UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO, 

as representative of

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors.

1

PROMESA 

Title III 

No. 17 BK 3283-LTS 

Re: ECF Nos. 20458, 20467, 21902, 

21982

(Jointly Administered)

SUPPLEMENT TO DECLARATION OF EDUARDO M. INCLÁN PIETRANTONI IN 

ACCORDANCE WITH THE PUERTO RICO RECOVERY ACCURACY IN DISCLOSURES 

ACT AND RESPONSE TO ORDER TO SHOW CAUSE [ECF NO. 21902]

I, Eduardo M. Inclán Pietrantoni, under penalty of perjury, declare as follows:

1. I am a Managing Director of Bluhaus Capital, LLC (“Bluhaus”), a Puerto Rico-based advisory and 

investment management firm. Bluhaus provides consulting services to the Puerto Rico Fiscal 

Agency and Financial Authority (“AAFAF”), which is the sole entity authorized to act on behalf 

of Puerto Rico government entities, by virtue of Act 2-2017. Bluhaus has provided such services 

to AAFAF, under separate contracts, since February 2017 in matters not related to the Title III 

cases. From time to time, Bluhaus, acting at AAFAF’s instructions, supports other governmental 

instrumentalities, agencies, and elected officials, officers, or employees of the Commonwealth or 

other governmental instrumentalities or agencies in their official capacity. Additionally, in the past, 

since 2018, Bluhaus has supported other governmental entities under separate contracts, including 

the Puerto Rico Highways and Transportation Authority, the Puerto Rico Industrial Development 

Company and the Governing Board of the University of Puerto Rico, in matters not related to the 

Title III cases. 

1 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number and the last four 

(4) digits of each Debtor’s federal tax identification number, as applicable, are the (i) Commonwealth of Puerto 

Rico (“Commonwealth”) (Bankruptcy Case No. 17-BK-3283- LTS) (Last Four Digits of Federal Tax ID: 3481); 

(ii) Puerto Rico Sales Tax Financing Corporation (“COFINA”) (Bankruptcy Case No. 17-BK-3284-LTS) (Last 

Four Digits of Federal Tax ID: 8474); (iii) Puerto Rico Highways and Transportation Authority (“HTA”) 

(Bankruptcy Case No. 17-BK-3567-LTS) (Last Four Digits of Federal Tax ID: 3808); (iv) Employees Retirement 

System of the Government of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17-BK-3566-

LTS) (Last Four Digits of Federal Tax ID: 9686); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17- BK-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) Puerto Rico Public 

Buildings Authority (“PBA” and together with the Commonwealth, COFINA, HTA, ERS, and PREPA, the 

“Debtors”) (Bankruptcy Case No. 19-BK-5523-LTS) (Last Four Digits of Federal Tax ID: 3801) (Title III case 

numbers are listed as Bankruptcy Case numbers due to software limitations).

Case:17-03283-LTS Doc#:22685 Filed:10/25/22 Entered:10/25/22 17:23:28 Desc: Main

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2. I submit this supplement (the “Supplement”) to the declaration (the “Declaration”, ECF No. 21982) 

I made in accordance with the Puerto Rico Recovery Accuracy in Disclosures Act, Pub. L. No. 

117-82, 48 U.S.C. § 2178(c) (“PRRADA”) and rule 2014(a) of the Federal Rules of Bankruptcy 

Procedure to make certain additional disclosures contained herein. Unless otherwise stated in this 

Supplement and the Declaration, I have personal knowledge of the facts set forth herein and, if 

called as a witness, I would testify thereto.

3. I submit this Supplement to address and provide answers to certain questions raised by the United 

States Trustee, specifically, whether any entity on Schedule I of the Declaration exceeded 2% of 

Bluhaus’ gross revenue during any year of Bluhaus’ representation of the AAFAF.

4. As set forth in Schedule I of the Declaration, Bluhaus disclosed that HTA was a former client. 

Consistent with that disclosure and to supplement the same, Bluhaus further discloses that HTA’s 

engagement represented approximately 19% of Bluhaus’ gross revenues in 2018 and 17% of 

Bluhaus’ gross revenues in 2019. 

5. Finally, I reiterate that, to the best of my knowledge, Bluhaus does not represent and will not 

represent any entity, including AAFAF (or, through AAFAF, certain government entities and 

individuals in their official capacity as members of the government of Puerto Rico), in matters 

related to these Title III cases. Furthermore, to the best of my knowledge, I believe that Bluhaus: 

(i) is a “disinterested person”, as that term is defined in section 101(14) of the Bankruptcy Code, 

relative to any entity or person on the Amended MIP List, and (ii) does not represent or hold an 

adverse interest in connection with the Title III cases.

6. Bluhaus reserves all rights to amend and/or supplement its disclosures contained herein. If 

additional MIPs are provided to Bluhaus and any new material relevant facts or relationships are 

discovered or identified, Bluhaus will promptly file additional supplemental declarations.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that, to the best of my knowledge and after 

reasonable inquiry, the foregoing is true and correct.

Executed on October 25, 2022

/s/________________________

Eduardo M. Inclán Pietrantoni

Case:17-03283-LTS Doc#:22685 Filed:10/25/22 Entered:10/25/22 17:23:28 Desc: Main

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