UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors1

 

PROMESA

Title III

Case No. 17 BK 3283-LTS

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

Debtor

PROMESA 

Title III 

Case No. 17 BK 4780-LTS

PARTY IN INTEREST'S PRELIMINARY FACT WITNESS LIST

COMES NOW, PV Properties, Inc. (“PV Properties”), through its undersigned attorneys 

and respectfully submits its preliminary fact witness list as to the hearing on the confirmation of 

the Second Amended Title III Plan of Adjustment of the Puerto Rico Electric Power Authority as 

follows: 

Victor Luis González: PV Properties’ President: May provide testimony as to Puerto 

Rico’s public policy regarding energy and its environmental attributes associated with the 

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); and (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17 BK 4780-LTS) (Last Four Digits of Federal Tax ID: 3747).

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generation of electricity by renewable energy, as established by the corresponding legislation and 

PREPA’s obligation to purchase from distributed generation Prosumers Renewable Energy 

Credits (“RECs”) generated and self-consumed and those generated and exported to the Grid, 

including determination of the value of the RECs and PV Properties’ claim against PREPA for its 

refusal to purchase RECs thereby; Puerto Rico Energy Bureau’s jurisdiction to establish the rate to 

Net Meters consumers as part of PROMESA, including the rate or mechanism to compensate 

customers for energy supplied to the electric power grid, as well as the value of the RECs, and the 

Legacy Charge rate, usurped by the Oversight Board. 

WHEREFORE, it is respectfully requested that PV Properties be deemed in 

compliance with the deadline for the submittal of its Preliminary Fact Witness List established 

by the Court.

CERTIFICATE OF SERVICE: We hereby certify that on this same date we 

electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which 

will send notification of such filing to all CM/ECF participants. 

San Juan, Puerto Rico this 21

st day of March 2023

s/Fernando E. Agrait 

USDC-PR 127212

701 Avenida Ponce de León

Edificio Centro de Seguros 

Oficina 414

San Juan, Puerto Rico 00907

Tel. 787-725-3390/3391

Fax: 787-724-0353

E-mail: agraitfe@agraitlawpr.com

s/Charles A. Cuprill-Hernández

USDC-PR 114312

Charles A. Cuprill, P.S.C., Law Offices

356 Fortaleza Street - Second Floor

San Juan, PR 00901

Tel.: 787-977-0515

Fax: 787-977-0518

E-mail: cacuprill@cuprill.com

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