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Exhibit 1 

(Proposed Order)

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WEIL, GOTSHAL & MANGES LLP 

Richard W. Slack (pro hac vice) 

(richard.slack@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 KIM LLP 

Jane Kim (#298192) 

(jkim@kbkllp.com) 

David A. Taylor (#247433) 

(dtaylor@kbkllp.com) 

Thomas B. Rupp (#278041) 

(trupp@kbkllp.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors and Reorganized Debtors 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

[PROPOSED] ORDER ENFORCING 

DISCHARGE AND INJUNCTION PROVISIONS 

OF PLAN AND CONFIRMATION ORDER 

AGAINST CERTAIN PENDING ACTIONS

 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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Upon the Reorganized Debtors’ Omnibus Motion to Enforce the Discharge and Injunction 

Provisions of Plan and Confirmation Order Against Certain Pending Actions, dated April 26, 2023 

[Docket No. [●]] (the “Motion”),1 of PG&E Corporation (“PG&E”) and Pacific Gas and Electric 

Company (the “Utility” and together with PG&E, the “Debtors” or “Reorganized Debtors”) in the 

above-captioned chapter 11 cases (the “Chapter 11 Cases”), pursuant to sections 105, 524 and 1141 of 

title 11 of the United States Code, Rules 1015(c), 3020(d), and 9007 of the Federal Rules of Bankruptcy 

Procedure, Sections 4.7, 4.26, 10.3 10.6, and 10.7 of the Plan and Paragraphs 48, 49, 52, and 53 of the 

Confirmation Order, for entry of an order enforcing the discharge and injunction provisions set forth the 

Plan and Confirmation Order as more fully described in the Motion, and other related relief; and this 

Court having jurisdiction to consider the Motion and the relief requested therein pursuant to 28 U.S.C. 

§§ 157 and 1334, Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General 

Order 24 (N.D. Cal.), and Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District 

Court for the Northern District of California; 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, and it appearing that no other 

or further notice need be provided; and this Court having reviewed the Motion and the Eggleton 

Declaration; and this Court having determined that the legal and factual bases set forth in the Motion 

establish just cause for the relief granted herein; and it appearing that the relief requested in the Motion 

is in the best interests of the Reorganized Debtors, the Debtors’ estates, creditors, and all parties in 

interest; 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 relief requested in the Motion is granted as set forth herein. 

2. No later than fourteen days after entry of this Order, the State Court Plaintiffs listed in 

Annex A shall have taken all appropriate actions to dismiss their Pending Actions and otherwise comply 

1

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

terms in the Motion. 

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with the discharge and injunction provisions of the Plan and the Confirmation Order, including but not 

limited to filing a Request for Dismissal in each of the Pending Actions. 

3. If a State Court Plaintiff fails to comply with Paragraph 2 above, this Court, upon further 

motion of the Reorganized Debtors, may issue an order holding such State Court Plaintiff in contempt 

of this Court for violating the terms of this Order and the discharge and injunction provisions of the Plan 

and the Confirmation Order. 

4. Further, in connection with any contempt proceeding against a State Court Plaintiff, the 

Reorganized Debtors shall be permitted to seek sanctions against such State Court Plaintiff in this Court 

for reasonable fees and costs incurred by the Reorganized Debtors in connection with further 

enforcement of the discharge and injunction provisions of the Plan and the Confirmation Order after the 

fourteen-day period in Paragraph 2 above has elapsed. 

5. This Court approves the form of notice attached hereto as Annex B, which the 

Reorganized Debtors may file in each Pending Action, consisting of a description of this Order and the 

ability of the Reorganized Debtors to seek sanctions in the event of non-compliance with this Order. 

6. The Reorganized Debtors are authorized to take all actions necessary to effectuate the 

relief granted pursuant to this Order. 

7. The terms and conditions of this Order shall be immediately effective and enforceable 

upon its entry. 

8. This Court shall retain exclusive jurisdiction to hear and determine all matters arising 

from or related to the implementation, interpretation, or enforcement of this Order. 

** END OF ORDER ** 

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Annex A 

(Pending Actions and State Court Plaintiffs) 

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Annex B 

(Enforcement Order Notice) 

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