From the motion to Intervene by the 2020 Bondolders (represented by Blackrock Investments):
" The Court should also exercise its discretion to stay execution on its August 23, 2018 judgment without bond until the Third Circuit decides PDVSA’s appeal. Because the shares of PDVH have already been attached, they can be promptly utilized to satisfy the judgment if Crystallex prevails on appeal. In contrast, execution at this time will irreversibly harm the Bondholders and other PDVSA creditors. In these circumstances, a stay without bond is the appropriate course. In re Revel AC, Inc., 802 F.3d 558, 565 (3d Cir. 2015); Dillon v. City of Chicago, 866 F.2d 902, 904 (7th Cir. 1988). That approach is especially warranted here given PDVSA’s likelihood of success on appeal."