UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

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In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO,

as representative of,

THE COMMONWEALTH OF PUERTO 

RICO, et al.

Debtors.1

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:

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PROMESA 

Title III

No. 17 BK 3283-LTS 

(Jointly Administered)

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SECOND URGENT UNOPPOSED MOTION SEEKING EXTENSION OF TIME TO 

FILE SUPPLEMENTAL VERIFIED STATEMENT OF DELOITTE CONSULTING LLP

AND DELOITTE FINANCIAL ADVISORY SERVICES LLP DISCLOSING 

CONNECTIONS TO MATERIAL INTERESTED PARTIES PURSUANT TO 

PUERTO RICO RECOVERY ACCURACY IN DISCLOSURE ACT

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

Deloitte Consulting LLP (“Deloitte Consulting”) and Deloitte Financial Advisory Services 

LLP (together with Deloitte Consulting, the “Deloitte US Entities”) respectfully submit this second 

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

A, extending to November 14, 2022 any applicable time for the Deloitte US Entities to file a 

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) 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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supplemental verified statement(s) pursuant to the to Order on Motion of the United States Trustee 

for Amendment of the Third Amended Order Setting Procedures for Interim and Final 

Compensation and Reimbursement of Expenses of Professionals [Docket No. 21334] and the 

Puerto Rico Recovery Accuracy in Disclosures Act, Pub. L. No. 117-82 (“PRRADA”). In support 

of this Motion, the Deloitte US Entities respectfully represent as follows:

BACKGROUND

1. On February 22, 2022, the Oversight Board filed the Motion of Financial Oversight 

and Management Board for Puerto Rico Requesting Order Approving Proposed List of Material 

Interested Parties Pursuant to the Puerto Rico Recovery Accuracy in Disclosures Act [ECF No. 

20194] (the “PRRADA Motion”), seeking Court approval of a list of material interested parties 

attached thereto as Exhibit A (the “Initial MIP List”) pursuant to PRRADA.

2. On March 21, 2022, the Court entered its Order Regarding Proposed List of 

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

[ECF No. 20419], directing the Oversight Board to file an amended MIP List.

3. On March 29, 2020, the Oversight Board filed the Notice of Filing Amended List of 

Material Interested Parties Pursuant to Puerto Rico Recovery Accuracy in Disclosures Act [ECF 

No. 20458], which attached a list of material interested parties with respect to all Title III Debtors 

as Exhibit A thereto (the “Amended MIP List”). The Amended MIP List broke out the material 

interested parties in separate schedules for each of the debtors.

4. On March 30, 2022, the Court entered the Order, which approved the Amended 

MIP List and directed all professionals to file the disclosures required under PRRADA by May 16, 

2022. That deadline was extended for the Deloitte US Entities to June 15, 2022 by Order of this 

Court dated May 16, 2022 [Docket No. 20807]

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5. On June 15, 2022, the Deloitte US Entities timely filed the Declaration of Kirk 

Blair Disclosing Connections of Deloitte Consulting LLP and Deloitte Financial Advisory 

Services LLP to Material Interested Parties Pursuant to Puerto Rico Recovery Accuracy in 

Disclosure Act (the “Initial PRRADA Declaration”). 

6. Pursuant to paragraph 3 of the Order on Motion of the United States Trustee for 

Amendment of the Third Amended Order Setting Procedures for Interim and Final Compensation 

and Reimbursement of Expenses of Professionals [Docket No. 21334] (the “Amended Order”), the 

United States Trustee (the “US Trustee”) provided informal comments and questions on the Initial 

PRRADA Declaration on or before the August 15, 2022 deadline set by that order. 

7. On September 15, 2022, the Court entered the Order Extending Time to File 

Supplemental Verified Statement Pursuant to Puerto Rico Recovery Accuracy in Disclosure Act 

[Docket No. 22219] (as modified by Docket No. 22339, the “First Extension Order”). The First 

Extension Order extended the time for the Deloitte US Entities to file a supplemental declaration 

under PRRADA to October 14, 2022. 

BASIS FOR RELIEF

8. Paragraph 5 of the Amended Order provides that the US Trustee “may agree to one 

consensual extension of up to sixty (60) days, where reasonably necessary, to such professionals 

as may be determined are required to file a PRRADA disclosures.” Because the Deloitte US 

Entities have already filed their PRRADA disclosures through the Initial PRRADA Declaration, 

it is not clear that this timeframe is applicable to the Deloitte US Entities. However, the US Trustee

did extend any applicable time for submission of a supplemental declaration by the Deloitte US 

Entities through September 14, 2022. As noted above, that time was extended by the Court to 

October 14, 2022 pursuant to the Extension Order. 

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9. The Deloitte US Entities had previously provided a draft supplemental declaration

to the US Trustee. Yesterday, the Deloitte US Entities received indication from the US Trustee 

that he may have further questions regarding that draft supplemental declaration. The Deloitte US 

Entities hope to work in good faith with the US Trustee to resolve those questions, to the extent 

possible. In order to give the Deloitte US Entities and the US Trustee an opportunity to engage in 

further discussions on these matters, the Deloitte US Entities are requesting an additional 30-day 

extension of their time to file a supplemental extension, through November 14, 2022. 

10. The US Trustee has indicated that he does not object to this extension of time and 

the Deloitte US Entities have agreed that the United States Trustee shall have thirty days from the

date of filing of any supplemental disclosure to review such supplemental disclosures and to 

submit formal or informal objections, if any.

WHEREFORE the Deloitte US Entities respectfully request 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.

Dated: October 13, 2022 Respectfully submitted,

San Juan, Puerto Rico

/s/Alexandra C. Casellas 

Alexandra Casellas-Cabrera

USDC-PR No. 301010

ADSUAR MUÑIZ GOYCO SEDA & PÉREZOCHOA, P.S.C.

P.O. Box 70294

San Juan, PR 00936-8294

Tel: 787-756-9000

Fax: 787-756-9010

Email: acasellas@amgprlaw.com

and

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LOEB & LOEB LLP

Daniel B. Besikof

345 Park Avenue

New York, New York 10154

Tel: (212) 407-4000

Fax: (212) 407-4990

Email: dbesikof@loeb.com

Attorneys for Deloitte Consulting LLP and Deloitte 

Financial Advisory Services LLP

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Exhibit A

Proposed Order

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UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

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

In re:

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO,

as representative of,

THE COMMONWEALTH OF PUERTO 

RICO, et al.

Debtors.2

:

:

:

:

:

:

:

:

:

:

:

PROMESA 

Title III

No. 17 BK 3283-LTS 

(Jointly Administered)

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

SECOND ORDER EXTENDING TIME TO FILE 

SUPPLEMENTAL VERIFIED STATEMENT PURSUANT TO

PUERTO RICO RECOVERY ACCURACY IN DISCLOSURE ACT

Upon the Second Urgent Unopposed Motion Seeking Extension of Time to File a 

Supplemental Verified Statement of Deloitte Consulting LLP and Deloitte Financial Advisory 

Services LLP Disclosing Connections to Material Interested Parties Pursuant to Puerto Rico 

Recovery Accuracy in Disclosure Act (the “Motion”);3and the Court having found it has subject 

matter jurisdiction over this matter pursuant to PROMESA section 306(a); and it appearing that 

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) 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).

3 Capitalized terms used but not otherwise defined herein have the meanings given to them in the Motion.

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venue is proper pursuant to PROMESA section 307(a); and the Court having found that the relief 

requested in the Motion is in the best interests of the Debtors, their creditors, and other parties in 

interest, it is HEREBY ORDERED THAT:

1. The Motion is granted as set forth herein.

2. The time for Deloitte Consulting LLP and Deloitte Financial Advisory Services 

LLP to file a supplemental verified statement(s) pursuant to Order on Motion of the United States 

Trustee for Amendment of the Third Amended Order Setting Procedures for Interim and Final 

Compensation and Reimbursement of Expenses of Professionals [Docket No. 21334] and the 

Puerto Rico Recovery Accuracy in Disclosures Act, Pub. L. No. 117-82 shall be extended to 

November 14, 2022, without prejudice to the right of Deloitte Consulting LLP and Deloitte 

Financial Advisory Services LLP to request further extensions of time. 

3. The United States Trustee shall have thirty days from the date of filing of any 

supplemental disclosure described in paragraph 2 above to review such supplemental disclosures 

and to submit formal or informal objections, if any.

4. This Court retains exclusive jurisdiction with respect to all matters arising from or 

related to the implementation, interpretation, and enforcement of this Order.

5. This Order resolves docket entry no. ___________.

SO ORDERED.

Dated: , 2022

San Juan, Puerto Rico LAURA TAYLOR SWAIN

United States District Judge

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