Exhibit C

Case:17-03283-LTS Doc#:24583-3 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit C Page 1 of 6
1 FERNANDO BATLLE

2 oversight board.

3 Q Now, you've been -- well,

4 going back briefly, do you recall that

5 under the 2019 RSA, which we discussed

6 earlier today, to which the board was a

7 party, all monoline insurers, including

8 National, received the same economic

9 treatment under that RSA or would have

1 0 received the same economic treatment?

1 1 A I want to say generally,

1 2 yes. But I do not remember specifically

1 3 if there was a difference in fees between

1 4 the monolines. I just don't remember

1 5 that detail.

1 6 Q But in terms of percentage

1 7 recovery, it was the same across the

1 8 board for monolines under the 2019 RSA;

1 9 right?

2 0 A That is my recollection,

2 1 counsel.

2 2 Q And I know you were

2 3 involved. I was involved.

2 4 COFINA and Commonwealth

2 5 plans of adjustment, your recollection --

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Case:17-03283-LTS Doc#:24583-3 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit C Page 2 of 6
1 FERNANDO BATLLE

2 and I know I'm testing it -- was that

3 monoline insurers received the same

4 percentage recovery under both of those

5 plans than all other monoline insurers;

6 is that right?

7 A That's my recollection, to

8 the extent that they own the same class

9 of securities because they were, as you

1 0 recall, senior and sub. That's my

1 1 recollection.

1 2 Q Do you know why monoline

1 3 insurers or National is being treated

1 4 better than other monoline insurers under

1 5 the plan of adjustment?

1 6 MR. FRIEDMAN: I'm going to

1 7 instruct you as always not to reveal

1 8 any discussions with counsel.

1 9 Q Let me just repeat it.

2 0 Do you know why National is

2 1 receiving better, higher percentage

2 2 recovery than other monoline insurers

2 3 under the amended PREPA plan of

2 4 adjustment?

2 5 A It's driven likely by the

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Case:17-03283-LTS Doc#:24583-3 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit C Page 3 of 6
1 FERNANDO BATLLE

2 board's desire to -- within the same

3 resource envelope as a term, the amount

4 of dollars available for settling the

5 claims, having more people be part of the

6 process is better. And maybe that's the

7 reason why they did it.

8 Q Let me make sure I

9 understand.

1 0 Giving one monoline insurer

1 1 a higher percentage recovery than all

1 2 other monoline insurers, is it AAFAF's

1 3 understanding that that increases the

1 4 amount of people who will support the

1 5 plan? I just want to make sure I

1 6 understand your question.

1 7 A Well, it's another party

1 8 that supports the plan; right?

1 9 Q You mean National?

2 0 A Yes.

2 1 Q So if I understand you

2 2 correctly, the decision to give National

2 3 a higher percentage recovery under the

2 4 amended plan of adjustment was based on

2 5 bringing National onboard to the plan?

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Case:17-03283-LTS Doc#:24583-3 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit C Page 4 of 6
1 FERNANDO BATLLE

2 MR. FRIEDMAN: Object to

3 form.

4 A I mean I wasn't part of

5 those deliberations. But that is my

6 personal view of why it was done.

7 Q Do you know, does AAFAF know

8 if Syncora Guarantee was offered a deal

9 with the same economic terms as National

1 0 at any point?

1 1 A I don't know.

1 2 Q Does AAFAF know whether

1 3 other bondholders were offered a similar

1 4 or the same deal as National was offered?

1 5 MR. FRIEDMAN: I'm just

1 6 going to instruct you not to answer

1 7 anything that you learned in the

1 8 context of mediation, not to testify

1 9 about anything -- if you know

2 0 anything from mediation, don't reveal

2 1 it or through our discussions about

2 2 mediation.

2 3 A No. I don't recall if they

2 4 were -- you asked if they were offered

2 5 the same terms as National.

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Case:17-03283-LTS Doc#:24583-3 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit C Page 5 of 6
1 FERNANDO BATLLE

2 Q Yes.

3 A I don't know.

4 Q Do you know or was AAFAF

5 aware that Syncora Guarantee, in fact,

6 was offered a much less favorable deal

7 from the oversight board than the one

8 reached with National?

9 MR. FRIEDMAN: Object to

1 0 form.

1 1 A I don't recall today whether

1 2 we were notified of that. We might have.

1 3 But I don't recall.

1 4 Q Who would have been notified

1 5 within AAFAF?

1 6 A It could have been many

1 7 times, likely me as a representative of

1 8 AAFAF.

1 9 Q Anyone from Ankura, other

2 0 than you?

2 1 A No. Me.

2 2 MR. SALINAS: Mr. Batlle,

2 3 thank you so much for your time. I

2 4 appreciate your time and your

2 5 patience. I have no further

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Case:17-03283-LTS Doc#:24583-3 Filed:06/15/23 Entered:06/15/23 11:50:32 Desc:

Exhibit C Page 6 of 6