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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF PUERTO RICO

PROMESA

Title III

No. 17 BK 3283-LTS

(Jointly Administered)

MOTION FOR JOINDER OF CREDITOR R&D MASTER ENTERPRISES, INC.

TO: (A) MOTION TO DISQUALIFY McKINSEY & COMPANY, INC. AND ITS 

AFFILIATES (DOC. NO. 22,025), AND (B) MOTION TO DISQUALIFY

THE LAW FIRM O’NEILL & BORGES LLC (DOC. NO. 20,873)

To the Honorable United States District Judge Laura Taylor Swain:

Comes now Creditor, R&D Master Enterprises, Inc., by and through the undersigned 

attorney, who respectfully requests and prays as follows:

1. Creditor R&D Master Enterprises, Inc., a corporation organized under the laws of the 

Commonwealth of Puerto Rico (the “Movant”), hereby joins in support of certain

pending petitions under the Puerto Rico Recovery Accuracy in Disclosures Act of 

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.)

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO,

as representative of

THE COMMONWEALTH OF PUERTO 

RICO, et al.,

Debtors.

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2021, 48 U.S.C. 2101 et seq. (hereinafter, “PRRADA”), to disqualify McKinsey & 

Company, Inc. and its affiliates (collectively, “McKinsey”) and the law firm O’Neill & 

Borges LLC (“O&B”), respectively, both of whom serve as advisors to the Financial 

Oversight and Management Board for Puerto Rico (the “Oversight Board”), the sole 

representative of the Commonwealth of Puerto Rico, the Puerto Rico Electric Power 

Authority, and other covered instrumentalities in these Title III proceedings. In 

connection therewith, the Movant respectfully states and prays as follows. 

2. The Movant is a creditor of the Commonwealth of Puerto Rico with standing to file 

this motion for joinder in these Title III proceedings.

3. The Movant hereby joins relator Carlos Lamoutte in support of the allegations that 

McKinsey and O&B have failed to make clear and transparent disclosures to the Court 

and to the U.S. Trustee Program under PRRADA and supplemental bankruptcy 

procedure disclosure standards, in relation to the unresolved disqualification pleadings 

that are the subject matter of Doc. Nos. 20,873, 20,923, 20,946, 20,989, 20,959, 21,094, 

21,096, 21,124, 21,485, 21,572, 21,604, 21,854, 21,925, 21,938, 21,970, 21,975, 

21,989, 21,990, 22,020, 22,025, 22,035, 22,090, 22,146, 22,216, 22,232, 22,320, 

22,401, 22,404, 22,419, 22,468, 22,485, 22,487, 22,756, 22,779, and 22,800 

(collectively, the “Disqualification Pleadings”).

4. The Movant hereby separately affirms and restates all allegations set forth in the 

Disqualification Pleadings filed to date by relator Carlos Lamoutte, as if fully made

herein by the Movant.

5. The Movant is a creditor of the Commonwealth of Puerto Rico and has an interest in 

the Disqualification Pleadings that would not be represented or protected unless 

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Movant joins in the Disqualification Pleadings prior to their adjudication by the Court.

6. Therefore, the Movant petitions to be included in relator Carlos Lamoutte’s 

Disqualification Pleadings in order to obtain the relief sought under PRRADA.

WHEREFORE, the Movant hereby respectfully petitions the Court to enter an Order

granting Movant’s joinder in support of the pending petitions to disqualify McKinsey and 

O&B, in substantially the form attached hereto as Exhibit A.

RESPECTFULLY SUBMITTED.

In San Juan, PR this 10th day of November 2022. 

It is hereby certified that the foregoing motion was filed with the Clerk of the Court

and notified to the parties, via the CM/ECF system of the Court. 

S/Javier A Rivera-Vaquer

USDC-PR No. 225809

JOSE A RIVERA-CORDERO

JAVIER A RIVERA-VAQUER

PO BOX 192376

SAN JUAN, PR 00919-2376

TEL (787) 759-3634

EMAIL: jariva@rimerico.com

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