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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 FILING OF REVISED 

PROPOSED ORDER APPROVING 

MOTION OF DEBTORS PURSUANT TO 

11 U.S.C. §§ 105(a), 363(b), AND 503(c) 

FOR ENTRY OF AN ORDER (I) 

APPROVING DEBTORS’ INCENTIVE 

PROGRAM FOR CERTAIN KEY 

EMPLOYEES AND (II) GRANTING 

RELATED RELIEF 

Re: Dkt. No. 2664 

Date: August 9, 2019 

Time: 11:30 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# 3435 Filed: 08/07/19 Entered: 08/07/19 16:13:38 Page 1 of

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

PLEASE TAKE NOTICE that On June 19, 2019, the Debtors filed the Motion of Debtors 

Pursuant to 11 U.S.C. §§ 105(a), 363(b) and 503(c) for Entry of an Order (I) Approving Debtors’ 

Incentive Program for Certain Key Employees and (II) Granting Related Relief [Dkt. No. 2664] (the 

“Motion”). 

PLEASE TAKE FURTHER NOTICE that a proposed form of order with respect to the relief 

sought therein was attached as Exhibit A to the Motion (the “Original Proposed Order”). 

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

on August 9, 2019, at 11:30 a.m. (Pacific Time) (the “Omnibus Hearing”) at the United States 

Bankruptcy Court for the Northern District of California (San Francisco Division) (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 

Motion were required to be filed and served on or before July 17, 2019 at 4:00 p.m. (Pacific Time) (the 

“Objection Deadline”). 

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 Motion (the “Revised Proposed 

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

which reflect changes made to the Original Proposed Order following discussions with the Official 

Committee of Unsecured Creditors (the “Creditors Committee”). With these changes, the Motion 

has the support of the Creditors Committee. 

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

modify, or supplement the proposed order on the Motion 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 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 7, 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# 3435 Filed: 08/07/19 Entered: 08/07/19 16:13:38 Page 2 of

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