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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 REVISED PROPOSED 

ORDER AND REQUEST FOR ENTRY OF 

ORDER BY DEFAULT ON 

ENVIRONMENTAL AGREEMENTS 

ASSUMPTION MOTION 

[Re: Dkt No. 3581] 

Date: September 24, 2019 

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

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: September 10, 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# 3886 Filed: 09/12/19 Entered: 09/12/19 16:00:34 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 Fourth Omnibus Motion of the 

Debtors Pursuant to 11 U.S.C. § 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 for an Order 

(I) Approving Assumption of Environmental Agreements and (II) Granting Related Relief 

(“Environmental Agreements Assumption Motion”) [Dkt No. 3581] (the “Motion”). 

RELIEF REQUESTED IN THE MOTION 

The Motion seeks an order (i) approving the Debtors’ assumption of agreements with 

four (4) counterparties thereto (collectively, the “Owners”) that provide the Debtors access to the 

Owners’ property to carry out environmental investigation and, in certain instances, land remediation 

and restoration obligations and (ii) granting related relief. A proposed order (the “Original Proposed 

Order”) was attached as an exhibit to the Motion. A revised proposed order (the “Revised Proposed 

Order”), which reflects that no hearing was held on the Motion, is attached hereto as Exhibit 1-1. A 

redline comparison of the Original Proposed Order and the Revised Proposed Order is attached hereto 

as Exhibit 1-2.

NOTICE AND SERVICE 

A Notice of Hearing on Fourth Omnibus Motion of Debtors Pursuant to 11 U.S.C. 

§ 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 for an Order (I) Approving Assumption of 

Environmental Agreements and (II) Granting Related Relief was filed concurrently with the Motion on 

August 16, 2019 [Dkt. No. 3583] (the “Notice of Hearing”). The Motion, the supporting declaration of 

Margaret A. Pietrasz, and the Notice of Hearing were served as described in the Certificate of Service 

of Alain B. Francoeur filed on August 21, 2019 [Dkt. No. 3642]. 

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

Case: 19-30088 Doc# 3886 Filed: 09/12/19 Entered: 09/12/19 16:00:34 Page 2 of

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

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

DECLARATION OF NO OPPOSITION RECEIVED 

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

that: 

1. I am an attorney with the firm of Keller & Benvenutti LLP, co-counsel for the 

Debtors. 

2. 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 Motion. 

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

WHEREFORE, the Debtors hereby request entry of the Revised Proposed Order 

substantially in the form attached to the hereto, granting the Motion as set forth therein. 

Dated: September 12, 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# 3886 Filed: 09/12/19 Entered: 09/12/19 16:00:34 Page 3 of

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