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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)

REQUEST FOR ENTRY OF ORDER BY DEFAULT 

ON DEBTORS’ MOTION PURSUANT TO FED. R. 

BANKR. P. 4001(d) TO APPROVE STIPULATION 

BETWEEN DEBTORS AND MICHAEL S. DANKO 

AND MARY S. DANKO FOR MODIFICTION OF 

AUTOMATIC STAY

[Re: Dkt No. 4132]

Objection Deadline: October 25, 2019

 4:00 p.m. (Pacific Time)

No hearing requested absent timely objection. If 

timely objection is filed, hearing reserved for: 

Date: November 13, 2019

Time: 10:00 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 

ý Affects both Debtors

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

Case: 19-30088 Doc# 4488 Filed: 10/28/19 Entered: 10/28/19 12:07:39 Page 1 of

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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 Debtors’ Motion Pursuant to Fed. 

R. Bankr. P. 4001(d) to Approve Stipulation Between Debtors and Michael S. Danko and Mary S. Danko 

for Modification of Automatic Stay [Dkt. No. 4132] (the “Motion”).

RELIEF REQUESTED IN THE MOTION

The Motion seeks an order approving an agreement between the Debtors and Michael S. 

Danko and Mary S. Danko, individually and as trustees of the Michael and Mary Danko Living Trust 

dated July 27, 2007 as embodied in the Stipulation Between Debtors and Michael S. Danko and Mary S. 

Danko for Modification of Automatic Stay (the “Stipulation”), which was attached to the Motion as 

Exhibit A. A proposed order (the “Proposed Order”) was attached as Exhibit B to the Motion. 

NOTICE AND SERVICE

A Notice of Opportunity for Hearing on Debtors’ Motion Pursuant to Fed. R. Bankr. P. 

4001(d) to Approve Stipulation Between Debtors and Michael S. Danko and Mary S. Danko for

Modification of Automatic Stay was filed concurrently with the Motion on September 11, 2019 [Dkt. 

No. 4135] (the “Notice of Opportunity for Hearing”). The Motion, the supporting declarations of Jana 

Contreras [Dkt. No. 4133] and Joseph Echols [Dkt. No. 4134], and the Notice of Opportunity for Hearing 

were served as described in the Certificate of Service of Andrew G. Vignali, filed on October 9, 2019 

[Dkt. No. 4169].

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

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

Case: 19-30088 Doc# 4488 Filed: 10/28/19 Entered: 10/28/19 12:07:39 Page 2 of

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Weil, Gotshal & Manges LLP

767 Fifth Avenue

New York, NY 10153-0119

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 Proposed Order substantially in 

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

Dated: October 28, 2019

WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP

/s/ Dara L. Silveira

Dara L. Silveira

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 4488 Filed: 10/28/19 Entered: 10/28/19 12:07:39 Page 3 of

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