IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

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In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO 

 as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al.,

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 Debtors. 

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PROMESA 

Title III 

Case No. 17-bk-3283 (LTS) 

(Jointly Administered) 

NOTICE OF FILING OF SUPPLEMENTAL DECLARATION 

OF JOFF MITCHELL OF ZOLFO COOPER, LLC 

PLEASE TAKE NOTICE that on July 11, 2017 the Official Committee of Unsecured 

Creditors of all title III Debtors (other than PBA and COFINA) (the “Committee”) filed the 

Application of Official Committee of Unsecured Creditors of Commonwealth of Puerto Rico for 

Entry of Order Authorizing Employment and Retention of Zolfo Cooper, LLC as Financial Advisor 

Effective as of June 27, 2017 (the “Application”) [Docket No. 615], and an order was entered by 

the Court approving the Application on August 10, 2017 [Docket No. 1001]. 

 

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 (the “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”) (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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PLEASE TAKE FURTHER NOTICE that on September 14, 2017, the Committee filed 

the Notice of Filing of Supplemental Declaration of Carol Flaton in Furtherance of Application 

of Official Committee of Unsecured Creditors of Commonwealth of Puerto Rico for Entry of Order 

Authorizing Employment and Retention of Zolfo Cooper, LLC as Financial Advisor, Effective as 

of June 27, 2017 (the “Second Supplemental Declaration) [Docket No. 1304]. 

PLEASE TAKE FURTHER NOTICE that on November 14, 2017, the Committee filed 

the Notice of Filing of Supplemental Declaration of Carol Flaton in Furtherance of Application 

of Official Committee of Unsecured Creditors of Commonwealth of Puerto Rico for Entry of Order 

Authorizing Employment and Retention of Zolfo Cooper, LLC as Financial Advisor, Effective as 

of June 27, 2017 (the “Third Supplemental Declaration”) [Docket No. 1769]. 

PLEASE TAKE FURTHER NOTICE that on November 6, 2018, the Committee filed 

the Notice of Filing of Supplemental Declaration of Carol Flaton in Furtherance of Application 

of Official Committee of Unsecured Creditors of Commonwealth of Puerto Rico for Entry of Order 

Authorizing Employment and Retention of Zolfo Cooper, LLC as Financial Advisor, Effective as 

of June 27, 2017 (“Fourth Supplemental Declaration”) [Docket No. 4189]. 

PLEASE TAKE FURTHER NOTICE that on December 11, 2018, the Committee filed 

the Notice of Filing of Supplemental Declaration of Carol Flaton of Zolfo Cooper, LLC (“Fifth 

Supplemental Declaration”) [Docket No. 4445]. 

PLEASE TAKE FURTHER NOTICE that on May 1, 2019, the Committee filed the 

Notice of Filing of Supplemental Declaration of Carol Flaton of Zolfo Cooper, LLC (“Sixth 

Supplemental Declaration”) [Docket No. 6780]. 

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PLEASE TAKE FURTHER NOTICE that on July 1, 2019, the Committee filed the 

Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (“Seventh 

Supplemental Declaration”) [Docket No. 7778]. 

PLEASE TAKE FURTHER NOTICE that on April 29, 2020, the Committee filed the 

Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (“Eighth 

Supplemental Declaration”) [Docket No. 12988]. 

PLEASE TAKE FURTHER NOTICE that on July 27, 2020, the Committee filed the 

Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (“Ninth 

Supplemental Declaration”) [Docket No. 13848]. 

PLEASE TAKE FURTHER NOTICE that on November 9, 2020, the Committee filed 

the Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (“Tenth 

Supplemental Declaration”) [Docket No. 15040]. 

PLEASE TAKE FURTHER NOTICE that on May 4, 2021, the Committee filed the 

Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (“Eleventh 

Supplemental Declaration”) [Docket No. 16679]. 

PLEASE TAKE FURTHER NOTICE that on March 4, 2022, the Committee filed the 

Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (“Twelfth 

Supplemental Declaration”) [Docket No. 20263]. 

PLEASE TAKE FURTHER NOTICE that on May 16, 2022, the Committee filed the 

Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (the 

“Thirteenth Supplemental Declaration”) [Docket No. 20828]. 

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PLEASE TAKE FURTHER NOTICE that on July 19, 2022, the Committee filed the 

Notice of Filing of Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (the 

“Fourteenth Supplemental Declaration”) [Docket No. 21545]. 

PLEASE TAKE FURTHER NOTICE that in support of the Application, attached hereto 

as Exhibit A is the Supplemental Declaration of Joff Mitchell of Zolfo Cooper, LLC (the “Fifteenth 

Supplemental Declaration”). 

[Remainder of page intentionally left blank] 

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Dated: November 11, 2022 

 

/s/ G. Alexander Bongartz .

PAUL HASTINGS LLP 

Luc A. Despins, Esq. (Pro Hac Vice) 

Nicholas A. Bassett, Esq. (Pro Hac Vice) 

G. Alexander Bongartz, Esq. (Pro Hac Vice) 

200 Park Avenue 

New York, New York 10166 

Telephone: (212) 318-6000 

lucdespins@paulhastings.com 

nicholasbassett@paulhastings.com 

alexbongartz@paulhastings.com 

Counsel to the Official Committee of Unsecured 

Creditors 

- and - 

/s/ Juan J. Casillas Ayala .

CASILLAS, SANTIAGO & TORRES LLC 

Juan J. Casillas Ayala, Esq. (USDC - PR 218312) 

Israel Fernández Rodríguez, Esq. (USDC - PR 

225004) 

Juan C. Nieves González, Esq. (USDC - PR 231707) 

Cristina B. Fernández Niggemann, Esq. (USDC - PR 

306008) 

PO Box 195075 

San Juan, PR 00919-5075 

Tel.: (787) 523-3434 Fax: (787) 523-3433 

jcasillas@cstlawpr.com 

ifernandez@cstlawpr.com 

jnieves@cstlawpr.com 

cfernandez@cstlawpr.com 

Local Counsel to the Official Committee of 

Unsecured Creditors 

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EXHIBIT A

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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.,

1

 Debtors. 

--------------------------------------------------------------- 

x 

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x 

PROMESA 

Title III 

Case No. 17-bk-3283 (LTS) 

(Jointly Administered) 

SUPPLEMENTAL DECLARATION 

OF JOFF MITCHELL OF ZOLFO COOPER, LLC 

Pursuant to 28 U.S.C. § 1746, I, Joff Mitchell, state under penalty of perjury, that: 

1. I am an authorized representative of Zolfo Cooper, LLC (“Zolfo Cooper”),2 which 

has a place of business at 909 Third Avenue, Floor 30, New York, New York 10022. 

2. Except as otherwise noted, I have personal knowledge of the matters set forth herein 

and, if called as a witness, would testify competently thereto. 

3. I am filing this supplemental declaration to supplement the disclosures that were 

 

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 (the “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”) (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). 

2

 On November 1, 2018, AlixPartners, LLP acquired Zolfo Cooper, LLC. A Supplemental Declaration disclosing 

the acquisition of Zolfo Cooper, LLC by AlixPartners, LLP was filed on November 6, 2018 (Docket No. 4189). 

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included in the original declaration dated July 11, 2017 [ECF No. 615-3] filed in support of the 

Application of the Official Committee of Unsecured Creditors of the Commonwealth of Puerto 

Rico, for Entry of an Order Authorizing the Employment and Retention of Zolfo Cooper as 

Bankruptcy Consultant and Financial Advisor to the Committee nunc pro tunc to June 27, 2017 

[ECF No. 615-1] and the prior supplemental declarations filed with this Court [ECF Nos. 1304, 

1769, 4189, 4445, 6780, 7778, 12988, 13848, 15040, 16679, 20263, 20828, and 21545]. 

4. In accordance with the Puerto Rico Recovery Accuracy in Disclosures Act (the 

“PRRADA”) and the Court’s related orders [Docket Nos. 19859, 19980, 20419, and 20467], the 

Oversight Board submitted an initial List of Material Interested Parties, as defined in the PRRADA 

(the “Initial MIP List”), which the Oversight Board thereafter amended (the “Amended MIP List” 

and, together, the “MIP List”). On March 21 and 30, 2022, the Court directed that, “to the extent 

any professional persons (as identified in PRRADA) have already complied with the requirements 

of Rule 2014(a) of the Federal Rules of Bankruptcy Procedure, any future disclosures by such 

professional persons as required by PRRADA must supplement, but need not duplicate, what has 

already been filed by those professional persons.” See Docket Nos. 20419 and 20467. 

5. Consistent with these orders, Zolfo Cooper continues to review its conflicts check 

system for these parties, and the results were compiled and analyzed by Zolfo Cooper professionals 

acting under my supervision. 

6. In its capacity as a subsidiary of AlixPartners, LLP and affiliates (“AP”), Zolfo 

Cooper would like to disclose the following: 

 AP follows a practice to solicit from the members of its Boards their connections to the 

parties in interest independent of AP. In response, one or more of the members of its 

Boards have offered the following disclosures: 

o Arent Fox LLP, a professional in this bankruptcy matter, is a current or former legal 

services provider to an AP investor or one of its affiliates. 

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o O`Melveny & Myers LLP, a professional in this bankruptcy matter, is a current or 

former legal services provider to an AP investor or one of its affiliates. 

 As disclosed in the Twelfth Supplemental Declaration, AlixPartners was engaged to 

provide services to (i) the Commonwealth of Puerto Rico and Bank of New York Mellon 

as Trustee in connection with the annual calculation of outperformance metrics with 

respect to securities to be issued upon the effectiveness of the Commonwealth of Puerto 

Rico’s plan of adjustment (the “Plan”); and (ii) the Commonwealth of Puerto Rico with 

respect to certain annual future obligations contingent upon the Commonwealth’s actual 

surplus relative to the certified fiscal plan as of the effective date of the Plan (the 

“Contingent Future Obligations”). As further disclosed in the Twelfth Supplemental 

Declaration, the provision of these services by AlixPartners were all contingent upon the 

effectiveness of the Plan and execution of formal engagement letters on both 

workstreams. As of the date hereof, the Plan has gone effective and engagement letters 

on both workstreams have been executed. 

 Abengoa Puerto Rico S.E. and Abengoa S.A., material creditors and inactive claimants of 

PREPA in this bankruptcy matter, and affiliates are adverse litigation parties to a current 

AP client in matters unrelated to the Debtors. 

 ACP Master, LTD., a party in interest in this bankruptcy matter, is an adverse litigation 

party to a former AP client in matters unrelated to the Debtors. 

 AES Ilumina, LLC and AES Puerto Rico L.P, material creditors of PBA in this bankruptcy 

matter, and affiliates are lenders and affiliates to a current AP client in matters unrelated to 

the Debtors. 

 Alvarez & Marsal North America, LLC, a professional in this bankruptcy matter, and 

affiliates are parent companies to former AP clients in matters unrelated to the Debtors. 

 Ankura Consulting Group, LLC, a professional in this bankruptcy matter, and affiliates are 

lenders to current and former AP clients in matters unrelated to the Debtors. 

 Bailey Duquette P.C., counsel to a material creditor in this bankruptcy matter, is a 

professional to a current AP client in matters unrelated to the Debtors. 

 Barings LLC, a material creditor of PREPA in this bankruptcy matter, is a parent company 

to a former AP client in matters unrelated to the Debtors. 

 Becton Dickinson and Company, Becton Dickinson Biosciences, Becton Dickinson 

Biosciences, System and Reagents, and Becton Dickinson Caribe LTD, parties in interest 

in this bankruptcy matter, and affiliates are former employers of a current AP employee. 

 Black Diamond Credit Strategies Master Fund, Ltd., a Commonwealth inactive claimant 

and material creditor of PREPA in this bankruptcy matter, and affiliates are parent 

companies and adverse litigation parties to former AP clients in matters unrelated to the 

Debtors. 

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 BlueMountain Capital Management, LLC, on behalf of itself and funds and/or accounts 

managed or advised by it, BlueMountain Credit Alternatives Master Fund L.P., 

BlueMountain Credit Opportunities Master Fund I L.P., BlueMountain Foinaven Master 

Fund L.P., BlueMountain Fursan Fund L.P., BlueMountain Guadalupe Peak Fund L.P., 

BlueMountain Kicking Horse Fund L.P., BlueMountain Logan Opportunities Master Fund 

L.P., BlueMountain Montenvers Master Fund SCA SICAV-SIF, BlueMountain Summit 

Trading L.P. and BlueMountain Timberline LTD., litigation parties to the Debtors, and 

affiliates are lienholders to a current AP client in matters unrelated to the Debtors. 

 Brigade Capital Management, LP, a party in interest in this bankruptcy matter, is a 

lienholder to a current AP client in matters unrelated to the Debtors. 

 Brown Rudnick LLP, a professional in this bankruptcy matter, is a former employer of a 

current AP employee. 

 Cardinal Health PR 120, INC., a Commonwealth inactive claimant in this bankruptcy 

matter, and affiliates are litigation parties to current AP clients in matters unrelated to the 

Debtors. 

 Cesar Castillo, Inc., a material creditor of the Commonwealth in this bankruptcy matter, is 

a professional to a former AP client in matters unrelated to the Debtors. 

 CNA Surety and Continental Casualty Company, material creditors of PREPA in this 

bankruptcy matter, are insurance providers to AP 

 Continental Casualty Company, a party in interest in this bankruptcy matter, is an insurance 

provider to AP. 

 Costco Wholesale Corporation (“Costco”), a party in interest in this bankruptcy matter, is 

a lessee to a current AP client in matters unrelated to the Debtors. Costco is a former 

employer of a current AP employee. 

 Crowe Horwath LLP, a party in interest in this bankruptcy matter, and affiliates are vendors 

to AP. 

 Dechert, LLP, a professional in this bankruptcy matter, is a former employer of a current 

AP employee. 

 Dentons US LLP, a professional in this bankruptcy matter, and affiliates are opposing 

counsel to a current AP client in matters unrelated to the Debtors. 

 DLA Piper (Puerto Rico) LLC and DLA Piper LLP (US), professionals in this bankruptcy 

matter, and affiliates are current legal services providers to AP. 

 Drivetrain, LLC, as the Creditors’ Trustee for Doral Financial Corporation, an Official 

Committee of Unsecured Creditors Member in this bankruptcy matter, is a professional to 

a current AP client in matters unrelated to the Debtors. 

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 General Electric Company and GE Industrial of PR LLC and Caribe GE International of 

Puerto Rico, Inc., Commonwealth inactive claimants in this bankruptcy matter, and 

affiliates (“GE”) are bondholders, adverse litigation parties, lenders, associated companies, 

related parties, litigation parties, shareholders, lienholders, lessors, director-affiliates 

companies and joint venture entities to current and former AP clients in matters unrelated 

to the Debtors. GE is a current and former AP client in matters unrelated to the Debtors. 

GE is a former employer of current AP employees. 

 Global Opportunities LLC and Global Opportunities Offshore LTD, parties in interest in 

this bankruptcy matter, and affiliates are lenders to a current AP client in matters unrelated 

to the Debtors. 

 HDI Global Insurance Company, an HTA inactive claimant in this bankruptcy matter, and 

affiliates are insurance providers to AP. 

 Hewlett Packard Caribe BV, LLC and Hewlett Packard Enterprise Development LP, 

Commonwealth inactive claimants in this bankruptcy matter, and affiliates (“HP”) are 

lessors to current AP clients in matters unrelated to the Debtors. HP is a vendor to AP. 

 Luskin, Stern & Eisler LLP, a professional in this bankruptcy matter, is counsel to a current 

AP client in matters unrelated to the Debtors. 

 Macy's Puerto Rico, a material creditor of the Commonwealth in this bankruptcy matter, 

and affiliates are former employers of a current AP employee. 

 Marathon Asset Management, LP, on behalf of funds and/or accounts managed or advised 

by it, a PREPA material creditor in this bankruptcy matter, and affiliates are lienholders to 

a current AP client in matters unrelated to the Debtors. 

 Maslon LLP, counsel to material creditors in this bankruptcy matter, is a professional to a 

current AP client in matters unrelated to the Debtors. 

 Nixon Peabody, a professional in this bankruptcy matter, is counsel to a current AP client 

in matters unrelated to the Debtors. 

 Nokota Capital Master Fund, LP, a material creditor in this bankruptcy matter, and 

affiliates are shareholders to a former AP client in matters unrelated to the Debtors. 

 O`Melveny & Myers LLP, a professional in this bankruptcy matter, is a professional and 

counsel to current AP clients in matters unrelated to the Debtors. 

 Pfizer Pharmaceuticals LLC, a Commonwealth inactive claimant in this bankruptcy matter, 

is a former employer of a current AP employee. 

 Puerto Rico Electric Power Authority, a Debtor in this bankruptcy matter, is a former AP 

client in unrelated matters. 

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 Ropes & Gray LLP, a professional in this bankruptcy matter, is a former employer of a 

current AP employee. 

 Shell Trading (US) Company, a material creditor and inactive claimant of the 

Commonwealth in this bankruptcy matter, and affiliates are litigation parties to a current 

AP client in matters unrelated to the Debtors. 

 Silver Point Capital Fund, LP, Silver Point Capital Offshore Master Fund, L.P. and Silver 

Point Capital, L.P., parties in interest in this bankruptcy matter, and affiliates are investors 

to a former AP client in matters unrelated to the Debtors. 

 Skadden, Arps, Slate, Meagher & Flom LLP, a professional in this bankruptcy matter, is a 

former legal services provider to AP. 

 State Street Global Advisors Trust Company, a PREPA inactive claimant in this 

bankruptcy matter, and affiliates are litigation parties to a current AP client in matters 

unrelated to the Debtors. 

 Taconic Master Fund 1.5 L.P. and Taconic Opportunity Master Fund L.P., parties in 

interest in this bankruptcy matter, and affiliates are lienholders to a current AP client in 

matters unrelated to the Debtors. 

 The Bank of Nova Scotia as Transferee of Scotiabank de Puerto Rico, a Commonwealth 

inactive claimant in this bankruptcy matter, is a parent company to a former AP client in 

matters unrelated to the Debtors. 

 The Brattle Group, Inc., a professional in this bankruptcy matter, is opposing counsel to a 

current AP client in matters unrelated to the Debtors. 

 The Travelers Indemnity Company, a material creditor of the Commonwealth in this 

bankruptcy matter, and affiliates are litigation parties to current and former AP clients in 

matters unrelated to the Debtors. 

 U.S. Department of Labor, a Commonwealth inactive claimant in this bankruptcy matter, 

is an adverse litigation party to former AP clients in matters unrelated to the Debtors. 

 UMB Bank, N.A., as Successor Trustee for the Puerto Rico Infrastructure Financing 

Authority (“PRIFA”) Mental Health Infrastructure Revenue Bonds, 2007 Series A (MEPSI 

Campus Project), a material creditor of HTA in this bankruptcy matter, is a current AP 

client in matters unrelated to the Debtors. 

7. I continue to reserve the right to supplement Zolfo Cooper’s disclosures in the event 

that I learn of any additional connections that require disclosure. If any new material relevant facts 

or relationships are discovered or arise, Zolfo Cooper will promptly file a supplemental declaration 

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pursuant to Bankruptcy Rule 2014(a). 

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

and correct. 

Dated: November 10, 2022 

 /s/ Joff Mitchell 

 Joff Mitchell 

 Zolfo Cooper, LLC 

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