EXHIBIT A

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Exhibit A- Proposed Order Page 1 of 4
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

THE COMMONWEALTH OF PUERTO RICO,

Debtor.

PROMESA

Title III

No. 17 BK 3283-LTS

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of

PUERTO RICO HIGHWAYS & TRANSPORTATION 

AUTHORITY,

Debtor.

PROMESA

Title III

No. 17 BK 3567-LTS

ASSURED GUARANTY CORP., et al.,

Plaintiffs,

v.

COMMONWEALTH OF PUERTO RICO, et al., 

Defendants.

Adv. Proc. No. 17-156-LTS in 

17 BK 3567-LTS 

Adv. Proc. No. 17-155-LTS in 

17 BK 3283-LTS

PEAJE INVESTMENTS LLC,

Plaintiff,

v.

PUERTO RICO HIGHWAYS & TRANSPORTATION 

AUTHORITY, et al.,

Defendants.

Adv. Proc. No. 17-151-LTS in 

17 BK 3567-LTS 

Adv. Proc. No. 17-152-LTS in 

17 BK 3283-LTS

[PROPOSED] SCHEDULING ORDER

Upon consideration of the urgent motion by Assured Guaranty Corp. (“AGC”), Assured 

Guaranty Municipal Corp. (f/k/a Financial Security Assurance Inc.) (“AGM” and, together with 

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AGC, “Assured”), Financial Guaranty Insurance Company (“FGIC”), and National Public 

Finance Guarantee Corporation (“National,” together with Assured and FGIC, “Insurers”), in 

support of a parallel briefing and discovery schedule in Peaje Investments LLC v. Puerto Rico 

Highways & Transportation Authority, et al., Adv. Proc. Nos. 17-151, 17-152 (the “Peaje 

Action”), and Assured Guaranty Corp, et al. v. Commonwealth of Puerto Rico, et al., Adv. Proc. 

Nos. 17-155, 17-156 (the “Insurer Action”), and given the Court’s Order Scheduling Hearing, 

which set an evidentiary hearing in the Peaje Action for August 8, 2017(Dkt. 47), the following 

deadlines shall apply in the two actions in advance of the evidentiary hearing:

1. Discovery. The Peaje Action and the Insurer Action shall be consolidated for 

purposes of discovery, and the parties shall participate in discovery on the same schedule in both 

actions.

2. Briefing for Preliminary Injunction Motion in Peaje Action.

a. June 23, 2017: Deadline for Insurers to file any motion to intervene or 

amicus petition.

b. July 11, 2017: Deadline to file: (a) brief(s) in opposition to motion for 

preliminary injunction; and (b) any opposition to Insurers’ motion to 

intervene or amicus petition.

c. July 28, 2017: Deadline to file: (a) reply brief in further support of 

motion for preliminary injunction; and (b) reply in further support of 

Insurers’ motion to intervene or amicus petition. 

3. Briefing for Partial Summary Judgment Motion in Insurer Action.

a. June 23, 2017: Deadline to file partial summary judgment motion

pursuant to Fed. R. Civ. P. 56 and opening brief. 

b. July 11, 2017: Deadline to file brief(s) in opposition to partial summary 

judgment motion.

c. July 28, 2017: Deadline to file reply brief in further support of partial 

summary judgment motion. 

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4. Relief from any deadline in this Order shall be granted for cause shown on 

application to the Court by the parties in the adversary proceedings.

June __, 2017

SO ORDERED:

________________________________________

HONORABLE LAURA TAYLOR SWAIN

UNITED STATES DISTRICT JUDGE

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