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

Exhibit A 

[PROPOSED] Order 

Case: 19-30088 Doc# 4481-1 Filed: 10/25/19 Entered: 10/25/19 15:21:05 Page 1

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

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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,

Bankruptcy Case 

No. 19 -30088 (DM) 

Chapter 11 

(Lead Case) 

(Jointly Administered) 

[PROPOSED] SECOND ORDER 

PURSUANT TO FED. R. BANKR. P. 

9006(b) AND 9027 ENLARGING THE 

TIME WITHIN WHICH TO FILE 

NOTICES OF REMOVAL OF RELATED 

PROCEEDINGS 

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). 

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

Upon the Motion, dated October 25, 2019 [Docket No. #] (the “Motion”),1 of 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, pursuant to Bankruptcy Rules 9006(b) and 9027, and Bankruptcy Local Rule 9006-1, seeking 

a further extension of time for the Debtors to file notices of removal of the civil actions and 

proceedings to which the Debtors are parties (the “Civil Actions”) from October 28, 2019 until the 

earlier of the effective date of a confirmed chapter 11 plan (the “Effective Date”) and June 30, 2020, 

all as more fully set forth in the Motion; 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 Bankruptcy Local Rule 

5011-1(a); 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 under the circumstances, and it appearing that no other or 

further notice need be provided; and this Court having reviewed the Motion, the Wells Declaration (as 

amended on February 2, 2019 [Docket No. 263]), and the Boken Declaration; and this Court having 

held a hearing on the Motion; 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 Debtors, their estates, creditors, shareholders, 

and all parties in interest; and it appearing that cause exists to grant the relief requested in the Motion; 

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 Motion is granted as provided herein. 

1

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

terms in the Motion. 

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

2. The deadline by which the Debtors may file notices of removal under 

Bankruptcy Rule 9027(a) is extended through and including the earlier of the Effective Date and June 

30, 2020. 

3. The Debtors are authorized to take all steps necessary or appropriate to carry 

out this Order. 

4. This Order shall be without prejudice to any position the Debtors may take 

regarding whether section 362 of the Bankruptcy Code applies to stay any litigation pending against 

the Debtors. 

5. Notwithstanding entry of this Order, nothing herein shall create, nor is it 

intended to create, any rights in favor of or enhance the status of any claim held by, any party. 

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

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

** END OF ORDER ** 

Case: 19-30088 Doc# 4481-1 Filed: 10/25/19 Entered: 10/25/19 15:21:05 Page 4

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