EXHIBIT B

Case:17-03283-LTS Doc#:22843-2 Filed:11/10/22 Entered:11/10/22 20:59:52 Desc:

Exhibit B - Redline Rule 2004 Proposed Order Page 1 of 5
In re:

THE FINANCIAL OVERSIGHT AND MANAGEMENT

BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al.,

Debtors.1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

PROMESA Title III

No. 17-BK-3283-LTS

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND MANAGEMENT

BOARD FOR PUERTO RICO,

as representative of

THE PUERTO RICO ELECTRIC POWER AUTHORITY,

Debtor.

PROMESA Title III

No. 17-BK-4780-LTS

1

 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number

and the last four (4) digits of each Debtor’s federal tax identification number, as applicable, are

the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four

Digits of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation (“COFINA”)

(Bankruptcy Case No. 17-BK-3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Puerto

Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567-LTS)

(Last Four Digits of Federal Tax ID: 3808); (iv) Employees Retirement System of the

Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No.

17-BK-3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (v) Puerto Rico Electric Power

Authority (“PREPA”) (Bankruptcy Case No. 17-BK-4780-LTS) (Last Four Digits of Federal Tax

ID: 3747); and (vi) Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy Case No.

19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed

as Bankruptcy Case numbers due to software limitations).

Case:17-03283-LTS Doc#:22843-2 Filed:11/10/22 Entered:11/10/22 20:59:52 Desc:

Exhibit B - Redline Rule 2004 Proposed Order Page 2 of 5
[PROPOSED] ORDER GRANTING URGENT MOTION OF FUEL LINE LENDERS

FOR EXAMINATION OF OVERSIGHT BOARD UNDER FEDERAL RULE OF

BANKRUPTCY PROCEDURE 2004 CONCERNING VITOL SETTLEMENT

AGREEMENT

Upon consideration of the Urgent Motion of Fuel Line Lenders under Federal Rule of

Bankruptcy Procedure 2004 to Conduct an Examination of the Financial Oversight and

Management Board for Puerto Rico Concerning a Settlement Reached Between the Oversight

Board and Vitol S.A or its Affiliates (the “Rule 2004 Motion”) and the Joinder of Assured

Guaranty Corp., Assured Guaranty Municipal Corp., the Ad Hoc Group of PREPA Bondholders,

National Public Finance Guarantee Corporation, Syncora Guarantee Inc., and the PREPA Bond

Trustee to Urgent Motion of Fuel Line Lenders for Examination of Oversight Board Under

Federal Rule of Bankruptcy Procedure 2004 Concerning Vitol Settlement Agreement (ECF No.

22810) (the “Joinder”); and the Court having found and determined that (i) it has jurisdiction

over this proceeding and, the Rule 2004 Motion, and the Joinder; (ii) good cause exists for the

relief requested therein; (iii) notice of the Rule 2004 Motion being adequate and proper under the

circumstances; IT IS HEREBY ORDERED THAT:

1. The Rule 2004 Motion is GRANTED.

2. The Fuel Line Lenders, the Trustee, and the PREPA Bondholders are authorized

to seek document discovery from the Oversight Board consistent with the requests described in

Exhibit B to the Rule 2004 Motion (filed as ECF No. 22810-2).

3. The Oversight Board shall comply with the document requests described in

Exhibit B by the dates set forth in the document requests, unless extended by mutual agreement.

4. Any documents, information, or responses produced as authorized by this Order

or in response to any subpoena shall be produced to the Fuel Line Lenders, U.S. Bank National

Association as Trustee (the “Trustee”), Assured Guaranty Corp. and Assured Guaranty

Case:17-03283-LTS Doc#:22843-2 Filed:11/10/22 Entered:11/10/22 20:59:52 Desc:

Exhibit B - Redline Rule 2004 Proposed Order Page 3 of 5
Municipal Corp. (“Assured”), the Ad Hoc Group of PREPA Bondholders (the “Ad Hoc Group”),

National Public Finance Guarantee Corporation (“National”), and Syncora Guarantee Inc.

(“Syncora,” and together with Assured, the Ad Hoc Group, and National, the “PREPA

Bondholders”), and counsel to the Fuel Line Lenders, Trustee, Assured, the Ad Hoc Group,

National, and Syncora shall have the right to attend and participate in any depositions authorized

by the Court. The Fuel Line Lenders, Trustee, Assured, the Ad Hoc Group, National, and

Syncora shall also have the right to participate in any meet-and-confer process and/or hearing

related to the Rule 2004 Motion or this Order.

5. 4. Nothing herein shall limit the Fuel Line Lenders’, the Trustee’s, Assured’s, the

Ad Hoc Group’s, National’s, or Syncora’s right to request additional discovery, including any

additional document requests or depositions, under Rule 2004 and/or any other applicable law,

based on any information that may be revealed as a result of the information provided pursuant

to this Order or otherwise.

6. 5. This Court shall retain jurisdiction to resolve any dispute arising from or

related to this Order and to interpret, implement and enforce the provisions of this Order.

SO ORDERED

Date: , _________________________ 2022 

____________________________________

 JUDITH GAIL DEIN 

UNITED STATES MAGISTRATE JUDGE

Case:17-03283-LTS Doc#:22843-2 Filed:11/10/22 Entered:11/10/22 20:59:52 Desc:

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Case:17-03283-LTS Doc#:22843-2 Filed:11/10/22 Entered:11/10/22 20:59:52 Desc:

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