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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,

Bankruptcy Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

REQUEST FOR ENTRY OF ORDERS BY 

DEFAULT ON MOR DEADLINES AND FORM 

MODIFICATION MOTION 

[Re: Dkt No. 1788] 

Date: June 26, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: June 19, 2019 

 4:00 p.m. (Pacific Time) 

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# 2678 Filed: 06/20/19 Entered: 06/20/19 09:55:54 Page 1 of

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

REQUEST FOR ENTRY OF ORDER BY DEFAULT 

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 abovecaptioned chapter 11 cases (the “Chapter 11 Cases”), hereby request, pursuant to Rule 9014-1(b)(4) of 

the Bankruptcy Local Rules for the United States District Court for the Northern District of California, 

as made applicable to these Chapter 11 Cases by the Second Amended Order Implementing Certain 

Notice and Case Management Procedures entered on May 14, 2019 [Dkt No. 1996] (“Case 

Management Order”), that the Court enter an order by default on the Application Pursuant to L.B.R. 

2015-2(e) and 11 U.S.C. § 105(a) for an Order Modifying Debtors’ Deadlines for Filing Monthly 

Operating Reports and Approving Proposed Modifications to Form of Monthly Operating Reports [Dkt 

No. 1788] (the “Application”). 

RELIEF REQUESTED IN THE APPLICATION

The Application seeks entry of an order (a) modifying the deadlines, as required under 

section 521 of the Bankruptcy Code and Bankruptcy Local Rule 2015-2(a), for the Debtors to file 

monthly operating reports (“Monthly Operating Reports”) to coincide with their reporting 

requirements to the Securities and Exchange Commission (the “SEC”), and (b) approving certain 

modifications to the form of Monthly Operating Reports required under Bankruptcy Local Rule 2015-

2(d) to conform with the Debtors’ existing reporting processes and procedures. A proposed order was 

attached as an exhibit to the Application. 

NOTICE AND SERVICE 

A Notice of Motions to be Heard at May 22, 2019 Omnibus Hearing was filed 

concurrently with the Application on May 1, 2019 [Dkt. No. 1807] (the “Notice of Hearing”). The 

Application, its supporting Declaration of John Boken, and the Notice of Hearing were served as 

described in the Certificate of Service of Jesse A. Offenhartz filed on May 15, 2019 [Dkt. No. 2022]. 

On May 10, 2019, the Debtors filed a Notice of Continued Hearing on MOR Deadlines 

and Form Modification Motion [Dkt No. 1973], which continued the hearing on the Application to June 

11, 2019, at 9:30 a.m. (Pacific time). 

On May 31, 2019, the Debtors filed a Second Notice of Continued Hearing on MOR 

Case: 19-30088 Doc# 2678 Filed: 06/20/19 Entered: 06/20/19 09:55:54 Page 2 of

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

Deadlines and Form Modification Motion [Dkt No. 2302], which continued the hearing on the 

Application to June 26, 2019, at 9:30 a.m. (Pacific time), and further extended the deadline for parties 

to file responses or oppositions to the Application to June 19, 2019, at 4:00 p.m. (Pacific time). 

The deadline to file responses or oppositions to the Application has passed, and no 

oppositions or responses have been filed with the Court or received by proposed counsel for the Debtors. 

The Office of the United States Trustee (the “U.S. Trustee”) gave informal comments to the Debtors, as 

a result of which the Debtors and the U.S. Trustee have agreed on the revised form of Proposed Order 

attached hereto as Exhibit A. 

DECLARATION OF NO RESPONSE RECEIVED 

The undersigned hereby declares, pursuant to 28 U.S.C. § 1746, under penalty of perjury, 

that: 

1. I am a partner of the firm of Keller & Benvenutti LLP, co-counsel for the Debtors. 

2. I have not received any response or opposition to the Application. 

3. I have reviewed the Court’s docket in the Chapter 11 Cases and have determined 

that no response or opposition has been filed with respect to the Application. 

4. This declaration was executed in San Francisco, California. 

WHEREFORE, the Debtors hereby request entry of an order substantially in the form 

attached hereto as Exhibit A, granting the Application as set forth therein. 

Dated: June 20, 2019 

WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

By: /s/ Jane Kim ____________ 

 Jane Kim 

Attorneys for Debtors 

and Debtors in Possession 

Case: 19-30088 Doc# 2678 Filed: 06/20/19 Entered: 06/20/19 09:55:54 Page 3 of

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