Sent from AOL Desktop 

In a message dated 6/27/2018 9:23:49 AM Eastern Standard Time, 

stmangiaracina@aol.com

writes: 

 Sent Via Email & Overnight Delivery 

 Hon. Laura Taylor Swain 

 U.S. District Court S.D.N.Y. 

 500 Pearl Street 

 New York, N.Y. 10007 

 Dear Judge Swain: 

 My name is Stephen T. Mangiaracina. I recently sent you emails on behalf of my family 

regarding the above on June 15, 2018 and May 17, 2018. Please see below. 

 The sales tax secured bond holders are not creditors of the Commonwealth of Puerto Rico 

which is in bankruptcy. Our bonds were not purchased from, nor secured by the full faith and 

credit of the Commonwealth. The Commonwealth has not defaulted on any obligations it owes 

us, since it has none. 

 Sales tax bond holders are secured creditors of Cofina, established as an independent 

corporation by the Commonwealth government. It is made independent, free of any control by 

the Commonwealth, because there would have been no market for its bonds otherwise. 

 The Cofina bond trustee has been ready, willing and able to continue to meet all its 

obligations to all its sales tax bond holders. The stay imposed by the Court is not a default. If 

Cofina did default, we sales tax bond holders could not claim recourse against the 

Commonwealth. 

 Unless the Court were to first find in the motion papers for summary judgment before it on 

April 10, 2018, that the establishment of Cofina and its commitments to its bondholders are 

invalid, any settlement regarding Commonwealth creditors, cannot include Cofina. Although its 

very existence is being challenged, it is not part of the bankruptcy. Since Cofina is not in 

default, its bond holders have no claim against it.

 Arguments for both sides of the issue have been fully briefed and submitted to the Court on 

April 10, 2018 for decision. It is one thing for the Court requiring sufficient time to render a 

decision on a matter submitted to it over two months ago. It is quite another for those seeking 

the demise of Cofina to request a delay in the publication of a decision. This would be to the 

detriment of the sales tax bond holders such as my family who have already missed two bond 

payments due to the stay and another payment is due August 1st. 

 Settlement efforts regarding the many creditors of the Commonwealth are not the 

issue. Cofina and its sales tax bond holders just do not belong in them. 

Case:17-03283-LTS Doc#:4215-16 Filed:11/13/18 Entered:11/13/18 12:08:37 Desc:

Exhibit June 27 2018 Letter to Judge Swain Page 1 of 2
 I called and spoke with someone at Willkie Farr. I was told a settlement had been reached 

and not to expect anything to happen until sometime in September when I will be given an 

opportunity to object to any settlement then. When I asked if the Court was informed, the reply 

was the Court said something like "This sounds monumental". 

 I am hoping this was the Court simply making an innocuous tongue in cheek comment and 

will think this out. Yet, it is troubling that those having clout, compared to others who do not, 

have ready easy access to the Court and accommodation. It challenges one's faith in the fairness 

of the judicial process. 

 If this is true, how can this Court justify holding off on publishing a decision, as soon as 

reasonably possible, with the stay still in effect?

 The efforts of those seeking "settlement" would result in the taking of property belonging to 

others and having it anointed by judicial process. This is hubris at its best. What plot would 

they hatch to have the Court gain jurisdiction over thousands of sales tax bond holders? 

 It is my understanding that the Cofina trustee will receive a sales tax money delivery shortly 

for the benefit of Cofina sales tax bond holders. How long will we be in a state of uncertainty as 

to whether Cofina will be permitted to pay its bond obligations, including the next one due 

August 1st. 

 Sales tax bond holders, particularly retirees including Puerto Rico residents, have suffered so much 

already. Financial distress grows greater by the day, while the position of those trying to avoid a decision 

gets brighter each day the stay remains in effect. 

 It would be unconscionable to expose sales tax bond holders,under financial duress,to these 

settlement predators. If the stay were removed and all back interest payed, these settlement 

machinations would die forthwith. 

 The equitable remedy of a stay never should have happened. At the time it was sought there was no 

one acting, on behalf of the Cofina sales tax bond holders, to oppose the request with the clout to match 

that of those seeking it. If briefs, of the quality of those submitted to the Court on April 10, 2018, arguing 

for the validity of Cofina's existence, were before this Court in opposition to the stay, I suggest the Court 

would not have granted it. 

 Those seeking the stay would have had an insurmountable burden to overcome. For over 10 years, 

no one including the Commonwealth,ever challenged Cofina's existence, its bond issues and sale of 

bonds, and timely payments by the Cofina trustee of interest to its bond holders. Issues and points of law 

would have been presented to the Court such as the unlikelihood of success of the claim against Cofina's 

existence, laches, bond buyer reliance and the irreparable harm to them, estoppel, etc. in opposition to 

the stay being granted. 

 I respectfully ask the Court to render its decision and remove the stay sua sponte. Thank you. 

 Stephen T. Mangiaracina 

 5 Salem Road 

 Hilton Head Island, SC 29928 

 Tel. 843 785 5800 

 Fax 843 785 4100 

Case:17-03283-LTS Doc#:4215-16 Filed:11/13/18 Entered:11/13/18 12:08:37 Desc:

Exhibit June 27 2018 Letter to Judge Swain Page 2 of 2