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Exhibit A

(Proposed Order)

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

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:

In re: :

:

THE FINANCIAL OVERSIGHT AND : PROMESA

MANAGEMENT BOARD FOR PUERTO RICO, : Title III

:

as representative of : Case No. 17-BK-3283 (LTS)

:

THE COMMONWEALTH OF PUERTO RICO et al., : (Jointly Administered)

:

Debtors.1:

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ORDER GRANTING OMNIBUS MOTION BY THE AVOIDANCE ACTIONS

TRUSTEE TO LIFT LITIGATION STAY IN CERTAIN AVOIDANCE ACTIONS

Upon the Omnibus Motion by the Avoidance Actions Trustee to Lift Litigation Stay in 

Certain Avoidance Action [DE __] (the “Motion”)2 of Drivetrain, LLC (“Trustee”), in its capacity 

as the trustee of the Commonwealth Avoidance Actions Trust (the “Avoidance Actions Trust”); 

and the Court having jurisdiction over this matter under 28 U.S.C. 1331, and under section 306(a)-

(b) of PROMESA, 48 U.S.C. §2166(a)-(b); and venue being proper under section 307(a) of 

PROMESA, 48 U.S.C. § 2167(a); and due and proper notice of the Motion having been provided, 

and it appearing that no other or further notice need be provided; and the Court having reviewed 

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) (Title III case numbers are listed as 

Bankruptcy Case numbers due to software limitations); and (vi) Puerto Rico Public Buildings Authority (“PBA”) 

(Bankruptcy Case No. 19-BK-5233-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case numbers are 

listed as Bankruptcy Case numbers due to software limitations). (Title III case numbers are listed as Bankruptcy 

Case numbers due to software limitations).

2 All capitalized terms that are not otherwise defined in this Order shall have the meaning ascribed to such terms 

in the Motion. 

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the Motion and any oppositions, and the Court having determined that the legal and factual bases 

set forth in the Motion establish just cause for the relief granted herein; and upon all of the 

proceedings had before the Court and after due deliberation and sufficient cause appearing 

therefore, it is hereby:

ORDERED: 

1. The Motion is granted. 

2. The stay imposed by the Procedures in the Mediated Actions listed in Appendix I 

and the Rosso Action listed in Appendix II of the Motion is lifted.

3. Within 21 days of this Order, the Parties shall file a joint scheduling report and 

proposed order that complies with the Procedures; provided that, such joint scheduling report and 

proposed order shall provide a time by which the Trustee may amend the complaint (or seek leave 

to amend the complaint). 

Dated: [*****], 2023

___________________________________

Honorable Judith G. Dein

United States Magistrate Judge

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