Given the Republic’s recalcitrant attitude, one may wonder why the Republic wastes this Court’s time by submitting a proposal that purportedly mirrors the offers previously rejected by the holdouts

one may wonder why the 
Republic wastes this Court’s time



THE DUANE MORRIS INDIVIDUAL PLAINTIFFS’ BRIEF
IS DESIRABLE AND RELEVANT TO THE DISPOSITION
OF THE CASE.

This Court had already held that the Republic violated the pari passu 
clause of the 1994 FAA when it made payments to the Exchange Bondholders 
without a corresponding payments to the holdout bondholders and when it 
passed the Lock Law. Id. at 3. The only question is the determination of the
appropriate scope of the remedy available for the Republic’s violation.

Given the Republic’s recalcitrant attitude, one may wonder why the 
Republic wastes this Court’s time by submitting a proposal that purportedly 
mirrors the offers previously rejected by the holdouts.

One may also wonder 
why the Republic continues to avail itself of the protections of our courts, all the 
while publicly stating that: it has no intention of complying with orders of the 
Court with which it disagrees; and as recently as March 31, 2013, reiterating its
Case: 12-105 Document: 955-2 Page: 3 04/22/2013 915179 10
4 of 49 4
DM3\2517147.1
disdain for our courts by restating its intention to pay Exchange Bondholders
“no matter what[.]”1

http://www.shearman.com/files/upload/Motion_to_File_Amicus_-_Duane_Morris.pdf