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Exhibit A

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WEIL, GOTSHAL & MANGES LLP 

Richard W. Slack (pro hac vice) 

(richard.slack@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 KIM LLP

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Gabrielle L. Albert (#190895) 

(galbert@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: (415) 496-6723 

Fax: (650) 636 9251 

Attorneys for Debtors and Reorganized Debtors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Case Nos. 19-30088 (DM) (Lead Case) 

(Jointly Administered) 

[PROPOSED] ORDER FURTHER 

EXTENDING DEADLINE FOR THE 

REORGANIZED DEBTORS TO OBJECT 

TO CLAIMS AND GRANTING RELATED 

RELIEF 

[Related to Dkt. No. [•]] 

Date: June 7, 2023 

Time: 10:00 a.m. (Pacific Time) 

Place: (Tele/videoconference Only)

 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). 

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Upon the Motion for Entry of an Order Further Extending Deadline for the Reorganized 

Debtors to Object to Claims and for Related Relief, dated May 17, 2023 [Docket No. [•]] (the 

“Motion”)1 of PG&E Corporation and Pacific Gas and Electric Company, as debtors and 

reorganized debtors (together, the “Debtors” or the “Reorganized Debtors”) in the abovecaptioned chapter 11 cases, in accordance with Section 7.1 of the Plan, sections 105(a) and 1142 of 

title 11 of the United States Code, and Rule 9006(b) of the Federal Rules of Bankruptcy Procedure, 

for entry of an order extending the deadline for the Reorganized Debtors to object to claims, without 

prejudice to the Reorganized Debtors’ right to seek additional extensions thereof, approving certain 

amendments to the Securities Procedures in substantially the form attached as Exhibit B to the 

Motion, and approving the procedures attached as Exhibit C to the Motion (the “Securities Claims 

Merits Litigation Procedures – Part 1”) for facilitating the timely submission of the factual and 

legal basis for the Securities Claims and providing for the efficient litigation thereof; 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, and it appearing that no other or further notice need be provided; 

and this Court having reviewed the Motion and the Declarations of Richard Slack, Robb 

McWilliams, and Angela Ferrante submitted in support thereof; and the Court having held a hearing 

to consider the relief requested in the Motion at the above-captioned date and time, with appearances 

as noted on the record (the “Hearing”); and upon the record of the Hearing and this Court having 

determined that the legal and factual bases set forth in the Motion establish just cause for the relief 

granted herein; and it appearing that the relief granted herein is in the best interests of the Debtors 

and Reorganized Debtors, their estates, creditors, shareholders, and all parties in interest; and after 

 

1

 Capitalized terms used but not herein defined have the meanings ascribed to such terms in the 

Motion, the Debtors’ and Shareholder Proponents’ Joint Chapter 11 Plan of Reorganization Dated 

June 19, 2020 [Dkt. No. 8048] (as it may be amended, modified, or supplemented and together 

which any exhibits or schedules thereto, the “Plan”), or the Order Confirming Debtors’ and 

Shareholder Proponents’ Joint Chapter 11 Plan of Reorganization Dated June 19, 2020 [Dkt. No. 

8053] (the “Confirmation Order”), as applicable. 

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due deliberation and sufficient cause appearing therefor, 

IT IS HEREBY ORDERED THAT: 

1. The Motion is granted as provided herein. 

2. All objections and responses received to the Motion that have not been resolved are 

overruled other than as expressly provided herein. 

3. The deadline for the Reorganized Debtors to object to Claims under Section 7.1 of the 

Plan (as approved by Paragraph 31 of the Confirmation Order) which was extended by prior orders 

to June 20, 2023 is further extended by one hundred eighty (180) days (after application of 

Bankruptcy Rule 9006(a)) to December 18, 2023, without prejudice to the right of the Reorganized 

Debtors to seek additional extensions thereof. 

4. The Securities Procedures are amended as provided in Exhibit B to the Motion and 

the Reorganized Debtors are authorized to implement the Securities Procedures as amended by this 

Order. 

5. The Securities Claims Merits Litigation Procedures – Part 1 attached as Exhibit C to 

the Motion are approved, and the Reorganized Debtors are authorized to implement the Securities 

Claims Merits Litigation Procedures – Part 1 as set forth therein. 

6. Consistent with the Plan and Confirmation Order, the Debtors and Reorganized 

Debtors shall have no obligation to object to Fire Victim Claims or Subrogation Wildfire Claims, 

nor shall any such non-objection constitute an allowance or deemed allowance of any Fire Victim 

Claim or Subrogation Wildfire Claim. Pursuant to the Plan and the Confirmation Order, all Fire 

Victim Claims and Subrogation Wildfire Claims have been channeled to the Fire Victim Trust or 

the Subrogation Wildfire Trust, as applicable, and shall be resolved by the applicable Fire Victim 

Trust or Subrogation Wildfire Trust, in each case, without any recourse to or Claims whatsoever 

against the Debtors or Reorganized Debtors or their assets and properties. 

7. For the avoidance of doubt, the relief granted herein does not apply to the existing 

deadline for the Reorganized Debtors to object to the remaining United States Claims.2

 

2

 As used here, “United States Claims” means Class 4B Utility General Unsecured Claims of the 

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8. This Court shall retain jurisdiction to hear and determine all matters arising from or 

related to the implementation, interpretation, or enforcement of this Order. 

** END OF ORDER ** 

 

United States that are identified by claim number and amount in Docket No. 9718 as required by 

the Initial Extension Order. 

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