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

ORDER REGARDING COBRA 

ACQUISITIONS LLC’S MOTION TO MODIFY STAY ORDER

Upon Cobra Acquisitions LLC’s Motion to Modify Stay Order [Case No. 17-BK-4780, ECF 

No. 3507, Case No. 17-BK-3283, ECF No. 24219] (the “Motion”),2and the Court having found 

and determined that (i) it has subject matter jurisdiction over this matter pursuant to PROMESA 

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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section 306(a), (ii) venue is 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. No later than June 14, 2023, PREPA shall provide Cobra and the Court with 

the status of PREPA’s review of the Approved Unpaid Invoices,3including the remaining steps that 

need to be completed before PREPA will submit the invoices for reimbursement from COR3 (as 

submitted, the “Submitted Invoices”). For each such invoice, PREPA shall provide where it is in 

the review process. The review process is as follows: (a) confirmation that each invoice has all 

required supporting documentation; (b) accuracy review; (c) purchase order matching to confirm 

the invoiced services were actually requested; (d) verification that invoices were approved by 

authorized personnel; (e) expense classification to confirm any credits and discounts were properly 

applied; (f) tax compliance review to validate any tax calculations; (g) resolution of any 

discrepancies; and (h) approval for payment by PREPA’s Executive Director and Finance 

Department Director. For any incomplete item in the foregoing list, PREPA shall provide an 

expected timeline on when the item will be completed.

2. No later than June 14, 2023, PREPA, in consultation with COR3 and its 

representatives, shall provide the Court with information regarding the expected timeline for 

COR3 to review and process the Submitted Invoices for payment. 

3. Except as set forth herein, the Order Setting Deadline for Further Status 

Report [Case No. 17-BK-4780, ECF No. 3155] remains in effect.

3 As used in this Order, Approved Unpaid Invoices mean those invoices issued by Cobra to PREPA for which 

FEMA has obligated funding on or around March 27, 2023 and for which Cobra has not yet received full payment 

from PREPA.

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

interpretation, implementation and enforcement of this Order.

5. This Order resolved ECF No. 3507 in Case No. 17-BK-4780 and ECF No. 

24219 in Case No. 17-BK-3283.

SO ORDERED.

Dated: , 2023

San Juan, Puerto Rico LAURA TAYLOR SWAIN

United States District Judge

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