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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 WILDFIRE FUND

MOTION

[Re: Dkt No. 3444]

Date: August 28, 2019

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

Place: United States Bankruptcy Court

 Courtroom 17, 16th Floor San Francisco, CA 94102

Objection Deadline: August 21, 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# 3686 Filed: 08/25/19 Entered: 08/25/19 17:30:49 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 Motion of Debtors Pursuant to 

11 U.S.C. §§ 105(a) and 363 for an Order Authorizing Debtors to Participate in AB-1054 Wildfire Fund

[Dkt No. 3444] (the “Motion”).

RELIEF REQUESTED IN THE MOTION

The Motion seeks an order authorizing the Debtors to participate in and contribute to 

the Go-Forward Wildfire Fund (as defined in the Motion) upon their emergence from these Chapter 11 

Cases, in accordance with the terms of the Wildfire Legislation (as defined in the Motion). A proposed 

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

NOTICE AND SERVICE

A Notice of Hearing on Motion of Debtors Pursuant to 11 U.S.C. §§ 105(a) and 363 for 

an Order Authorizing Debtors to Participate in AB-1054 Wildfire Fund (the “Wildfire Fund Motion”)

was filed concurrently with the Motion on August 7, 2019 [Dkt. No. 3447] (the “Notice of Hearing”). 

The Motion and the Notice of Hearing were served as described in the Certificate of Service of Alain B. 

Francoeur filed on August 12, 2019 [Dkt. No. 3508].

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. The Official Committee of 

Unsecured Creditors filed the Statement of the Official Committee of Unsecured Creditors in Support of 

the Motion of Debtors Pursuant to 11 U.S.C. §§ 105(a) and 363 for an Order Authorizing Debtors to 

Participate in AB-1054 Wildfire Fund on August 21, 2019 [Dkt. No. 3636] (the “UCC Supporting 

Statement”) expressing its support of the Motion. The Official Committee of Tort Claimants filed the 

Response of the Official Committee of Tort Claimants to Motion of Debtors Pursuant to 11 U.S.C. 

Case: 19-30088 Doc# 3686 Filed: 08/25/19 Entered: 08/25/19 17:30:49 Page 2 of

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767 Fifth Avenue

New York, NY 10153-0119

§§ 105(a) and 363 for an Order Authorizing Debtors to Participate in AB-1054 Wildfire Fund (the 

“Wildfire Fund Motion”) on August 22, 2019 [Dkt. No. 3664] (the “TCC Response”) which does not

object to the specific relief requested in the Motion and seeks to reserve certain rights as described in the 

TCC Response. The TCC has consented to entry of an order granting the Motion by default.

DECLARATION OF NO OPPOSITION RECEIVED

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

that:

1. I am a partner 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 other than the UCC Supporting Statement and the TCC Response 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: August 25, 2019

WEIL, GOTSHAL & MANGES LLP

KELLER & BENVENUTTI LLP

/s/ Jane Kim

Jane Kim

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 3686 Filed: 08/25/19 Entered: 08/25/19 17:30:49 Page 3 of

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