Welcome to your weekly Title III update for February 5, 2018. This week has been dominated by the PREPA Interim Financing request but again issues outside the litigation are looming large. Due to the importance of the DIP loan sought and the number of motions filed in the last four days, this Update will be longer than usual.

Many motions opposing the request for an order for interim financing for PREPA were filed. The Board listed them as:

“(a) Limited Objection by and Reservation of Rights of Arc American, Inc. to the Urgent Joint Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders (a) Authorizing Postpetition Secured Financing, (b) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (c) Modifying the Automatic Stay, (d) Scheduling a Final Hearing, and (e) Granting Related Relief [ECF No. 563] (the “Arc Objection”), filed by Arc American, Inc.

(b) The Ad Hoc Group of General Obligation Bondholders’ (i) Objection to the Urgent Joint Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders (a) Authorizing Postpetition Secured Financing, (b) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (c) Modifying the Automatic Stay, (d) Scheduling a Final Hearing, and (e) Granting Related Relief, and (ii) Urgent Cross-motion, in the Alternative, to Intervene [ECF No. 566] (the “GO Objection”), filed by the Commonwealth’s General Obligation Bondholders.

(c) Objection and Reservation of Rights of PREPA Bond Trustee to Urgent Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders (a) Authorizing Postpetition Secured Financing, (b) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (c) Modifying the Automatic Stay, (d) Scheduling a Final Hearing, and (e) Granting Related Relief [ECF No. 568] (the “Bond Trustee Objection”), filed by the PREPA Bond Trustee.

(d) Objection of Ad Hoc Group of PREPA Bondholders to Urgent Joint Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders (a) Authorizing Postpetition Secured Financing, (b) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (c) Modifying the Automatic Stay, (d) Scheduling a Final Hearing, and (e) Granting Related Relief [ECF No. 570] (the “PREPA Bondholder Objection”), filed by PREPA’s Bondholders.

(e) Limited Objection of Whitefish Energy Holdings, LLC to Urgent Joint Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders (a) Authorizing Postpetition Secured Financing, (b) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (c) Modifying the Automatic Stay, (d) Scheduling a Final Hearing, and (e) Granting Related Relief [ECF No. 571] (the “WEH Objection”), filed by Whitefish Energy Holdings, LLC (“WEH”).

(f) Response and Limited Objection of Scotiabank de Puerto Rico, as Administrative Agent, to Urgent Motion for Entry of an Interim Order Authorizing Postpetition Secured Financing [ECF No. 572] (the “Scotiabank Response”), filed by Scotiabank de Puerto Rico.

(g) Statement of Solus Alternative Asset Management LP in Response to the Urgent Joint Motion for Postpetition Secured Financing [ECF No. 576] (the “Solus Statement”), filed by Solus Alternative Asset Management LP.

(h) Objection of National Public Finance Guarantee Corporation to Urgent Joint Motion of the Financial Oversight and Management Board of Puerto Rico and the Puerto Rico Fiscal Agency & Financial Advisory Board for Entry of Interim and Final Orders (a) Authorizing Postpetition Secured Financing, (b) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (c) Modifying the Automatic Stay, (d) Scheduling a Final Hearing, and (e) Granting Related Relief

[ECF No. 580] (the “National Objection”), filed by the National Public Finance Guarantee Corporation.

(i) Ambac Assurance Corporation’s (i) Objection to the Urgent Joint Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Interim and Final Financing Orders, and (ii) Urgent Cross-Motion, in the Alternative, to Intervene [ECF No. 582] (the “Ambac Objection”), filed by Ambac Assurance Corporation.

(j) Objection of Assured Guaranty Corp., Assured Guaranty Municipal Corp., and Syncora Guarantee Inc. to the Urgent Joint Motion of Financial Oversight and Management Board for Puerto Rico, and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders (a) Authorizing Postpetition Secured Financing, (b) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (c) Modifying the Automatic Stay, (d) Scheduling a Final Hearing, and (e) Granting Related Relief [ECF No. 585] (the “Assured Objection”), filed by Assured Guaranty Corp., Assured Guaranty Municipal Corp., and Syncora Guarantee Inc.

(k) Statement of Official Committee of Unsecured Creditors in Response to Urgent Joint Motion of the Financial Oversight and Management Board for Puerto Rico and the Puerto Rico Fiscal Agency and Financial Advisory Authority for Entry of Interim and Final Orders (A) Authorizing Postpetition Secured Financing, (B) Granting Priming Liens and Providing Superpriority Administrative Expense Claims, (C) Modifying the Automatic Stay, (D) Scheduling a Final Hearing, and (E) Granting Related Relief [ECF No. 597], filed by the Official Committee of Unsecured Creditors of the Commonwealth of Puerto Rico.

(l) Joinder of U.S. Bank National Association in its Capacity as PREPA Bond Trustee to Objections to Urgent Joint Motion of the Financial Oversight and Management Board of Puerto Rico and the Puerto Rico Fiscal Agency & Financial Advisory Board For Entry of Interim and Final Orders (A) Authorizing Postpetition Secured Financing, (B) Granting Priming Liens And Providing Superpriority Administrative Expense Claims, (C) Modifying The Automatic Stay, (D) Scheduling A Final Hearing, And (E) Granting Related Relief [ECF No. 606], filed by U.S. Bank National Association in its Capacity as PREPA Bond Trustee.

(m) Siemens Transportation Partnership Puerto Rico, S.E.’s Limited Objection With Respect to the Urgent Motion for Postpetition Secured Financing, Priming Liens, and Providing Superpriority Administrative Expense Claims [ECF No. 2335 in Case No. 17-03282], filed by Siemens Transportation Partnership Puerto Rico, S.E.”

The oppositions to the loan request included questions on the amount of the loan, its particulars and the fact that the Commonwealth is the lender. Here are a few.

Arc objects and states:

“If the Motion is approved in its current form, Arc may never be paid millions of dollars despite having conferred post-petition tangible benefits directly to PREPA, its bankruptcy estate and the people of Puerto Rico. Instead, Puerto Rico, as Lender, and the professionals for the Debtor, Oversight Committee and Creditors’ Committee, likely will be the only administrative creditors that are paid, while bondholders may receive a minimal recovery and Arc is unlikely to recover anything on an administrative expense claim, in an amount close to $19 million, once allowed by the court.”

The Ad Hoc Group of GO Bondholders objected and stated:

“Let us be clear, the GO Group does not object to PREPA obtaining financing to meet a demonstrated need, from an appropriate source, and on commercially reasonable terms. But the Proposed Loan meets none of those criteria. Rather, the Proposed Loan reflects a unilateral decision by the Oversight Board to use the resources of the Commonwealth—itself a Title III debtor that claims to be unable to pay its own creditors—to subsidize a legally separate instrumentality that has its own Title III case, its own creditors, and its own assets. Worse still, the Oversight Board’s maneuvering seeks to displace the legitimate path for seeking such funding for PREPA, which would involve a reasonable market process and adequate disclosures of the debtor’s finances. The Oversight Board, which serves as representative of both the would-be borrower and the would-be lender, has simply determined for itself that this unprecedented transaction is best for all involved. To the contrary, the Proposed Loan is a massive windfall to PREPA, a severe and unnecessary financial blow to the Commonwealth, and a startling arrogation of power by the Oversight Board. The Proposed Loan seeks immediate authorization for $550 million, even though the movants’ own (unsupported) numbers justify only a small fraction of that amount in the near term. The terms of the loan do not resemble a reasonable, arms-length transaction.”

Scotiabank, a fuel line supplier of credit, also objected:

“The Fuel Line Lenders, however, have several objections to the Interim Financing Order in its present form. First, the Oversight Board has requested authority to borrow up to $550 million prior to a final hearing. But, under the “Initial 13-Week Budget” submitted with the Financing Motion, PREPA does not need that amount on an interim basis. Moreover, based on public information, PREPA is owed significant amounts by Government entities. Before PREPA is permitted to borrow funds that it does not immediately need, PREPA must either collect what it is owed by other Government entities or provide a compelling justification for failing to collect those amounts.”

Siemens claims that the HTA owes it several millions for the Urban Train and filed a limited objection:

“Siemens objects to the Motion only to the extent that the terms of the financing requested therein seeks to pledge, use as collateral, or otherwise encumber funds that are held by GDB for Siemens’ benefit, including the funds located in the Siemens Account. While Siemens does not believe that the Motion contemplates a lien on the Siemens Account or funds held therein, in an abundance of caution Siemens files this Limited Objection.”

National Public Finance Corporation also objected:

“PREPA has failed to demonstrate that the Facility meets the entire fairness standard for insider transactions and the Bankruptcy Code’s and PROMESA’s requirements for postpetition financing, or that the Commonwealth should be entitled to the good faith protections for a postpetition lender under the Bankruptcy Code. First, PREPA has not shown it was unable to obtain financing on an unsecured basis. The Commonwealth could easily have provided PREPA with ample liquidity simply by paying—or causing its instrumentalities to pay—some or all of the outstanding electricity bills owed to PREPA. Second, PREPA has not demonstrated that the $550 million requested on an interim basis and $1.3 billion requested on a final basis are commensurate with PREPA’s actual needs. In fact, given the unpaid electric bills that the Commonwealth has accrued, there is little doubt that any immediate and irreparable harm could be avoided by payment of even some of these outstanding amounts. Third, the Facility is not fair and reasonable because the payment obligations are not offset or reduced by the Commonwealth’s unpaid bills. In addition, granting an administrative expense claim to the Commonwealth would effectively permit the Commonwealth to exercise control over PREPA’s plan of adjustment process, to the further detriment of PREPA’s creditors. Fourth, to grant priming liens to the Commonwealth, PREPA must ensure that bondholders’ liens are adequately protected. The FOMB’s insistence that bondholders are adequately protected because proceeds of the Loans will be utilized to preserve PREPA’s assets is entirely speculative and therefore wholly insufficient to provide adequate protection.

Finally, given the role of the FOMB and AAFAF in negotiating the Facility for both borrower and lender, and the Commonwealth’s overreaching in requesting a superpriority claim and priming lien, PREPA has not shown that the Facility was negotiated at arms’ length and in good faith. Instead, the Financing Motion leaves open many questions regarding the circumstances and process followed to develop the proposed Facility.”

U.S. Bank National Association, in its capacity as the PREPA Bond Trustee, objected to the DIP financing as premature and prefers the Commonwealth to pay what it owes the utility. It stated:

“The DIP Motion proposes a solution that is premature, improper, and the proposed priming lien violates 11 U.S.C. § 364(d). In addition, the PREPA Bond Trustee submits that the proposed interim financing order includes findings that are and will be unsupported by the record and grant rights and protections that are objectionable as set forth herein.

The DIP Motion lumps together two distinct proposed lending relationships between PREPA and the Commonwealth bankruptcy estates that should be reviewed by the Court separately. The first consists of low interest rate direct advances by the Commonwealth to PREPA of up to $550 million (the “Direct Advances”) pursuant to Joint Resolution 196 of the Puerto Rico legislature, dated January 25, 2018 (the “Joint Resolution”). The second proposed relationship consists of the Commonwealth serving as a pass-through lender of proceeds that the Commonwealth hopes to receive from the federal government for community disaster loans (“CDLs”) that PREPA could qualify for under applicable disaster relief statutes (the “Pass-Through Advances”). Together the Direct Advances and the Pass-Through Advances could total $1.3 billion. In both cases, however, the proposed lender/borrower relationship is premature and imposes an inequitable burden on the PREPA bankruptcy estate and its creditors. And, any priming lien would violate § 11 U.S.C. 364(d)(1)(A) and (B).”

Even the UCC informally (whatever that may mean) objected to the DIP request:

“Although the Committee is not formally objecting to the Financing Motion, given the Committee’s overarching responsibility as a “watchdog” for the Debtors in these title III cases, the Committee is duty-bound to advise the court of the Committee’s position and concerns with respect to the Financing.

First, the Committee is, of course, supportive of PREPA having sufficient liquidity to operate and continue to operate as close as possible to ordinary course of business under the circumstances.4 Moreover, the Committee recognizes that the Commonwealth and its unsecured creditors generally benefit from the continued operation of PREPA given the critical importance of a functioning electricity infrastructure. That said, PREPA and the Commonwealth are separate Debtors with separate asset pools and different sets of creditors, and, therefore, the impact and benefits of the Financing must be evaluated separately for creditors of each Debtor and the Financing should be as close as possible to market terms.

Second, while the Committee generally supports PREPA’s efforts to obtain postpetition financing, the Committee believes that the proposed Financing does not reflect market terms from the point of view of the Commonwealth. This is especially true for the interest rate, which would be 0% for the first six months, increase by 50 basis points every six months thereafter, and then top out at 3% after three years. Zero percent DIP loans do not exist in the marketplace, and this feature means that millions of dollars of value are being transferred from the Commonwealth and its creditors to PREPA (and possibly and unintentionally, to the benefit of the entity which will acquire PREPA pursuant to the recently announced privatization program). As a point of comparison, the PREPA secured bondholders previously offered postpetition financing to PREPA at an effective interest rate of approximately 8%.

The Committee recognizes that the court is being asked to authorize PREPA (not the Commonwealth) to enter into the proposed Financing. Indeed, the Oversight Board takes the position that the Commonwealth need not seek court authorization to use its funds to extend the Financing to PREPA on the grounds that (a) section 305 of PROMESA prohibits the court from interfering with any of the Commonwealth’s property or revenues, unless the Oversight Board consents,5 and (b) section 363 of the Bankruptcy Code is not incorporated into title III of PROMESA. However, the matter is not as clear-cut. In fact, in the proposed order attached to the Financing Motion, the Oversight Board is seeking a factual finding that the Financing is fair to the Commonwealth.6 The Oversight Board cannot, on the one hand, claim that the court may not interfere with the Commonwealth’s decision to enter into the Financing, but then, on the other hand, ask this court to bless the transaction from the perspective of the Commonwealth. By asking the court to make factual findings as it relates to the Commonwealth, the Oversight Board is, in essence, consenting to the court’s interference with the Commonwealth’s use of property and revenue, thereby taking the matter outside of section 305 of PROMESA. Accordingly, the court should evaluate the proposed Financing from the perspective of both PREPA and the Commonwealth.”

Ambac, who is not a PREPA creditor, also filed an objection to the fair and reasonable language of the proposed order and also stated:

“The Court must not lose sight of the fact that this is not the typical case. Here, the entity proposing to hand out more than a billion dollars virtually interest free for up to 30 years is itself a debtor with nearly $18 billion dollars of debt. In light of the financial condition of the Commonwealth, and the potential impact the Proposed Loan will have on the Commonwealth’s ability to service its debt, it is a virtual certainty that it will be subject to scrutiny and attack by Commonwealth creditors.

The Proposed Loan is a sweetheart deal for PREPA that will deplete the Commonwealth of sorely needed cash and harm the Commonwealth’s creditors. Although Ambac agrees that PREPA must be provided with adequate liquidity, that liquidity cannot be provided on terms that are both inconsistent with PREPA’s actual needs and harmful to the Commonwealth and its creditors.”

The PREPA Ad Hoc Creditors Committee objected extensively to the DIP loan, including under the premise of adequate protection:

“There is no emergency need here other than the one created by the Commonwealth itself. Even if PREPA’s 13-week budget is a good faith estimate of its cash needs, the budget shows PREPA needs less than $77 million prior to a final hearing on the proposed loan.4 If the Commonwealth and its instrumentalities (collectively, the “Commonwealth Government”) were to pay what they owe to PREPA under past due bills for power provided during this Title III case, PREPA would have more than enough cash to operate without the Commonwealth Loan . . .

The Commonwealth controls PREPA; it controls its other instrumentalities. It has the money to make the loan – therefore it has the money to pay past-due bills. It also has the power to direct PREPA to bill other customers and collect from other customers. Instead, it has directed PREPA (alone among its instrumentalities) not to bill and not to collect from its customers – but to continue supplying power that is not being paid for.

Because the Commonwealth has required PREPA to provide power to customers who do not pay, thus forcing PREPA to take ever-increasing credit risk, the Commonwealth should be required to pay, rather than lend, the cost of this subsidy. Having PREPA’s bondholders bear the cost of power-for-free by granting a priming lien on their collateral would constitute a taking under the Fifth and Fourteenth Amendments of the United States Constitution. Armstrong v. United States, 364 U.S. 40 (1960).

Moreover, where the lender controls the borrower, and the need for the loan is created by the lender’s own defaults and the lender’s own constriction of the borrower’s revenues, the lender – the Commonwealth – is not extending credit in good faith under 11 U.S.C. § 364(e). The Oversight Board – which controls both the Commonwealth and PREPA – cannot show either the “immediate and irreparable harm” required by Bankruptcy Rule 4001(c)(2) or that the Commonwealth Loan passes the “entire fairness” standard that governs approval of selfinterested transactions. Therefore, the Commonwealth Loan cannot be approved.”

Solus, however, did support the loan, but with modifications:

“Based on PREPA’s publicly filed 13-week cash flow forecast, Solus recognizes that PREPA has an immediate liquidity need to meet its operating expenses because PREPA’s General Fund is projected to be negative by the week ending February 16, 2018.5 Until the CDL loans or other sources of funding become available, the DIP Facility appears to be the best (and only) option to pay for PREPA’s near-term operating expenses.

Nevertheless, Solus believes certain modifications to the DIP Facility are appropriate, including (i) limiting the amount of loans that can be borrowed on an interim basis to the amount that PREPA projects will be needed during this interim period (per the 13-week cash flow forecast); (ii) preserving PREPA’s setoff rights against amounts owed by the Commonwealth and its instrumentalities; and (iii) requiring notice and a hearing for any material amendments to the DIP Facility.”

After the first objections started coming in, the Board asked the Court to limit the scope of its review to only two issues, to wit “whether PREPA could obtain similar or better financing without providing to the Commonwealth a priming lien and superpriority claim, and whether PREPA’s bondholders, asserting a security interest in PREPA’s Revenue, are adequately protected.” Judge Swain, however, disagreed:

“The Court has considered all of the submissions carefully. The Scope Motion improperly seeks to curtail the scope of the Interim Hearing and is hereby denied.

In connection with the Omnibus Hearing, scheduled for February 7, 2018, the Court will conduct an Interim Hearing on the Financing Motion in the following two stages:

First, the Court will hear oral argument and any relevant evidence as to whether interim relief is “necessary to avoid immediate and irreparable harm” prior to a final hearing on the Financing Motion that will be held, in New York, on February 15, 2018.

Second, if the Court determines that interim relief is necessary, the Court will then hear oral argument, and any relevant evidence, on the merits of the Financing Motion.

The Debtor is directed to file, with its reply papers on the Financing Motion: (i) an updated budget that includes actual amounts for recent weeks, (ii) a declaration identifying and quantifying any additional sources of receipts that are not otherwise identified on the Debtor’s budget (e.g., insurance proceeds), and (iii) a supplement to the Financing Motion that includes a revised summary of the key terms of the credit agreement that satisfies the express requirements Federal Rule of Bankruptcy Procedure 4001(c)(1)(B).”

The Board quickly complied with the Court’s order and replied to the objections in an Omnibus order. It withdrew its request for interim financing given the final hearing date of February 15. The Board’s order also states:

“(i) clarify that material amendments must be approved by the Court after notice and a hearing; (ii) for creditors who wish to obtain information that do not participate in mediation, PREPA will address requests for information as received; and (iii) clarify that the Final Financing Order does not alter any setoff rights PREPA or any other party has, and all setoff rights are reserved.”

The Board continued its arguments that the only questions at hand were whether PREPA could obtain a better deal and the adequate protection of its bondholders.

In my opinion, it failed to explain why the Commonwealth and its dependencies could not pay PREPA what is owed or why the terms, which could not be obtained commercially, were fair and reasonable. Also, although PROMESA Section 305 prevents the Court from interfering with the Commonwealth’s use of its funds, it behooves the mind to believe that it cannot question whether it can lend to an entity that needs judicial permission to take a loan.

As several parties suggested, PREPA can continue operating with a much more modest loan that the one proposed by the Board. Why offer so much then? My take is that the Board and the Commonwealth, acting in concert, want to dramatically draw down the latter’s liquidity in order to convince the US Treasury to release the CDLs it wants. Moreover, since the CDLs, if and when they come, will likely be for an interest rate above what the Commonwealth is offering, the advantageous terms are illusory.

As the Judge Swain stated in her order, she will decide whether she will hear oral arguments on this issue, which runs counter to her practice of usually having them. Hence, we may or may not know on February 7 whether she will approve said financing.

HTA and GO Rulings

In addition to all this, Judge Swain issued two important opinions in cases involving HTA Bonds and GO Bonds. In the first case dealing with HTA, the Judge dismissed all claims, but those having to do with the claim of lien were dismissed for jurisdictional reasons, namely ripeness, and can be, as the Judge suggested, at a later time such as when the Plan of Adjustment is to be confirmed. Judge Swain determined that 11 U.S.C. § 922 does not require that revenue bonds be paid and hence are not subject to the automatic stay. Rather, she opined, it gave the debtor the chance to determine whether it would continue to pay the revenue bonds. Importantly, Judge Swain decided that bondholders were not the owners of the HTA funds or that they were held in trust for them. Since these are some of the allegations of the COFINA bondholders, this does not abode well for their claims.

As to the GO claims, again, the Judge dismissed for jurisdictional reasons the claims as to liens and priorities, clearly leaving them for another date. Although AFFAF’s Gerardo Portela claimed a “significant victory” for the Commonwealth, his exuberance is misplaced and a fundamental misunderstanding of Judge Swain’s ruling, but we’ve come to expect this from the Rosselló government. The Section 922 issue definitely is the ultimate question of liens and priorities is more important. In bankruptcy, liens must be paid. If these liens exist, the Plan of Adjustment must include their payment. In any event, GO bondholders filed a notice of appeal and the HTA bondholders will probably do the same.

Clearly, Judge Swain is taking a leaf out of Judge Rhodes book: Deny everything and force creditors into agreements in mediation. The difference here is that the Puerto Rico Fiscal Plan presented to the Board has no provision for debt payment. Also, the Board said on November 13, 2017, that there was no money for debt payment in the next 5 years. This position may have changed, however. During the Puerto Rico Chamber of Commerce Second PROMESA Conference, José Carrión was one of the speakers. When asked what was the Board’s position as to paying debt service, Mr. Carrión said: “The vision of the Board is that debt must be paid. . . We are basing ourselves on the premise that the right thing is that we should pay sustainable debt. Because if we don’t, we believe that we will not be complying with a fundamental part of our mandate, which is to ensure that Puerto Rico can regain access to the capital markets.”  At the same time, Carrion refused to answer a question on the validity of bondholder’s liens.

Does the above mean that the Board will now change its tune? I doubt it. This can very well mean that the Board will graciously offer its bond creditors “growth bonds”, to wit, a new instrument that will be paid when Puerto Rico starts growing at a particular clip. It is doubtful, however, whether bondholders will accept this, so litigation will continue up to the Plan of Adjustment and beyond. More and more of Puerto Ricans taxpayer money going to lawyers.

Mr. Carrión also made it clear that Puerto Rico does not deserve the power system it has and that PREPA must be sold. He stated that the Board is behind the Government’s intention of selling PREPA. I seldom agree with Mr. Carrión, but I wholeheartedly support the idea of selling PREPA. The devil, however, is in the details.

Finally, I found disturbing that Arc claims it is owed $19 million and Whitefish claims it is owed $100 million. How is Puerto Rico going to rise if those who are doing the dirty work are not paid? This reinforces the idea that PREPA must be sold, the sooner the better.

This summary is merely what I believe are the more salient motions and decisions in the cases. I receive an average of 20 filings each day so it would be impossible to summarize everything. If you have legal interest in these cases, I urge you to hire an attorney to represent you.