Exhibit A 

Proposed Order 

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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.

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

PUERTO RICO ELECTRIC POWER

AUTHORITY (“PREPA”)

Debtor.1

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PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

PROMESA

Title III

No. 17 BK 4780-LTS

 [PROPOSED] ORDER ON COBRA ACQUISITIONS LLC’S MOTION TO

MODIFY STAY ORDER

Upon Cobra Acquisitions LLC’s Motion To Modify Stay Order [ECF No. ___ in Case No. 

17-BK-4780-LTS, the “Motion”),2 and the Court having found and determined that (i) it has 

subject matter jurisdiction over this matter pursuant to PROMESA section 306(a), (ii) venue is 

 

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 (Bankruptcy Case No. 17 BK 3284-LTS) (Last Four Digits of Federal Tax ID: 8474); 

(iii) Puerto Rico Highways and Transportation Authority (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 (Bankruptcy Case No. 17 BK 3566-LTS) (Last Four Digits of Federal Tax ID: 9686); (v) Puerto Rico 

Electric Power Authority (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-5233-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 used but not defined herein have the meanings ascribed to them in the Motion.

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proper pursuant to PROMESA section 307(a), and (iii) due and proper notice of the Motion has 

been provided, and after due deliberation and good and sufficient cause appearing therefor, it is 

HEREBY ORDERED THAT:

1. The Motion is GRANTED.

2. The Stay Order is modified to permit Cobra to seek allowance of an 

administrative expense claim in respect of the Approved Unpaid Invoices.

3. The Stay Order is modified to permit litigation regarding Cobra’s right to 

payment of the Available FEMA Funds if necessary.

4. The Court retains jurisdiction over any disputes relating to the 

interpretation, implementation and enforcement of this Order.

5. This Order resolved ECF No. ___ in Case No. 17-BK-4780.

SO ORDERED.

Dated: , 2023 

San Juan, Puerto Rico LAURA TAYLOR SWAIN

United States District Judge

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