Exhibit A

Case:17-03283-LTS Doc#:3092-1 Filed:05/17/18 Entered:05/17/18 17:37:00 Desc:

Exhibit A - Proposed Order Page 1 of 3
24554614.4 05/17/2018

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

-------------------------------------------------------------x 

In re:

THE FINANCIAL OVERSIGHT AND

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et

al., 

Debtors.1

-------------------------------------------------------------x 

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

[PROPOSED] ORDER GRANTING MOTION BY THE AMERICAN FEDERATION OF

STATE, COUNTY AND MUNICIPAL EMPLOYEES, AFL-CIO (AFSCME) TO

COMPEL COMPLIANCE WITH THE AUGUST 10, 2017 STIPULATION AND ORDER

Upon the motion (the “Motion”)

2

by the American Federation of State, County and 

Municipal Employees International Union, AFL-CIO (“AFSCME”), on behalf of its local

affiliates in Puerto Rico and their members, requesting that the Court enter an order compelling 

the Mediation Team, Oversight Board, AAFAF, the COFINA Agent, and their professionals to

comply with the Court’s August 10, 2017 Stipulation and Order Approving Procedure to Resolve 

Commonwealth-COFINA dispute (Docket #996) (“the Stipulation”); and the Court having 

jurisdiction to consider the Motion and the relief requested therein; and venue being proper 

before this Court; and notice of the Motion having been given as provided in the Motion, and 

such notice having been adequate and appropriate under the circumstances; and it appearing that

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); and (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).

2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Motion.

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Exhibit A - Proposed Order Page 2 of 3
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24554614.4 05/17/2018

no other or further notice of the Motion need be provided; and the Court having held a hearing to

consider the relief requested in the Motion; and the Court having found and determined that the

relief sought in the Motion and granted herein is in the best interests of the Commonwealth,

COFINA, their creditors, and all parties in interest, and that the legal and factual bases set forth

in the Motion establish just cause for the relief granted herein; and after due deliberation and

sufficient cause appearing therefor,

IT IS HEREBY ORDERED THAT:

1. The Motion is hereby granted as provided herein;

2. The Mediation Team, Oversight Board, AAFAF, the COFINA Agent, and their

professionals shall comply immediately with the Stipulation, and specifically the procedures for

negotiating a settlement to the Commonwealth-COFINA Dispute as set forth at Section 4 of the

Stipulation, including but not only by not participating in any discussions to settle the

Commonwealth-COFINA dispute with the Commonwealth Creditor Representative selected by

the Ad Hoc Group of General Obligation Bondholders and Assured Guaranty Corp. (“the GO

Creditor Representative”) unless and until such a settlement is reached between the

Commonwealth Agent and the COFINA Agent first.

3. This Court shall retain jurisdiction to resolve any dispute arising from or related

to this Order and to interpret, implement, and enforce the provisions of this Order.

SO ORDERED.

Dated: ____________________, 2018

San Juan, Puerto Rico

HONORABLE LAURA TAYLOR SWAIN

UNITED STATES DISTRICT JUDGE

Case:17-03283-LTS Doc#:3092-1 Filed:05/17/18 Entered:05/17/18 17:37:00 Desc:

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