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

Tig 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 

Attorneys for Debtors 

and Debtors in Possession 

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 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION, 

 - and - 

PACIFIC GAS AND ELECTRIC COMPANY, 

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 No. 19-30088 (DM) 

Chapter 11 

(Lead Case) (Jointly Administered) 

REQUEST FOR JUDICIAL NOTICE 

IN SUPPORT OF DEBTORS’ 

PRELIMINARY LIMITED 

OPPOSITION TO VLAZAKIS 

DEFENDANTS’ MOTION AS TO 

THE INAPPLICABILITY OF STAY, 

AND IN THE ALTERNATIVE FOR 

RELIEF FROM STAY 

Relates to Dkt. Nos. 4846, 4847 

Date: December 17, 2019 

Time: 10:00 a.m. 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102

 

Case: 19-30088 Doc# 5091 Filed: 12/12/19 Entered: 12/12/19 15:16:50 Page 1 of

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

TO THE COURT AND TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 

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

with PG&E Corporation (“PG&E Corp.”, together with the Utility, the “Debtors”) in the abovecaptioned Chapter 11 Cases (the “Chapter 11 Cases”) hereby respectfully requests that the Court 

take judicial notice pursuant to Federal Rule of Evidence 201 of the following documents filed in 

in the Superior Court for the County of Alameda, PG&E v. Vlazakis et al., Case No. RG19021463 

(the “State Court Action”): 

1. The Declaration of Brian Garber in Support of Pacific Gas and Electric Company’s 

Application for Preliminary Injunction, filed on June 6, 2019, a true and correct copy of which is 

attached hereto as Exhibit A. 

3. The Supplemental Declaration of Brian Garber in Support of Pacific Gas and Electric 

Company’s Application for Preliminary Injunction, filed on July 11, 2019, a true and correct copy 

of which is attached hereto as Exhibit B. 

It is appropriate for the Court to take judicial notice of Exhibits A and B. Under Federal 

Rule of Evidence 201, upon the request of a party, a court may take judicial notice of a fact that 

“can be accurately and readily determined from sources whose accuracy cannot reasonably be 

questioned.” Fed. R. Evid. 201(b)(2). The authenticity of Exhibits A and B cannot reasonably be 

questioned because they are publicly available filings in the State Court Action. 

Accordingly, the Debtors respectfully request that the Court take judicial notice of the 

documents identified above and attached hereto as Exhibits A and B. 

Dated: December 12, 2019 WEIL, GOTSHAL & MANGES LLP

KELLER & BENVNUTTI LLP 

By: /s/ Peter J. Benvenutti 

 Peter J. Benvenutti 

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 5091 Filed: 12/12/19 Entered: 12/12/19 15:16:50 Page 2 of

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