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EXHIBIT A 

PROPOSED ORDER 

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LABATON SUCHAROW LLP 

Thomas A. Dubbs 

Louis Gottlieb 

Carol C. Villegas 

Jeffrey A. Dubbin (SBN 287199) 

140 Broadway 

New York, New York 10005 

LOWENSTEIN SANDLER LLP 

Michael S. Etkin (pro hac vice) 

Andrew Behlmann (pro hac vice) 

One Lowenstein Drive 

Roseland, New Jersey 07068

Lead Counsel to Lead Plaintiff and the Class Bankruptcy Counsel to Lead Plaintiff 

and the Class 

MICHELSON LAW GROUP 

Randy Michelson (SBN 114095) 

220 Montgomery Street, Suite 2100 

San Francisco, California 94104 

Bankruptcy Counsel to Lead Plaintiff 

and the Class 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION 

 - and – 

PACIFIC GAS AND ELECTRIC 

COMPANY, 

 Debtors. 

Case No. 19-30088 (DM) (Lead Case) 

Chapter 11 

(Jointly Administered) 

[PROPOSED] ORDER GRANTING 

SECURITIES LEAD PLAINTIFF’S MOTION 

TO APPLY BANKRUPTCY RULE 7023 TO 

CLASS PROOF OF CLAIM

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Upon the Motion, dated December 9, 2019 [ECF No. _]1, of Public Employees 

Retirement Association of New Mexico (“Lead Plaintiff” or “PERA”), the court-appointed lead 

plaintiff in the securities class action captioned as In re PG&E Corporation Securities Litigation, 

Case No. 18-03509 (the “Securities Litigation”) pending in the U.S. District Court for the 

Northern District of California (the “District Court”) on behalf of itself and the proposed class it 

represents in the Securities Litigation (the “Class”), together with York County on behalf of the 

County of York Retirement Fund, City of Warren Police and Fire Retirement System, and MidJersey Trucking Industry & Local No. 701 Pension Fund (collectively, the “Securities Act 

Plaintiffs” and together with Lead Plaintiff, the “Securities Plaintiffs”), for entry of an order, 

pursuant to Rules 9014(a) and (c) of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”), directing that Bankruptcy Rule 7023 applies to the class proofs of claim 

filed by Lead Plaintiff on behalf of itself and the Class against each of the Debtors (the “Class 

Claims”) [Claim Nos. 72193, 72273] and establishing a briefing schedule for and scheduling a 

hearing, if necessary, on certification of the Class for all purposes in the chapter 11 bankruptcy 

cases (the “Chapter 11 Cases”) of the above-captioned debtors in possession (the “Debtors”); 

and this Court having jurisdiction to consider the Motion and the relief requested therein 

pursuant to 28 U.S.C. §§ 157 and 1334, the 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 this Court having found and determined that notice of the Motion was reasonable and 

sufficient, and it appearing that no other or further notice need be provided; and this Court 

having reviewed the Motion and held a hearing to consider 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 appropriate under 

the circumstances; and upon the record of all of the proceedings had on the Motion before this 

Court, and after due deliberation and sufficient cause appearing therefor, 

 

1

 Capitalized terms used but not defined herein have the meanings given thereto in the Motion. 

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IT IS HEREBY ORDERED THAT:

1. The Motion is granted as set forth herein. 

2. Pursuant to Federal Rule of Bankruptcy Procedure 9014, the Court hereby directs 

that Federal Rule of Bankruptcy Procedure 7023 applies to the Motion and the Class Claim. 

3. Lead Plaintiff shall file its brief in support of certification of the Class for purposes 

of the Chapter 11 Cases on or before ________________, 2020. The Debtors shall file their 

brief, if any, in opposition to certification of the Class for purposes of the Chapter 11 Cases on or 

before ________________, 2020. Lead Plaintiff shall file its reply brief, if any, in further 

support of certification of the Class for purposes of the Chapter 11 Cases on or before 

________________, 2020. 

4. Nothing in this Order shall preclude Lead Plaintiff from seeking withdrawal of the 

bankruptcy reference with respect to certification of the Class for purposes of the Chapter 11 

Cases. 

** END OF ORDER ** 

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