Hearing Date: February 7, 2018 at 9:30 a.m. (Atlantic Standard Time)

IN THE UNITED STATES DISTRICT COURT 

FOR THE 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 

(Jointly Administered) 

RESERVATION OF RIGHTS OF THE AD HOC GROUP OF GENERAL OBLIGATION 

BONDHOLDERS AS TO THE DEBTORS’ MOTION FOR ORDER (A) ESTABLISHING 

DEADLINES AND PROCEDURES FOR FILING PROOFS OF CLAIM AND 

(B) APPROVING FORM AND MANNER OF NOTICE THEREOF 

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 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 (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); and (v) Puerto Rico Electric 

Power Authority (“PREPA”) (Bankruptcy Case No. 17 BK 04780-LTS) (Last Four Digits of 

Federal Tax ID: 3747) (Title III case numbers are listed as Bankruptcy Case numbers due to 

software limitations). 

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The Ad Hoc Group of General Obligation Bondholders (the “GO Group”) respectfully 

submits this Reservation of Rights as to the Debtors’ Motion for Order (A) Establishing 

Deadlines and Procedures for Filing Proofs of Claim and (B) Approving Form and Manner of 

Notice Thereof (Dkt. 2255, the “Motion”).2 In support of its Reservation of Rights, the GO 

Group states as follows: 

1. On January 16, 2018, the Debtors filed the Motion. The objection deadline was 

originally set for January 23, 2018 at 4:00 p.m. (Atlantic Standard Time). Pursuant to an 

agreement between the GO Group and the Debtors, the objection deadline for the GO Group was 

extended to January 25, 2018 at 6:00 p.m. (Atlantic Standard Time). 

2. The GO Group had concerns with respect to certain provisions of the Proposed 

Order that accompanied the Motion. To address those concerns, the GO Group has engaged in 

negotiations with the Debtors that have culminated in an agreement with respect to certain 

modifications to the Proposed Order. The GO Group understands that the Debtors intend to file 

a revised Proposed Order that will incorporate these agreed-upon modifications (the “Revised 

Proposed Order”). The GO Group submits this reservation of rights to preserve the GO Group’s 

right to object to the Motion in the event that the Revised Proposed Order does not correspond to 

the agreement between the GO Group and the Debtors. 

[Remainder of page intentionally left blank.] 

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 The GO Group submits this Limited Objection exclusively on its own behalf and does not 

assume any fiduciary or other duties to any other creditor or person. 

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Dated: January 25, 2018 

/s/ Ramón Rivera Morales 

J. Ramón Rivera Morales 

USDC-PR Bar No. 200701 

JIMÉNEZ, GRAFFAM & LAUSELL

P.O. Box 366104 

San Juan, PR 00936 

Telephone: (787) 767-1030 

Facsimile: (787) 751-4068 

Email: rrivera@jgl.com 

Respectfully submitted, 

/s/ Mark T. Stancil 

Lawrence S. Robbins (admitted pro hac vice) 

Mark T. Stancil (admitted pro hac vice) 

Gary A. Orseck (admitted pro hac vice) 

Ariel N. Lavinbuk (admitted pro hac vice) 

Donald Burke (admitted pro hac vice) 

ROBBINS, RUSSELL, ENGLERT, ORSECK,

UNTEREINER & SAUBER LLP 

1801 K Street, N.W., Suite 411-L 

Washington, DC 20006 

Telephone: (202) 775-4500 

Facsimile: (202) 775-4510 

Email: mstancil@robbinsrussell.com 

/s/ Andrew N. Rosenberg 

Andrew N. Rosenberg (admitted pro hac vice) 

Richard A. Rosen (admitted pro hac vice) 

Walter Rieman (admitted pro hac vice) 

Kyle J. Kimpler (admitted pro hac vice) 

Karen R. Zeituni (admitted pro hac vice) 

PAUL, WEISS, RIFKIND, WHARTON 

& GARRISON LLP 

1285 Avenue of the Americas 

New York, NY 10019 

Telephone: (212) 373-3000 

Facsimile: (212) 757-3990 

Email: arosenberg@paulweiss.com 

Counsel to the Ad Hoc Group of General Obligation Bondholders 

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