GreenbergTraurig NYSCEF. New York, New York 10007

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1 James W. Perkins Tel (212) Fax (212) GreenbergTraurig February 28, 2018 BY NYSCEF Hon. Saliann Scarpulla Supreme Court of the State of New York, Commercial Division 60 Centre Street, Courtroom 208 (Part 39) New York, New York Re: Universal Investment Advisory SA, et al. v. Bakrie Telecom PTE, et al. No /2014 Dear Justice Scarpulla: We are counsel to the Plaintiffs herein and write concerning the Stipulation and Stipulation" [Proposed] Order Regarding Entry of Judgment (the "Judgment Stipulation") that we submitted to the Court by letter dated February 22, This is to advise that the federal bankruptcy court today entered the attached stipulation and order. Accordingly, we respectfully request that the Court enter the Judgment Stipulation and direct the Judgment Clerk to enter judgment in the form attached to that Stipulation. Should the Court have any questions about the foregoing, we are available to address them during the telephonic conference scheduled for tomorrow at 10:00 a.m. Respec lly submitted j J es W. Perkins Attachment cc: All parties of record (via NYSCEF) GREENBERGTRAURIG, LLP ATTORNEYS AT LAW = ~ ~ ~ Te' ~ VletLife Building 200 Park Avenue New York. NY :0C Fax C.

2 Pg 1 of 22 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF NEW YORK X X In re: Chapter 15 PT BAKRIE TELECOM TBK Case No shl Debtor in a Foreign Proceeding X STIPULATION AND ORDER (I) SCHEDULING COMBINED HEARING ON PETITION FOR RECOGNITION AND RELIEF, (II) FIXING DISCOVERY AND BRIEFING DEADLINES, AND (III) SPECIFYING FORM AND MANNER OF SERVICE OF NOTICE "Stipulation" This Stipulation (the "Stipulation") is entered into this _ day of February, 2018, by and between Jastiro Abi, in his asserted capacity as Foreign Representative of the Debtor in a Foreign (" Petitioner" Proceeding ("Petitioner") on behalf of the above-captioned Debtor in a Foreign Proceeding (the Debtor" "Foreign Debtor"), and Universal Investment Advisory SA, Universal Absolute Return SP, Vaquero Master EM Credit Fund, Ltd., Harshil Kantilal Kothari, Footbridge Capital, LLC and Growth Credit Fund IC (collectively, "Noteholders," and together with Petitioner, the "Parties" "Parties") by and through their respective undersigned counsel. RECITALS WHEREAS, on January 29, 2018, Petitioner filed that certain Verified Petition of Jastiro Abi, as Foreign Representative of the Debtor in a Foreign Proceeding, for (I) Recognition of Foreign Main Proceeding Pursuant to 11 U.S.C and 1517 and (11) Relief Pursuant to "Petition" 11 U.S.C and 1521 (D.E. #4) (the "Petition") in this Court, seeking recognition as a foreign main proceeding under Chapter 15 of the Bankruptcy Code of that certain Indonesia PKPU proceeding commenced in the Central Jakarta Commercial Court (the "Indonesian

3 Pg 2 of 22 Court" Court") pursuant to Law No. 37 of 2004 on Bankruptcy and Suspension of Debt Payment Obligations; and WHEREAS, on September 22, 2014, the Noteholders filed an action in the Supreme Court" Court of the State of New York, County of New York (the "State Court") as Index No. Action" /2014 (the "State Court Action") against the Foreign Debtor and others, seeking, inter alia, a judgment for the alleged breach by the Foreign Debtor for the failure to pay to the "Default" "Notes" Noteholders principal and interest (the "Default") upon certain notes (the "Notes"); and WHEREAS, the State Court has ruled that the Foreign Debtor and the issuer and other corporate guarantors of the Notes are liable for the Default and the Noteholders are entitled to judgment thereon and has pending, inter alia, a motion to quantify the Default damages and enter judgment against the Foreign Debtor and the issuer and other corporate guarantors (the "Judgment Motion"); and WHEREAS, concurrently with the filing of the Petition, Petitioner filed the Application for an Order Granting Provisional Relief Pursuant to Sections 105(a) and 1519 of the Relief" Bankruptcy Code (D.E. #5) (the "Application for Provisional Relief"); and WHEREAS, concurrently with the filing of and in support of the Petition, Petitioner filed the Declaration of Gregorius Petrus Aji Wijaya (D.E. #7); and WHEREAS, on June 9, 2017, the Noteholders filed their Notice of Opposition and Request for Status Conference (D.E. #15); and WHEREAS, the Petitioner intends to file in this Court a motion seeking to enforce the Plan" debt restructuring plan (the "PKPU Plan") approved by the Indonesian Court (the "Plan Motion" Implementation Motion"); and 2

4 shi Doc 33 Filed 02/28/18 Entered 02/28/18 12:59:13 Main Document Pg 3 of 22 WHEREAS, the Court convened a Status Conference on Wednesday, February 7, 2018, and a further telephonic hearing on February 9, 2018, to consider scheduling and related issues in respect of the Petition; and WHEREAS, counsel for the Parties hereto and to the State Court Action have met and conferred and they and the Parties to this proceeding and to the State Court Action have agreed to resolve certain disputes over the prosecution of this proceeding and the State Court Action on the following terms: entry of judgment on the Judgment Motion; no enforcement of the resulting judgment pending the outcome of this proceeding; no further discovery or other proceedings in the State Court Action pending the outcome of this proceeding; and use in this proceeding of the discovery propounded and responded to in the State Court Action; NOW, THEREFORE, in order to create efficiencies in the prosecution of this proceeding and the State Court Action and to streamline the discovery and briefing process leading up to a final hearing on the Petition and the Plan Implementation Motion, the Parties stipulate and agree as follows: 1. The State Court may proceed to grant the Judgment Motion in accordance with the executed stipulation annexed hereto as Exhibit A, and enter a judgment in the form attached Judgment" hereto as Exhibit B (the "State Court Judgment"), which form shall be presented to the State Court for entry and docketing immediately after entry of this Stipulation and Order; 2. The Noteholders shall take no steps to enforce the State Court Judgment, and the parties in the State Court Action shall not pursue any pending or additional discovery or other proceedings in that Action, or initiate any related action in any court or before any tribunal prior to a decision by this Court on the Petition and the Plan Implementation Motion, without prejudice to the rights of the Parties to propound, pursue and object to similar, additional or overlapping 3

5 Pg 4of 22 discovery in this Chapter 15 case in this Court. the scope of which shall be framed by Fed. R. Bankr. P as made applicable by Fed. R. Bankr. P. 9014; 3. The Parties shall make a good faith effort to seek expeditious determinations by this Court on the Petition, the Plan Implementation Motion, and all procedures and discovery related thereto. Unless altered by written agreement of Petitioner and Noteholders or by Order of this Court, the following schedule, deadlines and procedures shall govern discovery in this Chapter 15 case: A. March 9, 2018â 1. Petitioner to serve Response and Objections to Request for Production; Noteholders' First 2. Petitioner and Noteholders to propound any additional written discovery requests, with time for Response/Objection and production of documents to be shortened to fourteen (14) days and twenty-one (21) days, respectively, from service of requests, B. March 26, 2018 â Petitioner to produce documents in response to Noteholders' First Request for Production (including designation and identification of documents previously produced in state court to be included in production), subject to Response and Objections as provided above. C. Any disputes relating to discovery shall be submitted to the Court for resolution by telephone conference, to be scheduled not less than two (2) business days from such request or as convenient to the Court. D. March 30, 2018 â Petitioner to file the Plan Implementation Motion, E. Week of April 23, 2018 â Depositions of Jastiro Abi and Gregorius Petrus Aji Wijaya to be taken in New York; provided, however, that consistent 4

6 Pg 5 of 22 with paragraph 2 above, the Noteholders shall not attempt to serve legal process on Mr. Abi and Mr. Wijaya while they are in the United States for their depositions or any hearings or other proceedings in this Chapter 15 case, in each instance for the fourteen (14)-day period commencing upon their arrivals in the United States for such depositions or hearings; F. â May 10, 2018-Deadline for completion of all discovery. G. â May 2, 2018-Status Conference and hearing on all unresolved discovery disputes at 2:00 p.m. (Prevailing Eastern Time), or as soon thereafter as counsel shall be heard, in Room 701 of the United States Bankruptcy Court for the Southern District of New York, One Bowling Green, New York, NY H. â May 25, 2018-Noteholders to file and serve Omnibus Response to the Petition and the Plan Implementation Motion, in accordance with paragraph 4 of this Order. I. June â 8, 2018-Petitioner to file and serve Reply in Support of the Petition and the Plan Implementation Motion, in accordance with paragraph 5 of this Order. J. June â 12, 2018-Parties to exchange witness and exhibit lists. K. June â 27, 2018-Final Pretrial Conference on the Petition and the Plan Implementation Motion, at 2:00 p.m. (Prevailing Eastern Time), or as soon thereafter as counsel shall be heard, in Room 701 of the United States Bankruptcy Court for the Southern District of New York, One Bowling Green, New York, NY

7 Pg 6 of 22 L. Starting July 10, 2018 and continuing on July 11, 2018 and July 12, 2018 as necessary-combined final evidentiary hearing on the Petition and the Plan Implementation Motion, at 10:00 a.m. (Prevailing Eastern Time), or as soon thereafter as counsel shall be heard, in Room 701 of the United States Bankruptcy Court for the Southern District of New York, One Bowling Green, New York, NY Any Responses or Objections to the Petition or the Plan Implementation Motion must be made in writing describing the basis therefore, and shall be filed with this Court and served on Schnader Harrison Segal & Lewis LLP, 140 Broadway, Suite 3100, New York, NY (Attn: Kenneth R. Puhala), Greenberg Traurig, LLP, 200 Park Avenue, New York, NY (Attn: James W. Perkins and Maria J. DiConza) and 333 S.E. 2nd Avenue, Miami, FL (Attn: Mark D. Bloom), and the Office of the United States Trustee, 201 Varick Street, Suite 1006, New York, NY 10014, so as actually to be received by them no later than 4:00 p.m. (Prevailing Eastern Time) on May 25, Petitioner's Reply to any Responses or Objections to the Petition or the Plan Implementation Motion or the relief requested therein, shall be filed and served Greenberg Traurig, LLP, 200 Park Avenue, New York, NY (Attn: James W. Perkins and Maria J. DiConza) and 333 S.E. 2nd Avenue, Miami, FL (Attn: Mark D. Bloom), and the Office of the United States Trustee, 201 Varick Street, Suite 1006, New York, NY 10014, so as actually to be received by them no later than 4:00 p.m. (Prevailing Eastern Time) on June 8, All other notice requirements set forth in Section 1514(c) of the Bankruptcy Code are hereby waived. 6

8 shl Doc 33 Filed 02/28/18 Entered 02/28/18 12:59.13 Main Document Pg 7 of Bankruptcy Rule 1010 does not apply to the Petition, and accordingly, the summons requirement in Bankruptcy Rules 1010(a) and 1011(b) is inapplicable. 8. The form of Notice of the Recognition Hearing and Plan Implementation Motion Notice" Hearing attached hereto as Exhibit C (the "Chapter 15 Notice") is hereby approved. 9. Petitioner shall serve copies of the Chapter 15 Notice upon the Notice Parties (as defined in the Application for Order Scheduling Hearing and Spectfying the Form and Manner of Service of Notice (D.E. #9)) by mail, within three (3) business days of the entry of this Order. 10. If any party files a notice of appearance in this case, Petitioner shall serve the Chapter 15 Notice upon such party within three (3) business days of the filing of such notice of appearance if the Chapter 15 Notice has not already been served on such party (or its counsel). 11. Service of the Chapter 15 Notice in accordance herewith is hereby approved as adequate and sufficient notice and service of the Chapter 15 Notice on all interested parties. 12. This Stipulation may be executed in counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same. 13. The undersigned represent and warrant that they have full authority to execute this Stipulation on behalf of their respective Party or client and have obtained all necessary approvals. 14. This Stipulation shall be binding on the Parties from the date of its execution, but is expressly subject to and contingent upon its approval by the Court. If the Court does not approve this Stipulation, this Stipulation shall be null and void. 15. This Stipulation shall constitute the entire agreement by and among the Parties hereto regarding the matters addressed herein. No extrinsic or parol evidence may be used to vary any of the terms herein. All representations, warranties, inducements, and/or statements of 7

9 Pg 8 of 22 intention made by the Parties are embodied in this Stipulation, and no Party hereto relied upon, shall be bound by, or shall be liable for any alleged representation, warranty, inducement, or statement of intention that is not expressly set forth in this Stipulation. 16. No modification, amendment or waiver of any of the terms or provisions of this Stipulation shall bind any Party unless such modification, amendment or waiver is in writing, and has been executed by counsel for the Party against whom such modification, amendment or waiver is sought to be enforced, or the provisions are modified or amended by further Order of this Court. I7. The Parties acknowledge that this Stipulation is the joint work product of all of the Parties, and that, accordingly, in the event of ambiguities in this Stipulation, no inferences shall be drawn against any Party on the basis of authorship of this Stipulation. 18. This Stipulation shall be governed by and construed in accordance with the Bankruptcy Code and the laws of the state of New York without regard to the conflict of laws principles thereof. This Court shall retain exclusive jurisdiction over any and all disputes arising out of or otherwise relating to this Stipulation. 19. In light of the terms of this Stipulation, Petitioner will not pursue the Application for Provisional Relief, and no hearing will be scheduled on that Application. 8

10 Pg 9 of 22 Dated: February, 2018 SCHNADER HARRISON SEGAL GREENBERG TRAURIG, LLP & LEWIS LLP By: /s/ Mark D. Bloom By: Maria J. DiConza Kenneth R. Puhala James W. Perkins Theodore L. Hecht Anne C. Reddy 140 Broadway, Suite 3100 Elizabeth J. Sullivan New York, NY Park Avenue Phone: (212) New York, New York Fax: (212) Telephone: (212) kpuhala@schnader.com Facsimile: (212) thecht@schnader.com diconzam@gtlaw.com perkinsj@gtlaw.com Richard A. Barkasy (Pro Hac Vice) reddya@gtlaw.com Daniel M. Pereira (Pro Hac Vice) sullivanel@gtlaw.com Schnader Harrison Segal & Lewis LLP 1600 Market Street, Suite 3600 Mark D. Bloom (Pro Hac Vice) Philadelphia, PA Greenberg Traurig, P.A. Telephone: (215) Avenue of the Americas Facsimile: (215) Miami, FL rbarkasy@schnader.com Telephone: (305) dpereira@schnader.com Facsimile: (305) bloomm@gtlaw.com Counsel for Jastiro Abi, as Foreign Representative Counsel for Universal Investment Advisory SA, Universal Absolute Return SP, Vaquero Master EM Credit Fund, Ltd., Harshil Kantilal Kothari, Footbridge Capital, LLC and Growth Credit Fund IC - and - STONE & MAGNANINI LLP David S. Stone Julio C. Gomez 100 Connell Drive, Suite 2200 Berkeley Heights, New Jersey Telephone: (973) Facsimile: (973) DStone@stonemagnalaw.com JGomez@stonemagnalaw.com Counsel for Universal Investment Advisory SA and Universal Absolute Return SP 9

11 Pg 10 of 22 APPROVED AND SO ORDERED: This 28th day of February 2018 /s/ Sean H. Lane HONORABLE SEAN H. LANE UNITED STATES BANKRUPTCY JUDGE 10

12 Pg 11 of 22 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: COMMERCIAL DIVISION x NIEEl SÃL iñ ES 1 ÑNT ÃDÏIËOÏ Ÿ bã UNIVERSAL ABSOLUTE RETURN SP; VAQUERO : MASTER EM CREDIT FUND LTD; HARSHIL KANTILAL: Index No /2014 KOTHARI,' KOTHARI; FOOTBRIDGE CAPITAL, LLC; GROWTH : CREDIT FUND IC, : (Hon. Saliann Scarpulla) Plaintiffs, v. STIPULATION AND ORDER REGARDING ENTRY OF JUDGMENT BAKRIE TELECOM PTE, LTD; PT BAKRIE TELECOM TBK; PT BAKRIE NETWORK; PT BAKRIE : CONNECTIVITY, PT BAKRIE & BROTHERS TBK, : ANINDYA NOVYAN BAKRIE, FREDERIK JOHANNES : MEIJER, MUHAMMAD xvxvs msvuvmu BULDANSYAH, JULIANDUS v uaanswuu o An : LUMBAN TOBING, RAKHMAT JUNAIDI, JASTIRO ABI, : GAFUR SULISTYO UMAR, Al MULYADI MAMOER, : RAJSEKAR KUPPUSWAMI MITTA, NALINKANT A : RATHOD, AMBONO JANURIANTO, :. Defendants, x WHEREAS, pursuant to an Indenture dated May 7, 2010 and a Supplemental Indenture "Indenture" dated January 27, 2011 (collectively, "Indenture"), Defendant Bakrie Telecom Pte, Ltd. (" Issuer" (" Notes" ("Issuer") issued $380 million of guaranteed senior notes, due on May 7, 2015 ("Notes"); Debtor" WHEREAS, Defendants PT Bakrie Telecom Tbk (the "Foreign Debtor"), PT Bakrie Network and PT Bakrie Connectivity ("Guarantors" and, together with the Issuer, "Issuer and Defendants" Guarantor Defendants") issued Guarantees irrevocably and unconditionally guaranteeing payment of the Issuer's obligations under the Notes; WHEREAS, Plaintiffs alleged herein that they are holders of more than 25% of the outstanding $380 million in Notes; WHEREAS, Plaintiffs alleged herein that the Issuer and Guarantor Defendants defaulted on their payment obligations under the Notes, Indenture and Guarantees; EXHIBIT A

13 Pg 12 of 22 WHEREAS, on July 27, 2015, Plaintiffs moved for summary judgment on the First Cause of Action of their Second Amended Complaint for breach of the Notes, Indenture and (" Action" Guarantees due to non-payment ("First Cause of Action"); WHEREAS, after due deliberation, the Court (Honorable Saliann Scarpulla, IAS Part 39) entered a Decision and Order dated April 18, 2016, entered by the New York County Court Clerk on Order" April 22, 2016 (the "Decision and Order"), that, inter alia, granted Plaintiffs' motion establishing liability on the First Cause of Action against the Issuer and Guarantor Defendants and in favor of Plaintiffs; WHEREAS, on June 17, 2016, Plaintiffs moved for an order and judgment fixing damages on the First Cause of Action, or, in the alternative, for an order of reference pursuant to CPLR Rule 3212(c) and/or 4317(b) to hear and determine the damages amount (the "Judgment Motion" Motion"); WHEREAS, by Decision and Order entered August 29, 2017, after due deliberation, the Supreme Court, Appellate Division, First Department affirmed the Decision and Order of this Court as to the First Cause of Action; WHEREAS, this Court heard argument on the Judgment Motion on October 4, 2017 and it is now sub judice; WHEREAS, on January 29, 2018, the Foreign Debtor filed in the United States Bankruptcy Court for the Southern District of New York the Verified Petition of Jastiro Abi, as Foreign Representative of the Debtor in a Foreign Proceeding, for (I) Recognition of Foreign Q' Main Proceeding Pursuant to 11 U.S.C and 1517 and (II) Relief Pursuant to 11 U.S.C. (" Case" 1520 and 1521 filed on January 29, 2018 (Case No shl) ("Chapter 15 Case"); 2

14 Pg 13 of 22 WHEREAS, as part of the Chapter 15 Case, the Plaintiffs and the Foreign Debtor stipulated and the Bankruptcy Court So Ordered the Stipulation And Order (i) Scheduling Combined Hearing On Petition For Recognition And Relief (ii) Fixing Discovery And Briefing Deadlines, And (iii) Specifying Form And Manner Of Service Of Notice (the "Chapter 15 Stipulation" Stipulation"), in which the Foreign Debtor agreed, subject to the terms of the Chapter 15 Stipulation, to the entry of judgment herein in the form attached as Exhibit A. NOW, THEREFORE, IT IS hereby STIPULATED AND AGREED by counsel for the Plaintiffs and the Issuer and Guarantor Defendants that: 1. The Judgment Motion shall be granted as provided in and in the amounts set forth in Exhibit A hereto; 2. The New York County Clerk is directed to enter and docket judgment in the form attached hereto as Exhibit A; and 3. Plaintiffs will take no steps to execute upon or otherwise enforce collection of the judgment, and the parties hereto shall not pursue any pending or additional discovery or other proceedings in this Court until such time as any one or more Orders are entered by the United States Bankruptcy Court for the Southern Debtor' District of New York (a) denying (i) recognition of the Foreign Debtor's Proceeding" Indonesian PKPU proceeding (the "Indonesian Proceeding"), or (ii) enforcement of the restructuring plan approved in the Indonesian Proceeding within the territorial jurisdiction of the United States, or (iii) relief for the benefit and protection of any Defendants in this action other than the Foreign Debtor, but further proceedings shall be permitted only to the extent such relief for the Defendants other than the Foreign Debtor has been denied as provided in an 3

15 Pg 14 of 22 order or decision by the United States Bankruptcy Court for the Southern District ofnew York, or (b) dismissing the Chapter 15 Case. Dated: New York, New York February3 1, 2018 Respectfully submitted, GREENBERGp At mig I r? ) SCHNADER HARRISON SEGAL & LEWIS LLP C.M p.p~ James W. Perkins Kenneth R. Puhala Anne C, Reddy Theodore L. Hecht MetLife Building 140 Broadway, Suite Park Avenue New York, New York New York, NY Phone: (212) Telephone: (212) Fax: (212) Facsimile: (212) kpuhala@schnader.com perkinsj@gtlaw.com thecht@schnader.com reddya@gtlaw.com Counsel for Defendants Bakrie Telecom Pte, Counsel for Plaintiffs Universal Investment Advisory SA, Universal Ltd., PT Bakrie Telecom Tbk, PT Bakrte Network and PT Bakrie Connectivity Absolute Return SP, Vaquero Master EM Credit Fund, Ltd., Harshil Kantilal Kothari, Footbridge Capital, LLC and Growth Credit Fund IC - and - STONE & MAGNANINI LLP David S. Stone Julio C. Gomez 100 Connell Drive, Suite 2200 Berkeley Heights, New Jersey Telephone: (973) Facsimile: (973) DStone@stonemagnalaw.com JGomez@stonemagnalaw.com Counsel for PlaintifTs Universal Investment Advisory SA and Universal Absolute Retum SP 4

16 Pg 15 of 22 EXHIBIT A

17 Pg 16 of 22 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK: COMMERCIAL DIVISION "x UNIVERSAL INVESTMENT ADVISORY SA; UNIVERSAL ABSOLUTE RETURN SP; VAQUERO MASTER EM CREDIT FUND LTD; HARSHIL KANTILAL: Index No /2014 KOTHARI; FOOTBRIDGE CAPITAL, LLC; GROWTH CREDIT FUND IC, (Hon. Saliann Scarpulla) Plaintiffs, V. [PROPOSED] JUDGMENT BAKRIE TELECOM PTE, LTD; PT BAKRIE TELECOM TBK; PT BAKRIE NETWORK; PT BAKRIE CONNECTIVITY, PT BAKRIE &, BROTHERS TBK, ANINDYA NOVYAN BAKRIE, FREDERIK JOHANNES MEIJER, MUHAMMAD BULDANSYAH, JULIANDUS A: LUMBAN TOBING, RAKHMAT JUNAIDI, JASTIRO ABI,: GAFUR SULISTYO UMAR, AI MULYADI MAMOER, RAJSEKAR KUPPUSWAMI MITTA, NALINKANT A RATHOD, AMBONO JANURIANTO, Defendants. X WHEREAS, pursuant to an Indenture dated May 7, 2010 and a Supplemental Indenture "Indenture" dated January 27, 2011 (collectively, ), Defendant Bakrie Telecom Pte, Ltd. (" Issuer" ) issued $380 million of guaranteed senior notes, due on May 7, 2015 (" Notes" ); WHEREAS, Defendants PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity (" Guarantors" and, together with the Issuer, "Issuer and Guarantor Defendants" ) issued Guarantees irrevocably and unconditionally guaranteeing payment of the Issuer's under obligations the Notes; WHEREAS, Plaintiffs alleged herein that they are holders of more than 25'/o of the outstanding $380 million in Notes; WHEREAS, Plaintiffs alleged herein that the Issuer and Guarantor Defendants defaulted on their payment obligations under the Notes, Indenture and Guarantees;

18 Pg 17 of 22 WHEREAS, on July 27, 2015, Plaintiffs moved for summary judgment on the First Cause of Action of their Second Amended Complaint for breach of the Notes, Indenture and (" Action" Guarantees due to non-payment ("First Cause of Action"); WHEREAS, after due deliberation, the Court (Honorable Saliann Scarpulla, IAS Part 39) entered a Decision and Order dated April 18, 2016, entered by the New York County Court Order" Clerk on April 22, 2016 (the "Decision and Order"), that, inter alia, granted Plaintiffs' motion to the extent of finding liability on the First Cause of Action against the Issuer and Guarantor Defendants and in favor of Plaintiffs; WHEREAS, on June 17, 2016, Plaintiffs moved for an order and judgment fixing damages on the First Cause of Action, or, in the alternative, for an order of reference pursuant to CPLR Rule 3212(c) and/or 4317(b) to hear and determine the damages amount (the "Judgment Motion" Motion"); WHEREAS, by Decision and Order entered August 29, 2017, after due deliberation, the Supreme Court, Appellate Division, First Department affirmed the Decision and Order of this Court as to the First Cause of Action; WHEREAS, this Court heard argument on the Judgment Motion on October 4, 2017 and that Motion is currently under submission to the Court; WHEREAS, pursuant to the terms of a Stipulation and Order Regarding Entry of Judgment, the Issuer and Guarantor Defendants have agreed to permit the entry of judgment against each of them on the First Cause of Action in the amounts and on the terms set forth below; WHEREAS, pre-judgment interest continues to accrue from February 15, 2018 through the date of entry of judgment at the following rates: $24, per diem in favor of Plaintiff 2

19 Pg 18 of 22 Universal Investment Advisory SA; $1, per diem in favor of Plaintiff Universal Absolute Return SP; $2, per diem in favor of Plaintiff Vaquero Master EM Credit Fund Ltd.; $71.57 per diem in favor of Harshil Kantilal Kothari; $1, per diem in favor of Plaintiff Footbridge Capital LLC; and $ per diem in favor of Plaintiff Growth Credit Fund IC; NOW, THEREFORE, it is ADJUDGED that Plaintiffs have judgment against Bakrie Telecom Pte, Ltd., PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity as follows: 1. It is ADJUDGED that Plaintiff Universal Investment Advisory SA has judgment against Bakrie Telecom Pte, Ltd., PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity jointly and severally in the amount of $132,265,082.22, inclusive of contractual and statutory pre-judgment interest through February 15, 2018, plus $ in additional pre-judgment interest for a total amount of $ : 2. It is ADJUDGED that Plaintiff Universal Absolute Return SP has judgment against Bakrie Telecom Pte, Ltd., PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity jointly and severally in the amount of $6,238,201.28, inclusive of contractual and statutory pre-judgment interest through February 15, 2018, plus $ in additional pre-judgment interest for a total amount of $ ; 3. It is ADJUDGED that Plaintiff Vaquero Master EM Credit Fund Ltd. has judgment against Bakrie Telecom Pte, Ltd., PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity jointly and severally in the amount of $14,230,706.48, inclusive of contractual and statutory pre-judgment interest 3

20 Pg 19 of 22 through February 15, 2018, plus $ in additional pre-judgment interest for a total amount of $ ; 4. It is ADJUDGED that Plaintiff Harshil Kantilal Kothari has judgment against Bakrie Telecom Pte, Ltd., PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity jointly and severally in the amount of $380,378.12, inclusive of contractual and statutory pre-judgment interest through February 15, 2018, plus $ in additional pre-judgment interest for a total amount of $ 5. It is ADJUDGED that Plaintiff Footbridge Capital LLC has judgment against Bakrie Telecom Pte, Ltd., PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity jointly and severally in the amount of $6, , inclusive of contractual and statutory pre-judgment interest through February 15, 2018, plus $ in additional pre-judgment interest for a total amount of $ 6. It is ADJUDGED that Plaintiff Growth Credit Fund IC has judgment against Bakrie Telecom Pte, Ltd., PT Bakrie Telecom Tbk, PT Bakrie Network and PT Bakrie Connectivity jointly and severally in the amount of $1,141,134.38, inclusive of contractual and statutory pre-judgment interest through February 15, 2018, plus $ in additional pre-judgment interest for a total amount of $. Judgment signed and entered on this dayday of February CLERK 4

21 Pg 20 of 22 Kenneth R. Puhala Theodore L. Hecht SCHNADER HARRISON SEGAL & LEWIS LLP 140 Broadway, Suite 3100 New York, NY Phone: (212) Fax: (212) Attorneys for Jastiro Abi, as Foreign Representative IN TIIE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF NEW YORK X â â â â â â â â â â â â â â â â â â â â â â â â â â In re: : Chapter 15 PT BAKRIE TELECOM TBK, : Case No shl Debtor in a Foreign Proceeding. : X : X NOTICE OF FILING AND HEARING UNDER CHAPTER 15 OF THE UNITED STATES BANKRUPTCY CODE PLEASE TAKE NOTICE, on January 29, 2018, Jastiro Abi, the duly authorized foreign representative (the "Foreign Representative") of the above-captioned debtor in a foreign proceeding (the "Foreign Debtor") commenced in the Central Jakarta Commercial Court (the Court" "Indonesian Court") pursuant to Law No. 37 of 2004 on Bankruptcy and Suspension of Debt Payment Obligations (the "Indonesian Proceeding"), filed a petition for relief under Chapter 15 Code" of title 11 of the United States Code (the "Bankruptcy Code") and the Verified Petition of Jastiro Abi, as Foreign Representative of the Debtor in a Foreign Proceeding, for (I) Recognition of Foreign Main Proceeding Pursuant to 11 U.S.C and 1517 and (II) Relief Pursuant to 11 "Petition" U.S.C and 1521 (collectively, the "Petition") in the United States Bankruptcy Court for Court" the Southern District of New York (the "Bankruptcy Court"). In addition, the Foreign Debtor shall be filing on or before March 30, 2018, a motion seeking enforcement of the restructuring plan approved by the Indonesian Court in the Indonesian Proceeding (the "Plan Implementation Motion" Motion"). PLEASE TAKE FURTHER NOTICE, that the Bankruptcy Court has scheduled a hearing on, 2018 at a.m. / p.m. (Prevailing Eastern Time) before the Honorable Sean H. Lane in Courtroom 701 of the United States Bankruptcy Court for the Southern District of New York, One Bowling Green, New York, New York to consider (a) approval of the Petition and granting the relief requested therein; and (b) the Plan Implementation Motion (the "H~tearin ").

22 Pg 21 of 22 PLEASE TAKE FURTHER NOTICE, that any party in interest wishing to submit a response or objection to the Petition, the Plan Implementation Motion or the relief requested by the Foreign Representative therein must do so in accordance with the Bankruptcy Code and the Local and Federal Rules of Bankruptcy Procedure in writing and setting forth the bases therefore with specificity and the nature and extent of the respondent's interests in the Foreign Debtor's estates. Such response or objection must be filed with the Office of the Clerk of the Court, One Bowling Green, New York, New York , and served upon Schnader Harrison Segal & Lewis LLP, 140 Broadway, Suite 3100, New York, NY (Attn: Kenneth R. Puhala), and the Office of the United States Trustee, 201 Varick Street, Suite 1006, New York, NY so as to be actually received by them no later than 4:00 p.m. (Prevailing Eastern Time), on May 25, PLEASE TAKE FURTHER NOTICE, that the Foreign Representative's reply, if any, to any responses or objections to the Petition, the Plan Implementation Motion or the relief requested therein, shall be filed and served by 4:00 p.m. (Prevailing Eastern Time), on June 8, PLEASE TAKE FURTHER NOTICE, that all parties in interest opposed to the Petition, the Plan Implementation Motion or the request for relief contained therein must appear at the Hearing at the time and place set forth above. PLEASE TAKE FURTHER NOTICE, that the Hearing may be adjourned from time to time without further notice other than an announcement in open court of the adjourned date or dates or any further adjourned hearing. PLEASE TAKE FURTHER NOTICE, that if no response or objection is timely filed and served as provided above, the Bankruptcy Court may grant the relief requested by the Foreign Representative without further notice or hearing. Copies of the Petition, the Plan Implementation Motion and the documents supporting same will be made available upon request made to Kenneth R. Puhala, Schnader Harrison Segal & Lewis LLP, 140 Broadway, Suite 3100, New York, NY Telephone: , kpuhala@schnader.com. 2

23 shi Doc 33 Filed 02/28/18 Entered 02/28/18 12:59:13 Main Document Pg 22 of 22 SCHNADER HARRISON SEGAL & LEWIS LLP By: /s/ Kenneth R. Puhala Kenneth R. Puhala Theodore L. Hecht 140 Broadway, Suite 3100 New York, NY Phone: (212) Fax: (212) and - Richard A. Barkasy (admitted pro hac vice) Daniel M. Pereira (admitted pro hac vice) 1600 Market Street, Suite 3600 Philadelphia, PA Phone: (215) Fax: (215) rbarkasy@schnader.com dpereira@schnader.com Attorneys for Jastiro Abi Dated: February, 2018 as Foreign Representative 3

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