STOEL RIVES LLP

ATTORNEYS AT LA W

SEATTLE

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Notice of Hearing on Enel’s Safe Harbor Motion and Motion to File Under Seal - Case No. 19-

30088 (DM)

1

OREN B. HAKER (pro hac vice)

DAVID B. LEVANT (pro hac vice)

GABRIELLE GLEMANN (pro hac vice)

STOEL RIVES LLP

600 University Street, Suite 3600

Seattle, WA 98101

Telephone: 206.386.7530

Facsimile: 206.386.7500

gabrielle.glemann@stoel.com

Attorneys for Party in Interest

Enel Green Power North America, Inc.

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)

NOTICE OF HEARING ON ENEL

GREEN POWER NORTH AMERICA’S

(I) MOTION TO CONFIRM SAFE 

HARBOR PROTECTION UNDER 

11 U.S.C. §§ 362(b)(6) AND 556; AND

(II) MOTION TO FILE UNDER SEAL 

 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).

Hearing Date: March 12, 2019

Time: 9:30 a.m. 

Courtroom: Hon. Dennis Montali

 450 Golden Gate Avenue

 16th Floor, Courtroom 17

 San Francisco, CA 94102

Objections Due: March 5, 2019, 4 p.m.

PLEASE TAKE NOTICE that Enel Green Power North America, Inc. (“Enel”) has filed 

a motion to confirm safe harbor protection under 11 U.S.C. §§ 362(b)(6) and 556 (the “Safe 

Harbor Motion” Dkt. 481), and a motion to file certain contracts and related filings under seal 

Case: 19-30088 Doc# 485 Filed: 02/19/19 Entered: 02/19/19 18:00:20 Page 1 of 3
STOEL RIVES LLP

ATTORNEYS AT LA W

SEATTLE

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 Notice of Hearing on Enel’s Safe Harbor Motion and Motion to File Under Seal - Case No. 19-

30088 (DM)

2

(the “Motion to File Under Seal,” Dkt. 483, and together with the Safe Harbor Motion, the 

“Motions”). 

PLEASE TAKE FURTHER NOTICE that the Motions are each based on the 

Memorandum of Points and Authorities annexed thereto, respectively, the Declaration of 

Giovanni Bertolino filed in support of the Motions [Dkt. 484], the complete files and records of 

the referenced matters, the arguments of counsel, and such other and further matters as this Court 

may consider at or before any hearing on the Motions. 

PLEASE TAKE FURTHER NOTICE that the Motions are set for hearing on March 

12, 2019 at 9:30 a.m. (PST) before the Honorable Dennis Montali at the United States 

Bankruptcy Court for the Northern District of California, San Francisco Division, located at 450 

Golden Gate Avenue, 16th Floor, Courtroom 17, San Francisco, CA 94102. 

PLEASE TAKE FURTHER NOTICE that any responses or objections to the Motions 

shall be in writing, shall conform to the Federal Rules of Bankruptcy Procedure and the Local 

Bankruptcy Rules for the Northern District of California, shall be filed with the Bankruptcy Court 

in accordance with the customary practices of the Bankruptcy Court, and shall be served on (i) the 

Chambers of the Honorable Judge Dennis Montali, United States Bankruptcy Court for the 

Northern District of California, 450 Golden Gate Ave, 16th Floor, Courtroom 17, San Francisco, 

CA 94102; (ii) counsel for the Debtors, Weil, Gotshal & Manges, 767 Fifth Avenue, New York, 

NY 10153-0119, Attn: Stephen Karotkin, Jessica Liou and Matthew Goren, and Keller & 

Benvenutti LLP, 650 California Street, Suite 1900, San Francisco, CA 94108, Attn: Tobias S. 

Keller, Jane Kim; (iii) the Office of the United States Trustee, 450 Golden Gate Avenue, 5th 

Floor, Suite #05-0153, San Francisco, CA, 94102, Attn: James L. Snyder, Timothy Laffredi; (iv) 

each member of the Official Committee of Unsecured Creditors specified in the Notice of 

Appointment of the Official Committee of Unsecured Creditors [Docket 409], or proposed 

counsel for the Official Committee, once such counsel has been proposed; (v) each member of the 

Official Committee of Tort Claimants specified in the Notice of Appointment of the Official 

Committee of Tort Claimants [Docket No. 453], or proposed counsel for the Official Committee, 

Case: 19-30088 Doc# 485 Filed: 02/19/19 Entered: 02/19/19 18:00:20 Page 2 of 3
STOEL RIVES LLP

ATTORNEYS AT LA W

SEATTLE

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28 Notice of Hearing on Enel’s Safe Harbor Motion and Motion to File Under Seal - Case No. 19-

30088 (DM)

3

once such counsel has been proposed; (vi) counsel for Enel, Stoel Rives LLP, Attn: Gabrielle 

Glemann (gabrielle.glemann@stoel.com), 600 University Street, Suite 3600, Seattle, WA 98101; 

and (vii) all parties requesting notice in these chapter 11 cases pursuant to Rule 2002 of the 

Federal Rules of Bankruptcy Procedure, so as to be so filed or received no later than March 5, 

2019, at 4:00 p.m. (PST) (the "Objection Deadline"). 

PLEASE TAKE FURTHER NOTICE that reply papers in further support of the 

Motions must be filed and served no later than 12:00 p.m. (PST) on March 8, 2019. 

PLEASE TAKE FURTHER NOTICE that failure to properly file and serve an 

opposition may be deemed consent to the relief requested in the Motions or a waiver of any right 

to oppose it.

Dated: February 19, 2019 STOEL RIVES LLP

By: /s/ Gabrielle Glemann

 Gabrielle Glemann

STOEL RIVES LLP

Oren B. Haker

David B. Levant

Gabrielle Glemann 

600 University Street, Suite 3600

Seattle, WA 98101

Telephone: 206.624.0900

Facsimile: 206.386.7500

gabrielle.glemann@stoel.com

Attorneys for Party in Interest

Enel Green Power North America, Inc.

Case: 19-30088 Doc# 485 Filed: 02/19/19 Entered: 02/19/19 18:00:20 Page 3 of 3