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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

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:

In re: :

:

THE FINANCIAL OVERSIGHT AND : PROMESA

MANAGEMENT BOARD FOR PUERTO RICO, : Title III

:

as representative of : Case No. 17-BK-3283 (LTS)

:

THE COMMONWEALTH OF PUERTO RICO et al., : (Jointly Administered)

:

Debtors. 1:

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MOTION SUBMITTING VERIFIED STATEMENT OF CANCIO, NADAL & RIVERA 

L.L.C. PURSUANT TO 48 U.S.C. § 2178 AND BANKRUPTCY 

RULE 2014(a) AS FORMER COUNSEL TO THE PUERTO RICO ELECTRIC POWER 

AUTHORITY

TO THE HONORABLE COURT:

Comes Now, Cancio Nadal & Rivera L.L.C. through the undersigned legal counsel 

and respectfully STATES, ALLEGES AND PRAYS:

In accordance with the Puerto Rico Recovery Accuracy in Disclosures Act, Pub. L. No. 

117-82, 48 U.S.C. § 2178(c) (“PRRADA”), the Court’s related Order Approving List of Material 

Interested Parties Pursuant to the Puerto Rico Recovery Accuracy in Disclosure Act [Docket No. 

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) 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); (iv) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) (Last 

Four Digits of Federal Tax ID: 3808); and (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 

BK 4780-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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20467] and the Court’s Order Concerning Non-Compliance with the Puerto Rico Recovery 

Accuracy in Disclosure Act and the Court’s Order Related Thereto [Docket No. 22062] (the 

“Order”), the Cancio, Nadal & Rivera L.L.C. as former counsel to the Puerto Rico Electric Power 

Authority (the “PREPA”), hereby submits this Verified Statement pursuant to Rule 2014(a) of the 

Federal Rules of Bankruptcy Procedure.

Dated: October 12, 2022

In San Juan, Puerto Rico.

/s/ José Luis Barrios Ramos

JOSÉ LUIS BARRIOS RAMOS

USDC No. 223611

jbarrios@prestigelegalpr.com

PRESTIGE LEGAL SERVICES LLC

278 César González Ave.

San Juan, PR 00918

Tel. (787) 593-6641

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CERTIFICATE OF SERVICE 

I hereby certify that, on this same date, I electronically filed the foregoing with the Clerk of 

the Court using the CM/ECF system, which will send notifications of such filing to all CM/ECF 

participants in this case.

/s/ José Luis Barrios Ramos

JOSÉ LUIS BARRIOS RAMOS

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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

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

:

In re: :

:

THE FINANCIAL OVERSIGHT AND : PROMESA

MANAGEMENT BOARD FOR PUERTO RICO, : Title III

:

as representative of : Case No. 17-BK-3283 (LTS)

:

THE COMMONWEALTH OF PUERTO RICO et al., : (Jointly Administered)

:

Debtors. 2:

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VERIFIED STATEMENT OF CANCIO, NADAL & RIVERA L.L.C. PURSUANT TO 48 

U.S.C. § 2178 AND BANKRUPTCY RULE 2014(a) AS 

FORMER COUNSEL TO THE PUERTO RICO ELECTRIC POWER AUTHORITY

I, Rafael Barreto Sola, state the following under penalty of perjury:

1. I am the Managing Member in the law firm of Cancio, Nadal & Rivera L.L.C. (“CNR” 

or the “Firm”), located at 403 Muñoz Rivera Ave. San Juan, Puerto Rico. CNR is a full-service law 

firm, with over thirty (30) attorneys providing legal services to both private and governmental 

clients in San Juan, Puerto Rico. I am a member in good standing of the bars of the Commonwealth 

of Puerto Rico and the United States District Court for the District of Puerto Rico.

2.In accordance with the Puerto Rico Recovery Accuracy in Disclosures Act, Pub. L. No. 

117-82, 48 U.S.C. § 2178(c) (“PRRADA”), and the Court’s related Order Approving List of 

2 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) 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); (iv) Puerto Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17 BK 3567-LTS) (Last 

Four Digits of Federal Tax ID: 3808); and (v) Puerto Rico Electric Power Authority (“PREPA”) (Bankruptcy Case No. 17 

BK 4780-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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Material Interested Parties Pursuant to the Puerto Rico Recovery Accuracy in Disclosure Act 

[Docket No. 20467] and the Court’s Order Concerning Non-Compliance with the Puerto Rico 

Recovery Accuracy in Disclosure Act and the Court’s Order Related Thereto [Docket No. 22062] 

(the “Order”), CNR as former counsel to the Puerto Rico Electric Power Authority (the “PREPA”), 

hereby informs that it failed to timely comply with PRRADA due to, among others, the following: 

(i) all the attorneys that manage and worked directly as local counsels for PREPA in the 

PROMESA Title III case left the law firm of Cancio Nadal Rivera & Díaz (“CNRD”), which is 

currently known as Cancio, Nadal & Rivera (“CNR”), on or about August 2019 and are currently 

part of the Díaz & Vázquez Law Firm P.S.C., the Law Firm that currently continues to serve as 

local counsel for PREPA in the PROMESA Title III Case; (ii) PRRADA was enacted after August 

2019, date upon which CNR was no longer serving as local counsel for PREPA in the Title III 

Case: and (iii) none of CNR current attorneys is actively representing clients in the PROMESA 

Title III of PREPA or is receiving notices from the PROMESA Title III Case of PREPA or other 

Debtors, which in part cause CNR to be unaware that under PRRADA and the Court’s Order 

[Docket No. 22062] the disclosure requirements applied retroactively to services rendered to a 

Debtor in the Title III cases prior to its enactment. 

3.Therefore, CNR in accordance with the Court’s Order hereby submits this Verified 

Statement pursuant to Rule 2014(a) of the Federal Rules of Bankruptcy Procedure in order to 

comply with said Order and PRRADA.

4.This Verified Statement is intended to provide the disclosures required under PRRADA, 

the Order and Bankruptcy Rule 2014(a). The undersigned has personal knowledge of the matters 

set forth herein. To the extent any information disclosed in this Verified Statement requires 

amendment or modification upon the Firm’s completion of further review, or as additional 

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information becomes available, a supplemental Verified Statement will be submitted to the Court 

reflecting such amended or modified information.

5.In accordance with PRRADA, CNR conducted a check for conflicts of interest and other 

conflicts and connections. CNR maintains a database which includes the names of current and former 

clients and regularly conducts conflict checks analysis to identify conflicts of interest or other 

potential conflict issues. I caused CNR to review and analyze the conflicts database to determine 

whether CNR has any relationships with the material interested parties (“MIPs”) listed on the 

Amended List of Material Interested Parties Pursuant to Puerto Rico Recovery Accuracy in 

Disclosure Act [ECF No. 20458] (the “Amended MIP List”). CNR also requested information from 

all current attorneys working at CNR regarding MIPs in prior employments and whether the 

representation of these MIPs in prior employments was related to PREPA or any other Debtor in 

the PROMESA cases during the time that CN&R serve as local counsel to PREPA in the Title III 

Case (“the period”).

6. To the extent that such searches indicated that CNR or any of its attorneys has or had a 

relationship with any MIPs during the period, the identity of such entities, and CNR relationships 

therewith, are as follows:

(a) List of MIPs that CNR attorneys represented during the period in matters wholly 

unrelated to the PROMESA cases and were CNR does not represent or has represented these MIPs 

in any matter concerning PREPA or the other Debtors:

1. Employees Retirement Sy stem of the Government of the Commonwealth of Puerto 

Rico;

2. American Federation of Teachers and its Affiliate Asociación de Maestros de Puerto 

Rico;

3. Cooperativa de Ahorro y Crédito de la Asociación de Maestros de Puerto Rico;

4. Autonomous Municipality of Ponce;

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5. Caribbean Medical Center;

6. Government Development Bank of Puerto Rico;

7. Puerto Rico Aqueduct and Sewer Authority (PRASA);

8. Puerto Rico State Insurance Fund;

9. Vaquería Tres Monjitas, Inc.

10. Cooperativa de Ahorro y Crédito de Arecibo (CooPACA);

11. Firstbank of Puerto Rico;

12. Multinational Insurance Co.;

13. EC Waste LLC;

14. Banco Popular de Puerto Rico;

15. DEYA Elevator Service, Inc.;

16. Skytec, Inc.

 (b) CNR hereby states that it does not represent or is currently involved in advising any 

MIPs in connection with the PROMESA cases. Other than the disclosures made above, CNR does 

not represent and has not represented any of the MIPs in matters relating to PREPA or the other 

Debtors.

7. To the best of my knowledge, CNR does not represent and after its engagement as local

counsel of PREPA on the Title III case was terminated in July 30, 2019, CNR has not represent any 

MIPs in matters related to these Title III cases. Furthermore, to the best of my knowledge, I believe that 

CNR (i) is a “disinterested person,” as that term is defined in section 101(14) of the Bankruptcy Code, 

relative to any entity or person on the Amended MIP List and (ii) does not represent or hold an adverse 

interest in connection with PREPA’s Title III case.

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

true and correct to the best of my knowledge, information and belief.

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Dated: October 12, 2022

In San Juan, Puerto Rico.

/s/ Rafael E. Barreto Solá

RAFAEL E. BARRETO SOLÁ

Member

USDC No. 211801

rbarreto@cnr.law

CANCIO, NADAL & RIVERA, LLC

PO Box 364966

San Juan, PR 00936-4966

Tel. (787) 767-9625

Fax (787) 622-2238/764-4430

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