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

 

EXHIBIT B 

[Proposed] Order 

Case: 19-30088 Doc# 3874-2 Filed: 09/11/19 Entered: 09/11/19 10:08:43 Page 1

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Case: 19-30088 Doc# 4132-2 Filed: 10/04/19 Entered: 10/04/19 13:21:27 Page 1

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

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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) 

Peter J. Benvenutti (#60566) 

(pbenvenutti@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) 

[PROPOSED] ORDER APPROVING 

STIPULATION BETWEEN DEBTORS AND 

MICHAEL S. DANKO AND MARY S. DANKO 

FOR MODIFICTION OF AUTOMATIC STAY 

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

Upon the Motion, dated October 4, 2019 (the “Motion”)1 of PG&E Corporation and 

Pacific Gas and Electric Company (the “Utility”), as debtors and debtors in possession (each, a 

“Debtor,” and collectively, the “Debtors”) in the above-captioned chapter 11 cases (the “Chapter 

11 Cases”), pursuant to section 362(d) of title 11 of the United States Code (the “Bankruptcy 

Code”), Rule 4001(d) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), 

and Rules 4001-1 and 9014-1(b)(3) of the Bankruptcy Local Rules for the United States District 

Court for the Northern District of California (the “Bankruptcy Local Rules”), all as more fully set 

forth in the Motion; and this Court having jurisdiction to consider the Motion and the relief 

requested therein pursuant to 28 U.S.C. §§ 157 and 1334, the Order Referring Bankruptcy Cases 

and Proceedings to Bankruptcy Judges, General Order 24 (N.D. Cal.), and Bankruptcy Local Rule 

5011-1(a); 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 under the circumstances, and it 

appearing that no other or further notice need be provided; and this Court having determined that 

the legal and factual bases set forth in the Motion and the Declarations of Jana Contreras and Joseph 

Echols establish just cause for the relief sought; and upon all of the proceedings had before this 

Court and after due deliberation and sufficient cause appearing therefor, 

 IT IS HEREBY ORDERED THAT: 

1. The Stipulation is approved, and limited relief from the automatic stay of Bankruptcy 

Code Section 362 is granted as follows, effective immediately: 

a. The automatic stay is modified to permit the Dankos to litigate the Complaint 

against the Utility in San Mateo Superior Court Case No. 18-CIV-05681 (the ”San 

Mateo Action”) and to defend themselves against the Cross-Complaint; 

1

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them 

in the Motion. 

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

b. To the extent it applies, the automatic stay is modified to permit the Utility to 

litigate the Cross-Complaint in the San Mateo Action and defend itself against the 

Complaint; and 

c. The relief from stay provided by this Order shall not permit, and the automatic stay 

shall instead remain in effect with respect to, the enforcement by the Dankos of any 

judgment they may obtain in their favor in the San Mateo Action. 

 2. The Court shall retain jurisdiction to resolve any disputes or controversies arising from 

this Order or the Stipulation. 

* * * END OF ORDER * * * 

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