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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

CRAVATH, SWAINE & MOORE LLP

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

825 Eighth Avenue 

New York, NY 10019

Tel: 212 474 1000 

Fax: 212 474 3700 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

1

 Subsequent to this request for entry of order by default, the Debtors plan to file a notice continuing 

the hearing on this Motion. If no order is entered pursuant to this request, the Motion will be heard at 

the omnibus hearing scheduled for 10:00 a.m. on January 29, 2020. 

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 GRANTING DEBTORS’ 

MOTION PURSUANT TO 11 U.S.C. 

§§ 363(b) AND 105(a) AND FED. R. 

BANKR. P. 6004 AND 9019 FOR ENTRY 

OF AN ORDER (I) AUTHORIZING THE 

DEBTORS TO SETTLE THE CLAIMS OF 

TUBBS PREFERENCE CLAIMANTS AND 

(II) GRANTING RELATED RELIEF 

[Relates to Dkt. No. 5282] 

Hearing Date: January 23, 20201

Hearing Time:1:00 p.m. (Pacific Time) 

Place: United States Bankruptcy Court 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: January 17, 2020 

 12:00 p.m. (Pacific Time)

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# 5444 Filed: 01/22/20 Entered: 01/22/20 13:50:54 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 Debtors’ Motion Pursuant to 11 

U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9019 for Entry of an Order (i) Authorizing 

the Debtors to Settle the Claims of Tubbs Preference Claimants and (ii) Granting Related Relief filed by 

the Debtors on January 6, 2020 [Dkt. No. 5282] (the “Motion”). 

RELIEF REQUESTED IN THE MOTION 

The Motion seeks entry of an order (i) authorizing the Debtors to enter into settlement 

agreements, copies of which were filed under seal, settling and liquidating the claims asserted against 

the Debtors by the 18 elderly or infirm individual plaintiffs for whom the Court granted relief from the 

stay to pursue their claims relating to the Tubbs fire (including the 32 indispensable parties associated 

with such individuals’ claims, the “Tubbs Preference Claimants”), and (ii) granting related relief. 

A proposed order (the “Proposed Order”) was attached as Exhibit A to the Motion. 

The order being submitted is different from the Proposed Order attached to the Motion in that the 

reference to a hearing being held has been deleted. 

NOTICE AND SERVICE 

A Notice of Entry of Order Shortening Time and Notice of Hearing on Debtors’ Motion 

Pursuant to 11 U.S.C. §§ 363(b) and 105(a) and Fed. R. Bankr. P. 6004 and 9019 for Entry of an Order 

(i) Authorizing the Debtors to Settle the Claims of Tubbs Preference Claimants and (ii) Granting Related 

Relief [Dkt. No. 5294] (the “Notice of Hearing”) was filed on January 7, 2020, immediately after entry 

of the Court’s order shortening time for a hearing on the Motion [Dkt. No. 5292] (the “Order 

Shortening Time”). The Motion, and the supporting declaration of Janet Loduca, were served as 

described in the Certificate of Service of Alain B. Francoeur filed on January 9, 2020 [Dkt. No. 5326]. 

Case: 19-30088 Doc# 5444 Filed: 01/22/20 Entered: 01/22/20 13:50:54 Page 2 of

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

The Order Shortening Time and the Notice of Hearing were served as described in the Certificate of 

Service of Jamie B. Herszaft filed on January 10, 2020 [Dkt. No. 5338]. The deadline to file responses 

or oppositions to the Motion has passed, and no responses or oppositions have been filed with the Court 

or received by counsel for the Debtors. 

DECLARATION OF NO RESPONSE 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: January 22, 2020 

WEIL, GOTSHAL & MANGES LLP 

CRAVATH, SWAINE & MOORE LLP 

 KELLER & BENVENUTTI LLP 

/s/ Thomas B. Rupp 

 Thomas B. Rupp 

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 5444 Filed: 01/22/20 Entered: 01/22/20 13:50:54 Page 3 of

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