Hearing Date: February 7, 2018, 9:30 a.m. (Atlantic Standard Time)

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

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In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et

al.,

Debtors.1

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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 COMMONWEALTH OF PUERTO RICO,

Debtor.

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PROMESA

Title III

No. 17 BK 3283-LTS

This filing relates only to the

Commonwealth and shall only

be filed in the lead Case No. 17

BK 3283-LTS.

JOINDER OF SERVICE EMPLOYEES INTERNATIONAL UNION AND

INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE AND

AGRICULTURAL IMPLEMENT WORKERS OF AMERICA (UAW) TO JOINT

MOTION OF AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL

EMPLOYEES, AFL-CIO, AND AMERICAN FEDERATION OF TEACHERS, AFL-CIO,

FOR AN ORDER TO PERMIT THE PROCESSING THROUGH RESOLUTION OF

EMPLOYMENT ARBITRATION AND GRIEVANCE PROCEEDINGS

The Service Employees International Union (“SEIU”) and International Union, United

Automobile, Aerospace and Agricultural Implement Workers of America (UAW) (“UAW”) on

behalf of themselves, their local affiliates in Puerto Rico, and their members hereby joins in the

Joint Motion (the “Joint Motion”) of American Federation of State, County and Municipal

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

(iii) Puerto Rico Highways and Transportation Authority (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 (Bankruptcy Case No. 17 BK 3566-LTS); and (v) Puerto Rico Electric Power Authority (“PREPA”)

(Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747) (Title III case numbers are

listed as Bankruptcy Case numbers due to software limitations).

00923035.2

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Employees International Union, AFL-CIO (“AFSCME”) and American Federation of Teachers,

AFL-CIO (“AFT”), for an Order pursuant to 11 U.S.C. §§ 105 and 362 with respect to the

processing through resolution of employment arbitration and grievance proceedings, including

the position that the automatic stay is not applicable to such arbitrations. (Docket No. 2245).

The SEIU and UAW note that the Supreme Court has long held that grievancearbitration structures are so integral to labor agreements that an “agreement to arbitrate grievance

disputes is the quid pro quo for an agreement not to strike" and reflects a considered conclusion

that “industrial peace can be best obtained only in that way.” Textile Workers v. Lincoln Mills,

353 U.S. 448, 455 (1957). Here, Puerto Rico’s legislative scheme reflects these principles by

providing for the mandatory arbitration by government agencies of disputes under public

collective bargaining agreements, in tandem with a statutory obligation on the part of public

sector unions not to strike. This scheme, viewed in its entirety, and the continued good-faith

compliance by the Unions with their no-strike obligations, weighs heavily in favor of granting

the Joint Motion, so that Puerto Rico’s legislative labor relations scheme is carried forward as

intended by the Commonwealth.

CONCLUSION

For all the forgoing reasons, the SEIU and UAW respectfully request that the Court grant

the Joint Motion as provided in the proposed Order submitted with the Joint Motion.

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Dated: January 16, 2018 /s/ Richard M. Seltzer

Richard M. Seltzer

Peter D. DeChiara

Hiram M. Arnaud

Cohen, Weiss and Simon LLP

900 Third Avenue, 21st Floor

New York, New York 10022

(212) 356-0216

rseltzer@cwsny.com

pdechiara@cwsny.com

harnaud@cwsny.com

/s/ Miguel Simonet Sierra

Miguel Simonet Sierra

USDC # 210101

MONSERRATE SIMONET &

GIERBOLINI

101 San Patricio Ave.

Suite 1120

Guaynabo, PR 00968

Tel.: (787) 620-5300

Fax: (787) 620-5305

msimonet@msglawpr.com

Attorneys for International Union, United

Automobile, Aerospace and Agricultural

Implement Workers of America (UAW) and

Service Employees International Union

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 16th day of January, 2018, I electronically filed the

foregoing with the Clerk of the Court using the CM/ECF System which will notify all counsel of

record and caused to be mailed or emailed a copy, as provided in the Court-approved Case

Management Procedures in this case.

Dated: January 16, 2018 /s/ Hiram M. Arnaud

HIRAM M. ARNAUD

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