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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 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

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 ON SIXTH OMNIBUS 

MOTION PURSUANT TO 11 U.S.C 

§ 365(a), FED. R. BANKR. P. 6006, AND 

B.L.R. 6006-1 TO APPROVE THE 

UTILITY’S ASSUMPTION OF CERTAIN 

CONTRACT PRICE DISCOUNTED 

ENERGY PROCUREMENT 

AGREEMENTS 

[Relates to Dkt. No. 4203] 

Hearing Date: November 13, 2019 

Hearing Time:10:00 a.m. (Pacific Time) 

Place: United States BankruptcyCourt 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102 

Objection Deadline: October 30, 2019 

 4:00 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# 4534 Filed: 10/31/19 Entered: 10/31/19 13:51:44 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 Sixth Omnibus Motion Pursuant 

to 11 U.S.C. § 365(a), Fed. R. Bankr. P. 6006, and B.L.R. 6006-1 to Approve the Utility’s Assumption 

of Certain Contract Price Discounted Energy Procurement Agreements filed by the Debtors on 

October 15, 2019 [Dkt. No. 4203] (the “Motion”). 

RELIEF REQUESTED IN THE MOTION 

The Motion seeks entry of an order approving the Utility’s assumption of each of the 

EP Agreements (as defined in the Motion) identified on Exhibit B thereto, each as amended pursuant 

to the applicable EP Amendment (as defined in the Motion) to incorporate a price reduction and other 

agreed upon modifications set forth therein.. A proposed order (the “Proposed Order”) was attached 

as an exhibit to the Motion. The order being submitted is different from the Proposed Order attached 

to the Motion only in that the reference to a hearing being held has been deleted. 

NOTICE AND SERVICE 

A Notice of Hearing on Sixth Omnibus Motion Pursuant to 11 U.S.C. § 365(a), Fed. R. 

Bankr. P. 6006, and B.L.R. 6006-1 to Approve the Utility’s Assumption of Certain Contract Price 

Discounted Energy Procurement Agreements was filed concurrently with the Motion on October 15, 

2019 [Dkt. No. 4205] (the “Notice of Hearing”). The Motion, its supporting declaration of Marino 

Monardi, and the Notice of Hearing were served as described in the Certificate of Service of Alain B. 

Francoeur filed on October 18, 2019 [Dkt. No. 4308]. The deadline to file responses or oppositions to 

the Motion has passed, and no oppositions have been filed with the Court or received by counsel for the 

Debtors. 

Case: 19-30088 Doc# 4534 Filed: 10/31/19 Entered: 10/31/19 13:51:44 Page 2 of

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

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: October 31, 2019 

WEIL, GOTSHAL & MANGES LLP 

 KELLER & BENVENUTTI LLP 

/s/ Thomas B. Rupp 

 Thomas B. Rupp 

Attorneys for Debtors and Debtors in Possession

Case: 19-30088 Doc# 4534 Filed: 10/31/19 Entered: 10/31/19 13:51:44 Page 3 of

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