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APPLICATION FOR ORDER SHORTENING TIME ON 

MOTION TO CONFIRM INTERIM WAGE ORDER

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) 

Jessica Liou (pro hac vice) 

(jessica.liou@weil.com) 

Matthew Goren (pro hac vice) 

(matthew.goren@weil.com) 

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: (415) 636-9251 

Proposed Attorneys for Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re:

PG&E CORPORATION, 

 - and - 

Case No. 19-30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

DEBTORS’ EX PARTE APPLICATION 

PURSUANT TO B.L.R. 9006-1 

REQUESTING ORDER SHORTENING 

TIME FOR HEARING ON MOTION 

CONFIRMING INTERIM ORDER 

PURSUANT TO 11 U.S.C. §§ 105(a), 

363(b), AND 507 AND FED. R. BANKR. P. 

6003 AND 6004 AUTHORIZING 

DEBTORS TO (I) PAY PREPETITION 

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: 19-30088 Doc# 393 Filed: 02/08/19 Entered: 02/08/19 16:13:31 Page 1 of 5
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APPLICATION FOR ORDER SHORTENING TIME ON 

MOTION TO CONFIRM INTERIM WAGE ORDER - 2 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

WAGES, SALARIES, WITHHOLDING 

OBLIGATIONS AND OTHER 

COMPENSATION AND BENEFITS; 

(II) MAINTAIN EMPLOYEE WAGE AND 

BENEFITS PROGRAMS; AND (III) PAY 

RELATED ADMINISTRATIVE 

OBLIGATIONS 

[No Hearing Requested]

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 

above-captioned chapter 11 cases (the “Chapter 11 Cases”), hereby submit this Application (the 

“Application”), pursuant to Rule 9006-1 of the Bankruptcy Local Rules for the United States 

Bankruptcy Court for the Northern District of California (the “Bankruptcy Local Rules”), for 

entry of an order shortening the time for notice such that a hearing may be set on February 13, 

2019, or as soon thereafter as is convenient for the Court, on the Debtors’ Motion (the “Motion”) 

for an order confirming the interim relief approved in the Court’s Order, dated January 31, 2019 

[Dkt No. 210] (the “Interim Employee Wage Order”), with respect to the Motion of Debtors 

Pursuant to 11 U.S.C. §§ 105(a), 363(b), and 507 and Fed. R. Bankr. P. 6003 and 6004 for Interim 

and Final Authority to (I) Pay Prepetition Wages, Salaries, and other Compensation and Benefits; 

(II) Maintain Employee Benefit Programs; and (III) Pay Related Administrative Obligations filed 

on January 29, 2019 [Dkt No. 8] (the “Employee Wage Motion”), filed concurrently herewith.1

 

 

1

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

terms in the Employee Wage Motion. 

Case: 19-30088 Doc# 393 Filed: 02/08/19 Entered: 02/08/19 16:13:31 Page 2 of 5
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APPLICATION FOR ORDER SHORTENING TIME ON 

MOTION TO CONFIRM INTERIM WAGE ORDER - 3 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

MEMORANDUM OF POINTS AND AUTHORITIES 

I. JURISDICTION 

The Court has jurisdiction to consider this matter 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). This is a core proceeding pursuant to 28 U.S.C. 

§ 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

II. BACKGROUND 

On January 29, 2019 (the “Petition Date”), the Debtors commenced with the Court 

voluntary cases under chapter 11 of the Bankruptcy Code. The Debtors continue to operate their 

businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 

1108 of the Bankruptcy Code. No trustee, examiner, or statutory committee has been appointed 

in either of the Chapter 11 Cases. The Debtors’ Chapter 11 Cases are being jointly administered 

for procedural purposes only pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy 

Procedure (the “Bankruptcy Rules”). 

Additional information regarding the circumstances leading to the commencement of the 

Chapter 11 Cases and information regarding the Debtors’ businesses and capital structure is set 

forth in the Amended Declaration of Jason P. Wells, Senior Vice President and Chief Financial 

Officer of PG&E Corp., filed on February 1, 2019 [Dkt No. 263] in support of the Debtors’ chapter 

11 petitions and related first day relief (the “Wells Declaration”). 

III. SHORTENING TIME FOR HEARING ON THE MOTION IS WARRANTED 

Pursuant to Bankruptcy Local Rule 9014-1(b)(3)(A), a hearing on the Motion ordinarily 

requires at least twenty-one (21) days’ notice of an opportunity for a hearing. Bankruptcy Local 

Rule 9006-1(a) provides that, except as set forth therein, “approval of the Court is required to 

enlarge or to shorten time to perform any act or file any paper pursuant to the Federal Rules of 

Civil Procedures, the Bankruptcy Rules, or these Bankruptcy Local Rules.” B.L.R. 9006-1(a). 

At the hearing on January 31, 2019 (the “First Day Hearing”), the Court considered the 

Employee Wage Motion and issued the Interim Employee Wage Order. The Motion is brought to 

clarify the relief granted in the Interim Employee Wage Order and avoid any financial hardship to, 

Case: 19-30088 Doc# 393 Filed: 02/08/19 Entered: 02/08/19 16:13:31 Page 3 of 5
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APPLICATION FOR ORDER SHORTENING TIME ON 

MOTION TO CONFIRM INTERIM WAGE ORDER - 4 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

or further imposition on, the Debtors’ Employees as a result of the commencement of these Chapter 

11 Cases. Payment of pre-petition employee wages is vital to the continued smooth operation of 

the Debtors in this critical early stage of the chapter 11 reorganization process and the relief 

requested in the Motion is consistent with the relief granted in the Interim Employee Wage Order. 

As stated in the Employee Wage Motion and the Motion, payment of the Debtors’ 

Employees’ pre-petition wages and compensation is essential to promote Employee morale and 

avoid an undue hardship being imposed on the Employees. Additionally, as set forth in the Motion, 

the Debtors cannot risk the damage to their businesses, and the potential disruption to their ability 

to provide essential utilities to 16 million Californians, that would follow any decline in morale 

and resulting attrition that likely would occur if the Debtors fail to pay their Employees the 

Outstanding Compensation, Additional Relocation Payments, or other compensation and benefits. 

Accordingly, the Debtors submit that sufficient cause exists for the Court to shorten the time for 

notice of hearing on the Motion. 

IV. PROPOSED NOTICE OF THE MOTION 

Notice of the Motion will be provided to (i) the Office of the United States Trustee for 

Region 17 (Attn: James L. Snyder, Esq. and Timothy Laffredi, Esq.); (ii) the Debtors’ fifty (50) 

largest unsecured creditors on a consolidated basis; (iii) the Securities and Exchange Commission; 

(iv) the Internal Revenue Service; (v) the Office of the California Attorney General; (vi) the 

California Public Utilities Commission; (vii) the Nuclear Regulatory Commission; (viii) the 

Federal Energy Regulatory Commission; (ix) the Office of the United States Attorney for the 

Northern District of California; (x) counsel for the agent under the Debtors’ proposed debtor in 

possession financing facilities; (xii) the Banks; and (xiii) those persons who have formally 

appeared in these Chapter 11 Cases and requested service pursuant to Bankruptcy Rule 2002. 

Based on the urgency of the circumstances surrounding this Application and the nature of the relief 

requested herein, the Debtors respectfully submit that no further notice is required. 

V. EFFORTS TO SPEAK WITH RESPONDING PARTIES 

Counsel for the Debtors has spoken with counsel to the Office of the United States Trustee 

regarding a proposed hearing on the Motion, and the Office of the United States Trustee has 

Case: 19-30088 Doc# 393 Filed: 02/08/19 Entered: 02/08/19 16:13:31 Page 4 of 5
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APPLICATION FOR ORDER SHORTENING TIME ON 

MOTION TO CONFIRM INTERIM WAGE ORDER - 5 -

Weil, Gotshal & Manges LLP 

767 Fifth Avenue 

New York, NY 10153-0119

consented to a hearing on February 13, 2019 or as soon as possible thereafter (but has not been 

asked to, nor consented to, a response deadline). No official committee has been appointed in this 

case, and the Debtors submit that given the relief requested, it would be impracticable to speak 

with the entire proposed notice list for the Motion regarding the timing of a hearing. 

No previous request to shorten time has been made by the Debtors. 

WHEREFORE the Debtors respectfully request entry of an order: 

1. Shortening time for notice of hearing on the Motion such that the hearing may be 

set for 1:00 p.m. on February 13, 2019. 

2. Requiring any response or opposition to the Motion to be in writing and filed with 

the Court no later than 1:00 p.m. on February 12, 2019. 

Dated: February 8, 2019 WEIL, GOTSHAL & MANGES LLP 

KELLER & BENVENUTTI LLP 

By: /s/ Tobias S. Keller 

 Tobias S. Keller 

Proposed Attorneys for Debtors 

and Debtors in Possession 

Case: 19-30088 Doc# 393 Filed: 02/08/19 Entered: 02/08/19 16:13:31 Page 5 of 5