Case KG Doc Filed 04/17/15 Page 1 of 8 EXHIBIT A. Joint Stipulation of Facts

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1 Case KG Doc Filed 04/17/15 Page 1 of 8 EXHIBIT A Joint Stipulation of Facts

2 Case KG Doc Filed 04/17/15 Page 2 of 8 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE x In re TRUMP ENTERTAINMENT RESORTS, INC., et al., 1 Debtors x Chapter 11 Case No (KG) Jointly Administered Ref. Docket No. 251 JOINT STIPULATION OF FACTS Trump Entertainment Resorts, Inc. and its above-captioned affiliated debtors and debtors in possession (collectively, the Debtors ), and UNITE HERE Local 54 (the Union ), by and through their undersigned counsel, stipulate (the Joint Stipulation ) to the following facts for the purposes of the hearing (the Hearing ) on Debtors Motion, Pursuant to Sections 105 and 362 of the Bankruptcy Code, for Entry of an Order, (I) Enforcing the Automatic Stay Against UNITE HERE Local 54, (II) Requiring UNITE HERE Local 54 to Issue a Letter Informing All Parties that Received Union Communications Regarding the Chapter 11 Cases that Such Communications Were Misleading and in Violation of the Automatic Stay, (III) Requiring UNITE HERE Local 54 to Provide the Debtors with a List of All Parties It Previously Distributed the Misleading Communications to, and (IV) Awarding the Debtors Attorneys Fees and Expenses for UNITE HERE Local 54 s Willful Violation of the Automatic Stay [D.I. 251] (the Motion ) The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are Trump Entertainment Resorts, Inc. (8402), Trump Entertainment Resorts Holdings, L.P. (8407), Trump Plaza Associates, LLC (1643), Trump Marina Associates, LLC (8426), Trump Taj Mahal Associates, LLC (6368), Trump Entertainment Resorts Development Company, LLC (2230), TER Development Co., LLC (0425) and TERH LP Inc. (1184). The mailing address for each of the Debtors is 1000 Boardwalk at Virginia Avenue, Atlantic City, NJ

3 Case KG Doc Filed 04/17/15 Page 3 of 8 The parties have agreed to rely upon this Joint Stipulation in lieu of presenting witnesses at the Hearing. The parties also stipulate to the authentication of each document produced by the Union to the Debtors in connection with discovery relating to the Motion, but reserve their respective rights to object to the relevance of such documents and the following stipulated facts, and to object to the entry of any documents on the grounds that they are being offered into evidence for an inadmissible hearsay purpose. The parties have further agreed, subject to the approval of the Court, that the scope of the Hearing shall be limited to the following issues (i) whether the Union has violated the automatic stay of section 362 of the Bankruptcy Code, (ii), if so, whether federal labor law and/or the First Amendment preclude the Court from remedying such violation(s), and (iii) whether Section 362 is unconstitutionally overbroad, discriminatory or vague if it prohibits the Union s conduct. The issues concerning damages and any other relief requested in the Motion shall be reserved. Stipulations of Fact 2 1. On September 9, 2014 (the Petition Date ), the Debtors each filed a voluntary petition in the Court for relief under chapter 11 of the Bankruptcy Code, thereby commencing the above-captioned chapter 11 cases (collectively, the Chapter 11 Cases ). 2. The Union knew, as of the Petition Date, that the Debtors Chapter 11 Cases had commenced. 3. On September 17, 2014, the Debtors made a proposal to the Union (as subsequently amended, the Proposal ) regarding changes to the prepetition collective bargaining agreement between debtor Trump Taj Mahal Associates, LLC and the Union (the 2 Capitalized terms used but not otherwise defined in this Joint Stipulation shall have the meanings ascribed to them in the Motion

4 Case KG Doc Filed 04/17/15 Page 4 of 8 CBA ) that would have resulted in significant and immediate pension, healthcare, and other financial concessions from the Union. The Union rejected the Proposal. 4. On September 26, 2014, the Debtors filed their 1113 Motion [D.I. 134], which sought authorization to reject the CBA and unilaterally implement the Proposal, over the Union s objection. 5. The Union opposed the 1113 Motion, which was the subject of an evidentiary hearing before the Court on October 2 and 14, Following the hearing, the Court granted the 1113 Motion by order dated October 17, 2014 [D.I. 318] (the 1113 Order ), for the reasons set forth in an opinion dated October 24, 2014 [D.I. 325] (the 1113 Opinion ). The 1113 Order authorized the rejection of the CBA nunc pro tunc to September 26, 2014, and authorized the Debtors to implement the terms and conditions of the Proposal. 7. By its terms, the 1113 Order was immediately effective and enforceable upon its entry. The Union timely appealed the 1113 Order and 1113 Opinion, which appeal is currently pending before the Third Circuit Court of Appeals. During the October 17, 2014 telephonic hearing, the Union orally moved for stay of effectiveness of the 1113 Order pending appeal, which motion was denied on the record. 8. Beginning on or about September 26, 2014, the Union attempted to contact possible customers of the Taj Mahal to discuss the labor dispute between the Debtors and the Union and to urge them to boycott the Taj Mahal. The Union continued to do so following entry of the 1113 Order on October 17,

5 Case KG Doc Filed 04/17/15 Page 5 of 8 9. Subsequent to the Petition Date, the Union organized a phone bank to call possible customers of the Taj Mahal to inform them of the labor dispute between the Union and the Debtors and to urge them to boycott the Taj Mahal. 10. The Union s phone bank was implemented and its participants made calls to possible customers of the Taj Mahal during which such persons were informed of the labor dispute and urged to boycott the Taj Mahal. The phone bank continued to operate after entry of the 1113 Order on October 17, Beginning on or about September 26, 2014, Kaitlyn Schechter and Ben Begleiter ed or sent the Union Letter and other communications about the labor dispute to persons the Union believed were sponsors or organizers of conventions or meetings that have booked group accommodations at the Taj Mahal ( Convention or Group Clients ) or Convention Attendees. Ms. Schecter and Mr. Begleiter continued to do so following entry of the 1113 Order on October 17, Kaitlyn Schechter and Ben Begleiter were acting on behalf of the Union when they sent the Union Letter and other communications about the labor dispute to persons the Union believed to be Convention or Group Clients or Convention Attendees. 13. Kaitlyn Schechter and Ben Begleiter were authorized by the Union to send the Union Letter and other communications about the labor dispute to persons the Union believed to be Convention or Group Clients or Convention Attendees. 14. The Union instructed its representatives to send Union Letters to persons it believed to be Convention or Group Clients or Convention Attendees to protest the Debtors attempt to reject the CBA and change the benefits provided to Debtors employees and to strengthen its position in collective bargaining negotiations with the Debtors

6 Case KG Doc Filed 04/17/15 Page 6 of In connection with the Union s communications with persons it believed to be Convention or Group Clients, the Union suggested that Clients examine their respective contracts with the Taj Mahal to see whether the labor dispute was a force majeure that permitted termination of the contracts. The Union continued to do so following entry of the 1113 Order on October 17, The Union provided persons it believed to be Convention or Group Clients with form force majeure language to be included in their contracts with the Debtors. The Union continued to do so following entry of the 1113 Order on October 17, Through the Union Letters and other communications, the Union urged persons it believed to be Convention Attendees to demand that their organizations relocate scheduled events from the Taj Mahal to other properties in Atlantic City at which there was no labor dispute with the Union. The Union continued to do so following entry of the 1113 Order on October 17, One or more of the persons the Union contacted were Convention or Group Clients that had Contracts with the Debtors for conventions or other events at the Taj Mahal. 19. One or more of the persons the Union contacted were Convention Attendees whose organizations had scheduled conventions or other events at the Taj Mahal. 20. One or more of the Convention or Group Clients having Contracts with the Debtors that had been contacted by the Union cancelled their conventions or other events at the Taj Mahal and relocated such conventions or other events to another property

7 Case KG Doc Filed 04/17/15 Page 7 of The Union is still contacting possible customers of the Debtors through phone calls, s and other communications to discuss the labor dispute between the Debtors and the Union and to urge them to boycott the Taj Mahal. Dated April 17, 2015 /s/ Richard G. McCracken Richard G. McCracken Davis, Cowell & Bowe 595 Market Street, Suite 1400 San Francisco, CA (415) (415) (facsimile) McCracken, Stemerman & Holsberry 1630 S. Commerce St. Las Vegas, NV (702) (702) (facsimile) -and- William T. Josem, Esquire Cleary, Josem & Trigiani LLP Constitution Place 325 Chestnut Street, Suite 200 Philadelphia, PA (215) (215) (facsimile) wtjosem@cjtlaw.org -and- Joseph J. Rhoades Stephen T. Morrow Law Offices of Joseph J. Rhoades 1225 King Street, 12th Floor P.O. Box 874 Wilmington, DE (302) (302) (facsimile) Counsel for UNITE HERE Local

8 Case KG Doc Filed 04/17/15 Page 8 of 8 Dated April 17, 2015 YOUNG CONAWAY STARGATT & TAYLOR, LLP /s/ Michael S. Neiburg Matthew B. Lunn (No. 4119) Patrick A. Jackson (No. 4976) Michael S. Neiburg (No. 5275) Rodney Square 1000 North King Street Wilmington, Delaware Telephone (302) Facsimile (302) and- STROOCK & STROOCK & LAVAN LLP Kristopher M. Hansen Erez E. Gilad Gabriel E. Sasson 180 Maiden Lane New York, New York Telephone (212) Facsimile (212) Counsel to the Debtors