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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) 

REQUEST FOR ENTRY OF ORDER BY DEFAULT 

ON DEBTOR’S MOTION PURSUANT TO FED. R. 

BANKR. P. 4001(d) TO APPROVE STIPULATION 

BETWEEN DEBTOR PACIFIC GAS AND 

ELECTRIC COMPANY AND KATHLEEN 

PELLEY AND ALLAN PELLEY REGARDING 

MODIFICTION OF AUTOMATIC STAY 

[Re: Dkt No. 3874] 

Objection Deadline: October 2, 2019 

 4:00 p.m. (Pacific Time) 

No hearing requested absent timely objection. If 

timely objection is filed, hearing reserved for: 

Date: October 22, 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 

 Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

Case: 19-30088 Doc# 4080 Filed: 10/03/19 Entered: 10/03/19 08:07:51 Page 1 of

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28 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 Debtor’s Motion Pursuant to Fed. 

R. Bankr. P. 4001(d) to Approve Stipulation Between Debtor Pacific Gas and Electric Company and 

Kathleen Pelley and Allan Pelley Regarding Modification of Automatic Stay [Dkt. No. 3874] (the 

“Motion”). 

RELIEF REQUESTED IN THE MOTION 

The Motion seeks an order approving an agreement between the Utility and Kathleen 

Pelley and Allan Pelley as embodied in the Stipulation Between Debtor and Kathleen Pelley and Allan 

Pelley Regarding Modification of the 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 Debtor’s Motion Pursuant to Fed. R. Bankr. P. 

4001(d) to Approve Stipulation Between Debtor Pacific Gas and Electric Company and Kathleen Pelley 

and Allan Pelley Regarding Modification of Automatic Stay was filed concurrently with the Motion on 

September 11, 2019 [Dkt. No. 3879] (the “Notice of Opportunity for Hearing”). The Motion, the 

supporting declarations of Jana Contreras [Dkt. No. 3875] and Joseph Echols [Dkt. No. 3876], and the 

Notice of Opportunity for Hearing were served as described in the Certificate of Service of Jamie B. 

Herszaft, filed on September 16, 2019 [Dkt. No. 3896]. 

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# 4080 Filed: 10/03/19 Entered: 10/03/19 08:07:51 Page 2 of

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28 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 3, 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# 4080 Filed: 10/03/19 Entered: 10/03/19 08:07:51 Page 3 of

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