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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 

LEASE ASSUMPTION MOTION 

Re: Dkt. No. 3726 

Date: September 24, 2019 

Time: 9:30 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# 3973 Filed: 09/23/19 Entered: 09/23/19 14:31:27 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 January 29, 2019, PG&E Corporation and Pacific Gas and 

Electric Company, as debtors and debtors in possession (collectively, the “Debtors”) in the abovecaptioned chapter 11 cases, each filed a voluntary petition for relief under chapter 11 of title 11 of the 

United States Code with the United States Bankruptcy Court for the Northern District of California 

(San Francisco Division) (the “Bankruptcy Court”). 

PLEASE TAKE FURTHER NOTICE that on August 27, 2019, the Debtors filed the Fifth 

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 Approving Assumption of Real Property Leases [Docket No. 3726] (the “Motion”). A hearing 

on the Motion is scheduled to be held on September 24, 2019, at 9:30 a.m. (Pacific Time) (the 

“Omnibus Hearing”) at 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. 

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. A schedule of the Real Property Leases (as 

defined in the Motion) proposed to be assumed by the Debtors pursuant to the Motion along with any 

Cure Payments (as defined in the Motion) to be made in connection with such assumption, was attached 

as Exhibit B to the Motion (Exhibits A and B together, the “Original Proposed Order”). 

PLEASE TAKE FURTHER NOTICE that on September 10, 2019, Realty Income 

Corporation filed a reservation of rights with respect to the Motion [Docket No. 3859]. 

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 (including the amended 

list of Real Property Leases, the “Revised Proposed Order”) and a redline comparison of the Revised 

Proposed Order against the Original Proposed Order. The Revised Proposed Order incorporates 

changes to reflect updated Cure Payments to certain Real Property Leases, as well as additional Real 

Property Leases with the California State Lands Commission that the Debtors wish to assume. 

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 Bankruptcy 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. 

/ / / 

/ / / 

/ / / 

Case: 19-30088 Doc# 3973 Filed: 09/23/19 Entered: 09/23/19 14:31:27 Page 2 of

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

Dated: September 23, 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# 3973 Filed: 09/23/19 Entered: 09/23/19 14:31:27 Page 3 of

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