UNITED STATES DISTRICT COURT 

DISTRICT OF PUERTO RICO 

In re:

THE FINANCIAL OVERSIGHT AND MANAGEMENT 

BOARD FOR PUERTO RICO, 

as representative of 

PROMESA 

Title III 

THE COMMONWEALTH OF PUERTO RICO, THE PUERTO 

RICO SALES TAX FINANCING CORPORATION, THE 

PUERTO RICO HIGHWAYS AND TRANSPORTATION 

AUTHORITY, THE EMPLOYEES RETIREMENT SYSTEM 

OF THE GOVERNMENT OF THE COMMONWEALTH OF 

PUERTO RICO, THE PUERTO RICO ELECTRIC POWER 

AUTHORITY, AND THE PUERTO RICO PUBLIC 

BUILDINGS AUTHORITY,

No. 17 BK 3283-LTS 

(Jointly Administered) 

Re: ECF No. 20832, 22340 

Debtors.1

URGENT UNOPPOSED MOTION SEEKING ENTRY OF AN ORDER 

EXTENDING TIME TO FILE SUPPLEMENTAL VERIFIED STATEMENT 

PURSUANT TO THE PUERTO RICO RECOVERY ACCURACY IN DISCLOSURES ACT 

To the Honorable United States District Court Judge Laura Taylor Swain: 

McKinsey & Company Puerto Rico Consulting, Inc. (“McKinsey”) respectfully submits 

this motion (the “Motion”) for entry of an order, substantially in the form attached hereto as 

Exhibit A, extending to October 28, 2022, any applicable time for McKinsey to file a 

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 (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 Ill case numbers are listed as Bankruptcy Case numbers due to software limitations). 

Case:17-03283-LTS Doc#:22607 Filed:10/13/22 Entered:10/13/22 20:28:16 Desc: Main

Document Page 1 of 5
supplemental verified statement of connections under the Puerto Rico Recovery Accuracy in 

Disclosures Act of 2021. Pub. L. No. 117-82 (“PRRADA”). In support of this Motion, 

McKinsey respectfully represents as follows: 

Background 

1. PRRADA was signed into law on January 20, 2022, and generally imposes the 

Rule 2014 disclosure requirements of the Federal Rules of Bankruptcy Procedure that apply to 

professionals retained under sections 327 and 1103 of the Bankruptcy Code. 

2. On April 12, 2022, the Court entered its Third Amended Order Setting Procedures 

for Interim and Final Compensation and Reimbursement of Expenses of Professionals (“Third 

Amended Order”) [ECF No. 20546]. The Third Amended Order, among other things, set a May 

16, 2022, deadline for professionals to file PRRADA disclosures (Third Amended Order, ¶ 4.d.). 

That Order also required the United States Trustee to review and comment informally on or 

object to any professional’s PRRADA disclosures by June 30, 2022, or such deadline as the 

Court may order. (Third Amended Order, ¶ 4 e.i.). 

3. On May 16, 2022, McKinsey timely filed the Declaration of Dmitry Krivin, a 

Partner of McKinsey & Company, Inc. United States, Disclosing Connections to Material 

Interested Parties in Connection with the Puerto Rico Recovery Accuracy in Disclosures Act (the 

“Krivin Declaration”) [ECF No. 20832]. 

4. On August 15, 2022, the United States Trustee filed a status report regarding 

professionals’ PRRADA disclosures. See United States Trustees Comment and Related Status 

Report on the Verified Statements of Connections Filed by Professionals Under the Puerto Rico 

Recovery Accuracy in Disclosures Act [ECF No. 21840]. As noted in the status report, “the 

United States Trustee conferred with and requested supplemental information from 36 

Case:17-03283-LTS Doc#:22607 Filed:10/13/22 Entered:10/13/22 20:28:16 Desc: Main

Document Page 2 of 5
professionals,” including McKinsey. The United States Trustee also noted that it was awaiting 

submissions of supplemental disclosures from certain professionals, identified McKinsey as one 

such professional, and indicated that it “will file an updated Comment and Status Report with the 

Court as to these professionals as necessary.” Id. 

5. On September 15, 2022, McKinsey filed a status report with the Court regarding 

the status of its supplemental disclosures and the ongoing discussions with the United States 

Trustee. [ECF No. 22233]. 

6. On September 16, 2022, the Court entered an order extending to October 14, 

2022, McKinsey’s deadline to file a supplement to the Krivin Declaration, without prejudice to 

the right of McKinsey to request further extensions of time. [ECF No. 22340]. 

RELIEF REQUESTED 

7. As previously disclosed, McKinsey has been working diligently to supplement the 

Krivin Declaration in response to the United States Trustee’s comments and McKinsey has 

provided supplemental information to the United States Trustee. However, the parties would 

benefit from additional time for McKinsey to ensure that its supplemental disclosures fully 

address any outstanding questions or follow-up requests from the United States Trustee. 

Accordingly, McKinsey is requesting an additional 14 days, through October 28, 2022, to file its 

supplemental disclosures in order to continue these efforts. 

8. The Office of the United States Trustee has indicated that it does not object to a 

14-day extension, provided that after McKinsey files a supplement to the Krivin Declaration on 

the docket, the United States Trustee will have 30 days to further review the supplemental 

disclosures. 

[Remainder of page left intentionally blank]

Case:17-03283-LTS Doc#:22607 Filed:10/13/22 Entered:10/13/22 20:28:16 Desc: Main

Document Page 3 of 5
WHEREFORE McKinsey respectfully requests the Court to enter the Proposed Order 

attached hereto as Exhibit A, granting the relief requested herein and all other relief that is just 

and proper. 

WE HEREBY CERTIFY that on this 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 attorneys or record. 

RESPECTFULLY SUBMITTED. 

Dated: October 13, 2022 

San Juan, PR

REICHARD & ESCALERA LLC 

 

By: __________________________ 

/s/Sylvia M. Arizmendi 

Sylvia M. Arizmendi 

USDC-PR No. 210714 

arizmendis@reichardescalera.com 

/s/Joshua Rodríguez-Rivera 

Joshua Rodríguez Rivera 

USDC-PR No. 308601 

jrodriguez@reichardescalera.com 

MCS Plaza, Suite 1000 

255 Ave. Ponce de León 

Hato Rey, PR 00918 

P.O. Box 364148 

San Juan, PR 00936-4148 

Telephone: (787) 777-8888 

Case:17-03283-LTS Doc#:22607 Filed:10/13/22 Entered:10/13/22 20:28:16 Desc: Main

Document Page 4 of 5
DEBEVOISE & PLIMPTON LLP 

By: _/s/ Erica S. Weisgerber _______________ 

/s/ M. Natasha Labovitz (admitted pro hac vice) 

/s/ Erica S. Weisgerber (admitted pro hac vice) 

919 Third Avenue 

New York, New York 10022 

Telephone: (212) 909-6000 

Attorneys for McKinsey & Company Puerto Rico 

Consulting, Inc. and certain of its affiliates

Case:17-03283-LTS Doc#:22607 Filed:10/13/22 Entered:10/13/22 20:28:16 Desc: Main

Document Page 5 of 5