EXHIBIT A

Proposed Order

Case:17-03283-LTS Doc#:23785-1 Filed:03/10/23 Entered:03/10/23 13:29:18 Desc:

Exhibit A Page 1 of 3
UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO, et 

al.

Debtors.1

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

Re: ECF Nos. 23612 and 23621

[PROPOSED] ORDER GRANTING URGENT CONSENSUAL MOTION FOR 

EXTENSION OF DEADLINES REGARDING MOTION REQUESTING 

PAYMENT OF SEVERANCE DAMAGES

Upon the Urgent Consensual Motion for Extension of Deadlines Regarding Motion 

Requesting Payment of Severance Damages (Docket Entry No. ____ in Case No. 17-3283, the 

“Urgent Motion”);2 and the Court having found it has subject-matter jurisdiction over this matter 

pursuant to PROMESA section 306(a); and it appearing that venue in this district is proper 

 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 (“Commonwealth”) (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-BK3566-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).

2 Capitalized terms not otherwise defined herein shall have the meanings given to them in 

the Urgent Motion.

Case:17-03283-LTS Doc#:23785-1 Filed:03/10/23 Entered:03/10/23 13:29:18 Desc:

Exhibit A Page 2 of 3
2

pursuant to PROMESA section 307(a); and the Court having found the Debtor provided adequate 

and appropriate notice of the Urgent Motion under the circumstances and no other or further notice 

is required; and upon the record herein, after due deliberation thereon, the Court having found 

good and sufficient cause exists for the granting of the relief as set forth herein:

1. The Urgent Motion is GRANTED as set forth herein. 

2. The Scheduling Order shall be modified as provided herein.

3. The following briefing schedule is shall apply for filing responsive pleadings to 

the Motion:

• The deadline for parties to file an opposition to the Motion shall be 

March 24, 2023.

• The deadline for the Movant to file a reply to all oppositions and responses shall 

be March 31, 2023.

4. The Court will thereafter take the Motion on submission unless it determines 

otherwise.

5. The Court shall retain jurisdiction to hear and determine all matters arising from 

the implementation of this Order. 

6. This Order resolves Docket Entry No. _____ in Case No. 17-3283.

Dated: ___________, 2023.

SO ORDERED:

_________________________________

 HONORABLE LAURA TAYLOR SWAIN

United States District Judge

Case:17-03283-LTS Doc#:23785-1 Filed:03/10/23 Entered:03/10/23 13:29:18 Desc:

Exhibit A Page 3 of 3