UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO 

----------------------------------------------------------x 

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) 

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SUPPLEMENTAL DECLARATION OF KIRK BLAIR REGARDING DISCLOSURES 

OF DELOITTE FINANCIAL ADVISORY SERVICES LLP AND 

DELOITTE CONSULTING LLP 

I, Kirk Blair, declare as follows: 

1. I am a partner of the firm of Deloitte Financial Advisory Services LLP 

(“Deloitte FAS”), which has an office at 110 Morris Street, Morristown, New Jersey. I am duly 

authorized to make and submit this supplemental declaration (the “Declaration”) to supplement 

the disclosures contained in the declarations I previously submitted to the Court in connection with 

the respective retentions of Deloitte FAS and Deloitte Consulting LLP (“Deloitte Consulting”) 

1 The debtors in the jointly-administered Title III cases, along with each debtor’s respective Title III case number 

listed as a bankruptcy case number due to software limitations 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); (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”) 

(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). 

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(see Docket Nos. 21243 and 22831). Capitalized terms used but not defined herein shall have the 

meanings ascribed to those terms in such declarations. 

2. Accordingly, by this Declaration, I am updating the disclosure made in 

paragraph 10(i) of the declaration filed on June 28, 2022 by amending and restating it, as follows: 

a. In May of 2019, each of Deloitte FAS and Deloitte & Touche LLP entered into 

an agreement with the Financial and Oversight Management Board of Puerto 

Rico (the “FOMB”) and the Official Committee of Unsecured Creditors of the 

Puerto Rico Title III Debtors (the “UCC”), at their request, which tolled the 

running of time with respect to any statute of limitation, statute of repose or 

other time-based limitation or defense regarding potential claims against these 

Deloitte US Entities. The Deloitte US Entities understand that the potential 

claims, if any, relate to services performed for the Commonwealth of Puerto 

Rico prior to the commencement of these Title III cases. These tolling 

agreements have been extended from time to time by agreement with the FOMB 

and the UCC and no suit in respect of any claims has been commenced against 

Deloitte FAS or Deloitte & Touche. Subsequent to the date of the Initial 

Declaration, the Trustee of the Commonwealth Avoidance Actions Trust (the 

“Trustee”) requested to set a date for a mediation regarding potential claims, if 

any, against Deloitte FAS arising from pre-Title III services and the mediation 

was scheduled for January of 2023. Just prior to the commencement of this 

mediation, Deloitte FAS and the Trustee agreed to a settlement in principle with 

respect to certain alleged claims, subject to the execution of a mutually 

acceptable agreement memorializing the resolution of the matter. 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true 

and correct. 

Dated: January 25, 2023 

By: 

 Kirk Blair 

 Partner 

 Deloitte Financial Advisory Services LLP 

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I HEREBY CERTIFY that on this same date, I electronically filed the foregoing with the 

Clerk of Court using the CM/ECF system, which will send notification of such filing to 

all CM/ECF participants in this case. 

Dated: January 25, 2023 Respectfully submitted, 

San Juan, Puerto Rico 

/s/Alexandra Casellas-Cabrera 

Alexandra Casellas-Cabrera 

USDC-PR No. 301010 

ADSUAR MUÑIZ GOYCO 

SEDA & PÉREZ-OCHOA, P.S.C. 

P.O. Box 70294 

San Juan, PR 00936-8294 

Tel: 787-756-9000 

Fax: 787-756-9010 

Email: acasellas@amgprlaw.com 

and 

LOEB & LOEB LLP 

Daniel B. Besikof 

345 Park Avenue 

New York, New York 10154 

Tel: (212) 407-4000 

Fax: (212) 407-4990 

Email: dbesikof@loeb.com 

Attorneys for Deloitte Consulting LLP and Deloitte 

Financial Advisory Services LLP 

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