230327 HTA STIPULATION VERSION MARCH 27, 2023 1

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)

In re:

THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO,

as representative of

THE PUERTO RICO HIGHWAYS AND 

TRANSPORTATION AUTHORITY,

Debtor.

PROMESA

Title III

No. 17 BK-3567-LTS

SECOND AMENDED AND RESTATED STIPULATION AND AGREED ORDER

REGARDING THE DISPUTED FUNDS IN THE HTA BOND SERVICE

ACCOUNTS, REDEMPTION ACCOUNTS AND RESERVE ACCOUNTS

The Commonwealth of Puerto Rico (the “Commonwealth”) and the Puerto Rico Highways

and Transportation Authority (“HTA”), by and through the Financial Oversight and Management

Board for Puerto Rico (the “Oversight Board”), as the sole Title III representative of the

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.

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230327 HTA STIPULATION VERSION MARCH 27, 2023 2

Commonwealth and HTA pursuant to section 315(b) of the Puerto Rico Oversight, Management, 

and Economic Stability Act (“PROMESA”),2 The Bank of New York Mellon, solely in its capacity 

as fiscal agent (“BNYM” or the “HTA Fiscal Agent”) for several series of bonds issued by HTA

(the “HTA Bonds”), Ambac Assurance Corporation (“Ambac”), Assured Guaranty Corp., Assured 

Guaranty Municipal Corp. (together with Assured Guaranty Corp., “Assured”), Financial 

Guaranty Insurance Company (“FGIC”), Syncora Guarantee Inc. (“Syncora”), and National Public 

Finance Guarantee Corporation (“National” and together with Ambac, Assured, FGIC, and 

Syncora, the “Monolines”) hereby stipulate and agree as follows:

RECITALS

Commencement of Title III Cases

A. On May 3, 2017, the Oversight Board issued a restructuring certification pursuant 

to Sections 104(j) and 206 of PROMESA and filed a voluntary petition for relief for the 

Commonwealth pursuant to PROMESA Section 304(a), commencing a case under Title III thereof 

(the “Commonwealth Title III Case”).

B. On May 21, 2017, the Oversight Board issued a restructuring certification for HTA, 

commencing an additional case under Title III of PROMESA (the “HTA Title III Case” and

together with the Commonwealth Title III Case, the “Title III Cases”).

C. By operation of PROMESA and pursuant to PROMESA Section 315(b), the 

Oversight Board is the sole representative of the Commonwealth and HTA in their respective Title 

III Cases.

D. The Court has subject matter jurisdiction over this matter pursuant to PROMESA 

Section 306(a), and venue is proper in this District pursuant to PROMESA Section 307(a).

2 PROMESA is codified at 48 U.S.C. §§ 2101–2241.

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The Disputed Funds

E. After the filing of the Title III Cases, certain monoline insurers and bondholders 

commenced the following adversary proceedings regarding, among other issues, asserted liens on 

certain revenues, payments on the HTA Bonds, and monies allegedly pledged to secure the

repayment of HTA Bonds (collectively, the “Adversary Proceedings”): Ambac Assurance Corp.

v. Commonwealth of Puerto Rico, et al., Adv. Proc. No. 17-159-LTS; Assured Guaranty Corp., et 

al. v. Commonwealth of Puerto Rico, et al., Adv. Proc. Nos. 17-155-LTS, 17-156-LTS; and Peaje 

Investments, LLC v. Puerto Rico Highways and Transportation Authority, et al., Adv. Proc. Nos. 

17-151 LTS, 17-152-LTS.

F. Pursuant to applicable documents, BNYM, as Fiscal Agent, was scheduled to make 

a payment of principal and interest on several series of bonds issued by HTA to the bondholders 

in the aggregate amount of approximately $224,277,263.11 on July 3, 2017.

G. On or around June 20, 2017, the Puerto Rico Fiscal Agency and Financial Advisory 

Authority (“AAFAF”) instructed BNYM not to distribute cash and the proceeds of various 

investments (the “Disputed Funds”) held by BNYM, as HTA Fiscal Agent, to the bondholders,

asserting that the Disputed Funds are property of HTA and are subject to the automatic stay 

pursuant to section 362(a) of the Bankruptcy Code, as incorporated by Section 301(a) of 

PROMESA.

H. By letter, dated June 23, 2017, certain plaintiffs in the Adversary Proceedings stated 

their disagreement with the AAFAF position and asserted that BNYM must distribute the Disputed 

Funds on July 3, 2017 in accordance with the terms of the governing documents because the 

Disputed Funds (i) are not property of HTA, (ii) are held in trust for the benefit of the bondholders,

(iii) are “pledged special revenues,” pursuant to sections 902, 922(d) and 928 of the Bankruptcy 

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Code as incorporated by section 301(a) of PROMESA, and (iv) are not subject to the automatic 

stay.

I. As of July 3, 2017, BNYM, as HTA Fiscal Agent, held Disputed Funds with an 

estimated value of $76,149,000.00.

J. BNYM declined to take a position on the matter, and, in light of the dispute 

regarding the Disputed Funds, indicated that it would not distribute the Disputed Funds until 

appropriate relief was obtained from the Court.

K. On July 31, 2017, the parties to the Adversary Proceedings entered into that certain 

Stipulation and Proposed Order Governing the Disputed Funds in the HTA Bonds Accounts, 

Redemption Accounts and Reserve Accounts (the “Disputed Funds Stipulation”), which provides

that, among other things, pending further order of the Court, BNYM shall maintain the entirety of 

the Disputed Funds in the existing accounts into which they have been deposited.

L. On August 3, 2017, the Court approved the Disputed Funds Stipulation [Case No.

17-00152, ECF No. 179].

M. As of May 18, 2022, the Disputed Funds held by BNYM in cash and various 

investments total $90,845,316.28.

Confirmation of the Plan of Adjustment

N. On May 5, 2021, the Oversight Board, as representative of the Commonwealth and 

HTA in their Title III Cases, entered into that certain HTA/CCDA Related Plan Support 

Agreement (the “HTA/CCDA PSA”) with, among others, (a) certain holders of bonds issued by 

HTA, (b) Assured, and (c) National, which provided for, among other things, the terms of the 

resolution of litigation among the parties regarding the bonds issued by HTA, and the terms of 

securities to be issued pursuant to plans of adjustment for the Commonwealth and HTA.

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O. On July 15, 2021, Ambac and FGIC each executed joinders to the HTA/CCDA 

PSA.

P. On January 18, 2022, the Court entered the Order and Judgment Confirming 

Modified Eighth Amended Title III Joint Plan of Adjustment of the Commonwealth of Puerto Rico, 

the Employees Retirement System of the Government of the Commonwealth of Puerto Rico, and 

the Puerto Rico Public Buildings Authority [Case No. 17-03283, ECF No. 19813] 

(the “Confirmation Order”), confirming the Modified Eighth Amended Title III Joint Plan of

Adjustment of the Commonwealth of Puerto Rico, et al., dated January 14, 2021 [Case No. 17-

03283, ECF No. 19784] (the “Commonwealth Plan”)3, which incorporates the terms of the 

HTA/CCDA PSA.

Q. Section 4.1 of the HTA/CCDA PSA and decretal paragraph 52 of the Confirmation 

Order provide, in pertinent part, that “. . . within ten (10) Business Days following satisfaction of 

the HTA Distribution Conditions, HTA shall make an interim distribution to holders of HTA 68 

Bond Claims and HTA 98 Senior Bond Claims in the amounts of One Hundred Eighty-Four 

Million Eight Hundred Thousand Dollars ($184,800,000.00) and Seventy-Nine Million Two 

Hundred Thousand Dollars ($79,200,000.00), respectively, in Cash, which distributions shall 

reduce the principal amount of such HTA 68 Bonds and HTA 98 Senior Bonds, respectively, and 

the corresponding HTA Bond Claims . . . .” (the “Effective Date Payments”). Confirmation Order

¶ 52.

3 Unless otherwise defined herein, capitalized terms shall have the meanings ascribed thereto in the Commonwealth 

Plan or the HTA Plan, as applicable. 

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R. Sections 2.1 and 63.1 of the Commonwealth Plan provides for the treatment and 

global compromise and settlement of, among other things, claims against the Commonwealth 

relating to the HTA Bonds.

S. The Effective Date of the Commonwealth Plan occurred on March 15, 2022.

Fiscal Agent Fees and Expenses Dispute

T. On March 10, 2022, the Oversight Board filed the Urgent Motion for an Order 

Directing the Fiscal Agent to Disburse the Disputed Funds in the HTA Bond Service Accounts, 

Redemption Accounts, and Reserve Accounts [Case No. 17-03283, ECF No. 20297], seeking 

approval of a stipulation between the Oversight Board and BNYM, as HTA Fiscal Agent, that

provided for the deduction of the HTA Fiscal Agent’s fees and expenses from the Effective Date 

Payments, including the Disputed Funds. On March 11, 2022, the Oversight Board filed the Notice 

of Filing Amended and Restated Stipulation and Agreed Order Regarding the Disputed Funds in 

the HTA Bond Service Accounts, Redemption Accounts, and Reserve Accounts [Case No. 17-

03283, ECF No. 20316], attaching an amended stipulation thereto as Exhibit A (the “Stipulation”).

U. On March 15, 2022, Assured, FGIC, and National filed the Response of Assured 

Guaranty Corp., Assured Guaranty Municipal Corp., Financial Guaranty Insurance Company, 

and National Public Finance Guarantee Corporation with Respect to Supplemental Reply of the 

Financial Oversight and Management Board for Puerto Rico in Support of Urgent Motion for 

Order Directing the Fiscal Agent to Disburse the Disputed Funds in the HTA Bond Service 

Accounts, Redemption Accounts, and Reserve Accounts [Case No. 17-03283, ECF No. 20337]

(the “Monoline Objection”), asserting that the Stipulation does not comply with decretal paragraph 

52 of the Confirmation Order. 

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V. On March 16, 2022, the Court entered an order overruling the Monoline Objection 

based upon the representations set forth in the Stipulation, approving the Stipulation, and

authorizing the transaction contemplated therein.

W. On May 16, 2022, the Oversight Board filed the Amended Title III Plan of 

Adjustment of the Puerto Rico Highways and Transportation Authority [Case No. 17-3567, ECF 

No. 1177] (the “HTA Plan”).

X. The Monolines, BNYM, and the Oversight Board have continued to engage in 

arms-length, good faith negotiations to reach agreement regarding the deduction of the HTA Fiscal 

Agent’s Fees and Expenses (as defined herein) from the Effective Date Payments and, as a result 

of those negotiations, have reached an agreement consistent with the terms of this stipulation. 

NOW, THEREFORE, in consideration of the foregoing, the parties hereby agree as 

follows:

AGREEMENT

1. This stipulation (the “Amended Stipulation”) shall become effective upon entry of 

an order of the Court approving the terms and provisions hereof (the “Stipulation Date”) and, upon 

the Stipulation Date, shall amend, restate, and supersede the Stipulation in all respects. 

2. Within two (2) business days of the date of execution of this Amended Stipulation, 

the Oversight Board shall provide BNYM instructions for the liquidation of Disputed Funds that 

BNYM currently holds in investments other than cash.

3. Upon (a) satisfaction of the HTA Distribution Conditions, and (b) liquidation of the 

Disputed Funds that BNYM currently holds in investments other than cash, (i) the aggregate 

amount of cash on account in the Disputed Funds shall be deemed amounts to be applied by HTA 

in satisfaction of the Effective Date Payments, and (ii) the HTA Fiscal Agent shall provide the 

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Oversight Board and HTA a written statement setting forth the amount of the Disputed Funds as 

of such date.

4. The Effective Date Payments are inclusive of any and all HTA Fiscal Agent’s fees 

and expenses due and owing by HTA pursuant to the applicable bond resolutions with respect to 

amounts discharged pursuant to the HTA Plan (the “HTA Fiscal Agent’s Fees and Expenses”) and 

do not require an increase thereto on account thereof. Subject to the limitations contained in 

paragraph 6 of this Amended Stipulation, the HTA Fiscal Agent may deduct the HTA Fiscal 

Agent’s Fees and Expenses from the Disputed Funds, and the HTA Fiscal Agent shall either apply 

such amounts to the HTA Fiscal Agent’s Fees and Expenses then due and owing, or hold such 

amounts in a reserve for future fees and expenses, subject to the terms and provisions of paragraph 

7 of this Amended Stipulation. 

5. Upon deduction of the HTA Fiscal Agent’s Fees and Expenses from the Disputed 

Funds, the HTA Fiscal Agent shall transfer the remaining Disputed Funds to HTA, or its designee, 

to be applied as part of the Effective Date Payments. Consistent with the pro rata allocation of the

cost of the HTA Fiscal Agent’s Fees and Expenses required by Section 27.13 of the HTA Plan, 

HTA may deduct the cost of the HTA Fiscal Agent’s Fees and Expenses from the Effective Date 

Payments on a pro rata basis, such that the cost of such HTA Fiscal Agent’s Fees and Expenses is 

shared equally by all holders of HTA 68 Bond Claims4 and HTA 98 Senior Bond Claims5 based 

on the amount of their Claims.

4 For purposes of this Amended Stipulation, the term “HTA 68 Bond Claims” shall include (i) HTA 68 Bond 

Claims, (ii) HTA 68 Bond Claims (Ambac), (iii) HTA 68 Bond Claims (Assured), and (iv) HTA 68 Bond Claims 

(National), all as defined in the HTA Plan.

5 For purposes of this Amended Stipulation, the term “HTA 98 Senior Bond Claims” shall include (i) HTA 98 

Senior Bond Claims, (ii) HTA 98 Senior Bond Claims (Ambac), (iii) HTA 98 Senior Bond Claims (Assured), 

(iv) HTA 98 Senior Bond Claims (FGIC), and (v) HTA 98 Senior Bond Claims (National), all as defined in the 

HTA Plan.

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6. Notwithstanding anything in the HTA Plan, the HTA Confirmation Order, this 

Amended Stipulation, or the applicable bond resolutions to the contrary, (a) the HTA Fiscal 

Agent’s Fees and Expenses now or hereafter owing, including any amounts held in a reserve for 

future fees and expenses, shall not exceed $2,360,681.02, and (b) upon the HTA Fiscal Agent’s 

deduction of such HTA Fiscal Agent’s Fees and Expenses from the Disputed Funds, none of the 

Commonwealth, HTA, or any agency or instrumentality thereof shall have any further liability or 

obligation with respect to such fees and expenses. 

7. In the event amounts reserved or deducted by the HTA Fiscal Agent from the 

Disputed Funds exceed the HTA Fiscal Agent’s Fees and Expenses, such excess amounts shall be 

distributed, by or at the direction of, the HTA Fiscal Agent and/or HTA, or HTA’s designee, on a 

pro rata basis to holders of HTA 68 Bond Claims and HTA 98 Senior Bond Claims on the HTA 

Effective Date (the “Excess Distribution”). 

8. This Amended Stipulation shall be considered a full and final resolution of (a) all 

disputes relevant to the Disputed Funds that were raised as part of the Disputed Funds Stipulation, 

and (b) all disputes and reservation of rights raised or asserted in Case No. 17-03283, ECF Nos. 

20297, 20318, 20320, 20321, 20331, 20337, and 20340 related to the payment of the HTA Fiscal 

Agent’s Fees and Expenses, and, upon the HTA Fiscal Agent’s deduction of such HTA Fiscal 

Agent’s Fees and Expenses from the Disputed Funds, none of the Commonwealth, HTA, or any 

agency or instrumentality thereof shall have any further liability or obligation for the payment of 

the HTA Fiscal Agent’s Fees and Expenses.

9. The parties represent and warrant that they are duly authorized to enter into and be 

bound by this Amended Stipulation. Except as expressly provided herein, nothing herein shall 

impair any right, power, or obligation or be considered a waiver of any such right, power or 

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230327 HTA STIPULATION VERSION MARCH 27, 2023 10

obligation the parties hereto have with respect to any valid and existing agreements between the 

parties hereto, which agreements remain in full force and effect and are not modified hereby.

10. Each party hereto agrees that it has fully participated in the drafting of this 

Amended Stipulation. The rule of law that provides that ambiguities will be construed against the 

drafting party in interpreting written instruments shall be inapplicable to resolve any disputes over 

the meaning or intent of this Amended Stipulation or any of its provisions.

11. This Amended Stipulation is the full and complete agreement of the parties with 

respect to the matters set forth herein, and each party has entered into this Amended Stipulation 

voluntarily and without duress.

12. This Amended Stipulation shall be binding on the parties’ successors and assigns.

13. This Court shall retain jurisdiction to hear and determine all matters arising from 

or related to the implementation, interpretation, or enforcement of this Amended Stipulation.

14. This Amended Stipulation may be executed in multiple counterparts, any of which 

may be transmitted by facsimile or electronic mail, and each of which will be deemed an original, 

but all of which together will constitute one instrument.

Dated: May 24, 2022

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230327 HTA STIPULATION VERSION MARCH 27, 2023 11

STIPULATED AND AGREED TO BY:

PROSKAUER ROSE LLP

/s/ Brian S. Rosen

Martin J. Bienenstock (pro hac vice)

Brian S. Rosen (pro hac vice)

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

O’NEILL & BORGES LLC

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

Carla García-Benítez

USDC No. 203708

Gabriel A. Miranda

USDC No. 306704

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Attorneys for the Financial Oversight and 

Management Board as representative for the 

Commonwealth

SEPULVADO, MALDONADO & 

COURET

/s/ Albéniz Couret-Fuentes

Albéniz Couret-Fuentes

USDC-PR Bar No. 222207

304 Ponce de León Ave. – Suite 990

San Juan, PR 00918

Telephone: (787) 765-5656

Facsimile: (787) 294-0073

Email: acouret@smclawpr.com

REED SMITH LLP

/s/ Jared S. Roach 

Luke A. Sizemore (Pro Hac Vice)

Jared S. Roach (Pro Hac Vice)

225 Fifth Avenue, Suite 1200

Pittsburgh, PA 15222

Telephone: (412) 288-3131

Facsimile: (412) 288-3063

Email: lsizemore@reedsmith.com

Email: jroach@reedsmith.com

Counsel to The Bank of New York Mellon, in 

its capacity as Fiscal Agent

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WEIL, GOTSHAL & MANGES LLP

By: /s/ Kelly DiBlasi 

Jonathan Polkes* 

Gregory Silbert*

Robert Berezin* 

Kelly DiBlasi*

767 Fifth Avenue

New York, NY 10153

Telephone: (212) 310-8000

Facsimile: (212) 310-8007

Email: jonathan.polkes@weil.com

gregory.silbert@weil.com

robert.berezin@weil.com

kelly.diblasi@weil.com

Gabriel A. Morgan (admitted pro hac vice)

700 Louisiana Street, Suite 1700

Houston, TX 77002

Telephone: (713) 546-5000

Facsimile: (713) 224-9511

Email: gabriel.morgan@weil.com

*Admitted pro hac vice

Attorneys for National Public Finance 

Guarantee Corporation

ADSUAR MUNIZ GOYCO SEDA & 

PEREZ-OCHOA PSC

By: /s/ Eric Perez-Ochoa 

Eric Perez-Ochoa 

(USDC-PR No. 206314)

Luis A. Oliver-Fraticelli

(USDC-PR No. 209204)

208 Ponce de León Ave., Suite 1600

San Juan, PR 00936

Telephone: (787) 756-9000

Facsimile: (787) 756-9010

Email: epo@amgprlaw.com

loliver@amgprlaw.com

Attorneys for National Public Finance 

Guarantee Corporation

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CASELLAS ALCOVER & BURGOS P.S.C.

By: /s/ Heriberto Burgos Pérez 

Heriberto Burgos Pérez

USDC-PR No. 204,809

Ricardo F. Casellas-Sánchez

USDC-PR No. 203,114

Diana Pérez-Seda

USDC–PR No. 232,014

P.O. Box 364924

San Juan, PR 00936-4924

Tel.: (787) 756-1400

Fax: (787) 756-1401

E-mail: hburgos@cabprlaw.com 

 rcasellas@cabprlaw.com

 dperez@cabprlaw.com 

Counsel for Assured Guaranty Corp. and Assured 

Guaranty Municipal Corp.

CADWALADER, WICKERSHAM & 

TAFT LLP

By: /s/ Casey J. Servais 

Howard R. Hawkins, Jr.* 

Mark C. Ellenberg* 

Casey J. Servais*

William J. Natbony*

Thomas J. Curtin*

200 Liberty Street

New York, New York 10281

Tel.: (212) 504-6000

Fax: (212) 406-6666

Email: howard.hawkins@cwt.com

 mark.ellenberg@cwt.com

 casey.servais@cwt.com

 bill.natbony@cwt.com

 thomas.curtin@cwt.com

* Admitted pro hac vice 

Counsel for Assured Guaranty Corp. and 

Assured Guaranty Municipal Corp.

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REXACH & PICÓ, CSP

By: /s/ Maria E. Picó 

María E. Picó

USDC-PR 123214

802 Ave. Fernández Juncos

San Juan PR 00907-4315

Telephone: (787) 723-8520

Facsimile: (787) 724-7844

E-mail: mpico@rexachpico.com

Attorneys for Financial Guaranty Insurance

Company

BUTLER SNOW LLP

By: /s/ Martin A. Sosland 

Martin A. Sosland (pro hac vice)

2911 Turtle Creek, Suite 1400

Dallas, TX 75219

Telephone: (469) 680-5502

Facsimile: (469) 680-5501

E-mail: martin.sosland@butlersnow.com

James E. Bailey III (pro hac vice)

Adam M. Langley (pro hac vice)

6075 Poplar Ave., Suite 500

Memphis, TN 38119

Telephone: (901) 680-7347

Facsimile: (615) 680-7201

E-mail: jeb.bailey@butlersnow.com

adam.langley@butlersnow.com

Attorneys for Financial Guaranty Insurance

Company

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230327 HTA STIPULATION VERSION MARCH 27, 2023 15

FERRAIUOLI LLC

By: /s/ Roberto Cámara-Fuertes 

Roberto Cámara-Fuertes (USDC-PR No.

219002)

Sonia Colón (USDC-PR No. 213809)

221 Ponce de León Avenue, 5th Floor

San Juan, PR 00917

Telephone: (787) 766-7000

Facsimile: (787) 766-7001

Email: rcamara@ferraiuoli.com

scolon@ferraiuoli.com

Attorneys for Ambac Assurance Corporation

MILBANK LLP

By: /s/ Atara Miller 

Dennis F. Dunne (admitted pro hac vice)

Atara Miller (admitted pro hac vice)

Grant R. Mainland (admitted pro hac vice)

John J. Hughes, III (admitted pro hac vice)

Jonathan Ohring (admitted pro hac vice)

55 Hudson Yards

New York, NY 10001

Telephone: (212) 530-5000

Facsimile: (212) 530-5219

Email: ddunne@milbank.com

amiller@milbank.com

gmainland@milbank.com

jhughes2@milbank.com

johring@milbank.com

Attorneys for Ambac Assurance Corporation

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230327 HTA STIPULATION VERSION MARCH 27, 2023 16

SO ORDERED on March 27, 2023

/s/ Laura Taylor Swain

HON. LAURA TAYLOR SWAIN

UNITED STATES DISTRICT JUDGE

GOLDMAN ANTONETTI &

CORDOVA, LLC

By: /s/ Carlos A. Rodriguez-Vidal 

Carlos A. Rodriguez-Vidal

USDC-PR No. 201213

Solymar Castillo-Morales

USDC-PR No. 218310

P.O. Box 70364

San Juan, PR 00936-8364

Telephone: (787) 759-4117

E-mail: crodriguez-vidal@gaclaw.com

scastillo@gaclaw.com

Attorneys for Syncora Guarantee Inc.

NORTON ROSE FULBRIGHT US LLP

By: /s/ Eric Daucher 

Eric Daucher (pro hac vice pending)

1301 Avenue of the Americas

New York, NY 10019-6022

Telephone: (212) 318-3000

Facsimile: (212) 318-3400

E-mail: eric.daucher@nortonrosefulbright.com

Attorneys for Syncora Guarantee Inc.

Case:17-03283-LTS Doc#:23877 Filed:03/27/23 Entered:03/27/23 14:41:03 Desc: Main

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