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

 

EXHIBIT B 

[Proposed] Order 

Case: 19-30088 Doc# 3874-2 Filed: 09/11/19 Entered: 09/11/19 10:08:43 Page 1

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

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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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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) 

[PROPOSED] ORDER APPROVING 

STIPULATION BETWEEN DEBTOR PACIFIC 

GAS AND ELECTRIC COMPANY AND 

KATHLEEN PELLEY AND ALLAN PELLEY 

REGARDING MODIFICTION OF 

AUTOMATIC STAY 

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

Upon the Motion, dated September 11, 2019 (the “Motion”)1 of PG&E Corporation 

and Pacific Gas and Electric Company (the “Utility”), as debtors and debtors in possession (each, 

a “Debtor,” and collectively, the “Debtors”) in the above-captioned chapter 11 cases (the 

“Chapter 11 Cases”), pursuant to section 362(d) of title 11 of the United States Code (the 

“Bankruptcy Code”), Rule 4001(d) of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”), and Rules 4001-1 and 9014-1(b)(3) of the Bankruptcy Local Rules for the 

United States District Court for the Northern District of California (the “Bankruptcy Local 

Rules”), 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. §§ 157 and 1334, the Order Referring 

Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24 (N.D. Cal.), and 

Bankruptcy Local Rule 5011-1(a); 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 determined that the legal and factual bases set forth in the Motion and the Declarations of 

Jana Contreras and Joseph Echols establish just cause for the relief sought; 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 Stipulation is approved, and relief from the automatic stay of Bankruptcy Code 

Section 362 is granted as and to the extent set forth in the Stipulation, effective immediately. 

 2. The Court shall retain jurisdiction to resolve any disputes or controversies arising from 

this Order or the Stipulation. 

* * * END OF ORDER * * * 

1

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

in the Motion. 

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