is being filed 

contemporaneously hereto.

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 Objection (the “Revised 

Case: 19-30088 Doc# 3522 Filed: 08/12/19 Entered: 08/12/19 18:11:54 Page 2 of

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

Proposed Order, which (a) excludes the Continued 503(b)(9) Claims from the Revised Proposed Order; 

(b) incorporates certain amendments and revisions to resolve the issues and concerns raised in certain 

formal and informal responses to the Objection; and (c) incorporates revised treatments with respect to 

certain of the Responding 503(b)(9) Claims. 

PLEASE TAKE FURTHER NOTICE that the Debtors reserve the right to further amend, 

modify, or supplement the proposed order on the Objection at any time up to and during the Omnibus 

Hearing.

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.

Dated: August 12, 2019

WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP

/s/ Jane Kim

Jane Kim

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 3522 Filed: 08/12/19 Entered: 08/12/19 18:11:54 Page 3 of

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