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

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

Exhibit A 

[PROPOSED] Order

Case: 19-30088 Doc# 4825-1 Filed: 11/20/19 Entered: 11/20/19 17:04:16 Page 1

of 4
Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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

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] ORDER PURSUANT TO 

11 U.S.C. § 1121(d) EXTENDING THE 

EXCLUSIVE SOLICITATION PERIOD 

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# 4825-1 Filed: 11/20/19 Entered: 11/20/19 17:04:16 Page 2

of 4
Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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

Upon the Motion, dated November 20, 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 (the “Chapter 11 Cases”), pursuant to section 1121(d) of title 11 of the United States Code (the 

“Bankruptcy Code”), for entry of an order further extending the Exclusive Solicitation Period to and 

including March 20, 2020, subject to the relief granted by the Court pursuant to the Exclusivity 

Termination Order to allow the Official Committee of Tort Claimants (the “TCC”) and Ad Hoc 

Committee of Senior Noteholders of the Utility (the “Ad Hoc Noteholder Committee”) to file and 

solicit the TCC/Noteholder Plan, without prejudice to the Debtors’ right to seek additional extensions 

of the Exclusive Solicitation Period, 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 Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District Court for 

the Northern District of California (the “Bankruptcy Local Rules”); 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, 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 upon all of the proceedings had before this Court and after 

due deliberation and sufficient cause appearing therefor, 

1

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

terms in the Motion. 

Case: 19-30088 Doc# 4825-1 Filed: 11/20/19 Entered: 11/20/19 17:04:16 Page 3

of 4
Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153-0119

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

IT IS HEREBY ORDERED THAT: 

1. The Motion is granted as provided herein. 

2. Pursuant to section 1121(d) of the Bankruptcy Code, the Debtors’ Exclusive 

Solicitation Period in which to solicit acceptances of their chapter 11 plan is extended to and including 

March 20, 2020, subject to the relief granted by the Court pursuant to the Exclusivity Termination 

Order to allow the TCC and the Ad Hoc Noteholder Committee to file and solicit the TCC/Noteholder 

Plan. 

3. The extension of the Exclusive Solicitation Period granted herein is without 

prejudice to such further requests that may be made pursuant to section 1121(d) of the Bankruptcy 

Code by the Debtors or any party in interest, for cause shown, upon notice and a hearing. 

4. 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# 4825-1 Filed: 11/20/19 Entered: 11/20/19 17:04:16 Page 4

of 4