Objections Due: February 28, 2023 at 4:00 p.m. (AST)

Hearing Date: March 15, 2023 at 9:30 a.m. (AST)

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

(Jointly Administered)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO,

as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY, 

Debtor.

PROMESA

Title III

No. 17 BK 4780-LTS

This Motion relates to PREPA 

and shall be filed in Lead Case 

No. 17 BK 3283-LTS and Case 

No. 17 BK 4780-LTS.

NOTICE OF HEARING AND NOTICE OF FILING OF PREPA’S MOTION 

FOR ENTRY OF ORDER ALLOWING ADMINISTRATIVE EXPENSE CLAIM 

FOR COMPENSATION FOR MOBILIZATION SERVICES UNDER PUERTO 

RICO THERMAL GENERATION FACILITIES OPERATION AND 

MANAGEMENT AGREEMENT

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”) (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 NOTICE that a hearing on the contemporaneously filed PREPA’s 

Motion for Entry of Order Allowing Administrative Expense Claim for Compensation for 

Mobilization Services Under Puerto Rico Thermal Generation Facilities Operation and 

Management Agreement (the “Motion”) will be held before the Honorable Laura Taylor Swain, 

United States District Judge, on March 15, 2023 at 9:30 a.m. (AST) (the “Hearing”). 

PLEASE TAKE FURTHER NOTICE that any responses or objections (“Objections”) 

to the Motion by any party shall conform to the Federal Rules of Bankruptcy Procedure and the 

Local Bankruptcy Rules for the District of Puerto Rico, shall be filed with the Court (a) by 

attorneys practicing in the District Court, including attorneys admitted pro hac vice, electronically 

in accordance with rule 5 of the Local Rules for the District of Puerto Rico, and (b) by all other 

parties in interest, by submitting a hard copy via mail to the Clerk’s Office, United States District 

Court, Room 150 Federal Building, San Juan, PR 00918-1767 or by hand delivery to the Clerk’s 

Office, United States District Court, 150 Carlos Chardón Avenue, Room 150, San Juan, PR 00918, 

to the extent applicable, and shall be served in accordance with the Sixteenth Amended Case 

Management Procedures [ECF No. 20190-1], so as to be so filed and received no later than 

February 28, 2023 at 4:00 p.m. (AST) (the “Objection Deadline”). 

PLEASE TAKE FURTHER NOTICE any response or objection to the Motion by any 

party must also be served on the entities listed below, so as to be received on or before the 

Objection Deadline. 

PLEASE TAKE FURTHER NOTICE that if an Objection to the Motion is not received 

by the Objection Deadline, the relief requested shall be deemed unopposed, and the District Court 

may enter an order granting the relief sought without a hearing pursuant to the Sixteenth Amended 

Case Management Procedures. 

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PLEASE TAKE FURTHER NOTICE that copies of all documents filed in these Title 

III cases are available (a) free of charge by visiting https://cases.ra.kroll.com/puertorico/ or by 

calling +1 (844) 822-9231, and (b) on the Court’s website at http://www.prd.uscourts.gov, subject 

to the procedures and fees set forth therein. 

[Remainder of Page Intentionally Left Blank]

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Dated: February 21, 2023

San Juan, Puerto Rico

Respectfully submitted,

/s/ Martin J. Bienenstock

Martin J. Bienenstock*

Paul V. Possinger*

Ehud Barak*

PROSKAUER ROSE LLP

Eleven Times Square

New York, NY 10036

Tel: (212) 969-3000

Fax: (212) 969-2900

*Admitted pro hac vice

Attorneys for the Financial Oversight and 

Management Board, as representative for the 

Puerto Rico Electric Power Authority

O’NEILL & BORGES LLC

/s/ Hermann D. Bauer

Hermann D. Bauer

USDC No. 215205

250 Muñoz Rivera Ave., Suite 800

San Juan, PR 00918-1813

Tel: (787) 764-8181

Fax: (787) 753-8944

Attorneys for the Financial Oversight and 

Management Board, as representative for the 

Puerto Rico Electric Power Authority

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MARINI PIETRANTONI MUÑIZ LLC

/s/ Luis C. Marini-Biaggi

Luis C. Marini-Biaggi

USDC-PR No. 222301

Carolina Velaz-Rivero

USDC-PR No. 300913

250 Ponce de León Ave., Suite 900

San Juan, Puerto Rico 00918

Tel: (787) 705-2171

Fax: (787) 936-7494

Attorneys for the Puerto Rico Fiscal Agency 

and Financial Advisory Authority

DÍAZ & VÁZQUEZ LAW FIRM, P.S.C 

/s/ Arturo Díaz-Angueira

Arturo Díaz-Angueira

USDC-PR No. 231812 

290 Jesús T. Piñero Ave.

Oriental Tower, Suite 1105

San Juan, PR 00918

Tel.: (787) 395-7133

Fax: (787) 497-9664

Attorneys for the Puerto Rico Electric Power 

Authority

O’MELVENY & MYERS LLP

/s/ Maria J. DiConza

John J. Rapisardi*

Maria J. DiConza*

Gabriel L. Olivera

USDC-PR No. 303314

7 Times Square

New York, New York 10036

Tel: (212) 326-2000

Fax: (212) 326-2061

-andPeter Friedman*

1625 Eye Street, NW

Washington, D.C. 20006

Tel: (202) 383-5300

Fax: (202) 383-5414

-andElizabeth L. McKeen*

Ashley M. Pavel*

610 Newport Center Drive, 17th Floor

Newport Beach, CA 92660

Tel: (949) 823-6900

Fax: (949) 823-6994

*Admitted pro hac vice

Attorneys for the Puerto Rico Fiscal Agency 

and Financial Advisory Authority and the 

Puerto Rico Electric Power Authority

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