EXHIBIT 2

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 1 of 19
1

Sosa, Javier F.

From: Stolze, Eric D. <ericstolze@paulhastings.com>

Sent: Friday, May 5, 2023 7:28 PM

To: Alonzo, Julia D.; Sosa, Javier F.; Bassett, Nicholas; Farmer, Will C.; Despins, Luc A.; 

Jimenez, Pedro; Whitner, William K.; Bongartz, Alex

Cc: Swanson, Nicole O.; Dale, Margaret A.; Stafford, Laura; apavel@omm.com; 

mbenitesgutierrez@omm.com; Barak, Ehud; Possinger, Paul V.; emckeen@omm.com; 

Peter Friedman; Maria J. DiConza

Subject: RE: PREPA - Committee's First Set of Document Requests

Attachments: PREPA -- Informative Motion(170230230_4).DOCX

This email sent by ericstolze@paulhastings.com originated from outside the Firm.

Julia, 

In an additional effort to file a Joint Informative Motion, please modify the attached document and return it to us by the 

close of business on Monday so that we may file it by that evening. 

To the extent you contend any Discovery Dispute has not crystallized over our prior conference and these emails, I can 

be available at any point through Monday to discuss further (with the exception of Saturday from 11:00 a.m. to 2:00 

p.m. and Monday from 4:30 p.m. to 5:00 p.m.). Thank you. 

Eric D. Stolze | Of Counsel, Litigation Department 

Paul Hastings LLP | 1170 Peachtree Street, N.E., Suite 100, Atlanta, GA 30309 | Direct: 

+1.404.815.2315 | Main: +1.404.815.2400 | Fax: +1.404.685.5315 | 

ericstolze@paulhastings.com | www.paulhastings.com 

From: Alonzo, Julia D. <jalonzo@proskauer.com> 

Sent: Tuesday, May 2, 2023 4:15 PM 

To: Stolze, Eric D. <ericstolze@paulhastings.com>; Sosa, Javier F. <Jsosa@proskauer.com>; Bassett, Nicholas 

<nicholasbassett@paulhastings.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Despins, Luc A. 

<lucdespins@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Whitner, William K. 

<kwhitner@paulhastings.com>; Bongartz, Alex <alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Stafford, Laura 

<lstafford@proskauer.com>; apavel@omm.com; mbenitesgutierrez@omm.com; Barak, Ehud 

<ebarak@proskauer.com>; Possinger, Paul V. <ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman 

<pfriedman@omm.com>; Maria J. DiConza <mdiconza@omm.com> 

Subject: [EXT] RE: PREPA - Committee's First Set of Document Requests 

--- External Email --- 

Counsel: 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 2 of 19
2

We disagree with your characterization of the parties’ communications to date. In particular, I note that you did not 

respond to my email of April 27 until May 1, four days later. Any exigency is due to your own delay. 

If you believe a Discovery Dispute has crystallized pursuant to the terms of the Confirmation Procedures Order, we 

cannot prevent you from seeking relief from the Court. We will make our positions clear to the court in our joint 

informative motion. That said, we respond to each of the topics of your email in turn. 

First, attached hereto are the hit reports that we provided counsel to the Ad Hoc Group of PREPA Bondholders for their 

Request Nos. 2 and 6. We are in the process of uploading documents responsive to these Requests, based on the 

narrowed searches reflected in the hit reports, to the Plan Depository. We confirm that, for the reasons previously 

explained, we are not willing to search for or produce any additional communications to the Requests listed in your 

email. However, of the Requests listed in your email, we have provided documents responsive to your Request Nos. 9, 

11, and 21. We also served our privilege log last week, which provides information regarding our privilege assertions 

with respect to, among others, your Request Nos. 2, 3, 5, 6, 7, 15, 16, 17, 18, 19, 27, 28, and 51. Further, our 

forthcoming production of communications is responsive to your Request No. 62, which specifically seeks any 

documents uploaded in response to, among others, the Ad Hoc Group’s Request No. 2. 

More fundamentally, you have not narrowed the scope any of the Requests for which you seek communications, either 

in terms of custodian, time frame, or search terms. Given the overwhelming breadth of your Requests and your ongoing 

refusal to engage in such narrowing, we have no basis upon which to work with you to identify communications relating 

to critical issues. 

Second, as noted above, we sent our initial privilege log on April 28. We intend to update this log on May 12. As such, 

you now have our articulation of privilege with respect to communications. If you have questions regarding the 

assertions of privilege in that log, we are willing to discuss them with you. 

 

Third, we take issue with the accusation in your email that we are needlessly drawing out our investigations to avoid 

producing responsive documents. On the contrary, we have been engaging with you, and with all other parties, in good 

faith, including by continuing to investigate your Requests for which we indicated we would do so. Our letter of April 24 

provided substantive updates to twelve of the Requests, and we intend to send you via separate correspondence further 

updates regarding these investigations. We also have since uploaded documents to the Plan Depository that are 

responsive to another eight of your Requests. 

We intend to object to any efforts imposed by you to holding any depositions open beyond the 7 hours allocated by the 

Confirmation Procedures Order on the day that such depositions have been noticed. We reserve all rights in this 

respect. 

Lastly, we did not agree to provide you with specific bates numbers of uploaded documents during our meet and confer, 

and we do not agree to do so now. We request that you review all documents that are newly uploaded to the Plan 

Depository, and if you have questions about what documents are responsive to any of your Requests, please ask us and 

we will review. 

Thank you, 

Julia 

Julia D. Alonzo

Senior Counsel 

(she/her/hers) 

Proskauer

Eleven Times Square 

New York, NY 10036-8299 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 3 of 19
3

d 212.969.4558 

f 212.969.2900 

jalonzo@proskauer.com

greenspaces 

Please consider the environment before printing this email. 

From: Stolze, Eric D. <ericstolze@paulhastings.com> 

Sent: Monday, May 1, 2023 1:31 PM 

To: Alonzo, Julia D. <jalonzo@proskauer.com>; Sosa, Javier F. <Jsosa@proskauer.com>; Bassett, Nicholas 

<nicholasbassett@paulhastings.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Despins, Luc A. 

<lucdespins@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Whitner, William K. 

<kwhitner@paulhastings.com>; Bongartz, Alex <alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Stafford, Laura 

<lstafford@proskauer.com>; apavel@omm.com; mbenitesgutierrez@omm.com; Barak, Ehud 

<ebarak@proskauer.com>; Possinger, Paul V. <ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman 

<pfriedman@omm.com>; Maria J. DiConza <mdiconza@omm.com> 

Subject: RE: PREPA - Committee's First Set of Document Requests 

This email originated from outside the Firm.

Julia, 

Your ongoing refusal to join the requested motion has delayed our efforts to obtain resolution of this discovery 

dispute. The history of our communications, beginning with the April 19 meet and confer and continuing over email, 

evidences a transparent effort: (i) to avoid judicial review of the unreasonable positions taken within the Objections & 

Responses (and during our Dispute Conference); and (ii) to delay “Court intervention” by contending nothing has “yet 

crystalized.” 

 Complete Reversal Regarding Communications – To provide an accurate summary of the positions taken by the 

Board during our call, we were unequivocally told “no” in response to our direct question of whether the Board 

is willing to produce any communications. In addition, we were also flatly told that the Board would not be 

undertaking any search whatsoever for any Request where the Responses & Objections stated the Board 

“declines to search for documents”—as is the case for 19 of our Requests. 

We raised, and discussed, the “targeted” language Judge Dein used in the transcript you cite, but you were 

unmoved by it and maintained an absolute position that no searches for communications would be 

undertaken. Indeed, “General Objection” No. 3 within the Objections and Responses stated the Board “objects 

... to each and every Request, as unduly burdensome to the extent they seek “Communications” because any 

search would not be proportional to the needs of the case.” It is disingenuous for you to now claim a discovery 

dispute is not ripe “because [we] did not identify any specific requests that address communications for which 

you believe a more targeted, narrow search would result in responsive and not overwhelmingly privileged 

documents,” particularly where that discussion was truncated—and would have been futile—given your total 

refusal to search for communications. 

Nonetheless, please forward the following information about the “targeted search of communications” you are 

undertaking for the Ad Hoc Group: (i) list of custodians; (ii) data sources for each of those custodians; (iii) date 

range/time frame for each data source; and (iv) the search parameters being used. 

Because we have no context for what you subjectively deem to be “overwhelmingly privileged” or “more 

targeted, narrow search,” and so that we may have a clear and written record of your position, please advise in 

writing whether the Board (despite its initial position that it would not perform any searches for 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 4 of 19
4

communications) will now search for communications (and, if so, the scope of that search, i.e., custodians, date 

ranges, data sources, and number of search terms) for each of the following Requests: 2, 3, 5, 6, 7, 8, 9, 11, 15, 

16, 17, 18, 19, 21, 24, 25, 27, 28, 49, 50, 51. Although your Objections and Responses to Request 52 do not 

assert an objection to communications, please provide the information requested within this paragraph as to 

that Request as well. 

We need to have finality on your position, via a written response, no later than close of business tomorrow. 

 Privilege – We have no misunderstanding regarding privilege. Your response below confirms the assertion of 

privilege over documents that have not been reviewed. 

In addition, your response qualifies each assertion of privilege and concedes an expectation that non-privileged 

documents do exist. For example, you contend responsive documents would be “almost entirely ... covered by 

... privilege” and/or “overwhelmingly privileged.” Without any statistics about the number of documents that 

would be reviewed, or any factual basis on which to assert what proportion of responsive documents 

would/would not be privileged, no foundation exists for your assumption that undertaking searches would be 

burdensome. 

 Endless and Open-Ended Ongoing Investigation – The Board’s position appears to be that a discovery dispute 

will never ripen so long as you assert you are continuing to “investigate.” Given that depositions commence this 

week, and continue in the weeks that follow, we must have a date certain by which your investigation will 

conclude and your production will be complete (excluding supplementation for documents generated in the 

future). 

In the interim, we will reserve all rights in regards to the upcoming depositions, including to keep them open as 

a result of the Board not having completed its document production obligations. 

Finally, please honor the commitment made during our Discovery Conference for the Board to identify by Bates 

Number when additional documents are added to the data room that are responsive to any of our 

Request(s). Thank you. 

Eric D. Stolze | Of Counsel, Litigation Department 

Paul Hastings LLP | 1170 Peachtree Street, N.E., Suite 100, Atlanta, GA 30309 | Direct: 

+1.404.815.2315 | Main: +1.404.815.2400 | Fax: +1.404.685.5315 | 

ericstolze@paulhastings.com | www.paulhastings.com

From: Alonzo, Julia D. <jalonzo@proskauer.com> 

Sent: Thursday, April 27, 2023 7:06 PM 

To: Stolze, Eric D. <ericstolze@paulhastings.com>; Sosa, Javier F. <Jsosa@proskauer.com>; Bassett, Nicholas 

<nicholasbassett@paulhastings.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Despins, Luc A. 

<lucdespins@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Whitner, William K. 

<kwhitner@paulhastings.com>; Bongartz, Alex <alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Stafford, Laura 

<lstafford@proskauer.com>; apavel@omm.com; mbenitesgutierrez@omm.com; Barak, Ehud 

<ebarak@proskauer.com>; Possinger, Paul V. <ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman 

<pfriedman@omm.com>; Maria J. DiConza <mdiconza@omm.com> 

Subject: [EXT] RE: PREPA - Committee's First Set of Document Requests 

--- External Email --- 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 5 of 19
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Eric, 

Thank you for your clarification. We disagree with your positions and continue to believe that we have not reached an 

impasse warranting Court intervention. 

As a preliminary note, we disagree with your interpretation of what is required to inform the Court of a discovery 

dispute, nor do we agree that either the April 19 meet-and-confer or our April 24 letter constituted a “Dispute 

Conference” under the terms of the Confirmation Procedures Order. 

In any event, we address the substance of the three issues raised in your email below. 

First, as to communications, Judge Dein stated that the Ad Hoc Group “ha[d]n’t convinced [her] that this is an area that’s 

rich for discovery,” but that she was “not going to prevent [the parties] from continuing a discussion about producing 

communications” using narrowed search parameters. Hr’g Tr. at 35:7-10. We did, in fact, continue discussing search 

parameters for AHG Request Nos. 2 and 6, and we are currently reviewing the results from a targeted search of 

communications following negotiations as to scope, time frame, custodians, and search terms. We will upload 

responsive, non-privileged communications to the depository, and we believe they may be responsive to certain of your 

requests (including your Request Nos. 6, 31, 32, 38, and 62). Because you did not identify any specific requests that 

address communications for which you believe a more targeted, narrow search would result in responsive and not 

overwhelmingly privileged documents, we are not willing to undertake any additional searches at this time. 

Second, you misunderstand our privilege positions. We are not refusing to produce documents in response to your 

requests because we presume the documents are privileged. Instead, we are refusing to produce documents at this 

time because we believe any responsive documents would be so overwhelmingly privileged that it would be 

burdensome to review and log those documents. For example, Request Nos. 1, 2, and 4 seek drafts of the Fuel Line 

Lender PSA, documents communications regarding entering into the Fuel Line Lender PSA, and documents considered 

by the Oversight Board in determining whether to enter into the Fuel Line Lender PSA. Documents responsive to these 

Requests as drafted would almost entirely be covered by mediation privilege. The same is true for Request Nos. 14 and 

15, which seek similar materials for the National settlement. Numerous other Requests seek documents that would 

overwhelmingly be protected by attorney-client privilege, including 19 and 22 (the Oversight Board’s analysis of 

National’s claims), 49 through 51 (analysis and assessment of the Fuel Oil Litigation or other litigation claims), and 60 

(the Board’s assessment of any discrimination against GUC holders). Again, given your refusal thus far to narrow any of 

your searches in response to our privilege concerns, this burden remains. In any event, as we informed you on our meet 

and confer, we intend to produce an initial privilege log tomorrow, April 28. And as far as additional facts triggering 

privilege, the dates on which common interest privilege attached for the Vitol, Fuel Line Lenders, and National 

settlements are July 14, November 19, and December 16, respectively. 

Third, you are correct that discovery in this matter is ongoing. Indeed, fact discovery does not close until May 26. In 

connection with our April 24 letter, we uploaded documents relating to Request Nos. 11, 20, 21, 32 and 41. We also 

provided you with additional substantive information, including referring you to specific documents in the Plan 

Depository, for Request Nos. 32, 33(c) through (e), 34, 36, 48, 56. We subsequently informed you in our April 26 letter 

that we would be uploading documents responsive to Request Nos. 9, 10, 23, 26, and 47. We are continuing to 

investigate the remaining requests for which we indicated we would do so, including in large part by discussing whether 

LUMA has any responsive documents in their possession. And we intend to produce responsive documents that we 

discover, either from LUMA or elsewhere, in connection with the timeframe set by the Court. We fail to understand 

how our ongoing efforts to identify documents in response to your requests poses a dispute that is ripe for review by 

the Court. 

You don't often get email from jalonzo@proskauer.com. Learn why this is important

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 6 of 19
6

We remain willing to confer with you regarding these issues. Should you insist upon seeking Court intervention, we 

intend to make clear to the Court our view that the parties have not reached impasse on any requests, as we did in our 

prior disputes with the Ad Hoc Group. See ECF No. 3347. 

Regards, 

Julia 

Julia D. Alonzo

Senior Counsel 

(she/her/hers) 

Proskauer

Eleven Times Square 

New York, NY 10036-8299 

d 212.969.4558 

f 212.969.2900 

jalonzo@proskauer.com

greenspaces 

Please consider the environment before printing this email. 

From: Stolze, Eric D. <ericstolze@paulhastings.com> 

Sent: Wednesday, April 26, 2023 9:26 PM 

To: Alonzo, Julia D. <jalonzo@proskauer.com>; Sosa, Javier F. <Jsosa@proskauer.com>; Bassett, Nicholas 

<nicholasbassett@paulhastings.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Despins, Luc A. 

<lucdespins@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Whitner, William K. 

<kwhitner@paulhastings.com>; Bongartz, Alex <alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Stafford, Laura 

<lstafford@proskauer.com>; apavel@omm.com; mbenitesgutierrez@omm.com; Barak, Ehud 

<ebarak@proskauer.com>; Possinger, Paul V. <ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman 

<pfriedman@omm.com>; Maria J. DiConza <mdiconza@omm.com> 

Subject: RE: PREPA - Committee's First Set of Document Requests 

This email originated from outside the Firm.

Julia, 

We held a meet and confer with you on the afternoon of Wednesday, April 19. During that conversation, we outlined 

both our global issues with the Objections & Responses and discussed certain requests by number (following up with an 

email, as requested). We reached an impasse on some of our disputes on that very call. For other areas of 

disagreement, we cooperated by awaiting the update you provided on the evening of Monday, April 24. Based on that 

update (both its contents as well as the information omitted from it, which we requested and expected to see within it), 

we see no reason to delay presentation of this Discovery Dispute to the Court. 

The draft informative motion we prepared for the purpose of raising the dispute with the Court complies with the 

relevant portion of the Confirmation Discovery Procedures Order. Specifically, paragraph 22 of the order, which you 

reference, states only that the parties shall inform the Court of the existence of a discovery dispute via the filing of a 

joint informative motion. The order does not require identification of topics within the joint motion but instead 

instructs the parties to describe the subjects in dispute in subsequent letters to the Court. 

Although the issues in dispute were specified within our prior meet and confer, they are summarized below for your 

reference. 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 7 of 19
7

 Blanket Refusal to Produce Communications – The Responses & Objections flatly stated “any ... search” for 

Communications “will not be proportional.” During our meet and confer, we received confirmation this was 

your final position and that neither search of nor production of Communications will occur. This was despite our 

differing interpretation that Judge Dein did not impose a complete bar to discovery of Communications, but 

rather stated the need for targeted requests. We were willing to negotiate the scope of acceptable, targeted 

requests (to the extent you deemed our Requests to be broader)—but you took an absolute position that no 

Communications are proportional for any of our Requests. 

 Privilege – We expressed our inability to understand either what privilege(s) were being asserted, or the bases 

on which such privilege(s) were asserted, for any specific request. We asked that the update provided on 

Monday, April 24 contain additional information to assist us with evaluating your privilege assertions, including 

the facts that underlie them. That subject was not addressed in that update in any way. (To date, we have 

received only a citation to the Mediation Order). Further, as we confirmed during our meet and confer, you 

have asserted privilege(s) over documents without undertaking any review of them. Rather, you have 

“decline[d] to search for documents” based on your assessment of the probability that privilege(s) would be 

asserted, if a review was undertaken. That is improper and inconsistent with the Court’s prior discovery rulings.

 Generalities of the Update – Discovery in the matter is ongoing. Two depositions are scheduled for next week, 

with additional depositions in the weeks that follow. For several requests, the “update” provides no more 

information than what was provided in the Responses & Objections, i.e., the Responses and Objections (dated 

April 7) stated you were “willing to investigate,” and the April 24 (update) states you are “continuing to 

investigate” with an open-ended statement of “provid[ing] an update as soon as we can.” Although you request 

the “precise issues for which we seek judicial review,” that cannot be done exhaustively given the global issues 

outlined above and the limited information we have regarding your investigation, whether and what types of 

documents will be borne by that investigation, and on what timeline your production will be complete. 

We are, of course, willing to continue to speak with you to narrow, if not resolve, these areas of disagreement, assuming 

you are willing to modify your positions; however, we need to raise a discovery dispute with the Court as soon as 

possible given the commencement of depositions next week. 

Eric D. Stolze | Of Counsel, Litigation Department 

Paul Hastings LLP | 1170 Peachtree Street, N.E., Suite 100, Atlanta, GA 30309 | Direct: 

+1.404.815.2315 | Main: +1.404.815.2400 | Fax: +1.404.685.5315 | 

ericstolze@paulhastings.com | www.paulhastings.com

From: Alonzo, Julia D. <jalonzo@proskauer.com> 

Sent: Wednesday, April 26, 2023 10:27 AM 

To: Stolze, Eric D. <ericstolze@paulhastings.com>; Sosa, Javier F. <Jsosa@proskauer.com>; Bassett, Nicholas 

<nicholasbassett@paulhastings.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Despins, Luc A. 

<lucdespins@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Whitner, William K. 

<kwhitner@paulhastings.com>; Bongartz, Alex <alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Stafford, Laura 

<lstafford@proskauer.com>; apavel@omm.com; mbenitesgutierrez@omm.com; Barak, Ehud 

<ebarak@proskauer.com>; Possinger, Paul V. <ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman 

<pfriedman@omm.com>; Maria J. DiConza <mdiconza@omm.com> 

Subject: [EXT] RE: PREPA - Committee's First Set of Document Requests 

--- External Email --- 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 8 of 19
8

Eric, 

We are in receipt of your email and have reviewed the draft joint status report. You do not have our consent to file. The 

joint status report does not identify a single topic on which we have supposedly reached an impasse that necessitates 

going to the court. Before filing, you need to confer with us in order to explain the precise issues for which you seek 

judicial review. 

Furthermore, as you are undoubtedly aware, Judge Dein previously denied the Ad Hoc Group of PREPA Bondholders’ 

request to obtain judicial intervention regarding discovery issues that had not yet crystalized into a discovery dispute as 

contemplated by the Confirmation Procedures Order. See ECF No. 3352. Our April 24 letter to you included responsive 

information to numerous requests and, as stated in the letter, we are continuing to investigate many of the remaining 

open issues. Additionally, we are preparing a separate letter providing additional information and documents 

responsive to, among others, Request Nos. 9, 10, 23, 24, 26, and 47. In light of our ongoing investigation, and without 

knowing what specific issues that you believe require judicial review, we cannot consent to the joint status report at this 

time. 

Thank you. 

Julia 

Julia D. Alonzo

Senior Counsel 

(she/her/hers) 

Proskauer

Eleven Times Square 

New York, NY 10036-8299 

d 212.969.4558 

f 212.969.2900 

jalonzo@proskauer.com

greenspaces 

Please consider the environment before printing this email. 

From: Stolze, Eric D. <ericstolze@paulhastings.com> 

Sent: Tuesday, April 25, 2023 11:09 PM 

To: Sosa, Javier F. <Jsosa@proskauer.com>; Bassett, Nicholas <nicholasbassett@paulhastings.com>; Farmer, Will C. 

<willfarmer@paulhastings.com>; Despins, Luc A. <lucdespins@paulhastings.com>; Jimenez, Pedro 

<pedrojimenez@paulhastings.com>; Whitner, William K. <kwhitner@paulhastings.com>; Bongartz, Alex 

<alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Alonzo, Julia D. 

<jalonzo@proskauer.com>; Stafford, Laura <lstafford@proskauer.com>; apavel@omm.com; 

mbenitesgutierrez@omm.com; Barak, Ehud <ebarak@proskauer.com>; Possinger, Paul V. 

<ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman <pfriedman@omm.com>; Maria J. DiConza 

<mdiconza@omm.com> 

Subject: RE: PREPA - Committee's First Set of Document Requests 

This email originated from outside the Firm.

Counsel, 

You don't often get email from jalonzo@proskauer.com. Learn why this is important

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 9 of 19
9

A proposed joint filing is attached to inform the Court of this discovery dispute. Please advise if we have your consent to 

file. Thank you. 

Eric D. Stolze | Of Counsel, Litigation Department 

Paul Hastings LLP | 1170 Peachtree Street, N.E., Suite 100, Atlanta, GA 30309 | Direct: 

+1.404.815.2315 | Main: +1.404.815.2400 | Fax: +1.404.685.5315 | 

ericstolze@paulhastings.com | www.paulhastings.com

From: Sosa, Javier F. <Jsosa@proskauer.com> 

Sent: Monday, April 24, 2023 9:54 PM 

To: Stolze, Eric D. <ericstolze@paulhastings.com>; Bassett, Nicholas <nicholasbassett@paulhastings.com>; Farmer, Will 

C. <willfarmer@paulhastings.com>; Despins, Luc A. <lucdespins@paulhastings.com>; Jimenez, Pedro 

<pedrojimenez@paulhastings.com>; Whitner, William K. <kwhitner@paulhastings.com>; Bongartz, Alex 

<alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Alonzo, Julia D. 

<jalonzo@proskauer.com>; Stafford, Laura <lstafford@proskauer.com>; apavel@omm.com; 

mbenitesgutierrez@omm.com; Barak, Ehud <ebarak@proskauer.com>; Possinger, Paul V. 

<ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman <pfriedman@omm.com>; Maria J. DiConza 

<mdiconza@omm.com> 

Subject: [EXT] RE: PREPA - Committee's First Set of Document Requests 

--- External Email --- 

Counsel – Please see attached. 

Javier Sosa 

Associate

Proskauer

Eleven Times Square 

New York, NY 10036 

d 212.969.3742 

f 212.969.2900

Jsosa@proskauer.com 

greenspaces 

Please consider the environment before printing this email.

From: Stolze, Eric D. <ericstolze@paulhastings.com> 

Sent: Friday, April 21, 2023 2:19 PM 

To: Sosa, Javier F. <Jsosa@proskauer.com>; Bassett, Nicholas <nicholasbassett@paulhastings.com>; Farmer, Will C. 

<willfarmer@paulhastings.com>; Despins, Luc A. <lucdespins@paulhastings.com>; Jimenez, Pedro 

You don't often get email from jsosa@proskauer.com. Learn why this is important

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 10 of 19
10

<pedrojimenez@paulhastings.com>; Whitner, William K. <kwhitner@paulhastings.com>; Bongartz, Alex 

<alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Alonzo, Julia D. 

<jalonzo@proskauer.com>; Stafford, Laura <lstafford@proskauer.com>; apavel@omm.com; 

mbenitesgutierrez@omm.com; Barak, Ehud <ebarak@proskauer.com>; Possinger, Paul V. 

<ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman <pfriedman@omm.com>; Maria J. DiConza 

<mdiconza@omm.com> 

Subject: RE: PREPA - Committee's First Set of Document Requests 

This email originated from outside the Firm.

All, 

Further to our discussion this week, please find the request-specific list of issues on which you requested additional 

information below. This list is not intended to be comprehensive of our concerns regarding the Responses & Objections, 

and all rights are expressly reserved. 

In addition, we are having issues accessing the data room. Our logins are not being processed, and the main domain is 

displaying an Apache server test page. Is this a known issue and, if so, what is the estimated time to resolution? 

RFP Note

36 No Documents available address reasons, revenue foregone, alternatives, or other 

aspects of our Request. 

Please advise whether, and when, you intend to make this information available. 

41 As the most recent report in the data room is from March 17, 2023, please provide 

details regarding the rolling schedule for later (and future) time periods. 

42, 44 No Documents appear to provide listing of assets, values, or identify whether assets 

are in use/available. 

Please advise whether, and when, you intend to make this information available. 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 11 of 19
11

45-46 We are willing to cooperate with you on the specific aging periods and customer 

groups, among other criteria, that are available within the relevant accounting 

system(s). 

Please provide us with available parameters and ranges for the applicable systems 

regarding accounts receivable, and we will respond. 

48 The Response to this request directs us to the “Certain Briefing Related to Litigation 

Settlements” folder in the data Room, but no responsive Documents appear within 

this folder. 

Please advise if the correct folder is identified. 

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location. Eric D. Stolze | Of Counsel, Litigation Department 

Paul Hastings LLP | 1170 Peachtree Street, N.E., Suite 100, Atlanta, GA 30309 | Direct: 

+1.404.815.2315 | Main: +1.404.815.2400 | Fax: +1.404.685.5315 | 

ericstolze@paulhastings.com | www.paulhastings.com

From: Sosa, Javier F. <Jsosa@proskauer.com> 

Sent: Wednesday, April 19, 2023 6:10 PM 

To: Bassett, Nicholas <nicholasbassett@paulhastings.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Despins, 

Luc A. <lucdespins@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Whitner, William K. 

<kwhitner@paulhastings.com>; Stolze, Eric D. <ericstolze@paulhastings.com>; Bongartz, Alex 

<alexbongartz@paulhastings.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Dale, Margaret A. <mdale@proskauer.com>; Alonzo, Julia D. 

<jalonzo@proskauer.com>; Stafford, Laura <lstafford@proskauer.com>; apavel@omm.com; 

mbenitesgutierrez@omm.com; Barak, Ehud <ebarak@proskauer.com>; Possinger, Paul V. 

<ppossinger@proskauer.com>; emckeen@omm.com; Peter Friedman <pfriedman@omm.com>; Maria J. DiConza 

<mdiconza@omm.com> 

Subject: [EXT] RE: PREPA - Committee's First Set of Document Requests 

--- External Email --- 

As discussed during today’s meet-and-confer, the password for the protected documents in the “Legacy Charge Model 

and Related Data” folder in the Plan Depository is: brattlesquare 

Please let us know if you have any further difficulties with unlocking those files. 

Best, 

Javier 

Javier Sosa 

Associate

Proskauer

You don't often get email from jsosa@proskauer.com. Learn why this is important

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 12 of 19
12

Eleven Times Square 

New York, NY 10036 

d 212.969.3742 

f 212.969.2900

Jsosa@proskauer.com 

greenspaces 

Please consider the environment before printing this email.

-----Original Appointment----- 

From: Alonzo, Julia D. <jalonzo@proskauer.com> 

Sent: Tuesday, April 18, 2023 10:54 AM 

To: Alonzo, Julia D.; Bassett, Nicholas 

Cc: Swanson, Nicole O.; Farmer, Will C.; Despins, Luc A.; Jimenez, Pedro; Bongartz, Alex; Dale, Margaret A.; Stafford, 

Laura; Sosa, Javier F.; apavel@omm.com; mbenitesgutierrez@omm.com; Barak, Ehud; Possinger, Paul V.; Whitner, 

William K.; Stolze, Eric D.; emckeen@omm.com; Peter Friedman; Maria J. DiConza 

Subject: PREPA - Committee's First Set of Document Requests 

When: Wednesday, April 19, 2023 4:00 PM-5:00 PM (UTC-05:00) Eastern Time (US & Canada). 

Where: https://proskauer.zoom.us/j/6648134950

Hi there, 

Julia Alonzo is inviting you to a scheduled Zoom meeting. 

Join Zoom Meeting 

One tap mobile: US: +16468769923,,6648134950# or +16469313860,,6648134950# 

Meeting URL: https://proskauer.zoom.us/j/6648134950 

Meeting ID: 664 813 4950 

Join by Telephone 

For higher quality, dial a number based on your current location. 

Dial: 

US: +1 646 876 9923 or +1 646 931 3860 or +1 309 205 3325 or +1 

312 626 6799 or +1 301 715 8592 or +1 305 224 1968 or +1 346 248 

7799 or +1 360 209 5623 or +1 386 347 5053 or +1 408 638 0968 or 

+1 507 473 4847 or +1 564 217 2000 or +1 669 444 9171 or +1 669 

900 6833 or +1 689 278 1000 or +1 719 359 4580 or +1 253 205 0468 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 13 of 19
13

or +1 253 215 8782 or 877 853 5257 (Toll Free) or 888 475 4499 (Toll 

Free) or 833 548 0276 (Toll Free) or 833 548 0282 (Toll Free) 

Meeting ID: 664 813 4950 

International numbers

Join from an H.323/SIP room system 

H.323: 162.255.37.11 (US West) 

162.255.36.11 (US East) 

115.114.131.7 (India Mumbai) 

115.114.115.7 (India Hyderabad) 

213.19.144.110 (Amsterdam Netherlands) 

213.244.140.110 (Germany) 

103.122.166.55 (Australia Sydney) 

103.122.167.55 (Australia Melbourne) 

149.137.40.110 (Singapore) 

64.211.144.160 (Brazil) 

149.137.68.253 (Mexico) 

69.174.57.160 (Canada Toronto) 

65.39.152.160 (Canada Vancouver) 

207.226.132.110 (Japan Tokyo) 

149.137.24.110 (Japan Osaka) 

Meeting ID: 664 813 4950 

SIP: 6648134950@zoomcrc.com 

_____________________________________________ 

From: Bassett, Nicholas <nicholasbassett@paulhastings.com> 

Sent: Tuesday, April 18, 2023 10:23 AM 

To: Alonzo, Julia D. <jalonzo@proskauer.com> 

Cc: Swanson, Nicole O. <NSwanson@proskauer.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Despins, Luc A. 

<lucdespins@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Bongartz, Alex 

<alexbongartz@paulhastings.com>; Dale, Margaret A. <mdale@proskauer.com>; Stafford, Laura 

<lstafford@proskauer.com>; Sosa, Javier F. <Jsosa@proskauer.com>; apavel@omm.com; 

mbenitesgutierrez@omm.com; Barak, Ehud <ebarak@proskauer.com>; Possinger, Paul V. 

<ppossinger@proskauer.com>; Whitner, William K. <kwhitner@paulhastings.com>; Stolze, Eric D. 

<ericstolze@paulhastings.com>; Ashley Pavel <apavel@omm.com>; emckeen@omm.com; Peter Friedman 

<pfriedman@omm.com>; Maria J. DiConza <mdiconza@omm.com> 

Subject: Re: PREPA - Committee's First Set of Document Requests 

This email originated from outside the Firm. 

Julia, we can make that work. Will you send a dial-in? 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 14 of 19
14

Nick Bassett, Partner 

Paul Hastings LLP 

2050 M St., N.W. 

Washington, DC 20036 

202.551.1902<tel:202.551.1902> 

On Apr 17, 2023, at 12:36 PM, Alonzo, Julia D. <jalonzo@proskauer.com> wrote: 

--- External Email --- 

Nick — 

Thanks for your email. We are unavailable on Tuesday but Proskauer and OMM can meet on Wednesday from 4-5 ET. 

Please let us know if that works for you. 

On Apr 14, 2023, at 5:45 PM, Bassett, Nicholas <nicholasbassett@paulhastings.com> wrote: 

This email originated from outside the Firm. 

________________________________ 

Nicole, are you and OMM available to meet and confer early next week, perhaps on Tuesday? 

________________________________ 

<https://nam12.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.paulhastings.com%2F&data=05%7C01%7

Cnicholasbassett%40paulhastings.com%7C394aaa9121084feb5e5708db3f61cf90%7C04ffe8f5879440a685011ab59ab5d

0c7%7C1%7C0%7C638173461564153766%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJ

BTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=9qSAo%2FgCSgCqabgO5CBiStWgXiRaZry%2FiLcOgrSJY9

M%3D&reserved=0> 

<image001.png><https://nam12.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.paulhastings.com%2F&d

ata=05%7C01%7Cnicholasbassett%40paulhastings.com%7C394aaa9121084feb5e5708db3f61cf90%7C04ffe8f5879440a6

85011ab59ab5d0c7%7C1%7C0%7C638173461564153766%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJ

QIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=9qSAo%2FgCSgCqabgO5CBiStWgXiRaZry

%2FiLcOgrSJY9M%3D&reserved=0> 

Nick Bassett | Partner | Financial Restructuring Group 

Paul Hastings LLP | 2050 M Street NW, Washington, DC 20036 | Direct: +1.202.551.1902 | Main: +1.202.551.1700 | Fax: 

+1.202.551.0402 | nicholasbassett@paulhastings.com<mailto:nicholasbassett@paulhastings.com> | 

www.paulhastings.com<https://nam12.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.paulhastings.com

%2F&data=05%7C01%7Cnicholasbassett%40paulhastings.com%7C394aaa9121084feb5e5708db3f61cf90%7C04ffe8f587

9440a685011ab59ab5d0c7%7C1%7C0%7C638173461564309995%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAw

MDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Omie8rp46QvORkAZ5KkoZunb

hg2F%2B%2BAq2CkFLO%2BWoWo%3D&reserved=0> 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 15 of 19
15

From: Swanson, Nicole O. <NSwanson@proskauer.com> 

Sent: Friday, April 7, 2023 6:39 PM 

To: Farmer, Will C. <willfarmer@paulhastings.com>; Despins, Luc A. <lucdespins@paulhastings.com>; Bassett, Nicholas 

<nicholasbassett@paulhastings.com>; Jimenez, Pedro <pedrojimenez@paulhastings.com>; Bongartz, Alex 

<alexbongartz@paulhastings.com> 

Cc: Dale, Margaret A. <mdale@proskauer.com>; Alonzo, Julia D. <jalonzo@proskauer.com>; Stafford, Laura 

<lstafford@proskauer.com>; Sosa, Javier F. <Jsosa@proskauer.com>; apavel@omm.com; 

mbenitesgutierrez@omm.com; Barak, Ehud <ebarak@proskauer.com>; Possinger, Paul V. 

<ppossinger@proskauer.com> 

Subject: [EXT] RE: PREPA - Committee's First Set of Document Requests 

--- External Email --- 

You don't often get email from nswanson@proskauer.com<mailto:nswanson@proskauer.com>. Learn why this is 

important<https://aka.ms/LearnAboutSenderIdentification> 

Counsel, 

Please see attached. 

Best, 

Nicole 

Nicole Swanson 

Associate 

(she/her/hers) 

Proskauer<https://nam12.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.proskauer.com%2F&data=05%7

C01%7Cnicholasbassett%40paulhastings.com%7C394aaa9121084feb5e5708db3f61cf90%7C04ffe8f5879440a685011ab5

9ab5d0c7%7C1%7C0%7C638173461564309995%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2lu

MzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=KSlbDbdd10uQlMpz0ftUE1ttruJWaF5wTRrhI4YUR

QE%3D&reserved=0> 

Eleven Times Square 

New York, NY 10036-8299 

d 212.969.3593 

f 212.969.2900 

NSwanson@proskauer.com<mailto:NSwanson@proskauer.com> 

greenspaces 

Please consider the environment before printing this email. 

From: Farmer, Will C. <willfarmer@paulhastings.com<mailto:willfarmer@paulhastings.com>> 

Sent: Friday, March 24, 2023 7:16 PM 

To: Dale, Margaret A. <mdale@proskauer.com<mailto:mdale@proskauer.com>>; Possinger, Paul V. 

<ppossinger@proskauer.com<mailto:ppossinger@proskauer.com>>; Barak, Ehud 

<ebarak@proskauer.com<mailto:ebarak@proskauer.com>>; pfriedman@omm.com<mailto:pfriedman@omm.com>; 

mdiconza@omm.com<mailto:mdiconza@omm.com> 

Cc: Despins, Luc A. <lucdespins@paulhastings.com<mailto:lucdespins@paulhastings.com>>; Bassett, Nicholas 

<nicholasbassett@paulhastings.com<mailto:nicholasbassett@paulhastings.com>>; Jimenez, Pedro 

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 16 of 19
16

<pedrojimenez@paulhastings.com<mailto:pedrojimenez@paulhastings.com>>; Bongartz, Alex 

<alexbongartz@paulhastings.com<mailto:alexbongartz@paulhastings.com>> 

Subject: PREPA - Committee's First Set of Document Requests 

This email originated from outside the Firm. 

________________________________ 

Counsel, 

Please find attached the First Set of Document Requests of the Official Committee of Unsecured Creditors, propounded 

to the Oversight Board, PREPA, and AAFAF in connection with the Modified Second Amended Title III Joint Plan of 

Adjustment of Puerto Rico Electric Power Authority. 

Best regards, 

Will 

________________________________ 

<https://nam12.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.paulhastings.com%2F&data=05%7C01%7

Cnicholasbassett%40paulhastings.com%7C394aaa9121084feb5e5708db3f61cf90%7C04ffe8f5879440a685011ab59ab5d

0c7%7C1%7C0%7C638173461564309995%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJ

BTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Omie8rp46QvORkAZ5KkoZunbhg2F%2B%2BAq2CkFLO%

2BWoWo%3D&reserved=0> 

<image001.png><https://nam12.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.paulhastings.com%2F&d

ata=05%7C01%7Cnicholasbassett%40paulhastings.com%7C394aaa9121084feb5e5708db3f61cf90%7C04ffe8f5879440a6

85011ab59ab5d0c7%7C1%7C0%7C638173461564309995%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJ

QIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Omie8rp46QvORkAZ5KkoZunbhg2F%2B

%2BAq2CkFLO%2BWoWo%3D&reserved=0> 

Will Clark Farmer | Associate, Financial Restructuring Group 

Paul Hastings LLP | 515 South Flower Street, Twenty-Fifth Floor, Los Angeles, CA 90071 | Direct: +1.213.683.6177 | 

Main: +1.213.683.6000 | Fax: +1.213.996.3177 | willfarmer@paulhastings.com<mailto:willfarmer@paulhastings.com> | 

www.paulhastings.com<https://nam12.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.paulhastings.com

%2F&data=05%7C01%7Cnicholasbassett%40paulhastings.com%7C394aaa9121084feb5e5708db3f61cf90%7C04ffe8f587

9440a685011ab59ab5d0c7%7C1%7C0%7C638173461564309995%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAw

MDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=Omie8rp46QvORkAZ5KkoZunb

hg2F%2B%2BAq2CkFLO%2BWoWo%3D&reserved=0> 

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8f5879440a685011ab59ab5d0c7%7C1%7C0%7C638173461564309995%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wL

Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 17 of 19
17

jAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=UXALJbLcN0EimOXvjHFOG3

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8f5879440a685011ab59ab5d0c7%7C1%7C0%7C638173461564309995%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wL

jAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=UXALJbLcN0EimOXvjHFOG3

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and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com. 

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This message is sent by a law firm and may contain information that is privileged or confidential. If you received 

this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. 

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Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 18 of 19
18

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This message is sent by a law firm and may contain information that is privileged or confidential. If you received 

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Case:17-03283-LTS Doc#:24173-2 Filed:05/08/23 Entered:05/08/23 23:44:50 Desc:

Exhibit 2 Page 19 of 19