From: stmangiaracina@aol.com

To: swaindprcorresp@nysd.uscourts.gov

Cc: stmangiaracina@aol.com

Sent: 8/15/2018 9:19:25 AM Eastern Standard Time 

Subject: Territory of Puerto Rico Bankruptcy 

 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 

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

family,regarding the above on August 10,2018, August 7, 2018June 27, 2018,June 15,2018 and 

May 17, 2018. I also copied to the Court correspondence sent to the Willke Farr & Gallagher, 

LLP on June 2, 2018. 

 I recently read Barron's (Aug, 10, 2018) Caribbean Business MSC (Aug 8,2018) reporting 

the Oversight Board release in part stating the Oversight Board for the government of Puerto 

Rico reached an agreement with debt holders to restructure the Commonwealth's Cofina 

bonds..... The consensual deal with all Cofina bondholders proves the Board's and 

Government's commitment to reach consensual agreement to Puerto Rico's debt whenever 

possible.FOMB director Natalle Jaresko said in a statement.... Under the agreement, the 

bondholders of senior and junior bonds will exchange the current notes for new senior lien notes 

backed by 54% of a 5.5 sales tax.... 

....Senior bond holders will receive 93 cents on the dollar,with an additional 2 cents for being in 

the negotiating group. Junior bondholders will receive 56.4 cents on the dollar.Good news for 

Puerto Rico is good news for three bond insurers. The losses The senior Cofina bonds held by 

MBIA (ticker),Ambac Financial Group(AMBC) and Assured Guaranty(AGO) will be "modest' 

wrote Harry Fong at MKM Partners bur are likely to be "very close" to what the bond insurers 

estimated in their loss reserves as of June 30....Shares of the three companies climbed 

Thursday.... The key point today is that the Oversight Board, Puerto Rico and bondholders have 

come to an agreement on one of the terrory's debts,Fong wrote... 

The Caribbean BusinessMCS news release is similar. 

 San Juan- In separate releases,Puerto Rico's Financial Oversight and Management Board and 

the governor both announced that the Board-as representative of the Puerto Rico Sales Tax 

Financing Corp.(Cofina by the Spanish acronym)in the bankruptcy-like process underTitle III of 

the Puerto Rico Oversight Management and Stability Act(Promesa)-the government and a 

number of bondholders reached a deal to restructure the instrumentality debt. 

 "The agreement in principle" reached with senior and junior bondholders and monoline insurers 

includes new Cofina securities,under "terms that are aligned with the fiscal reality of Puerto 

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Rico" according to the release issued by the office of Gov.Ricardo Rossello.... 

The agreement in principle is the product of a mediation process ordered by Judge Laura Taylor 

Swain.and led by Judge Barbara House and her team of mediating judges. 

 In the Board's release Executive Director Natalle Jaresko wrote that the "objective has been to 

achieve a debt restructuring agreement with all COFINA parties consistent with the agreement 

in principle reached by the agents for the COFINA and Commonwealth,the terms of which were 

announced on June 7, 2018 and we believe the agreement has honored that goal. 

 The court agreed with the proposed protocol to settle the dispute over the 5.5 percent sales & 

use tax. The designated Cofina agent is Belina Wyhte and the commonwealth agent is Luc 

Despins, who represents the Unsecured Creditors Committee(UCC) in Title III proceeding,of 

which bondholders are members.... 

.....In a statement the Cofina Senior Bondholders Coalition said: This agreement between the 

Oversight Board and a substantial number of Cofina senior and subordinate creditors marks a 

major milestone for Puerto Rico on its road to recovery. The terms lay the groundwork for future 

capital markets access,equitable recoveries and the resumption of restructured cash interest for 

all bondholders,including a large cross-section of local retirees and individuals.Importantly,the 

deal also reduces Puerto Rico's debt by approximately $7 billion ,preserves access to low-cost 

securitizations and increases the Commonwealth's FY2019 sales tax revenue by more than $360 

million. 

 In my August 7,2018 letter to you, I noted " In a business setting what the Oversight Board is 

doing,through its Agents would be defined as tortious interference with contract. 

 After reading the releases,I see i was too kind. It now appears to be a criminal enterprise to 

conspire to take what is now owned by the Cofina junior bondholders and attempting to 

legitimatize the taking by getting the Court to sign off on it. 

 First, the independent corporation Cofina is not now in Title III bankruptcy. The issue on 

motion submitted to you on April 10,2010, by the Unsecured Creditors Committee as Agent of 

the Oversight Board as representative of the Oversight board, and Bettina Whyte as Agent of the 

Oversight Board as representative of Cofina, is to determine whether it belongs in 

the Commonwealth's Title III bankruptcy.Both sides submitted opposing advisory briefs to you 

on the motion for summary judgment to this Court .This convoluted set up was necessary 

because the Oversight Board claimed it wanted to remain neutral. 

 About a month after submission, I called Willke Farr and spoke with the primary drafter of the 

motion,arguing the formation of Cofina by the Commonwealth's legislature with the consent of 

the executive branch did not violate Puerto Rico's Constitution. He graciously helped me find the 

submission. I called him back to say he turned out some of the finest papers I ever read. The 

Cofina legislation is supported by so much case law from many other states' highest courts that 

ruled on similar issues in favor of such legislation,The courts deferred to a state's legislature, The

Commonwealth legislature in establishing Cofina did what these other states did . 

 Although I still had doubts about the Oversight Board due to its overlapping relationships,I felt 

very good, after reading the motion papers, there would be a favorable ruling that Cofina would 

not be going into the Title III bankruptcy.If Cofina wins so do its bondholders since, although 

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not a named party,wee are a very interested one.This was until I learned the Oversight Board 

assigned both Agents to work on a "settlement" before this Court had ruled..The Oversight 

Board then showed its true colors that it was not neutral at all. 

 As I stated before, a government entity cannot act or disavow its own duly passed laws,The 

Oversight Board is doing that because it now sits in the Commonwealth's shoes.Here the 

legislation was passed over 10 years ago establishing Cofina,This is very prejudicial to to the 

Cofina bond holders. The Oversight Board is thus indicating to the Court it wants to avoid a 

decision which it believes will be unfavorable to it.It also takes with it the Willke Farr law 

firm,after it wrote and submitted winning motion papers to the Court, to help negotiate with the 

unsecured creditors, Willke Farr should have refused and I said so. Does this encourage the 

Court to ignore their winning papers and let the motion die. Te Oversight Board is now sending 

out self serving joint press releases, about the recent claim of settlement :as to whether if Cofina 

is part of the Title III bankruptcy is of no concern, because it is a fait accompli. Various 

participants claim what a great accomplishment the"settlement' is,about how great it is for Puerto 

Rico and so many others.I do not mean any disrespect, but are they trying to scare you off from 

some unfinished business like a decision or if you did render a decision, because of the 

pressure, it would most likely go against Cofina .?

 Even though it is doing so without a legal basis, it is also shutting the Cofina jujnior 

bondholders out of negotiations.it is clear from the news releases placed by the Oversight Board 

that the juniors were not represented in the "agreement" negotiation.One Agent represented the 

unsecured creditors, with the help of the institutional holders representative and the insurance 

carrier's representative insuring the senior Cofina bonds 

 The 2 cents on the dollar given to senior bond holders to cover their legal expenses for being in 

the negotiating group. The junior bond holders were not awarded this because we were not 

included. at the table. 

 Senior bond holders have a priority over juniors only if Cofina were to default.Here Cofina has 

enough money to meet all its obligations to both seniors and juniors. If the juniors were at the 

table, the response would be that "we get what you get or we are out of here". 

 The lack of our presence allowed the senior Cofina's to get for all practical purposes payment in 

full without the court making a decision as to whether Cofina goes into the Title 

III bankruptcy.The insurance carrier guarantor for the seniors had its loss exposure 

reduced because of what was taken from the absent juniors, 

 The notice that was given in the Caribbean Business MCS release, given by the Financial 

Oversight and Management Board,states "In a statement,the Senior Bondholders Coalition said '' 

This agreement between the Oversight Board and a substantial number of COFINA senior and 

subordinate creditors marks a major milestone for Puerto Rico on its road to rercovery" Why use 

the term subordinate rather than junior ? 

 I understand there is another request for an extention before you make a decision. This time 60 

days so they can present some agreement to you..Wouldn't it be something if their thinking is 

presentation of a fully executed settlement document for you to sign off on and they also have 

an order for you to sign addressing your decision on the motion now before you since its 

submission on August `10,2018. 

 Did the Oversight Board pull a bait and switch to gain total control over the Title III bankruptcy 

issue and Cofina? In claiming neutrality ,appointing two Agents,one for the unsecured creditors 

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and one for Cofina, with each to brief and argue one side of the motion, the Oversight Board has 

been able to view the submissions to the Court and determine that the unsecured creditors would 

lose and Cofina would remain tndependant to meet its original obligations to its bondholders. 

So with no intention of waiting for this decision, it went into 

" settlement mode" where it now controls both sides to get a desired outcome 

which if approved,it will ripoff the Cofina junior bondholders 

 The Oversight Board and the unsecured creditors , with the "settlement" terms that have now 

been published,have thus admitted that Cofina was validly created by the Commonwealth 

legislature . The plan is to have Cofina continue to exist, This is an admission that the legislature 

did not violate Puerto Rico's constitution in creating Cofina. 

This is an excerpt from your hearing on April 10,20189 as reported by Nick brown,Edited by N. 

Zieminski ; 

 Stancil and other GO side lawyers said debt is senior to all obligations. 

 GO holders have the first claim on " available sources. 

 Stancil said and it can't just be assumed away that 

 available resources means whatever the legislature 

 says" 

 " it's up to the court to define,'he said. 

 Judge Swain had pointed questions,though, 

 How she asked Stancil " Is the court in position 

 to determine whether babies should eat or traffic lights 

 fiixed before bondholders get paid? 

 Swain also noted that Puerto Rico's constitutional debt limit 

 only applied to debt backed by Puerto Rico's full faith and credit, 

 such as GO debt. 

 It could have been written to encompass all debt,she said 

 but it wasn't written that way" 

 I believe after hearing you,is when a firm decision was made, by the Oversight Board and the 

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unsecured creditors,to act quickly to entertain "settlement" even though there is no authority to 

do so.without a decision and order by you.They saw the handwriting on the wall and believed 

then and now that they will lose.It is clear you were referring to the Cofina bondholders waiting 

to be paid. 

In speaking with insiders to the proposed "settlement" that, while the goal is have it completed 

by the end of the year,that is not likely and normally in these situations interest will not be 

paid,before a decision and order by the Court. 

 Cofina junior bondholders should not be forced into an unsecured creditor class subject to 

majority votes and the actions of others beyond our control,so as to help Puerto Rico out of 

bankruptcy and reduce the loses of the unsecured creditors and others. 

 The unsecured creditors filed a claim stating Cofina should be in Title III bankruptcy, 

submtted briefs and argued in a proceeding before you on April 10, 2018 when the motion was 

submitted for a decision on the merits and then,instead of waiting for that decision, the 

Oversight Board quickly began "settlement" machinations; sent out self serving press releases, 

along with input from other participants stating how great this all is for Puerto Rico, claiming 

success while inferring that Cofina is already in Title III bankruptcy.It was wrongful to ever 

begin going down this road so as to deny Cofina junior bondholders,such as my family, the due 

process of a decision on the merits by you,before our money is taken from us. 

 Just our rejection of what is going on is sufficient to stop this take over attempt of Cofina, 

which is in effect a takeover of Cofina junior bond holders' property. 

 I believe there are grounds for a referral to the Department of Justice for investigation.This will 

not go away. 

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

 Stephen T. Mangiaracina 

 5 Salem Road 

 Hilton Headf Island,SC 29928 

 Tel. 843 785 5800 

 Fax.843 785 5800 

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Sent from AOL Desktop 

From: 

stmangiaracina@aol.com

To: 

swaindprcorresp@nysd.uscourts.gov

Cc: 

STMangiaracina@aol.com

Sent: 8/10/2018 3:08:16 PM Eastern Standard Time 

Subject: Territory of Puerto Rico Bankruptcy 

 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 August 7, 2018, June 27, 2018, June 15, 2018 and May 17, 2018. 

I also copied to the Court correspondence sent to the Willkie Farr & Gallagher,LLP. law firm on 

July 2, 2018. 

 As to the issues that were put before you,via motion on April 10, 2018,for decision addressing 

the validity of Cofina and the sale of its bonds, I ask the Court to make an interim decision 

first.The Court granted equitable relief to the unsecured creditors with a stay stopping payments 

by Cofina to its sales tax bond holders during the pendency of the motion issues. This was done 

ex parte. Sales tax bond holders,such as my family never had a day in your Court to oppose the 

granting of the stay because we are not part of the bankruptcy;so I settle for writing letters.The 

caption on the motion submitted to the Court states the Oversight Board represents the 

Commonwealth. One issue which would have been raised is the principle that the 

government cannot disavow or act contrary to its own duly passed legislation(.Estoppel).Here, 

that is the creation of Cofina by the Commonwealth as an independent corporation 

and approved by the executive branch, authorized to sell bonds secured by sales taxes, that once 

collected are transferred to the Cofina trustee to meet its obligations to its bond holders.Here the 

Oversight Board by its actions is disavowing Cofina's statutory existence and purpose.Claiming 

to be neutral does not cut it.Example-The Commonwealth should not be paying the legal fees of 

the unsecured creditors on what is now before the Court. The Oversight Board thus facilitated 

the stay. 

 

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 Another point that would have been raised is that unsecured creditors had record notice

at the issuance of the Cofina bond public offerings in 2006 and 2007. If they felt their interests 

were compromised, they could have lobbied the Commonwealth legislature to express concerns 

or sought injunctive relief preventing the establishment of Cofina and its bond issues prior to 

sale, rather than after a bankruptcy filing 10 years later, after sales tax bond holders made their 

purchases. It was not a secret in 2006/2007 that the Commonwealth of Puerto Rico was credit 

dead. 

 The main point I would have argued to the Court is the unlikelihood of success of the 

claim that Cofina was not validly created.In looking at how the highest courts of several states 

(Massaachusetts, New York,etc) addressed similar issues, the tests applied are all similar. The 

courts deferred to the state legislatures.As long as the legislation was tightly defined,all state 

income does not have to go into its treasury first and withdrawn by specified appropriations by 

its legislature. The Commonwealth legislature in establishing Cofina did what all these other 

states did. It's as if they were following a textbook. 

 The stay was granted ex parte.This justifies starting over. I ask that the Court do so sua 

sponte It can always be granted again but with due process this time. 

 Cofina should no longer be treated like the Scarecrow in the Wizard of Oz. It should be given a 

brain. Willke Farr, or anyone else who answers to the Oversight board, should not be associated 

with controlling this independent corporation. This Court should appoint attorneys to represent 

Cofina and approve payment of legal fees.These attorneys should be responsible for representing 

and arguing in favor of Cofina's validity, its ongoing relationship with its bond holders, meeting 

Cofina's obligations and protecting it. 

 Cofina upon being given a brain would now argue for its own life.The caption now states the 

Oversight Board represents Cofina. This is flawed since Cofina is outside the bankruptcy 

proceeding.This would simply be changed to its own attorneys representing its interests. 

 This would address my August 7,2018 correspondence to the Court expressing my feeling of 

being defenseless. The Court would now be addressing the due process issues affecting my 

family whose bonds along with Cofina are outside the bankruptcy proceeding.I think it will also 

be a good thing for the rest of us similarly situated and the Court 

too.. 

 I believe Cofina's existence including the sale of its bonds is valid. The Court may not have to 

get to this issue after addressing the equitable ones. 

 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 

 

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Sent from AOL Desktop 

In a message dated 8/7/2018 3:40:53 PM 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 27,2018, June 15,2018 and May 17,2018. Please see below. I also 

copied to the Court correspondence sent to the Willke ,Farr,& Gallagher.,LLP. law firm on July 

2,2018. 

 I write to you after reading the attached copy of the August 2,2018 Cate Long Twitter blog 

notice. It is a request to delay again a decision date by the Court, from August 4.2018 to 

September 12,2018, on the validity of Cofina and the sale of its bonds, backed by sales tax 

revenues of the Commonwealth of Puerto Rico. 

, 

 What should first be determined is whether the present actions of the Agents who are both 

controlled by the Oversight Board, are legal and ethical. In my opinion I respectfully say "No". 

Much of what has to be said,I addressed in my earlier correspondence. Kindly refer. 

 As to Cofina, the Willke Farr & Gallagher LLP law firm was retained by the Oversight Board 

only to give the Court an advisory argument in the now submitted summary judgment motion 

supporting the validity of Cofina. Cofina is presently not part of the Commonwealth bankruptcy. 

It remains ready,willing and able to meet all its obligations to its sales tax bond holders but for 

the stay. My family opposes the firm doing anything that includes claiming to act on behalf of 

Cofina to effect a "settlement" that would be contrary to our interests. The caption on the motion 

before you states that the Commonwealth is the plaintiff and the defendant is Cofina.The caption 

also states that the Oversight Board represents the Commonwealth. 

 Willkie Farr argued for the defendant, which as an independent corporation is not now part of 

the Commonwealth bankruptcy proceeding. While being on the payroll of the Oversight Board, 

which would gain what the sales tax bond holders would lose in "settlement", Willkie 

Farr would have to work to bring Cofina, a corporation independent of the Commonwealth, 

into the bankruptcy proceeding,along with its bond holders. It is not retained by, nor did it 

represent Cofina. Thus it is acting at the behest of its client Oversight Board which is acting in 

the interest of the Commonwealth. The Commonwealth and its unsecured creditors have 

opposing interests from that of the Cofina bond holders whose interests are secured by the sales 

taxes 

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 The unsecured creditors,already in the Commonwealth bankruptcy proceeding,with their legal 

counsel are in it to settle their claims with the Oversight Board.The Oversight Board does not 

have the authority/standing to orchestrate a plot to take control of Cofina,which is not in the 

bankruptcy proceeding and then going after secured sales tax bond holders like my family,also 

not in the proceeding, to approve a predetermined "settlement" agreement. 

 In a business setting, what the Oversight Board is doing,through its attorneys and Agents, 

would be defined as tortious interference with contract. In the present environment,sales tax 

bond holders are defenseless and thus must rely on this Court to protect us. All I can do is write 

letters to the Court . We should not have to watch as an outcome is manipulated so as to deny us 

due process. What is going on should not be allowed to take place. As I wrote to the Court in an 

earlier letter, sales tax bond holders do not have the deep pockets and organizational capacity to 

fight against this farce that has been created to drag us into the bankruptcy proceeding 

 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 

 843 785 4100 

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Cate Long @cate_long Aug 2

Agents for Puerto Rico govt & Cofina bondholders ask Title lll court to allow them to continue 

negotiating Cofina settlement past Aug 4 deadline. Req new dealine of Sept 12. Appears that 

agents dont have sufficient bondholders on board yet (pg 4) 

https://drive.google.com/file/d/14hsz0aTGF1CS3EKS15F104lzYYAUZBql/view?usp=sharing 

... #muniland

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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. 

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 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. 

 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. 

. 

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Sent from AOL Desktop 

In a message dated 6/15/2018 8:45:04 AM Eastern Standard Time, 

stmangiaracina@aol.com

writes: 

 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 an email on behalf of my family 

regarding the above, dated 5/17/18. Please see below. 

 I just learned that there is a proposed settlement that will be presented to you by the agents for 

the Commonwealth of Puerto Rico and Cofina prior to the Court rendering a decision on the 

issues put before it on April 10,2018. In my earlier letter,I implored the Court to please render a 

decision of record prior to entertaining any settlement discussion,. 

 Again ,please make a decision on the matters that were submitted to you over two months ago.I 

have read the arguments by both agents including the history of the sales tax bonds from their 

birth until the present.The papers were submitted by the law firms retained by the Oversight 

Board to represent each agent for and against the validity of Cofina and its sales tax bond issues 

beginning over 10 years ago. 

 Whatever your decision, I trust it will be well reasoned and thorough.There is the right to 

appeal. It is the only thing that will give due process to the 'little people'. Once settlement is 

entertained, the big boys take control over our interests with no end in sight. 

 Under the unique circumstances of what is before you, I respectfully suggest it would be 

unethical for the law firms representing their "client " to present a settlement proposal to avoid a 

decision by you.Their client is one and the same. They cannot put form over substance to fog 

up this fact. How can you negotiate a settlement with yourself ? Cofina was created by the 

Commonwealth to raise funds for the benefit of the Commonwealth.If what is before the Court 

goes to decision,and Cofina prevails, then all the sales tax bond holders prevail also and there 

will be no issue as to senior or junior sales tax bond holders since there is more than enough 

money collected to meet the obligation to pay both.If there is a settlement,that issue will be 

reserved for settlement on another day.If the Court renders a decision,this will not be an issue 

later. 

 I have read the submission to the Court by Willkie Farr & Gallagher LLP. It is my 

understanding that they only represent the agent for Cofina and not its bondholders. Let me just 

say I am content with what I read. Now after hearing about settlement,I am very displeased. By 

the quality and extent of their papers I can only imagine what a major national law firm charges 

for this work.The same is true for their "adversary" law firm,. They are in effect retained by 

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the same Oversight Board. Why bring up settlement now at the 11th hour when a decision is 

fairly imminent? They have the same client,the Oversight Board, no matter what the caption 

says.The sales tax bond holders including those "little people" Puerto Rico retirees are not part 

of that caption. 

 The fact is that in 2006/2007 Puerto Rico was credit dead.,But for the creation of Cofina by the 

Commonwealth and the sales taxes upon receipt belonging to Cofina and deposited into a 

"lockbox" under its control,bond buyers could not have been lured to buy its bonds. Cofina bond 

holders have a right to rely on the Commonwealth's representations and actions made over 10 

years ago.The Commonwealth and its Control Board charged with managing it and its financial 

affairs should be estopped from claiming and acting otherwise. 

 Cofina is a corporation formed for a purpose by the Commonwealth..But for the Court putting 

a stay on the payment of interest,it would not be in default.Even if Willkie Farr only argued to 

establish the validity of Cofina and not on behalf of bond holders in what is before the Court 

,the fact is that if Cofina wins,so do all its bond holders. In order to now encourage the Court to 

approve a settlement,will Willkie Farr argue that its submission,on behalf of the Oversight 

Board,,has weaknesses? It sure looks great to me.Their summary judgment motion and 

reply covered thoroughly every single issue Why would the firm do this at this point if not 

taking its marching orders from the Oversight Board ? In the true sense, it is not representing a 

client as is normally understood. This would be severely prejudicial for the sales tax bond 

holders. 

 I submit to the Court that the assigned mission for each firm is to argue opposite sides to 

enable the Court to render a decision on the merits.It does not include these firms being retained 

to settle what my family and the other sales tax bond holders should get.They served their 

limited purpose and I assume are being paid handsomely by the Oversight Board. .The caption 

for what is before the Court clearly shows it is the ring leader..It was established to manage the 

interests of the Commonwealth.The "little people" sales tax bond holders have not come to this 

Court and suggested settlement before this Court renders its decision. My family just wants a 

decision. This settlement scheme being hatched smells.The Oversight Board's interests which 

are the Commonwealth, are contrary to those of the sales tax bond holders. .It should not be 

allowed to orchestrate a settlement scenario where it controls everything including the 

outcome to avoid a decision it apparently fears coming soon.We do not have the deep pockets 

and organizational capability to engage in such a charade.I assume most of the other sales tax 

bond holders are similarly situated,.People(families) need to plan their lives and know where 

they stand,win or lose. I believe the Court at this point in time knows how it intends to rule on 

this matter. 

 I respectfully ask the Court to render its decision.Thank you. 

 Stephen T. Mangiaracina 

 5 Salem Road 

 Hilton Head Island,SC 29928 

 Tel. 843 785 5800 

 

 

 

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Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 14 of 24
Sent from AOL Desktop 

From: 

stmangiaracina@aol.com

To: 

swaindprcorresp@nysd.uscourts.gov

Cc: 

STMangiaracina@aol.com

Sent: 5/17/2018 4:01:13 PM Eastern Standard Time 

Subject: Fwd: Territory of Puerto Rico 

Bankruptcy 

 

Sent: 5/17/2018 3:51:12 PM Eastern Standard Time 

Subject: Territory of Puerto Rico Bankruptcy 

 Hon. Laura Taylor Swain 

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

 500 Pearl Street 

 New York,NY 10007 

 Dear Judge Swain: 

 My name is Stephen T. Mangiaracina. My wife MaryAnn and I are owners of Cofina (sales 

tax) junior bonds which are a subject of the above proceedings before you. On April 10,2018 

you heard arguments on the issues before you before taking the matter for decision and 

order.This matter is deciding the rights and priority to the sales taxes collected and set aside to 

meet the obligations owed to sales tax bond holders( senior and junior) both as to timely paying 

interest owed every 6 mounts and at maturity paying the full par value of the bonds. 

 Up until the bankruptcy and the Court staying the payment of the interest on these bonds, there 

has been no default since these bonds were first issued over 10 years ago.There has been no 

default on the payment of principal on any matured Cofina bonds. 

 My wife and I resiide at 5 Salem Road,Hilton Head Island ,SC29928. I also write to you also on 

behalf of my daughter Kim and her husband Steven Schidrich who reside at 2 Stillwater Lane, 

Bluffton,SC 29910 and my wife's sister Georgiana Persichilli. residing at 6 Doharty 

Lane,Bluffton SC 29909.They also purchased Puerto Rico Cofina junior sales tax bonds at my 

suggestion. We all await your decision. 

 I am duly licensed to practice law in the states of New York, South Carolina,and Florida ( 

presently on retired status ). 

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

Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 15 of 24
 My concern now is what is appearing on the internet about settlement discussions, while your 

decision is still pending These various groups negotiating have nothing in common with the 

interests of my family. They represent pension funds,bond funds,etc. which manage various 

Puerto Rico bond issues including general obligation bonds on behalf of those who have a 

financial interest in these funds but do not have direct ownership of the bonds as my family does. 

 None of these players have been given authorization to act on our behalf. We oppose this and 

do not wish to be bound by any of the agreements that may be presented to you. This 

would deny us due process. 

 The settlement negotiations,as reported, say the order of priority would be senior Cofina 

,general obligations and then junior Cofina. The oversight board would also be a major player in 

its approval. There are those,with conflicts of interest all over the place,looking to avoid this 

Court making a decision that would make the junior Cofina bond owners whole.I assume the 

fund managers now negotiating among themselves manage funds with diversified portfolios 

including both Cofina (senior and junior) and general obligation bonds among others.My family 

only purchased the junior Cofina bond issues, The earliest maturity is in 2038. Upon 

information and belief,the paying agent for the collected sales taxes held in trust, would have 

made all interest payments due but for the stay. To deem our bonds to be in default, is more 

nuance than real. if any such settlement were effected,our bonds would be defaulted and we 

would only get a small percentage of the face amount of our bonds. 

 We do not have to be active participants for this Court to make a decision on the merits based 

on the history of all the bond issues which is now before it. We purchased our bonds from FMS 

Bonds,Inc. located in North Miami,Florida. It is my understanding that the record of our 

ownership is with the Court. Our hope is that the Court finds that the Cofina bond owners, both 

senior and junior,have continued recourse to all the sales taxes collected for both interest 

payments, due now and in the future, and payment in full of all money due at maturity to the 

exclusion of the general obligation bond holders,If any of us are unhappy with the decision you 

make,an appeal can be considered. At least due process would not be denied. 

 I respectfully ask the Court to acknowledge receipt of this correspondence.. 

 Thank you. 

 Stephen. T. Mangiaracina,Esq. 

 5 Salem Road 

 Hilton Head Island,SC 28828 

 Tel, 843 785 5800 

 Fax.843 785 2400 

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

Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 16 of 24
From: stmangiaracina@aol.com

To: ckoenig@willkie.com

Cc: swaindprcorresp@nysd.uscourts.gov, stmangiaracina@aol.com

Sent: 7/2/2018 8:39:33 AM Eastern Standard Time 

Subject: Territory of Puerto Rico Bankruptcy 

 July 2, 2018 

 Sent Via Email & Overnight Delivery 

 Christopher Koenig,Esq. 

 Willkie Farr & Gallagher LLP 

 787 Seventh Avenue 

 New York,NY 100019-6009 

 Dear Chris: 

 We last spoke when i called you on Wednesday 6/13/2018. I expressed my dismay at 

learning your firm requested a delay from Judge Swain in rendering a decision on the 

summary judgment motion submitted to her on April 10, 2018.The reason given is that your firm 

is engaged in settlement negotiations that would avoid a need for a decision by the Court on the 

validity of Cofina's existence and its issuance and sale of bonds secured by sales taxes collected. 

Thus during the delay,the stay preventing the Cofina trustee,although ready,willing and able to 

make timely interest payments to bond holders,both senior and junior,would remain in effect. 

 I was very careful not to direct my displeasure at you, a good person but rather at those at 

your firm calling the shots. Your firm is conflicted and therefore has no business engaging in 

"settlement" negotiations that would impact the Cofina bond holders which includes me and my 

family. 

 The Oversight Board chose not to acknowledge the validity of Cofina established over ten 

years ago. Instead it retained your firm to argue and submit briefs in favor of its existence and 

actions. It retained another law firm, believed to be Proskauer Rose LLP to argue against it. You 

had the facts on your side and did outstanding work. 

 It was assumed the Court would render a decision as soon as reasonably possible, particularly 

because of the stay on payments by Cofina to its sales tax bond holders who along with Cofina 

are not part of the bankruptcy. 

 Apparently, what you did was so good that at the 11th hour the Oversight Board, whose 

mission it is to steer the Commonwealth of Puerto Rico out of bankruptcy, had both law firms 

reach out to the Court. The Oversight Board's purpose was to request a delay in the Court's 

decision by claiming a settlement was reached. Willkie Farr should have refused. It did the job 

for which it was retained. The new job assignment for the two firms appears to be deciding how 

much money to take through "settlement " from the sales tax bond holders like my family and 

turn it over to the Commonwealth; this is of course all being subject to approval by the Oversight 

Board, both firms' client. This is settling with yourself. It is no secret that the Oversight Board 

pays its New York attorneys very well; some have said too well, and the Court is addressing this 

issue. 

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Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 17 of 24
 You said I could object to the settlement approximately in September when everything will 

be put before the Court for approval. By then it would be to late. The conflict is glaring. Willkie 

Farr should get out and advise the Court it is no longer seeking a delay on the motion decision.If 

not, the Court should go forward anyway. 

 I have included three letters to Judge Swain dated 6/27/2018, 6/15/2018 and 

5/17/2018. They express more fully my concerns. I have also copied the Court this 

correspondence. 

 Thank you. 

 Sincerely, 

 Stephen T. Mangiaracina, Esq. 

 5 Salem Road 

 Hilton Head Island, SC 29928 

 Tel. 843 785 5800 

 Fax 843 785 4100 

 

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Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 18 of 24
Sent from AOL Desktop

In a message dated 6/27/2018 9:30:13 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 was 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, based on 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. 

 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". 

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Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 19 of 24
 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's 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 

. 

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Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 20 of 24
Sent from AOL Desktop

In a message dated 6/15/2018 8:45:04 AM Eastern Standard 

Time, stmangiaracina@aol.com writes: 

 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 an email on behalf of my family 

regarding the above, dated 5/17/18. Please see below. 

 I just learned that there is a proposed settlement that will be presented to you by the agents for 

the Commonwealth of Puerto Rico and Cofina prior to the Court rendering a decision on the 

issues put before it on April 10,2018. In my earlier letter,I implored the Court to please render a 

decision of record prior to entertaining any settlement discussion,. 

 Again ,please make a decision on the matters that were submitted to you over two months ago.I 

have read the arguments by both agents including the history of the sales tax bonds from their 

birth until the present.The papers were submitted by the law firms retained by the Oversight 

Board to represent each agent for and against the validity of Cofina and its sales tax bond issues 

beginning over 10 years ago. 

 Whatever your decision, I trust it will be well reasoned and thorough.There is the right to 

appeal. It is the only thing that will give due process to the 'little people'. Once settlement is 

entertained, the big boys take control over our interests with no end in sight. 

 Under the unique circumstances of what is before you, I respectfully suggest it would be 

unethical for the law firms representing their "client " to present a settlement proposal to avoid a 

decision by you.Their client is one and the same. They cannot put form over substance to fog 

up this fact. How can you negotiate a settlement with yourself ? Cofina was created by the 

Commonwealth to raise funds for the benefit of the Commonwealth.If what is before the Court 

goes to decision,and Cofina prevails, then all the sales tax bond holders prevail also and there 

will be no issue as to senior or junior sales tax bond holders since there is more than enough 

money collected to meet the obligation to pay both.If there is a settlement,that issue will be 

reserved for settlement on another day.If the Court renders a decision,this will not be an issue 

later. 

 I have read the submission to the Court by Willkie Farr & Gallagher LLP. It is my 

understanding that they only represent the agent for Cofina and not its bondholders. Let me just 

say I am content with what I read. Now after hearing about settlement,I am very displeased. By 

the quality and extent of their papers I can only imagine what a major national law firm charges 

for this work.The same is true for their "adversary" law firm,. They are in effect retained by 

the same Oversight Board. Why bring up settlement now at the 11th hour when a decision is 

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Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 21 of 24
fairly imminent? They have the same client,the Oversight Board, no matter what the caption 

says.The sales tax bond holders including those "little people" Puerto Rico retirees are not part 

of that caption. 

 The fact is that in 2006/2007 Puerto Rico was credit dead.,But for the creation of Cofina by the 

Commonwealth and the sales taxes upon receipt belonging to Cofina and deposited into a 

"lockbox" under its control,bond buyers could not have been lured to buy its bonds. Cofina bond 

holders have a right to rely on the Commonwealth's representations and actions made over 10 

years ago.The Commonwealth and its Control Board charged with managing it and its financial 

affairs should be estopped from claiming and acting otherwise. 

 Cofina is a corporation formed for a purpose by the Commonwealth..But for the Court putting 

a stay on the payment of interest,it would not be in default.Even if Willkie Farr only argued to 

establish the validity of Cofina and not on behalf of bond holders in what is before the Court 

,the fact is that if Cofina wins,so do all its bond holders. In order to now encourage the Court to 

approve a settlement,will Willkie Farr argue that its submission,on behalf of the Oversight 

Board,,has weaknesses? It sure looks great to me.Their summary judgment motion and 

reply covered thoroughly every single issue Why would the firm do this at this point if not 

taking its marching orders from the Oversight Board ? In the true sense, it is not representing a 

client as is normally understood. This would be severely prejudicial for the sales tax bond 

holders. 

 I submit to the Court that the assigned mission for each firm is to argue opposite sides to 

enable the Court to render a decision on the merits.It does not include these firms being retained 

to settle what my family and the other sales tax bond holders should get.They served their 

limited purpose and I assume are being paid handsomely by the Oversight Board. .The caption 

for what is before the Court clearly shows it is the ring leader..It was established to manage the 

interests of the Commonwealth.The "little people" sales tax bond holders have not come to this 

Court and suggested settlement before this Court renders its decision. My family just wants a 

decision. This settlement scheme being hatched smells.The Oversight Board's interests which 

are the Commonwealth, are contrary to those of the sales tax bond holders. .It should not be 

allowed to orchestrate a settlement scenario where it controls everything including the 

outcome to avoid a decision it apparently fears coming soon.We do not have the deep pockets 

and organizational capability to engage in such a charade.I assume most of the other sales tax 

bond holders are similarly situated,.People(families) need to plan their lives and know where 

they stand,win or lose. I believe the Court at this point in time knows how it intends to rule on 

this matter. 

 I respectfully ask the Court to render its decision.Thank you. 

 Stephen T. Mangiaracina 

 5 Salem Road 

 Hilton Head Island,SC 29928 

 Tel. 843 785 5800 

 Fax. 843 7852400 

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

Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 22 of 24
 

 

 

 

 

 

 Sent from AOL Desktop 

From: 

stmangiaracina@aol.com

To: 

swaindprcorresp@nysd.uscourts.gov

Cc: 

STMangiaracina@aol.com

Sent: 5/17/2018 4:01:13 PM Eastern Standard Time 

Subject: Fwd: Territory of Puerto Rico Bankruptcy 

 Hon. Laura Taylor Swain 

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

 500 Pearl Street 

 New York,NY 10007 

 Dear Judge Swain: 

 My name is Stephen T. Mangiaracina. My wife MaryAnn and I are owners of Cofina (sales 

tax) junior bonds which are a subject of the above proceedings before you. On April 10,2018 

you heard arguments on the issues before you before taking the matter for decision and 

order.This matter is deciding the rights and priority to the sales taxes collected and set aside to 

meet the obligations owed to sales tax bond holders( senior and junior) both as to timely paying 

interest owed every 6 mounts and at maturity paying the full par value of the bonds. 

 Up until the bankruptcy and the Court staying the payment of the interest on these bonds, there 

has been no default since these bonds were first issued over 10 years ago.There has been no 

default on the payment of principal on any matured Cofina bonds. 

 My wife and I resiide at 5 Salem Road,Hilton Head Island ,SC29928. I also write to you also on 

behalf of my daughter Kim and her husband Steven Schidrich who reside at 2 Stillwater Lane, 

Bluffton,SC 29910 and my wife's sister Georgiana Persichilli. residing at 6 Doharty 

Lane,Bluffton SC 29909.They also purchased Puerto Rico Cofina junior sales tax bonds at my 

suggestion. We all await your decision. 

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

Exhibit Attachment to September 20 2018 Letter to Judge Swain Page 23 of 24
 I am duly licensed to practice law in the states of New York, South Carolina,and Florida ( 

presently on retired status ). 

 My concern now is what is appearing on the internet about settlement discussions, while your 

decision is still pending These various groups negotiating have nothing in common with the 

interests of my family. They represent pension funds,bond funds,etc. which manage various 

Puerto Rico bond issues including general obligation bonds on behalf of those who have a 

financial interest in these funds but do not have direct ownership of the bonds as my family does. 

 None of these players have been given authorization to act on our behalf. We oppose this and 

do not wish to be bound by any of the agreements that may be presented to you. This 

would deny us due process. 

 The settlement negotiations,as reported, say the order of priority would be senior Cofina 

,general obligations and then junior Cofina. The oversight board would also be a major player in 

its approval. There are those,with conflicts of interest all over the place,looking to avoid this 

Court making a decision that would make the junior Cofina bond owners whole.I assume the 

fund managers now negotiating among themselves manage funds with diversified portfolios 

including both Cofina (senior and junior) and general obligation bonds among others.My family 

only purchased the junior Cofina bond issues, The earliest maturity is in 2038. Upon 

information and belief,the paying agent for the collected sales taxes held in trust, would have 

made all interest payments due but for the stay. To deem our bonds to be in default, is more 

nuance than real. if any such settlement were effected,our bonds would be defaulted and we 

would only get a small percentage of the face amount of our bonds. 

 We do not have to be active participants for this Court to make a decision on the merits based 

on the history of all the bond issues which is now before it. We purchased our bonds from FMS 

Bonds,Inc. located in North Miami,Florida. It is my understanding that the record of our 

ownership is with the Court. Our hope is that the Court finds that the Cofina bond owners, both 

senior and junior,have continued recourse to all the sales taxes collected for both interest 

payments, due now and in the future, and payment in full of all money due at maturity to the 

exclusion of the general obligation bond holders,If any of us are unhappy with the decision you 

make,an appeal can be considered. At least due process would not be denied. 

 I respectfully ask the Court to acknowledge receipt of this correspondence.. 

 Thank you. 

 Stephen. T. Mangiaracina,Esq. 

 5 Salem Road 

 Hilton Head Island,SC 28828 

 Tel, 843 785 5800 

 Fax.843 785 2400 

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